As an advance reminder to employers that are federal contractors subject to the revised regulations implementing Section 503 of the Rehabilitation Act of 1973 that were issued by the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) in 2013, you will be required to re-extend disability self-identification invitations to all of your current employees sometime during your upcoming AAP cycle, depending on the commencement date of the cycle.

Under the revised Section 503 rules, covered federal contractors must extend disability self-identification invitations at three distinct times. The first two invitations must be given at the pre-offer and post-offer stages. The third disability self-identification invitation must be extended to the contractor’s entire employee population every five years.

Thus, for contractors whose next AAP cycle starts January 1, 2020, the resurvey must be completed sometime during calendar year 2020. For contractors with upcoming cycles that start on another date occurring anytime after March 24 of this year – for example, on April 1 – the resurvey must be completed before the cycle ends, which for some contractors might be no later than March 31, 2020.

Members of the Center for Workplace Compliance (CWC) can read more here.