NT Lakis has filed written comments with the White House Office of Management and Budget (OMB) regarding the Office of Federal Contract Compliance Programs’ (OFCCP) request to extend for three years the recordkeeping and reporting requirements for federal contractors under OFCCP’s disability and veterans regulations, including a revised version of OFCCP’s prescribed Voluntary Self-Identification of Disability form (Form CC-305).
As we have reported previously, late last year OFCCP proposed minor but positive changes to Form CC-305 in conjunction with seeking extension of its disability and veterans regulations paperwork requirements, and solicited public comments on the proposed changes. NT Lakis in turn filed comments urging OFCCP to allow contractors more flexibility in how to solicit these data without having to use Form CC-305 as the sole means for doing so.
While OFCCP has elected to continue using the CC-305 as the means to collect disability self-ID information, the revised version of Form CC-305 submitted to OMB represents a marked improvement over the document that employers have been using for the last six years, and our comments to OMB point that out. We are also asking OMB to instruct OFCCP to make two additional changes to the CC-305 that we believe will enhance compliance.
Members of the Center for Workplace Compliance (CWC) can read more here.