The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has submitted a formal request to the White House Office of Management and Budget (OMB) to extend for three years the recordkeeping and reporting requirements for federal contractors under OFCCP’s disability and veterans regulations, including OFCCP’s prescribed Voluntary Self-Identification of Disability form (Form CC-305).

In connection with this process, earlier OFCCP had 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 make additional changes to the form allowing contractors more flexibility in how to comply. As discussed below, the version of the CC-305 submitted to OMB for final approval makes some additional minor improvements, but still does not address NT Lakis’ fundamental concerns.

In the meantime, as this process continues, OFCCP’s existing Form CC-305 has expired. In response, OFCCP has updated its website to advise employers to continue using the current (and now technically expired) Form CC-305 until OMB takes action on OFCCP’s proposed revisions, at which time contractors will have 90 days to begin using the new form.

Now that OFCCP’s final proposal has gone to OMB for approval, interested parties will have an additional 30 days to submit comments to OMB on OFCCP’s proposed changes, and NT Lakis will be filing comments by the March 2, 2020 comment deadline reiterating the recommendations we made to OFCCP.

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