11 May 2020

Disability Self-ID Form Updated for Federal Contractors/Subcontractors

The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) will soon start requiring federal government contractors and subcontractors to use a new disability self-identification form.  The revised self-ID form must be implemented no later than August 4, 2020 when soliciting applicants and employees to disclose whether they are an individual with a disability.  The 3-month ramp-up period gives covered employers time to incorporate the new self-ID into their electronic/online HRIS and applicant tracking systems.

This mandatory disability self-ID form’s language may not be modified by contractors, and makes several notable changes from the form that has been in use for years:

  • The revised self-ID form has been streamlined down to a single page format.
  • OFCCP updated and expanded the form’s list of typical disabilities. Examples now include fibromyalgia, heart disease, Crohn’s Disease, irritable bowel syndrome, migraine headaches, “low vision,” rheumatoid arthritis, “intellectual disability,” and depression or anxiety.
  • OFCCP removed a paragraph about reasonable accommodation, which many concerned employers believed triggered misinformation and accommodation requests that otherwise may not have occurred.
  • There is new language about the national 7% disability Utilization Goal for a contractor’s workforce, and that covered employers must re-survey employees about their disability status every five (5) years.

The revised disability self-ID form can be found here.

Practical Tip:  Be sure to notify your applicant tracking system/HRIS vendor as soon as possible to make sure they are aware of the upcoming change, and program in a software update.  If your business has created its own job application process, be sure to have your in-house IT department place this item on its “punch list” of projects for completing by August 4.

If you have questions about the new disability self-ID form, or about resurveying your workforce –  now that most contractors are at their five (5) year interval – contact one of Miller Johnson’s Affirmative Action and Government Contracts attorneys.