In accordance with the revised Section 503 regulations, federal contractors are required to invite applicants and employees to voluntarily disclose disability status from employees and applicants and including these figures in their affirmative action plans. This information is strictly voluntary, so contractors may not compel or coerce employees or applicants to complete the form. Therefore, 100% participation of employees or applicants in the voluntary invitation is not likely.
Given this, DCI clients have raised concerns about low participation rates in this voluntary process and the impact that this will have on the disability goals and other analytics. Therefore, we conducted a short survey for contractors to share their self-identification participation rates to establish an industry benchmark for contractor awareness. All information gathered from this survey was kept anonymous, and the following results have been aggregated.
This survey addressed four areas contractors should consider when interpreting self-identification results:
- Participation rate (percent of employees that filled out the survey);
- Response rate (of those that participated in the survey, what percent were disabled);
- Utilization rate (percent of employees disabled in comparison to the workforce); and
- Applicant response rate (percent of applicants identifying as disabled)
One additional analysis conducted was a correlation analysis to compare rates in comparison to contractor size. For example, are employees more likely to participate in the voluntary survey in a smaller company versus a larger company? A positive and high correlation would suggest the answer is yes.
1. Participation Rate
Participation rate was measured by the percent of the entire workforce that completed the voluntary self-identification form. Results showed that as the size of the company increased, the participation rate decreased.
- Average participation rate: 22.32
- Correlation between company size and participation rate: -0.28
2. Response Rate
Breaking the results down even further, response rate was also considered. Response rate assessed the percent of employees that responded affirmatively to having or having had a disability out of the employees that participated. Interestingly, this resulted in a positive correlation with company size, meaning, out of the employees that participated, the rate of those that responded affirmatively increased along with company size.
- Average response rate: 9.89
- Correlation between company size and response rate: 0.29
3. Utilization Rate
However, when affirmative responses were assessed against the entire company population, identified as utilization rate, we found a considerable decrease in the average number of employees who affirmatively self-identified as having or having had a disability. Much like the participation rate, a negative correlation was found between workforce rate and company size, meaning, as the size of the company increased, the number of employees who affirmatively self-identified decreased.
- Average workforce rate: 2.54
- Correlation between company size and workforce rate: -0.07
4. Applicant Response Rate
Finally, this survey also assessed the rate of applicant’s who affirmatively self-identified out of the entire applicant pool. Again, a negative correlation was found between applicant rate and company size.
- Average applicant rate: 2.17
- Correlation between company size and applicant rate: -0.16
When comparing self-disclosure rates to an industry benchmark, contractors should consider the method in which they analyze their company data. Here we have identified three potential ways contractors may be looking at their data, with each providing different results. Specifically, the difference in response rate and workforce rate should be cause for concern. By using a denominator (total workforce versus those that participated in the survey), we see a substantial decrease in self-identification rates, and a reversal in the direction of the correlation. Each method provides a different picture of the data, with some more favorable than others.
Although the sample was relatively small, a number of industries were represented, such as banking, education, healthcare, and manufacturing, to name a few, as well as company sizes, which consisted of ranges of 0-499 to over 50,000. Full survey results can be found here.
There were several comments in the survey that are worthy of addressing to guide other contractors in compliance efforts.
- Employees don’t feel comfortable and fear self-disclosing disability status.
- Concern about manager access of information.
- Union dislike of the data collection.
- Employee ID was a challenge to track since it was not on the survey.
- Seeing more participation from new hires than employee population.
- Difficulty in ensuring the data is collected in the same manner across the corporation.
- Applicants not completing the online application process (i.e. drop off before making it to the self-ID form).
Recall that the OFCCP is hopeful contractors will aspire for a welcoming environment in which applicants and employees feel comfortable self-disclosing disability status. It is imperative to effectively communicate how this information will be collected and maintained confidentially to appease any fear of information sharing or retaliation. This being said, it is important to communicate support from all levels of the organization, share resources and information with employees on why this change is occurring. In addition, consider providing supplemental information on the page before and after the mandated OFCCP form so that employees become more knowledgeable and comfortable with self-disclosing this information. This supplemental page will be an opportunity for contractors to collect employee ID information to annually complete the utilization analysis (i.e. link disability disclosure to job group within a location). Finally, if you notice any concerns with completion rate of the online application, consider the job seeker experience and review the process to ensure it is clear to the job seeker when they have gone through all the online application pages (i.e. make sure the job seeker is alerted to the fact they have been provided all the appropriate forms and it is time to submit).
As more contractors come into full compliance with Subpart C requirements, it will be useful to resurvey contractors to see if these industry benchmarks and trends change at all. Stay tuned for a resurvey of Section 503 compliance in Quarter 1 2016.
By Bryce Hansell, HR Analyst; Keli Wilson, Senior Consultant; and Dave Cohen, President, DCI Consulting Group
