In accordance with the revised Section 503 regulations, federal contractors are required to invite applicants and employees to voluntarily disclose disability status and include 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 follow-up to our 2015 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 six 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);
- Applicant Participation Rate (percent of applicants that filled out the survey);
- Applicant Response Rate (of those applicants that participated in the survey, what percent were disabled); and
- Applicant 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? The results suggest that the smaller the company, the more participation.
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: 32.33 (an increase from 22.32 in 2015)
- Correlation between company size and participation rate: -0.49 (a stronger correlation than -0.28 in 2015)
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: 6.69 (a decrease from 9.89 in 2015)
- Correlation between company size and response rate: 0.12 (a weaker, albeit positive, correlation than 0.29 in 2015)
3. Workforce 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: 1.89 (a decrease from 2.54 in 2015)
- Correlation between company size and workforce rate: -0.33 (a stronger correlation than -0.07 in 2015)
As with the workforce rates, applicant rates were also assessed using the same methods.
4. Applicant Participation Rate
Applicant participation rate was measured by the percent of all applicants that completed the voluntary self-identification form. Results showed that as the size of the company increased, the participation rate among applicants decreased.
- Average applicant participation rate: 62.8
- Correlation between company size and applicant participation rate: -0.33
5. Applicant Response Rate
Applicant response rate assessed the percent of applicants that responded affirmatively to having or having had a disability out of the applicants that participated. Similar to workforce response rates, this resulted in a positive correlation with company size, meaning, out of the applicants that participated, the rate of those that responded affirmatively increased along with company size.
- Average applicant response rate: 3.24
- Correlation between company size and applicant response rate: 0.33
6. Applicant Rate
Finally, this survey assessed the rate of applicants who affirmatively self-identified out of the entire applicant pool. As with the workforce utilization rate, a negative correlation was found between applicant rate and company size.
- Average applicant rate: 2.48 (an increase from 2.17 in 2015)
- Correlation between company size and applicant rate: -0.05 (a weaker correlation than -0.16 in 2015)
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 applicant and workforce 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 address challenges that employers are encountering with the self-identification invitation, such as:
- Lower participation rates for employees without email access.
- Employees don’t feel comfortable self-disclosing disability status.
- Some employees who may meet the definition of having a disability do not consider themselves disabled.
- Union dislike of the data collection.
- Individuals sometimes completed the self-identification form as an applicant, but not once they were hired.
Recall that 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, and 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-identifying. This supplemental page will be an opportunity for contractors to collect employee ID information to annually complete the utilization analysis (i.e., link disability status to job group within a location). Finally, monitoring the participation rates within your company will help you identify whether the workforce is more aware of and comfortable with the data collection.
DCI will continue to seek out opportunities to collect and present self-identification benchmarks to the contractor community.
By Keli Wilson, Principal Consultant, and Bryce Hansell, Associate Consultant at DCI Consulting Group