Now that everyone has had a chance to get a look at the new form, let’s break down what changed between the initial submission in November and the final form. First, the new form is more visually appealing, even though it is now on two pages. Effort was clearly made to improve the look of the form. In a November post, we discussed major concerns with the content of the initial form, and below we explore what was resolved.
- The response options problem was fixed. As you may remember, the initial form only allowed for individuals to either answer in the affirmative (Yes, I have or had a disability), or to answer (No, I do not wish to identify as having a disability). The problem with the second option was that it combined those who would have answered “no, I don’t have a disability” with those who would have answered “I do not wish to disclose this information.” There are now three response options on the form.
- Readability – The overall readability of the form has been improved from a post-graduate level to 12.9 (between a high school senior and a freshman in college), or a 38.2 (Difficult) reading ease level instead of the “very confusing” level of the initial form. The first section is written in a fairly straight forward manner, but the remaining sections add to the overall difficulty.
- We previously raised the concern of combining individuals who have a current disability with those who previously had a disability, but the final form retains this language.
- The initial form had no name or date, which would be a problem for contractors trying to determine whether they met the 7% utilization goal. There is now a place for individuals to add their name, which is helpful for those using emailed or paper copies. However, those converting the form for use in an online tracking system may consider having the system auto-populate this field and the date, or allowing applicants to complete these fields with text box responses.
- The initial form listed several major life activities, and the information provided was inconsistent both with the definitions in Section 503 and with the ADAAA. The updated form omits the list of life activities and instead provides a non-exhaustive bulleted list of disability examples.
As a reminder, Federal contractors will be required to use this form to solicit disability status of applicants, pre and post offer, as well as employees. Federal contractors should not begin this data collection with applicants until at least March 24, 2014, the effective date of the regulations. Contractors also have the option to begin data collection on their next affirmative action plan cycle date following the effective date.
by Kristen Pryor, M.S., HR Analyst, DCI Consulting Group