By: Kayin Banfield
On November 15, 2022, the Office of Federal Contract Compliance Programs (OFCCP) issued a revised version of its Voluntary Self-Identification of Disability form. The agency is currently soliciting comments regarding these revisions. The revised form and a discussion of changes to the form can be found at regulations.gov. The current version of the form will expire on May 31, 2023.
Federal contractors and subcontractors must invite applicants and new hires to self-identify as individuals with a disability using OFCCP’s mandated form and must resurvey their workforce once every five years using the mandated form. Federal contractors and subcontractors are required to use the most current version of the Voluntary Self-Identification of Disability form (form CC-305) approved by the federal Office of Management and Budget (OMB).
In its revised version of the form, OFCCP has proposed the addition of several disabilities to the list of disabilities that were present in the previous iteration of the form, including the following:
- Disfigurement, for example, disfigurement caused by burns, wounds, accidents, or congenital disorders
- Mobility impairment, benefiting from the use of a wheelchair, scooter, walker, leg brace(s) and/or other supports
- Neurodivergence, for example, attention-deficit/hyperactivity disorder (ADHD), autism spectrum disorder, dyslexia, dyspraxia, other learning disabilities
- Partial or complete paralysis (any cause)
- Pulmonary or respiratory conditions, for example, tuberculosis, asthma, emphysema
- Short stature (dwarfism)
- Substance use disorder (not currently using drugs illegally)
- Traumatic brain injury
OFCCP has also proposed several revisions to the current list of disabilities on the form. Some examples of disabilities have been broadened or made more specific. Others have been combined with previously listed disabilities or new conditions.
Some minor changes to the form include more straightforward language across all sections and subtle changes to check box fields. For example, the revised information collection form has substituted “physical or mental impairment or medical condition” for “condition” and “substantially limits a major life activity” for “substantially limits one or more of your ‘major life activities’”. Check box fields have been modified to allow individuals to check that they have a disability or “have had one in past” or that they do not have a disability or “have not had one in the past.” The “I don’t wish to answer” option remains unchanged.
The public is allowed to comment on proposed revisions to the disability self-identification form until January 17, 2023. DCI will continue to monitor any further developments.
