On January 31, the Office of Federal Contract Compliance Programs announced that the voluntary self-identification form for individuals with disabilities has been renewed through 2020. The renewed form remains the same with the exception of the new expiration date of January 31, 2020. Federal contractors should begin to use the renewed form or update their electronic versions immediately.
Below are some important reminders regarding this self-identification process for federal contractors:
- Contractors must invite applicants and new hires (after an offer, but before work begins) to self-identity as an individual with a disability.
- Contractors must invite their current employees to self-identify as an individual with a disability every five years. Also, at least once during the years between these invitations, contractors must remind their employees that they may voluntarily update their disability status at any time.
- There is no particular method that contractors must use to invite their employees to self-identify, so contractors can choose any methods that are reasonable given their circumstances as long the OFCCP’s self-identification form is used to collect the responses.
- Contractors can create an electronically fillable version of the form provided that the e-form (1) displays the Office of Management and Budget number and expiration date; (2) contains the text of the form without alteration; (3) uses a sans-serif font; and (4) uses at least 11-pitch for font size (with the exception of the footnote and burden statement, which must be at least 10-pitch). "Pitch" means the number of characters and spaces per inch.
- Contractors are encouraged to provide additional information about reasonable accommodation at the time that they invite voluntary self-identification of disability. This may include the name and contact information for the individual responsible for processing requests for reasonable accommodation, as well as information about the contractor’s procedures regarding the reasonable accommodation process. However, it is important to remember that contractors cannot alter the content of the form itself. Accommodation information, if provided, would have to be provided with the form, not on it.
This is Constangy’s flagship law blog, founded in 2010 by Robin Shea, who is chief legal editor and a regular contributor. This nationally recognized blog also features posts from other Constangy attorneys in the areas of immigration, labor relations, and sports law, keeping HR professionals and employers informed about the latest legal trends.
