CWC has filed comments with the Office of Federal Contract Compliance Programs in response to the agency’s proposal to revise the affirmative action requirements under Section 503 of the Rehabilitation Act. As we detailed earlier, OFCCP proposes eliminating the requirement that contractors “invite applicants and employees to self-identify their disability status,” along with the quantitative analytics that stem from tracking and tabulating these invitations.
CWC’s comments urge OFCCP to consider alternatives to this proposal that will satisfy the agency’s concerns that pre-employment disability solicitations conflict with the Americans with Disabilities Act, but without jeopardizing the important disability compliance programs that federal contractors develop each year. We note that while OFCCP’s Section 503 regulations can be challenging, CWC’s member employers have nonetheless found disability data to be valuable in ensuring that individuals with disabilities have equal access to workplace programs.