In September 2013, the OFCCP published final regulations under the Vietnam Era Veterans Readjustment Assistance Act, and Section 503 of the Rehabilitation Act which significantly expanded compliance obligations for institutions subject to affirmative action plan requirements as federal contractors. Pursuant to the final Section 503 regulations (“Regulations”), the OFCCP has released a new Voluntary Self-Identification of Disability form (“Form”). Covered institutions must use the Form, without modification, to offer applicants and employees the opportunity to self-identify as individuals with disabilities for all affirmative action plan years beginning after the effective date of the Regulations, March 24, 2014. The Form must be provided to applicants at both the pre and post-offer stages of the employment process, and to employees at least once every five years. Electronic fillable versions of the Form may be created and used so long as the OMB number and expiration date of the Form are displayed, the text of the Form is used without alteration, and a sans-serif font of at least 11-pitch size is used.
Client Tip: Colleges and universities subject to affirmative action plan requirements as federal contractors must take steps to meet their expanded obligations now, including training all personnel involved in the recruitment, screening, selection, promotion, disciplinary, and related processes to ensure that affirmative action program requirements are met. The Form and information concerning contractor obligations under the Regulations can be found at www.dol.gov/ofccp.