411 on 503: A “C2C” Tip Sheet

You might have heard about two regulations from DOL’s OFCCP, effective March 24, 2014: Section 503 and VEVRAA (Vietnam Veterans Readjustment Assistance Act).

 Maybe you’ve surfed OFCCP’s website looking for what to do and how to do it correctly.  Where do we find qualified applicants? How do we ask our own employees and applicants with disabilities to self identify in order to reach the 7% aspirational goal?

What’s It All About?

Prime and Subcontractors with contracts over $10,000 are now required to take affirmative action and document (for three years) efforts to outreach, recruit, hire, train, retain and promote qualified individuals with disabilities (IwDs). This good faith accountability meets Affirmative Action obligations, identifies impediments to EEO, and drives a more disability-inclusive diverse workforce.

503 prohibits employment discrimination on the basis of disability by Federal Prime and Subcontractors by establishing a nationwide 7% utilization goal of IwDs in each job group annually. If Contractors have less than 100 employees, the whole workforce is measured.  And for the first time under 503, contractors ask applicants and employees with disabilities to self-ID in pre-AND post-offer phases, and every five years.

A Few Resources:

OFCCP Website – Great Resources www.dol.gov/ofccp
Required Self-ID Form: http://www.dol.gov/ofccp/regs/compliance/section503.htm#bottom
Training Webinars Archive: http://www.dol.gov/ofccp/regs/compliance/final_rules_webinars.htm
Job Accommodation Network (JAN)
http://askjan.org or 1-800-526-6234 (voice), 1-877-781-9403 (TTY)

Background:

Bureau of Labor Statistics reports unemployment of individuals with disabilities significantly higher (15%) than those without disabilities (8%); Workforce participation is 31.6% for working-age people with disabilities and 76.5% for those without disabilities. Plus, “disability” definition changed with the Americans with Disabilities Act Amendments Act (ADAAA), and increased use of information and electronic technology (IET) prompted OFCCP’s herculean effort to harmonize public policy and disability definitions before it issued the Final Rules.

For questions about Section 503 or VEVRAA, employment resources for recruiting with Career Opportunities for Students with Disabilities (COSD) to career advancement with UCLA MultiDimensional Leaders Institute, EIN SOF can help – We Mean Business 25/7. Visit our Website: www.EINSOFcommunications.com

 Upcoming Blogs:

  • Outreach Tips: One-Stop Shopping from Recruiting to Career Advancement
  • Self-ID: Paving the intersection of LGBT and Disability Issues
  • Self-ID and Self-Disclosure: Important Distinctions

Tari Hartman Squire is CEO of EIN SOF Communications, Inc. a leading woman-owned small business and GSA Federal Contractor focused on disability-inclusive diversity and public policy; specializing in Market Research & Analysis, Communications, PR, Branding, Accessible Events and Employment Consultation. Squire co-chairs the National Disability Leadership Alliance Employment Team. Clients include AT&T, DOL’s Office of Disability Employment Policy, National Council on Disability, COSD and UCLA Anderson School of Management’s MultiDimentional Leaders Institute that includes disabilities, LGBT, African American and Latino.  EIN SOF means business 25/7!