March 24, 2014,
the Office of Federal Contract Compliance Programs (OFCCP) will implement
new 503 regulations for federal contractors. Contractors with more
than 100 employees will be required to set an aspirational goal to
achieve a workforce inclusive of 7 percent of individuals with disabilities
in each job category while businesses with fewer than 100 employees
will apply that goal across their workforce as a whole.
Contractors covered under Vietnam Era Veterans Readjustment
Assistance Act of 1974 (VEVRAA) will be required to establish an 8
percent benchmark for hiring individuals defined as protected
veterans, with the option of establishing benchmarks based on
regional workforce data at each location of operation.
Across the nation, contractors are starting to implement the new requirements
and utilizing resources such as the Employer Assistance and Resource
Network. These new regulations are a game changer as they require
a nationwide utilization goal, accountability through self-audit to
measure progress and correct any discriminatory practice. It will
also enable federal contractors to self-examine their employment practices
and discover unintentional barriers that may be preventing people
with disabilities from entering and remaining in the workforce.
Some key elements of an inclusive workplace:
1. Disability Recruitment and Community Outreach: Build relationships
with key disability and veterans organizations in the community to
facilitate candidate referrals; guidance on reasonable accommodations;
and access to technical assistance and resources. Outreach and recruitment
strategies are vitally important to contractor compliance, and will
be helpful in building a successful evaluation and assessment program
as part of a contractors overall recruitment efforts. It is
imperative that contractors:
Foster relationships by hosting open houses for representatives
of community-based organizations to describe their hiring process,
workplace culture, and types of positions available and qualifications
of candidates sought;
Offer a career fair or interview day to assist in targeted
recruitment by inviting agencies, providers, vocational training schools,
community colleges and universities-any and all entities that might
have job seekers with disabilities;
Establish a record-keeping protocol and assessment strategy
for a successful recruitment program;
Utilize internship programs as one strategy to build a talent
pipeline of diverse candidates.
2. Accessibility of Websites, Online Applications and Testing: Verify
that personnel processes give applicants with disabilities equal access,
and in no way exclude them.
Test websites and career pages for usability and accessibility;
Ensure there is no adverse impact on candidates with disabilities
applying for positions, or in any pre- or post-employment testing.
3. Proactive Reasonable Accommodation Processes: Develop a plan to
address reasonable accommodation requests; determine which staff will
have responsibility for handling and recording requests, as well as
for approving and procuring accommodations.
Consider establishing a centralized process for requests to
eliminate barriers in the process, and reduce the likelihood of supervisor
error in response to a request;
Create a centralized fund for accommodations for consistent
application and to reduce denial of accommodations based on local
or departmental budget restraints;
Define record keeping, approval, vendors for procurement, and
evaluation of the process.
4. Inclusive Cultures and Self-Disclosure: Convey best practices on
disability and inclusion that promote disability and veteran disclosure.
Certain actions on the part of the employer can create a culture of
greater acceptance and inclusion, thereby increasing the likelihood
that an applicant or employee with a disability will disclose.
Invite Applicants and employees to self-identify using the
OFCCP mandated form, which cannot be altered;
Invite new employees to complete the self-identification form
at both the pre- and post-offer stages of employment;
Invite self-identification of the existing workforce within
the first year of the new rules implementation, and at least once
every five years thereafter;
Record information in a data analysis file, kept separately
from personnel files.
5. Training and Evaluation: Institute formalized training to all employees
and managers to communicate new regulatory changes and information
related to compliance efforts.
Train employees on disability awareness, workplace culture,
recruitment of veterans and people with disabilities, goal setting,
effectiveness and assessment, reasonable accommodations principles,
self-identification considerations, performance management and supervision;
Develop an evaluation of a companys efforts to assess
which strategies are working;
Review efforts quarterly, semi-annually, or annually to gauge
effectiveness and make the necessary adjustments or changes that will
By incorporating inclusive hiring strategies, federal contractors
are in a great position to capitalize on new opportunities to expand
hiring of people with disabilities and veterans, which goes beyond
compliance, increases employee engagement and productivity, and creates
a culture that values the contributions of all employees.
by Kathleen Lee
Kathleen Lee is the business outreach specialist at Cornell Universitys
National Employer Technical Assistance, Policy and Research Center
on Employment of People with Disabilities
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