Accountability — Employing People with Disabilities


It is commonly accepted wisdom that ‘what gets measured gets done.’ Establishing metrics and holding managers accountable for hiring practices, particularly in relation to affirmative action and diversity goals, is also an effective way to promote demographic change within your organization’s workforce. This is especially true when considering disability as one of the diversity characteristics. With the anticipated final regulations from the Office of Federal Contract Compliance Programs (OFCCP) regarding Section 503 of the Rehabilitation Act, many employers who are doing business with the federal government will have to set a hiring goal, currently proposed at 7 percent, for workers with disabilities. Additional record keeping, benchmarking and adherence with utilization goals will also be required in the hiring of specified categories of protected military veterans under the Vietnam Era Veterans’ Readjustment Assistance Act, thereby increasing accountability to ensure compliance. Success in meeting these regulatory requirements depends on top leadership endorsement, knowledge of relevant local and national resources, development of strategic plans and then holding people accountable for effective implementation.

There are many public and private sector entities who are leading the way when it comes to measurement and accountability for diversity goals related to hiring and advancing veterans and people with disabilities. The common denominator for all these organizations is top management support. Organizational endorsement of hiring initiatives related to veterans and persons with disabilities should be expressly connected to other vision and mission statements regarding general diversity and inclusion. Written statements in internal documents and training materials that actively promote a culture of inclusion underscore the imperative to make disability a part of what is considered diversity goals. They also give a strong message to members of the existing workforce and thus help to take the fear out of self-disclosure. From there, the responsibilities related to implementation should be assigned to a specific group of personnel, whose performance will be measured in part by how effectively the organization meets those goals.

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The US Equal Employment Opportunity Commission (EEOC) issued guidance recommending that employers establish a designated “decision maker” regarding all requests for accommodations. This designated individual should be expertly familiar with the organization’s process for granting and funding accommodations. One of the most powerful tools that organizations can offer managers and supervisors is the ability to access a centralized accommodation fund. Even though, according to the Job Accommodation Network (JAN), in most cases there are no costs associated with providing an accommodation, a centralized fund eliminates the concerns regarding costs and creates a neutral assessment of candidates with disabilities for employment, including veterans with service connected disabilities. Centralized funds for accommodation could also make it easier to retain an incumbent employee who develops or discloses a disability for the first time. Designated decisionmakers can manage these centralized funds to ensure efficiency. However, frontline managers and supervisors must also be trained to recognize accommodation requests during the hiring process and throughout the employment cycle.

Training for all employees is a critical component of creating awareness and establishing accountability. Anyone in a position to hire or promote staff should receive regular mandated training on affirmative action goals, dealing with conscious and unconscious biases and issues pertaining to disability and military culture. Providing supervisors and managers with the right tools and resources to effectively recruit and evaluate candidates with disabilities and job seekers transitioning from military to civilian life, can demystify the process for those who may be unfamiliar with the skills and abilities of these target groups. When supervisors are aware of the policies and procedures related to interactively engaging an employee with a disability, and when an accommodation request is made with confidence that the organization has the necessary infrastructure to support them, a seamless process is created. This will ultimately have a positive net effect on workforce diversification and productivity. Providing the proper training to key employees and then holding them accountable for integrating that information into everyday employment practices, can be a powerful way to communicate desired organizational culture, as well as targeted employment outcomes.

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Once the right tools and supports are in place, establishing a system for evaluating data on hiring, promotions and compensation that is specific to the employment and advancement of veterans and people with disabilities should be implemented. In the federal sector, Executive Order 13548 emphasizes greater accountability or compliance with affirmative action mandates, for which detailed metrics can be useful. For federal contractors, this type of data is critical to ensuring compliance with OFCCP mandates and will become increasingly necessary as proposed new regulations begin to take effect over the course of 2013 and 2014. Beyond compliance, the data itself can become a useful strategy for improving diversity. When shared internally via regular reporting mechanisms, progress toward implementing affirmative action goals can be noted among specific departments and units and offering opportunities for recognizing groups that meet or exceed those goals. But even private sector employers who lack affirmative action mandates can benefit from centralized processes and effective data reporting mechanisms to improve their talent acquisition potential.

Employers who are required to comply with the Americans with Disabilities Act, the Family and Medical Leave Act and other federal, state and local employment laws can have a vested interest in benchmarking activities which highlight disability as an aspect of overall diversity. Creating accountability across all employment sectors can be an effective driver for diversity and inclusion and leverage the talents and contributions of all employees.


by Judy Young, MA and Ellice Switzer

Judy Young is the grant manager for the National Technical Assistance, Policy and Research Center for Employers on the Employment of Persons with Disabilities funded by the US Department of Labor, Office of Disability and Employment Policy (ODEP). Ms. Young’s areas of expertise include recruitment, accessibility, worksite accommodations, disability etiquette, diversity and inclusion and compliance with the Americans with Disabilities Act. Ms. Young is a frequent presenter at major diversity and employment conferences and she is a member of the speaker’s bureau of the Society of Human Resource Management (SHRM).

Ellice Switzer is the Technical Assistance Specialist for the Employer Assistance and Resource Network (EARN) operated under a grant from the US Department of Labor, Office of Disability and Employment Policy by the Employment and Disability Institute at Cornell University. She provides consultation to employers seeking to diversify their workforce by recruiting, hiring and retaining employees with disabilities.

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