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The OFCCP’s Proposed Rule Regarding PWD…Be Prepared

Is your company a U.S. federal contractor or subcontractor?  If so, you should already be aware of the 7% hiring goal proposed by the OFCCP.  With President Obama’s re-election, a President who has shown tremendous support for improving job opportunities for individuals with disabilities, it is believed that this proposed rule will, in some form, be put into law.  How prepared are you?

Highlights of the proposed rule include:

  • Goals: Federal contractors and subcontractors would be required to set a hiring goal of having 7-percent of their employees be workers with disabilities in each job group of the contractors’ workforce.
  • Data Collection: Improve collection of data on employment of people with disabilities by modifying the invitation for workers to self-identify by requiring that contractors invite all applicants to voluntarily self-identify as an “individual with a disability” at the pre-offer stage of the hiring process. Contractors also will be required to invite post-offer voluntary self-identification and to survey all employees annually in order to invite their self-identification in an anonymous manner.
  • Record-Keeping: Require that contractors maintain records on the number of individuals with disabilities applying for positions and the number of individuals with disabilities hired.
  • Accommodation Requests: Require, for the first time, that contractors develop and implement written procedures for processing requests for reasonable accommodation.
  • Outreach: Require that contractors engage in a minimum of three specific types of outreach and recruitment efforts to recruit individuals with disabilities.
  • Job Listings: Require that contractors list job openings with One-Stop Career Centers or other appropriate employment delivery systems.
  • Annual Reviews: Require previously recommended steps contractors must take to review their personnel processes, as well as their physical and mental job qualifications.
  • ADAAA Updates: Incorporate updates made necessary by the ADA Amendments Act (ADAAA) of 2008.

While these legal implications are important, it’s the practical applications that are critical.  The key to successfully meeting these requirements and doing so in a manner that is cost effective, mitigates risk, ensures productivity, and is consistent with corporate culture is organizational readiness.  Waiting can be costly. The following represents a checklist of action items:

  • Talent acquisition strategy and execution,
  • Training of recruiters, HR professionals and managers,
  • A fair and equitable reasonable accommodation process,
  • Disclosure guidance,
  • Etiquette and awareness training,
  • Website and related accessibility,
  • Essential job functions,

A comprehensive Corporate Assessment and Gap Analysis will determine your overall readiness and provide a comprehensive strategic blueprint.

To get you started, speak with one of Springboard’s leading experts to learn first-hand how this Rule will specifically impact your company and more importantly, what needs to be done.  To schedule your personalized guidance session, please contact Belinda Moore at T: 1-973-813-7260 x.109; E: belinda@consultspringboard.com.