Beyond IWD Outreach: Tips for Self-Identification

Federal contractors have seen regulation and compliance changes over the past year and a half, and there are additional proposed changes coming. While the U.S. Department of Labor published a Notice of Proposed Rule Making to modify the Section 503 regulations in July 2025, the proposal has not yet been finalized. As a result, federal contractors remain responsible for complying with the current regulations under Section 503, including the requirement to maintain an annual written AAP for individuals with disabilities.

There are also additional compliance pieces under Section 503 contractors need to ensure they are following, notably the self-ID regulations: soliciting self-ID from applicants pre-offer, asking new employees post-offer, and resurveying your existing workforce at least every five years.

Section 503 regulations specify a 7% utilization rate for individuals with disabilities in a contractor’s workforce; 7% of the total workforce for contractors with less than 100 employees, and 7% of each job group for contractors with more than 100 employees. We commonly hear from our clients that they are inviting employees to self-ID, but because the form is voluntary, most are not choosing to identify. Berkshire has compiled a list of tips for creating an inviting culture for employees who identify as individuals with disabilities to help increase self-ID responses.

First and foremost, employees need to understand why they are being asked. Self-identification data is used, usually in aggregate, for statistical and reporting purposes only. It should be clear that self-ID is voluntary and confidential. Still, employees may be fearful that self-identification could affect their employment, opportunities, relationships, or healthcare coverage. Be sure that communications sent with the DOL’s mandated self-ID form clarify the organization’s intent and commitment to inclusion. DOL recently sought to renew the Paperwork Reduction Act approval for the required self-ID form for another three years, but contractors can continue to use the existing OMB-approved form while the appropriate clearances are being obtained from the Office of Management and Budget.

To help facilitate a positive change in self-ID rates, make sure your organization places focus on disability awareness, and creates and maintains dedicated resources. There should be a holistic, integrated approach across the organization to create a supportive culture. Self-ID campaigns may involve providing incentives to employees, and while some larger organizations may dedicate funds to this, these initiatives do not have to mean major costs. Here are some examples:

• Show executive level support by including the top-level official’s commitment in the mission statement or sending a letter at the start of a campaign. If they identify as an individual with a disability, it helps if they voluntarily disclose, too.
• Explain additional reasons why the question is being asked and why self-identifying might be beneficial to the employee. For example, the organization may use the data to determine if additional programs or benefits would be useful to employees, it may be used during proposals for business, to determine a budget used exclusively for reasonable accommodations, or to ensure outreach efforts are effective. Provide FAQs and be clear that the data is only used in aggregate; each individual’s self-ID response is confidential.
• While the regulations require a resurvey every five years, demonstrate the organization’s commitment to supporting individuals with disabilities by soliciting voluntary self-ID more often. Many successful organizations will have a campaign every few years, or annually.
• Create memorable themes, logos, and slogans for the campaign. Consider integrating other areas of inclusion, such as Veterans.
• Create webinars or lunch & learns about disability or topics in other areas of inclusion.
• Increase personal story telling and testimonials through blogs, videos, or newsletters to make others feel more comfortable.
• October is Disability Employment Awareness Month. Be sure to recognize the occasion or even launch your campaign in October.
• Don’t forget about the caregivers in the workforce. Recognize and appreciate their challenges and any accommodations they might need.
• Research strategies from other companies who are successful. A video is available on the OFCCP website.
• Utilize other resources, such as Employer Assistance and Resource Network on Disability Inclusion (EARN), DOL’s Office of Disability Employment Policy (ODEP), Disability:IN, or the Job Accommodation Network (JAN).

For more information, EARN provides an additional list of tips for encouraging self-ID. By being open and creating a welcoming, supportive environment, you can encourage employees to bring their “whole selves” to work.