Getting Your Workforce to Self-Identify as Disabled

In 2014, federal contractors started tracking and reporting the workforce percentage that self-identified as being an Individual with a Disability (IWD). Time and time again, we hear from employers that applicants and current employees are unlikely to provide their disability status as part of the employment process. As a result, we usually see a low number of IWD’s identified in an affirmative action plan (AAP). The good news is the numbers are slowly getting better. According to the Bureau of Labor Statistics, last year the ratio went up. In 2023, the employment-population ratio for people with a disability increased by 1.2 percentage points to 22.5%. This was the highest recorded ratio since tracking began in 2008. (Bureau of Labor Statistics, Feb 22, 2024)

To increase the percentage of employees who self-identify as having a disability in your organization, we recommend the following approaches.

1. Designate an IWD ambassador - Berkshire has seen greater success in disability disclosure campaigns when the company highlights an ambassador, or someone in management who talks about working at the company with a disability. We have found it helpful when that person is not part of Human Resources. This person is a resource and shows the workforce that self-identifying did not hurt their career. The ambassador helps change the conversation around disability status and creates a culture of inclusivity. Sharing differences is seen as a positive in the company.
2. Resurvey Often – Office of Federal Contract Compliance Programs (OFCCP) regulations require contractors to offer the opportunity to self-identify during the application process, during onboarding, and resurvey every five years. We recommend surveying more often than that. The more often your workforce has the opportunity to identify, the larger your response percentage will be. Open enrollment is a good time to resurvey because your employee population is already renewing insurance and benefits forms.
3. Inform Employees on What “Disability” Means – Most people think of a disability as having a handicap that causes immobility or motor impairment that we can see such as missing limbs, deaf, blind, or crippled. In fact, the list of disabilities included on form CC-305 include many common chronic ailments such as diabetes, anxiety, depression and arthritis. OFCCP defines disability in the following manner:

“A disability is a condition that substantially limits one or more of your “major life activities.” If you have or have ever had such a condition, you are a person with a disability. Disabilities include, but are not limited to:

• Alcohol or other substance use disorder (not currently using drugs illegally)
• Autoimmune disorder, for example, lupus, fibromyalgia, rheumatoid arthritis, HIV/AIDS
• Blind or low vision
• Cancer (past or present)
• Cardiovascular or heart disease
• Celiac disease
• Cerebral palsy
• Deaf or serious difficulty hearing
• Diabetes
• Disfigurement, for example, disfigurement caused by burns, wounds, accidents, or congenital disorders
• Epilepsy or other seizure disorder
• Gastrointestinal disorders, for example, Crohn's Disease, irritable bowel syndrome
• Intellectual or developmental disability
• Mental health conditions, for example, depression, bipolar disorder, anxiety disorder, schizophrenia, PTSD
• Missing limbs or partially missing limbs
• Mobility impairment, benefiting from the use of a wheelchair, scooter, walker, leg brace(s) and/or other supports
• Nervous system condition, for example, migraine headaches, Parkinson’s disease, multiple sclerosis (MS)
• Neurodivergence, for example, attention-deficit/hyperactivity disorder (ADHD), autism spectrum disorder, dyslexia, dyspraxia, other learning disabilities
• Partial or complete paralysis (any cause)
• Pulmonary or respiratory conditions, for example, tuberculosis, asthma, emphysema
• Short stature (dwarfism)
• Traumatic brain injury

OFCCP has created a video for contactors to use to encourage applicants and employees to identify their disability status. It is called “Disability Inclusion Starts with You” and contractors may post a link (https://www.dol.gov/ofccp/selfidvideo.html) to the video on their company website. This video is designed to help explain to employees why providing disability status information is important, and how the information will be used.

Disability is a very personal topic that is not often discussed. It can have very emotional ties for some employees. Make sure to provide your employees with a secure and safe way to identify their disability and promote an environment in the organization where those disabled employees feel secure, safe, and included.