The revised form makes the following general changes:
The agency’s supporting statement indicates that the proposed “nonmaterial” changes were made “in an effort to increase the response rate on the form.” The agency went on to explain that the “changes include softening the tone of the form to make the language more positive, updating and alphabetizing the types of disability, and removing the reasonable accommodation notice.” The agency stated it was removing the reasonable accommodation notice because it “created confusion among applicants and employees who thought that completing the form automatically referred them for a reasonable accommodation.”
The proposal is subject to public comment until December 2, 2019. Contractors can view the proposal, including the revised form, online at regulations.gov at https://www.regulations.gov/document?D=OFCCP-2019-0005-0004.
Importantly, until the proposal is finalized, contractors should continue to use the current disability self-identification form, which expires in January 2020. If you have questions about the proposed changes, or how best to comment, please contact your Berkshire consultant.