As Berkshire previously reported, OFCCP was soliciting comments on its proposal to obtain approval from OMB to renew Form CC-305 Voluntary Self-Identification of Disability. In addition to the renewal, OFCCP proposed changes intended to increase the response rates of applicants and employees.
OMB has approved the renewal of Form CC-305 and with it the requested revisions. The new form updates the preferred language for certain disabilities and includes eight additional impairments or medical conditions identified as commonly meeting the definition of “disability”:
- Alcohol or other substance use disorder (not currently using drugs illegally)
- Disfigurement, for example, disfigurement caused by burns, wounds, accidents, or congenital disorders
- Mobility impairment, benefiting from the use of a wheelchair, scooter, walker, leg brace(s) and/or other supports
- 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
As before, the form notes that the list of disabilities is not all-inclusive.
The new form is available to begin using now, however, federal contractors and subcontractors are given until July 25, 2023 to implement the new form in their processes. The form may be reproduced electronically for use in HRIS and ATS systems, although federal contractors and subcontractors are to be reminded that the OMB approved form must be used without edits except in the space at the bottom where employers may modify the form to aide in their record keeping processes.
For more information on the Section 503 requirements or implementation of the self-identification form, visit OFCCP’s Section 503 information page.