OFCCP’s New Voluntary Self-Identification Requirements

Federal contractors must invite job applicants and employees to voluntarily self-identify as individuals with disabilities using a form that was recently released by the Office of Federal Contract Compliance Programs (OFCCP). Effective March 24, 2014, federal contractors must begin using the new form unless they have an affirmative action plan (AAP) in place on that date. In that case, they may delay their compliance until the start of their next plan cycle.

Under the Final Rule announced by the OFCCP last fall, a federal contractor is required to invite an applicant to voluntarily identify whether he or she is an individual with a disability. This invitation must be provided to each applicant when the individual applies or is considered for employment. The invitation may be included with the application materials for a position, but must be retained separate from the application. Federal contractors are also required to invite applicants to identify their