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Capitol Correspondence - 06.17.19

ANCOR Joins Comments on Disability Information Collection Requirements

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As part of its work with the Consortium for Citizens with Disabilities (CCD), ANCOR joined 16 other national organizations in comments expressing support for the continued collection of data on how contractors comply with federal requirements regarding employees with disabilities. This data is tracked for compliance with Section 503 of the Rehabilitation Act. ANCOR co-chairs a task force for employment and training policies for CCD, a coalition of over 100 national disability organizations.

As written in the letter:

“We strongly support OFCCP’s plan to conduct focused reviews of compliance with Section 503. We believe the information that OFCCP is seeking to collect is critically important for assessing compliance. We urge OFCCP to collect the following additional information, which we think is also essential to determining whether contractors are complying with Section 503:

  • The contractor’s policies concerning requests for leave as a reasonable accommodation, including leave that may extend beyond what the contractor offers as vacation and sick time and Family and Medical Leave Act time. Flexible leave policies are one of the most important accommodations enabling people with disabilities to maintain employment.
  • The contractor’s arrangements with disability services agencies, vocational rehabilitation agencies, Employment Networks, centers for independent living, and other entities to assist with recruitment of people with disabilities as well as with identifying appropriate accommodations that may be needed by employees with disabilities.
  • The screening tools used by the contractor in the hiring process, including criminal background checks, credit checks, personality tests, and other screening tools that may screen out applicants with disabilities and may be unnecessary or overbroad.
  • The contractor’s policies and practices to promote retention of employees with disabilities and prevent the need for “disability retirement.”
  • Information about the accessibility of the contractor’s workplaces and online platforms.
  • Information maintained by the contractor concerning the types of disabilities represented among the contractor’s employees. While the Section 503 rule does not include goals or provisions relating to individuals with “targeted disabilities,” like the EEOC’s subgoal for individuals with targeted disabilities in its regulations implementing Section 501, it is important for OFCCP to ensure that Section 503 affords opportunities to individuals with the types of disabilities that have historically been dramatically underrepresented in the workforce.”