As part of the affirmative action regulations regarding individuals with disabilities, the Office of Federal Contract Compliance Programs (OFCCP) requires federal contractors and subcontractors to invite employees to voluntarily disclose disability status at least once every five years using a survey form created by the OFCCP.   The self-identification form (CC-305) was designed by OFCCP as a tool for contractors to use to collect disability information from applicants and employees so that employers can measure whether or not they are meeting the disability utilization goal of  7% in each job group established in the disability regulations.

While covered employers are required to offer the survey at various times, completion of the survey form by applicants and employees is strictly voluntary.  The form indicates that responses will be kept confidential and will not have a negative impact on applicants or employees.  Despite these assurances, many employees are still hesitant to complete the form.  For some, sharing information on disability is seen as an invasion of privacy, while others have concerns regarding harassment or discrimination they may face for identifying as an individual with a disability. Others may choose not to self-identify as they do not understand the benefits of identifying as an individual with a disability.

Given the reluctance of employees to complete the form, it has become a challenge for federal contractors and subcontractors to develop ways to increase the response rate when surveying for disability status.  A good starting point for this is to create a welcoming and inclusive environment for disabled individuals.  For ideas on how to foster an inclusive work environment for disabled individuals, please see our previous blog.  However, employers can take other steps to help increase the rate of responses to disability surveys.

Pre-Survey Communication

As mentioned previously, federal contractors and subcontractors must re-survey their workforces for disability status every five years.  As employers prepare to conduct these re-surveys, they can increase employee participation by notifying employees in advance.  Here are a few items to consider when preparing pre-survey communications:

• Employers should send messages about disability surveys in a format that is accessible to their whole workforce.  Communication might come in the form of a memo on the intranet, a posting on a bulletin board, or a message sent via email.  It can also be included as part of an organization’s newsletter.  Employers should ensure that all employees have access to the organization’s preferred mode of communication as well as ensure that all communications can be made accessible for individuals with disabilities if requested.

• Employers should ensure communications address the objections that employees might have about completing the form such as privacy concerns and fears of negative repercussions for identifying as an individual with a disability.  Communications should also address the benefits of participating in the survey.

• Employers should include statements from the chief executive officer or other high-level officials explaining the importance of self-identification.  This can help to demonstrate management’s commitment to individuals with disabilities.

• Employers should connect with any disability employee resource groups (ERG) their organizations have.  These groups can play a key role in helping employers develop messaging about the importance and value of participating in the survey.

Survey Release

Once the groundwork for the disability survey has been set, here are a few items employers should think about when ready to send surveys to their workforces:

• Employers should ensure all employees have access to the survey form, so that no one is left out of the process.  Remote employees or employees who work on a production floor might not have regular access to a computer so surveys may need to be provided to these employees in other ways.  Surveys should be made available in accessible formats for individuals with disabilities if requested.

• Employers should include a shorter version of their original pre-survey communications with the survey.  This allows employers to once again emphasize that responses are kept confidential, that there will be no negative consequence for identifying as an individual with a disability, and that there are benefits to completing the form.

• Employers can include the video that OFCCP created that explains why the survey is being done and how the information will be used. Contractors can link to the video as part of the survey communication.

• Employers should consider surveying the workforce for disability status more frequently than every five years.  Doing so will help ensure that employers have accurate, up-to-date information and may calm any anxiety that employees might have about identifying as individuals with disabilities.

By encouraging employees to participate in the survey, contractors will have a better idea of whether they are truly meeting the 7% disability utilization goal.  Contractors that discover they are falling short of the 7% goal need to review their outreach efforts to disability sources.  In addition, they should review their application, screening, promotion, and other employment processes to ensure there are no barriers to employment or advancement for individuals with disabilities.  Ultimately, what is learned from the results of the disability survey should help organizations develop better processes and procedures that will lead to more opportunities for individuals with disabilities.