On October 3, OFCCP published a request for public comment on its proposed revisions to its self-identification form regarding disability status for applicants and employees. These comments were sought as part of the required renewal process from the Office of Management and Budget (OMB) for the current form that expires on January 31, 2020.

OFCCP’s proposed revisions appear to be focused on streamlining the form and providing more information to applicants and employees as to why disability information is being requested.

Proposed revisions include:

• The elimination of the second page of the current form regarding reasonable accommodation.
• Changing the affirmative response to read “Yes, I have a disability, or have a history/record of having a disability” from “Yes, I have a disability (or previously had a disability).”
• Additional narrative surrounding a federal contractor’s obligations to solicit disability status from applicants and employees.
• The addition of other examples of disabilities, including: autoimmune disorders, cardiovascular or heart disease, gastrointestinal disorders, nervous system conditions, and psychiatric conditions.

The agency is particularly interested in comments which evaluate the proposed revisions, including suggested updates “…for matching applicants with forms for affirmative action purposes using a method other than name.” They are also seeking comment on the accuracy of the agency’s estimated burden hours associated with the information collection, evaluation of the necessity and utility of the data collection, and suggestions for minimizing the burden of the information collection on federal contractors and subcontractors.

The public comment period closes on December 2, 2019, and comments can be submitted here.

Stay tuned to our blog for updates as we learn more.