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Polsinelli - Labor and Employment
         

  

February 2014

  

Federal Contractors Get in Compliance: New Self-Identification Form for Individuals with Disabilities Issued

  

 
 

  

     

  

 
 

Labor and Employment Professionals:

  

W. Terrence Kilroy

Practice Area Chair

816.374.0533

tkilroy@polsinelli.com

  

Anthony J. Romano

Practice Area Vice Chair

816.360.4251

aromano@polsinelli.com

  

Erin D. Schilling

816.374.0559

eschilling@polsinelli.com

  

  

To view a full list of our Labor and Employment Professionals, click here.

  

To learn more about our Labor and Employment practice, click here.

  


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New disability regulations issued by the Office of Federal Contract Compliance Programs (OFCCP) require covered federal contractors and subcontractors to invite applicants and employees to self-identify their disability status. A new form for inviting applicants and employees to voluntarily self-identify their disability status has been approved. This form invitation must be given on four different occasions: Pre-offer; post-offer; first-year survey of all employees; and five-year survey of all employees.

Unlike other self-identification forms issued by the OFCCP in the past, covered federal contractors and subcontractors may not modify this form. Rather, an identical copy of this form (including the font size) must be used to invite applicants and employees to self-identify their disability status. The form may be given to applicants and employees electronically or on paper. Once the form has been completed it must be kept in a data analysis file separate from the personnel file and the medical file.

The form was initially published without an expiration date but the revised form with an expiration date of 01/31/2017 is now available on the OFCCP's website.

The OFCCP's new regulations take effect on March 24, 2014. The new invitation to self-identify is not required to be implemented until the contractor's next AAP cycle after March 24, but the OFCCP is encouraging contractors to come into compliance as soon as possible after the effective date.

For More Information

If you have questions about the new invitation to self-identify as an individual with a disability or about the new regulations generally, please contact:

 
 

  

     

  

 

 

  

     

  

 
 

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