In addition to our Week In Review (WIR) and OFCCP Compliance Alerts, we like to provide Compliance Tips. These posts are quick snippets of advice for federal contractors, provided by a variety of field experts. This tip is actually the result of a meeting between the National Industry Liaison Group (NILG) and Debra Carr, Director, Division of Policy and Program Development.
Today’s OFCCP Compliance Tip: Electronic Form CC-305 (Disability Self-ID)
There is no preferred OFCCP way to use the form in an employer’s electronic system other than one that will maintain the form’s integrity (which includes but is not limited to the “look” of the form, and retention of the OMB Control and form numbers on the top of the form). Just as you can’t change the I-9 or the HIPPA privacy form, you can’t change the content of this form. Contractors can use one of the three formats OFCCP provided to them: radio button, drop down, and WORD, not to mention the more than 7 languages in which they now provide the form on OFCCP’s website. There are several reasons OFCCP created an official form instead of a sample template as was done for VEVRAA. For section 503 it is important that employees and applicants with disabilities know that the disclosure is voluntary, that there be consistency and uniformity of language, that employees and applicants know why they are being asked to make the voluntary disclosure (i.e., it’s a requirement of the government that should work to their benefit), and that employers’ inquiries not, even inadvertently, discourage disclosure.