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OFCCP seeks OMB approval of seven new foreign language versions and drop-down menu for disability self-id form

September 11th, 2014  |  Cynthia L. Hackerott

The OFCCP is seeking Office of Management and Budget (OMB) permission to implement two non-material changes to the previously-approved Voluntary Self-Identification of Disability form (CC-305) that is required by the OFCCP’s  revised regulations implementing Section 503 of the Rehabilitation Act (Section 503) (78 FR 58682-58752; effective March 24, 2014). The first change is to reproduce the previously approved form in seven additional languages, and the second is to make the form available in English and Spanish using a dropdown menu format, rather than the existing checkbox or radio button format. The proposed alternate formats do not alter the content or make any substantive changes to the previously approved form.

Federal contractors must use this form to invite job applicants and employees to voluntarily self-identify as an individual with a disability as required by 41 CFR Part 60-741.42 of the revised regulations. The form provides employees and job applicants three options for self-disclosure, provides examples of disabilities, highlights that disclosure is voluntary and confidential, and includes a short paragraph on reasonable accommodation.

The OMB approved the form in Word format in English on January 22, 2014. For posting on the Internet, the OFCCP converted this form to a fillable electronic format to prevent material alteration, but allowed contractors to reproduce the form for their use so long as they followed the guidelines approved by the agency and that were previously submitted to OMB by way of the OFCCP’s Frequently Asked Questions about the new regulations.

Alternate languages. On March 7, 2014 the OMB approved a fillable Spanish pdf version of the form as well as Microsoft Word versions in both English and Spanish. Subsequently, the OFCCP received several requests from federal contractors to make the form available in alternate languages, according to a supporting statement submitted to OMB by the agency on August 27, 2014. To this end, the OFCCP retained an outside vendor to professionally translate the form in the alternate languages, and, on September 8, 2014, submitted to OMB its request for approval to implement the CC-305 form in:

  • German Word and German fillable PDF;
  • Russian Word and Russian fillable PDF;
  • French Word and French fillable PDF;
  • Chinese Traditional Word and Chinese fillable PDF;
  • Chinese Standard Word and Chinese Standard fillable PDF;
  • Japanese Word and Japanese fillable PDF; and
  • Korean Word and Korean fillable PDF.

Dropdown menu. The OFCCP is also seeking OMB approval to permit contractors that are electronically reproducing the form to use a dropdown menu format, rather than the checkbox or radio button format that is currently permitted. As part the requested format, the OFCCP seeks approval to add the question “Do you have a disability?” next to the dropdown box before the three possible responses currently on the approved form. The three response options are:

  • Yes, I have a disability (or previously had a disability)
  • No, I don’t have a disability
  • I don’t wish to answer

In its supporting statement, the OFCCP says it considers the addition of the question to be a non-material change, but one that is warranted for clarity once the form is reformatted to use dropdowns. The agency is concerned that, because the dropdown box immediately follows the non-exhaustive list of disabilities, without the question some responders may believe that the dropdown menu will ask them to identify which listed disability they have and be deterred from responding.

The currently approved versions of Form CC-305 are available on the OFCCP website’s page regarding the revised Section 503 rule at: http://www.dol.gov/ofccp/regs/compliance/section503.htm. The proposed alternate formats are available on the OMB’s RegInfo.gov website at: http://www.reginfo.gov/public/do/PRAICList?ref_nbr=201408-1250-003. Other supplementary documents related to the OFCCP’s approval requests regarding the CC-305 form are posted at: http://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201408-1250-003.

OMB approval of all versions of the form – including the additional alternate formats, if granted – will expire on January 31, 2017.

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