by Nadine Vogel, President, Springboard Consulting LLC If a company is a U.S. federal contractor or subcontractor, its Diversity, HR, and EEO professionals are...

by Nadine Vogel, President, Springboard Consulting LLC

Nadine Vogel

Nadine Vogel

If a company is a U.S. federal contractor or subcontractor, its Diversity, HR, and EEO professionals are most likely aware of the 7 percent hiring goal proposed by the OFCCP.

With President Obama’s re-election, a President who has shown tremendous support for improving job opportunities for individuals with disabilities, it is believed that this proposed rule will, in some form, be put into law. But how prepared are these organizations?

Highlights of the proposed rule include:

Goals: Federal contractors and subcontractors would be required to set a hiring goal of having 7 percent of their employees be workers with disabilities in each job group of the contractors’ workforce.

Data Collection: Improve collection of data on employment of people with disabilities by modifying the invitation for workers to self-identify by requiring that contractors invite all applicants to voluntarily self-identify as an “individual with a disability” at the pre-offer stage of the hiring process. Contractors also will be required to invite post-offer voluntary self-identification and to survey all employees annually in order to invite their self-identification in an anonymous manner.

Record-Keeping: Require that contractors maintain records on the number of individuals with disabilities applying for positions and the number of individuals with disabilities hired.

Accommodation Requests: Require, for the first time, that contractors develop and implement written procedures for processing requests for reasonable accommodation.

Outreach: Require that contractors engage in a minimum of three specific types of outreach and recruitment efforts to recruit individuals with disabilities.

Job Listings: Require that contractors list job openings with One-Stop Career Centers or other appropriate employment delivery systems.

Annual Reviews: Require previously recommended steps contractors must take to review their personnel processes, as well as their physical and mental job qualifications.

ADAAA Updates: Incorporate updates made necessary by the ADA Amendments Act (ADAAA) of 2008.

The key to successfully meeting these requirements and doing so in a manner that is cost effective, mitigates risk, ensures productivity, and is consistent with corporate culture is organizational readiness. Waiting can be costly. Conducting a Disability Organizational Assessment and Gap Analysis will determine your overall readiness and provide a strategic blueprint for how to proceed successfully and sustainably. In the meantime, paying attention to the action items below will be helpful.

• Talent acquisition strategy and execution
• Training of recruiters, HR professionals, and managers
• A fair and equitable reasonable accommodation process
• Disclosure guidance
• Etiquette and awareness training
• Website and related accessibility
• Essential job functions

No matter how a company ultimately determines how to address these issues, they should keep in mind that although the legal implications are important, it’s the practical applications that are critical.

Nadine Vogel is president of Springboard Consulting LLC. Springboard ( is considered a global expert, working with corporations, governments, and organizations on issues pertaining to supporting the disability community in the workforce, workplace, and marketplace. She is also the author of DIVE IN, Springboard into the Profitability, Productivity and Potential of the Special Needs Workforce.

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