All federal contactors subject to the jurisdiction of the Office of Federal Contractor Compliance Programs (OFCCP) must begin surveying applicants and employees for disabilities using a new and approved Voluntary Self-Identification form.

Starting on August 4, 2020, federal contractors and subcontractors are required to implement the new form in their applicant and employee systems and processes. The new form can be found here. It is important to note that the only portion of the form that may be modified or deleted is the “For Employer Use Only” section, which was added to assist contractors with their recordkeeping for data analysis, as required by the OFCCP’s regulations.

See Faegre Drinker’s previous client alert regarding features of the new form.

Employee and applicant self-identification and disability tracking is an important part of a federal contractor’s affirmative action program. Accordingly, use of the new and approved form is a legal requirement and an important part of OFCCP audit preparation and defense.