OFCCP should allow federal contractors to create their own disability self-identification forms to fit their corporate cultures, CWC suggested in comments to the White House Office of Management and Budget. We filed the comments in response to OFCCP’s request for OMB approval to continue using Form CC-305 for another three years with only minor changes.
Federal contractors must use Form CC-305 without modifications to collect applicant and employee disability data. However, contractors often find the form confusing, misleading, and burdensome.
CWC recommended that federal contractors be allowed to use OFCCP’s VEVRAA model because it presents a reasonable compromise for satisfying the disability self-identification requirement. Under that model, OFCCP identifies the core elements that must be included but lets the contractor develop and execute the form.
Our comments also recommended the implementation of a pilot program, if necessary, to test the workability of this new flexible option.