Currently, contractors must satisfy the disability data collection requirement
by using Form CC-305 without alteration. Last November, OFCCP announced
its intent to extend the current Section 503/VEVRAA recordkeeping
requirements with minor changes. CWC submitted comments recommending
a pilot program under the same parameters used for the veteran self-
identification form in which contractors could test a more flexible approach
to Form CC-305. We also recommended that OFCCP clarify definitions in the data metrics requirements.
OFCCP declined to change the definitions because Section 503 and VEVRAA
have different data calculation and enforcement schemes. OFCCP also stated that its existing FAQs adequately define these terms.
However, OFCCP agreed to one of our recommendations by adding the
phrase “Disabilities include, but are not limited to” in bold on Form CC-305.
This change will clarify that the disabilities listed on the form are not
exhaustive. The final version of the CC-305 is otherwise identical to the
version that OFCCP published last November.