Improving Job Opportunities for Individuals with Disabilities - Part 3

For the past two days, we have been discussing the proposed rules published by the Department of Labor that will require Government contractors to significantly alter the policies, procedures, and practices regarding the recruitment of individuals with disabilities. Here are some of those added requirements:

Data collection - The proposed rule requires contractors collect and maintain several measurements and comparisons related to individuals with disabilities, including the

• number of individuals with disabilities referred to them by employment agencies
• number of individuals with disabilities referred to them by other entities, groups or organizations with which the contractor has a linkage agreement
• number of individuals with disabilities that applied for positions with the contractor; and
• number of individuals with disabilities hired by the contractor.

Compliance reviews - to improve the Office of Federal Contract Comploance Program's (OFCCP's) efficiency in conducting compliance evaluations, the proposed rule permits OFCCP to review contractor records for compliance checks and focused reviews wither on-site or off-site, at OFCCPs discretion. The proposed rule also allows OFCCP to perform pre-award compliance evaluations.

Mandatory job listing requirement - The proposed rule requires contractors to list all job openings with the nearest "One-Stop Career Center". One-Stop Career Centers provide job seekers with a full range of assistance under one roof. One-Stops operate in all 50 states and offer training referrals, career counseling, job listings, and similar employment-related services. This rule is designed to benefit both the contractor and the disability community by improving the contractor's ability to attract qualified applicants with disabilities.

Reasonable accommodation. The proposed rules require that contractors develop and implement specific written procedures for processing requests for reasonable accommodation, and details the minimum elements the procedures must include. Having these written procedures will assist the contractor in consistently satisfying its reasonable accommodation obligation by serving as a blueprint for the prompt handling of reasonable accommodation requests. The maintenance and dissemination of these procedures will also ensure that applicants and employees know how to request a reasonable accommodation, who is responsible for handling accommodation requests, and the maximum amount of time within which the contractor must complete the processing of an accommodation request.