Exceeding the Requirements of OFCCP Regulations- … · 2016-07-14 · Requirements of OFCCP Regulations- Recruitment, ... separate data analysis file Diversity Best Practices

Exceeding the Requirements of OFCCP Regulations- Recruitment, Accommodation and Inclusion of People with Disabilities

May 9th, 2014

WELCOME REMARKS Jennifer London Leader, Client Experience Diversity Best Practices

@NxtGenDiversity Diversity Best Practices | www.diversitybestpractices.com 3

• Talent Pipeline- where to find the best and brightest people with disabilities for your industry

• Recruitment strategies- utilizing technology to ensure that you are not missing out on top talent

• Creating a centralized reasonable accommodations policy

• Disability Awareness Training resources for recruitment professionals


Alicia Wallace Director, EEO, Diversity & Inclusion Team Wellpoint

Exceeding the Requirements of OFCCP Regulations

Jill Houghton Executive Director US Business Leadership Network


Alicia Wallace Director, EEO, Diversity & Inclusion Team Wellpoint


Section 503 of the Rehabilitation Act

Alicia Wallace, Director, EEO, Diversity & Inclusion Team, Wellpoint

Disability Focused Regulatory Changes

Section 503 of the Rehabilitation Act (similar to ADA ) but for Federal Contractors

• Definition of Disability as revised

• Self Identification obligations

• Goals

• Outreach & Recruitment efforts

• Access & Training

Director Patricia Shiu - DOL, OFCCP


Disability Definition

Definition of disability aligned with ADAAA

The ADA Amendments Act of 2008 (ADAAA) and the final regulations define a disability using a three-pronged approach: A physical or mental impairment that substantially limits one or more

major life activities (sometimes referred to in the regulations as an “actual disability”)

A record of a physical or mental impairment that substantially limited a major life activity (“record of”)

When a covered entity takes an action prohibited by the ADA because of an actual or perceived impairment that is not both transitory and minor (“regarded as”). [Section 1630.2(g)]


Self Identification

New invitation to Self-identify

Mandatory Self-ID Form, provided by OFCCP Pre-Offer: Template with required language

Post-Offer: Must invite current employees to self--identify and update every five (5) years with one reminder in-between

Employers can identify an IWD who did not self-identify disability if it is “obvious” or if an accommodation request is made (but, no guessing)

Self-identification information to remain confidential; separate data analysis file


Utilization Goal & Outreach

7% Utilization Goal of qualified individuals with disabilities – Assessed and tracked annually, similar to assessing minorities and

females

– Included in Affirmative Action Plans

– Employers can identify an IWD who did not self-identify disability if it is “obvious” or if an accommodation request is made (but, no guessing)

Increased Outreach & Recruitment Efforts – Increase efforts to identify and build relationships with diversity

partners

– Track referrals and assess effectiveness of resources

– Written notice to subcontractors, vendors & suppliers to share EO policy and request cooperation


Access & Training

Ensure EEO Policy is accessible

to applicants & employees

Provide reasonable accommodations to

applicants accessing online application system

Accessible formats of EEO Policy; physical office locations and online

Provide training to all employees involved in personnel decisions (i.e. Management, HR, Recruiters, etc.)

Diversity/EEO/AA Teams partnership


Increase Hiring of Individuals with Disabilities!

Kathleen Martinez

Assistant Secretary, ODEP


Jill Houghton

Executive Director US Business Leadership Network


Outreach & Recruitment

• State Vocational Rehabilitation – The National Employment Team (The NET) – Kathy West Evans , Director of Business Relations, CSAVR-NET – [email protected]

• America’s Job Centers – www.Jobcenter.usa.gov

• Veterans Administration – Ruth A. Fanning,

Director, Vocational Rehabilitation Services, U.S. Department of Veterans Affairs

– [email protected]

• Employer Assistance and Resource Network – www.askearn.com

• Employment Networks – http://nenaticket.org/membership/directory/

• Local disability employment providers • Career offices of educational institutions • Private recruitment sources


mailto:[email protected]



http://www.jobcenter.usa.gov/


http://nenaticket.org/membership/directory/

Outreach & Recruitment

• Formal briefing sessions

• Special efforts to reach students with disabilities at educational institutions

• Work-study, internships, job-shadowing programs

• Career days, youth motivation programs

• Attract individuals not currently in the workforce

• Consider applicants with known disabilities for all available positions


Mission Statement

The USBLN® mission is to help business drive performance by leveraging disability inclusion in the workplace, supply chain, and marketplace.

USBLN® Board Chair, Keith P.

Wiedenkeller, Chief People

Officer, AMC Theatres, (AMC)

(Retired)


Our Goal

Help businesses that are seeking ways to enhance their disability inclusion efforts.

Disability Equality IndexSM

Helps companies benchmark their progress and identify

avenues for continued improvement;

Keeps practitioners informed of best and emerging

practices and points them toward peers in the business

community that are already high performers; and,

Builds brand recognition amongst potential and current

employees, investors, and customers, including customers

with disabilities and their friends and families.


Survey Categories

Culture / Leadership (30) Culture Leadership

Enterprise-Wide Access (10) Employment Practices (40)

Benefits Recruitment Employment, Education, Retention, & Advancement Accommodations

Public Support & Engagement (20) Community Engagement Internal/External Support Services


Contact:

Jill Houghton

Executive Director

USBLN

[email protected]

www.usbln.org


For further questions, please e-mail: [email protected]


Upcoming DBP Events • May 21st Global Member Conference

Paris, FRANCE

• June 17-19 Network+Affinity Leadership Congress: Engage, Motivate, Thrive: ERGs DRIVE BUSINESS! New York Academy of Medicine, NY

• July 24th Web Seminar: Human Rights Campaign Corporate Equality Index 2016

• August 7th DBP Member Conference Chicago, IL


Documents

Exceeding the Requirements of OFCCP Regulations- … · 2016-07-14 · Requirements of OFCCP Regulations- Recruitment, ... separate data analysis file Diversity Best Practices