The contractor community has known for a long time that the OFCCP is focusing on (amongst other areas) outreach and recruitment for individuals with disabilities. Related to this, contractors are increasingly being sent “disability accommodation” questionnaires related to their websites and whether they are being developed with consideration for individuals with disabilities. Following are some of the questions contractors are facing:
1. Do you have an online application system used as a method for accepting applications for employment?
2. Are there non-online application methods?
3. Do you provide accommodations for people who cannot use the online system because of a disability?
4. Is your application system compatible with adaptive technology?
5. Do visually impaired applicants have an audio option?
6. Do hearing impaired applicants have a visual option?
7. Do applicants without access to a computer have an in-office application option? If so, is the in-office option accessible to applicants with mobility impairments?
8. Does your organization have a statement or policy indicating that it will take affirmative action to employ and advance individuals with disabilities?
9. Do you periodically evaluate and audit your organization’s personnel processes?
10. Have you provided reasonable accommodations to applicants with disabilities? If no, explain why:
11. Have you ensured that its recruitment process is accessible to all individuals?
Of course, the impact of negative findings to any of these questions will be specific to the audit, but one thing is clear, the OFCCP is following through on its commitment to enforce all of its mandates, including Section 503 of the Rehabilitation Act.
If you would like to talk with a BCG consultant regarding how to best prepare your organization for the increased oversight, contact us directly at 1.800.999.0438 x 102 or email us directly at staff@biddle.com.
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