1. April 7, 2019
New Self-Identification Disability Requirements for Apprenticeship Programs
Information for Apprenticeship Sponsors
Presented By: Office of Apprenticeship

2. Natalie Linton Program Analyst Office of Apprenticeship
Employment and Training Administration
U.S. Department of Labor

3. Debra Carr Zachary Boren Director of Policy,
Division Chief
Office of Apprenticeship
Employment and Training Administration
U.S. Department of Labor
Debra Carr
Director of Policy,
Office of Federal Contract Compliance Programs (OFCCP)
U.S. Department of Labor

4. Review phase-in schedule for the Apprenticeship EEO regulations
Explain the process and elements of the invitation to apprentices and applicants to self- identify as having a disability
Learn about the experience of federal contractors that have used this process for four years
Hear from the audience

5. Phase-In Schedule for Sponsors Registered with OA
Existing Sponsors
New Sponsors
Initial Requirements
January 18, 2017
Upon registration
July 17, 2017 Requirements
July 17, 2017

6. Phase-In Schedule for Sponsors Registered with OA
Existing Sponsors
New Sponsors
Final affirmative action provisions:
Draft written affirmative action plans due
Conduct initial workforce analysis for race & sex
Conduct initial workforce analysis for individuals with disabilities
Conduct initial review of personnel practices
Begin inviting applicants and apprentices to self-identify as having a disability
January 18, 2019
Two years after registration

7. Elements of Disability Self-Identification for Sponsors
Which sponsors are covered?
Why gather this information?
What is the process for gathering this information?
The Voluntary Disability Disclosure Form
When do sponsors offer the invitation to self- identify?
What do sponsors do with the forms and the data?

8. Disability Self-Identification: Which sponsors are covered?
Those Registered Apprenticeship programs required to develop a written affirmative action plan, which are programs that both:
Have five or more apprentices
AND
Do not already provide for the use of affirmative action goals under other specified laws

9. Disability Self-Identification: Why must sponsors gather this information?
Apprenticeship programs will now include disability status in their workforce analyses
Sponsors will need to know the number of apprentices and applicants with disabilities to evaluate their representation in the apprenticeship workforce
National aspirational goal of 7% for each major occupational group across apprenticeships

10. Disability Self-Identification: What is the process?
Invite all apprentices and applicants to self- identify whether they have a disability
No need to determine what disability an apprentice or applicant may have – just whether or not they have a disability
Information gathered using one standard form
Provide paper form in person
Provide online version of form

11. Disability Self-Identification: The Voluntary Disability Disclosure Form

12. Disability Self-Identification: The Voluntary Disability Disclosure Form
How Do I Know if I have a Disability?
You are considered to have a disability if you have:
Physical or mental impairment or medical condition that substantially limits a major life activity, OR
A history or record of such an impairment or medical condition
Disabilities include, but are not limited to:
Blindness, deafness, cancer, diabetes, epilepsy, autism, cerebral palsy, HIV/AIDS, schizophrenia, muscular dystrophy, bipolar disorder, major depression, multiple sclerosis, missing limbs or partially missing limbs, post-traumatic stress disorder, obsessive compulsive disorder, impairments requiring the use of a wheelchair, intellectual disability

13. Disability Self-Identification: When do sponsors offer the invitation to self-identify?
Current apprentices
By January 18, 2019
Annual reminder inviting them to update their status on the form if they wish
Applicants for apprenticeship
January 18, 2019 and beyond: invite all applicants to complete the form
Invite all applicants accepted into the program to complete the form – before they begin apprenticeship

14. Federal Contractors’ Experience with Disability Self-Identification
OFCCP enforces Section 503 of the Rehabilitation Act
Section 503 prohibits federal contractors and subcontractors from discrimination on the basis of disability and requires affirmative actions to recruit, hire, promote and retain individuals with disabilities
Beginning in March 2014, OFCCP required contractors to invite applicants and employees to self-identify as having a disability

15. Federal Contractors’ Experience with Disability Self-Identification
Issues raised by federal contractors – and steps taken to address them:
Violating ADA?
EEOC letter
Employees’ reluctance to complete the form
OFCCP video,
Not enough time to prepare for implementation
OA regulations provide two years
It all comes down to education – educating sponsors, apprentices and applicants

16. Disability Self-Identification Data
Recent Employer Survey Findings:
Self-ID rates: 47% of companies with self-ID campaigns report increase in disclosures
Overall disability representation: 3.9%
Percentage of companies attaining 7% representation: 12% reached the aspirational goal

17. Technical Assistance for Sponsors
Webpage containing:
Voluntary Disability Disclosure Form
Guide for Sponsors on Disability Self- Identification
Link to OFCCP video
Resource sheet on encouraging employees to self-identify
Link to Disability Page – many additional resources

19. Zach Boren Debra Carr Division Chief / Office of Apprenticeship
USDOL
Debra Carr
Director of Policy / Office of Federal Contract Compliance Programs