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Danger and Opportunity:
 The Business Advantage of
 OFCCP and EEOC Disability
        Compliance
Agenda
Introduction
The ROI of Hiring People with
 Disabilities
OFCCP Section 503
Directive 281
Accessibility
Recommendations
Disability Friendly Business
 Certification Program
Presenter:
 Leslie Wilson
 President/CEO
 Wilson Resources, Inc.
People with disabilities are
 America’s largest minority group.
 There are an estimated 36 million
  Americans with a disability. For
 businesses/employers that equals
untapped employees and customers.
     Source: U.S. Census Bureau, American Community Survey 2008
There are 19.8 million
Americans with disabilities
between the ages of 18-64 –
   working age. Their
unemployment rate is 79%.
     Source: U.S. Census Bureau, American Community Survey 2008
Where would the world be
  without the contributions of
    people with disabilities?
Stephen Hawking   James Earl Jones Sir Winston Churchill   Annie Sullivan   Pythagoras
The World is Changing
 The number of people with disabilities is on the rise
  due to many factors, including an aging population
 Technological advances
 The United      States, along with many other
  countries, has been taking major steps to ensure
  the rights of people with disabilities.
 Accessibility  is becoming a greater priority
  worldwide as evidenced by the UN Convention on
  the Rights of People with Disabilities.
Florida’s Local BLNs
Business Leadership
         Networks
The purpose of the BLNs is to create awareness of the
skills and abilities of workers with disabilities through
the organization of an employer-to employer network.
The 2007, 2008 and 2009 surveys of 351 Florida BLN
employers found that the number one impediment to
the employment of people with disabilities, at all
corporate levels, was: “Attitudes”

    The 2008 and 2009Florida BLN
         surveys highlighted
 “hiring managers” &“front-line staff”
   as most concerned about hiring
       workers with disabilities.
The Return On Investment of Hiring
People with Disabilities
 People with disabilities DO NOT cost
  more to employ than people without
  disabilities.
 Research has shown: There is no
  significant difference between the
  productivity of people with disabilities
  and people without disabilities,
  particularly in knowledge-related
  business.
 On the average, people with disabilities
  DO NOT miss more work than people
  without disabilities.
The Return On Investment of Hiring
People with Disabilities
• A national survey of 803 consumers randomly
selected from across the U.S., found that 92% felt
more favorable toward companies that hire
people with disabilities and 87% said they would
prefer to give their business to such companies.

•Nearly half (44%) of Walgreen’s Anderson, South
Carolina distribution center’s 430 workers are
disabled. Walgreens has found that the
distribution center in Anderson is no less
productive than its other centers. In fact,
Anderson is more productive. The training
and technologies that help workers with
disabilities do their jobs help all employees
do their jobs better.
The Return On Investment of Hiring
People with Disabilities
 • Over the course of nine months,
 Walgreens saved $17,000 in Workers
 Compensation due to fewer incidents
 caused by its employees with disabilities.
 Incidents that occurred were less costly,
 there was less property damage and the
 workers with disabilities returned to
 work in less time.
EEOC FY 2009 Charge Data

       People with disabilities are least likely to
       file discrimination charges when
       compared to four other minority groups.
       Charges based on:

                  Race:          36.0%
                  Sex:           30.0%
                  Age:           24.4%
                  Disability:    23.0%
Section 503 of the Rehabilitation Act

  Section 503 of the Rehabilitation Act of 1973 prohibits
   discrimination and requires employers with federal
   contracts or subcontracts that exceed $10,000 to take
   affirmative action to hire, retain, and promote
   qualified individuals with disabilities.
  This law is enforced by the Employment Standards
   Administration's Office of Federal Contract
   Compliance Programs (OFCCP) within the U.S.
   Department of Labor.
Sample of OFCCP Section 503 Requirements
  Maintain an Affirmative Action Program in accordance with 41
   C.F.R. PART 60–741 - Availability of Affirmative Action Program and
   Nondiscrimination Obligations Regarding People with Disabilities;

  Invite applicants to inform the contractor that they are a person with
   a disability as defined by the ADA, in accordance with 41 CFR 60-
   741.42 - Invitation to self-identify.
   Individual with a disability is defined as any person who:
      (i) Has a physical or mental impairment which substantially
            limits one or more of such person's major life activities;
      (ii) Has a record of such an impairment; or
      (iii) Is regarded as having such an impairment; and

  Undertake appropriate outreach, in accordance with 41 CFR 60-
   741.44 (f) – External dissemination of policy, outreach and positive
   recruitment.
OFCCP Section 503 Requirements
  Findings for the Northeast OFCCP Region: Four
     out of Five of the Section 503 Conciliation
    Agreements Contained Violations for FY10,
                      Including:

 Failure to maintain an Affirmative Action Program Regarding People
  with Disabilities;

 Failure to invite applicants to inform the contractor that they are a
  person with a disability; and

 Failure to undertake appropriate outreach. Most often there was “no”
  outreach.
OFCCP The New Review: Taking
   EEO Compliance to the Next Level

At the August 2010 National Industry Liaison Group Conference
in Las Vegas, OFCCP’s Sandra Zeigler announced that OFCCP is:

   Stepping up enforcement in its compliance reviews in areas
    they had not focused on before.

   Hiring a lot of new staff.

    Increasing emphasis on Section 503 and veterans with an
     uptick in 503 reviews and more onsite reviews to check for
     503 compliance.
OFCCP The New Review: Taking
   EEO Compliance to the Next Level
At the August 2010 National Industry Liaison Group Conference
in Las Vegas, OFCCP’s Sandra Zeigler announced that OFCCP is:

   Investigating outreach efforts to the community of
     individuals with disabilities – requires actually making an
     effort to contact the community resources. OFCCP will call
     them to check.

   Looking at Section 503 measurable results: How many
    people with disabilities were referred to you, did you
    recruit, hire and retain so you know the program is
    working. “Do not let it be a paperwork exercise.”
OFCCP The New Review: Taking
           EEO Compliance to the Next Level

At the August 2010 National Industry Liaison Group Conference in Las
Vegas, OFCCP’s Sandra Zeigler announced that OFCCP is:

    Looking at your efforts to assure the individual is given the opportunity
     to self-identify as an individual with a disability and what efforts, if any,
     were made to increase the likelihood the applicant would complete the
     invitation to self-identify. Recommendations to make people more
     comfortable:

             • Create an internal marketing piece that shows the company is
                proactive in recruiting people with disabilities
             • Talk openly with all candidates about the company’s efforts to
                recruit people with disabilities
OFCCP The New Review: Taking
  EEO Compliance to the Next Level
At the August 2010 National Industry Liaison Group
Conference in Las Vegas, OFCCP’s Sandra Zeigler
announced that OFCCP is:

   Looking at your application process to assure it is
    accessible. This includes web-based applications.

    Reviewing your process for requesting an
     accommodation and your accommodations policy.
The Big Picture
 One in four computer users has low
  vision or is blind.
 One in four computer users has a
  dexterity difficulty or impairment.
 One in five computer users is deaf
  or hard of hearing.
 Regardless of disability, EVERY
  computer user benefits from greater
  usability.
Directive 281
 In response to changing technologies, many contractors
  have moved towards using an online application system
  as their primary, if not exclusive, method for accepting
  applications for employment.
 While some of these systems may be accessible to
  individuals with disabilities, others may be completely
  inaccessible or only partially accessible due to
  technological limitations.
 Federal contractors and subcontractors must ensure that
  qualified individuals with disabilities and veterans with
  disabilities have an equal opportunity for employment.
Directive 281
 All compliance evaluations shall include a review
  of the contractor's online application systems to
  ensure that the contractor is providing equal
  opportunity to qualified individuals with
  disabilities and veterans with disabilities.
 The review should include whether the
  contractor is providing a reasonable
  accommodation, when requested, unless such
  accommodation would cause an undue hardship.
 In this directive, the term "online system" shall
  include, but not be limited to, all electronic or
  web-based systems that the contractor uses in all
  of its personnel activities.
Accessibility
 Web accessibility means that people with disabilities can use the
  Web.

 More specifically, Web accessibility means that people with
  disabilities can perceive, understand, navigate, and interact with
  the Web, and that they can contribute to the Web.

 Web accessibility encompasses all disabilities that affect access
  to the Web, including visual, auditory, physical, speech,
  cognitive, and neurological disabilities.

 Currently most Web sites and Web software have accessibility
  barriers that make it difficult or impossible for many people with
  disabilities to use the Web.
Job Accommodation Network (JAN)

   JAN is the leading source of free, expert, and
       confidential guidance on workplace
   accommodations and disability employment
issues. JAN works toward practical solutions that
      benefit both employer and employee.

 (800)526-7234 (Voice) (877)781-9403 (TTY)
             http://askjan.org/
TecAccess

  TecAccess specializes in making Information and
 Communication Technologies (ICT) accessible to the
  world´s largest and fastest growing demographic –
               people with disabilities.

                  (804) 749-8646
      Email: Debra Ruh: druh@tecassess.net
OFCCP Advanced Notice of
 Proposed Rulemaking Impacting
       Section 503 of the
    Rehabilitation Act of 1973
On July 23, 2010 OFCCP announced its Notice of
Proposed Rulemaking and asked for comments
on the following topics:
    What employment practices have been effective in recruiting, hiring,
   advancing and retaining qualified individuals with disabilities.

   What data are available that could be used to establish hiring goals and
   conduct utilization analyses of individuals with disabilities.

    How linkage agreements between federal contractors and organizations
   that focus on the employment of qualified individuals with disabilities can be
   strengthened to increase effectiveness.
OFCCP Advanced Notice of Proposed
        Rulemaking Impacting Section 503 of
           the Rehabilitation Act of 1973
The U.S. Department of Labor's Office of Federal Contract Compliance Programs is
seeking input from the public on ways to strengthen its regulations requiring federal
contractors to take affirmative action to employ and advance
in employment qualified individuals with disabilities.
In an Advance Notice of Proposed Rulemaking (ANPRM)
published in the Federal Register July 23, 2010 the agency
invites the public to help revise the regulations implementing
Section 503 of the Rehabilitation Act of 1973.

Comments must be received by OFCCP within 60 days of the
ANPRM's publication. To read the ANPRM or submit a
comment, go to the Federal eRulemaking Portal at
www.regulations.gov. The deadline for receiving comments
is --Sept. 21, 2010.

             http://www.regulations.gov/search/Regs/home.html#documentD
             etail?R=0900006480b1fd5a
Recommendations to Help You Meet OFCCP
     Affirmative Action Rules Related to
           People with Disabilities
1.   1. Be Proactive – Become Disability Friendly.
2.   2. Update your company’s Diversity Plan to include people
     with disabilities as part of your diverse workforce, and
     announce the company’s efforts so that employees with
     disabilities feel comfortable revealing their disabilities.
3.   3. Ensure your company has an annually revised Affirmative
     Action Plan that meets OFCCP rules related to people with
     disabilities. Ask for input.
4.   4. Train mid-level managers, supervisors and front-line staff
     to successfully work with people with disabilities by allaying
     concerns and dispelling myths.
5.   5. Organize an ERG for People with Disabilities, or if your
     company has limited ERGs, be sure to include people with
     disabilities.
Recommendations to Help You Meet OFCCP
         Affirmative Action Rules Related to
        People with Disabilities…continued
5.    6. Create a centralized budget for accommodations so that
      unit budgets are not affected.
6.    7. Maintain an Accommodations’ Log.
7.    8. Join your local Business Leadership Network (BLN) or serve
      on an employment service provider’s Employer Advisory
      Committee or Board of Directors.
      9. Create relationships with organizations assisting people
      with disabilities to become employed, e.g., Vocational
      Rehabilitation, service providers, school transition programs
      10. Participate in Disability Mentoring Day or other mentoring
      programs, and more formal Internship Programs.
      11. Become a Ticket to Work Employer Partner:
      www.cessi.net/ttw/employer/partners.html
2010 Top10
Companies for Disability
No. 1: IBM
No. 2: Ernst & Young
No. 3: Procter and Gamble
No. 4: Aetna
No. 5: KPMG
No. 6: Cisco Systems
No. 7: SC Johnson
No. 8: Eli Lilly & Co.
No. 9: Merck & Co.
No. 10: Sodexo
2010 Top10
Companies for Disability
 All have at least one resource group for employees with disabilities
   versus 76% of the DiversityInc Top 50; Organizations with ERGs have
   fewer EEOC charges, according to Cornell University’s EARN Program

 All offer dependent-care benefits (including childcare and eldercare)
  versus 94% of the DiversityInc Top 50

 All feature images and/or video of people with disabilities on their
  corporate websites, compared with 80% of the DiversityInc Top 50

 Eighty percent offer alternative career tracks for parents or others with long-term
  family-care issues; 62% of the DiversityInc Top 50 do so

 Eighty percent have mandatory diversity training for all employees versus 64% of
  the DiversityInc Top 50
BLN Three-Part Initiative Based
on Annual Survey Results:


 Educate BLN Employer Members


 Educate Other Employers in the
 Community

 Encourage Employment, and Organize
  Internships and Mentoring Opportunities
Disability Friendly Business
        Certification
               Is Your Company
                   Disability
                   Friendly?
              Bringing Disability to the
               Forefront of Diversity
                   www.NationalCTC.com




           Supported By:
Companies that Participated in
Developing the Certification
Program:
 Blue Cross and Blue Shield of
  Florida
Federal Reserve Bank of Atlanta
 (Jacksonville Branch)
 Holland and Knight Law Firm
 Great Florida Bank
 Baptist Health South Florida
 Merrill Lynch
 Citigroup
 Home Depot
 SunTrust Bank
 Bromberg & Associates
Disability Friendly
Business Certification
 Developed by Business for Business
A Cooperative Project of the Miami-Dade and First Coast
  Business Leadership Networks (BLNs) and the National
  Certification and Training Center,
  A Division of Wilson Resources, Inc. (WRI)

The purpose of the Disability Friendly Business
  Certification Program is to recognize businesses for
  their outstanding efforts to include and meet the needs
  of employees and customers with disabilities.
Disability Friendly
       Business Certification
                  Benefits to Employers
      Bringing Disability to the Forefront of Diversity
                  www.NationalCTC.com

 Assure your company is “disability friendly”
 Assist federal contractors to meet Affirmative Action
  requirements of the U.S. Department of Labor’s Office of
  Federal Contract Compliance Programs (OFCCP) for the
  recruitment of qualified workers with disabilities
 Promote your company as “disability-friendly” and attract the
  attention of the largest minority group in the country
 Internally and externally promote your company’s
  commitment to diversity, and a positive work environment
Disability Friendly
        Business Certification
                    Benefits to Employers
  Bringing Disability to the Forefront of Diversity
              www.NationalCTC.com

                Certified Businesses Receive:
 A framed certificate and the Disability Friendly Business logo to be posted on
  the business’ website, emails, stationery and other corporate printed materials

 Disability Friendly Business window stickers

 Posting of the names of all the Certified Disability Friendly Businesses on the
  National Certification and Training Center website: www.NationalCTC.com
Disability Friendly
Business Certification
     “In the process of completing the Disability
     Friendly Certification Program Application,
     and taking a very close look at the required
     dimensions, we saw that there were a
     number of areas where we could really
     improve…We also increased our education
     efforts and conducted more training on
     disability etiquette for our workforce.”
                            Margaret Downey
                            CSX, International
                            Transportation Company
Disability Friendly
      Business Certification
Example of a CSX Email                Example of a Federal
Signature                             Reserve Bank of Atlanta
                                      Email Signature
     Staffing Specialist – Military
     Recruiting & Diversity           FRB Atlanta, Jacksonville Branch
     500 Water Street
     5th Floor, J400
     Jacksonville, FL 32202
“I want to challenge every employer here to
hire a person with disabilities this year -- and
another one next year, and the year after
that. This effort isn’t charity or good
corporate citizenship – it’s just smart
business.”

-- Former Florida Governor Jeb Bush
Contact Information
 Leslie Wilson
 President/CEO
 Wilson Resources, Inc.

 1747 Amberwynd Circle West
 Palmetto, FL 34221
 Phone: 941/729-9673
 Email: lesliew@wilres.com
 Websites:
 www.wilres.com
 www.NationalCTC.com

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Wilson - The Business Advantage of OFCCP & EEOC Disability Compliance

  • 1. Danger and Opportunity: The Business Advantage of OFCCP and EEOC Disability Compliance
  • 2. Agenda Introduction The ROI of Hiring People with Disabilities OFCCP Section 503 Directive 281 Accessibility Recommendations Disability Friendly Business Certification Program
  • 3. Presenter: Leslie Wilson President/CEO Wilson Resources, Inc.
  • 4. People with disabilities are America’s largest minority group. There are an estimated 36 million Americans with a disability. For businesses/employers that equals untapped employees and customers. Source: U.S. Census Bureau, American Community Survey 2008
  • 5. There are 19.8 million Americans with disabilities between the ages of 18-64 – working age. Their unemployment rate is 79%. Source: U.S. Census Bureau, American Community Survey 2008
  • 6. Where would the world be without the contributions of people with disabilities? Stephen Hawking James Earl Jones Sir Winston Churchill Annie Sullivan Pythagoras
  • 7. The World is Changing  The number of people with disabilities is on the rise due to many factors, including an aging population  Technological advances  The United States, along with many other countries, has been taking major steps to ensure the rights of people with disabilities.  Accessibility is becoming a greater priority worldwide as evidenced by the UN Convention on the Rights of People with Disabilities.
  • 9. Business Leadership Networks The purpose of the BLNs is to create awareness of the skills and abilities of workers with disabilities through the organization of an employer-to employer network. The 2007, 2008 and 2009 surveys of 351 Florida BLN employers found that the number one impediment to the employment of people with disabilities, at all corporate levels, was: “Attitudes” The 2008 and 2009Florida BLN surveys highlighted “hiring managers” &“front-line staff” as most concerned about hiring workers with disabilities.
  • 10. The Return On Investment of Hiring People with Disabilities  People with disabilities DO NOT cost more to employ than people without disabilities.  Research has shown: There is no significant difference between the productivity of people with disabilities and people without disabilities, particularly in knowledge-related business.  On the average, people with disabilities DO NOT miss more work than people without disabilities.
  • 11. The Return On Investment of Hiring People with Disabilities • A national survey of 803 consumers randomly selected from across the U.S., found that 92% felt more favorable toward companies that hire people with disabilities and 87% said they would prefer to give their business to such companies. •Nearly half (44%) of Walgreen’s Anderson, South Carolina distribution center’s 430 workers are disabled. Walgreens has found that the distribution center in Anderson is no less productive than its other centers. In fact, Anderson is more productive. The training and technologies that help workers with disabilities do their jobs help all employees do their jobs better.
  • 12. The Return On Investment of Hiring People with Disabilities • Over the course of nine months, Walgreens saved $17,000 in Workers Compensation due to fewer incidents caused by its employees with disabilities. Incidents that occurred were less costly, there was less property damage and the workers with disabilities returned to work in less time.
  • 13. EEOC FY 2009 Charge Data People with disabilities are least likely to file discrimination charges when compared to four other minority groups. Charges based on: Race: 36.0% Sex: 30.0% Age: 24.4% Disability: 23.0%
  • 14. Section 503 of the Rehabilitation Act  Section 503 of the Rehabilitation Act of 1973 prohibits discrimination and requires employers with federal contracts or subcontracts that exceed $10,000 to take affirmative action to hire, retain, and promote qualified individuals with disabilities.  This law is enforced by the Employment Standards Administration's Office of Federal Contract Compliance Programs (OFCCP) within the U.S. Department of Labor.
  • 15. Sample of OFCCP Section 503 Requirements  Maintain an Affirmative Action Program in accordance with 41 C.F.R. PART 60–741 - Availability of Affirmative Action Program and Nondiscrimination Obligations Regarding People with Disabilities;  Invite applicants to inform the contractor that they are a person with a disability as defined by the ADA, in accordance with 41 CFR 60- 741.42 - Invitation to self-identify. Individual with a disability is defined as any person who: (i) Has a physical or mental impairment which substantially limits one or more of such person's major life activities; (ii) Has a record of such an impairment; or (iii) Is regarded as having such an impairment; and  Undertake appropriate outreach, in accordance with 41 CFR 60- 741.44 (f) – External dissemination of policy, outreach and positive recruitment.
  • 16. OFCCP Section 503 Requirements Findings for the Northeast OFCCP Region: Four out of Five of the Section 503 Conciliation Agreements Contained Violations for FY10, Including:  Failure to maintain an Affirmative Action Program Regarding People with Disabilities;  Failure to invite applicants to inform the contractor that they are a person with a disability; and  Failure to undertake appropriate outreach. Most often there was “no” outreach.
  • 17. OFCCP The New Review: Taking EEO Compliance to the Next Level At the August 2010 National Industry Liaison Group Conference in Las Vegas, OFCCP’s Sandra Zeigler announced that OFCCP is: Stepping up enforcement in its compliance reviews in areas they had not focused on before. Hiring a lot of new staff.  Increasing emphasis on Section 503 and veterans with an uptick in 503 reviews and more onsite reviews to check for 503 compliance.
  • 18. OFCCP The New Review: Taking EEO Compliance to the Next Level At the August 2010 National Industry Liaison Group Conference in Las Vegas, OFCCP’s Sandra Zeigler announced that OFCCP is: Investigating outreach efforts to the community of individuals with disabilities – requires actually making an effort to contact the community resources. OFCCP will call them to check. Looking at Section 503 measurable results: How many people with disabilities were referred to you, did you recruit, hire and retain so you know the program is working. “Do not let it be a paperwork exercise.”
  • 19. OFCCP The New Review: Taking EEO Compliance to the Next Level At the August 2010 National Industry Liaison Group Conference in Las Vegas, OFCCP’s Sandra Zeigler announced that OFCCP is: Looking at your efforts to assure the individual is given the opportunity to self-identify as an individual with a disability and what efforts, if any, were made to increase the likelihood the applicant would complete the invitation to self-identify. Recommendations to make people more comfortable: • Create an internal marketing piece that shows the company is proactive in recruiting people with disabilities • Talk openly with all candidates about the company’s efforts to recruit people with disabilities
  • 20. OFCCP The New Review: Taking EEO Compliance to the Next Level At the August 2010 National Industry Liaison Group Conference in Las Vegas, OFCCP’s Sandra Zeigler announced that OFCCP is: Looking at your application process to assure it is accessible. This includes web-based applications.  Reviewing your process for requesting an accommodation and your accommodations policy.
  • 21. The Big Picture  One in four computer users has low vision or is blind.  One in four computer users has a dexterity difficulty or impairment.  One in five computer users is deaf or hard of hearing.  Regardless of disability, EVERY computer user benefits from greater usability.
  • 22. Directive 281  In response to changing technologies, many contractors have moved towards using an online application system as their primary, if not exclusive, method for accepting applications for employment.  While some of these systems may be accessible to individuals with disabilities, others may be completely inaccessible or only partially accessible due to technological limitations.  Federal contractors and subcontractors must ensure that qualified individuals with disabilities and veterans with disabilities have an equal opportunity for employment.
  • 23. Directive 281  All compliance evaluations shall include a review of the contractor's online application systems to ensure that the contractor is providing equal opportunity to qualified individuals with disabilities and veterans with disabilities.  The review should include whether the contractor is providing a reasonable accommodation, when requested, unless such accommodation would cause an undue hardship.  In this directive, the term "online system" shall include, but not be limited to, all electronic or web-based systems that the contractor uses in all of its personnel activities.
  • 24. Accessibility  Web accessibility means that people with disabilities can use the Web.  More specifically, Web accessibility means that people with disabilities can perceive, understand, navigate, and interact with the Web, and that they can contribute to the Web.  Web accessibility encompasses all disabilities that affect access to the Web, including visual, auditory, physical, speech, cognitive, and neurological disabilities.  Currently most Web sites and Web software have accessibility barriers that make it difficult or impossible for many people with disabilities to use the Web.
  • 25. Job Accommodation Network (JAN) JAN is the leading source of free, expert, and confidential guidance on workplace accommodations and disability employment issues. JAN works toward practical solutions that benefit both employer and employee. (800)526-7234 (Voice) (877)781-9403 (TTY) http://askjan.org/
  • 26. TecAccess TecAccess specializes in making Information and Communication Technologies (ICT) accessible to the world´s largest and fastest growing demographic – people with disabilities. (804) 749-8646 Email: Debra Ruh: druh@tecassess.net
  • 27. OFCCP Advanced Notice of Proposed Rulemaking Impacting Section 503 of the Rehabilitation Act of 1973 On July 23, 2010 OFCCP announced its Notice of Proposed Rulemaking and asked for comments on the following topics:  What employment practices have been effective in recruiting, hiring, advancing and retaining qualified individuals with disabilities. What data are available that could be used to establish hiring goals and conduct utilization analyses of individuals with disabilities.  How linkage agreements between federal contractors and organizations that focus on the employment of qualified individuals with disabilities can be strengthened to increase effectiveness.
  • 28. OFCCP Advanced Notice of Proposed Rulemaking Impacting Section 503 of the Rehabilitation Act of 1973 The U.S. Department of Labor's Office of Federal Contract Compliance Programs is seeking input from the public on ways to strengthen its regulations requiring federal contractors to take affirmative action to employ and advance in employment qualified individuals with disabilities. In an Advance Notice of Proposed Rulemaking (ANPRM) published in the Federal Register July 23, 2010 the agency invites the public to help revise the regulations implementing Section 503 of the Rehabilitation Act of 1973. Comments must be received by OFCCP within 60 days of the ANPRM's publication. To read the ANPRM or submit a comment, go to the Federal eRulemaking Portal at www.regulations.gov. The deadline for receiving comments is --Sept. 21, 2010. http://www.regulations.gov/search/Regs/home.html#documentD etail?R=0900006480b1fd5a
  • 29. Recommendations to Help You Meet OFCCP Affirmative Action Rules Related to People with Disabilities 1. 1. Be Proactive – Become Disability Friendly. 2. 2. Update your company’s Diversity Plan to include people with disabilities as part of your diverse workforce, and announce the company’s efforts so that employees with disabilities feel comfortable revealing their disabilities. 3. 3. Ensure your company has an annually revised Affirmative Action Plan that meets OFCCP rules related to people with disabilities. Ask for input. 4. 4. Train mid-level managers, supervisors and front-line staff to successfully work with people with disabilities by allaying concerns and dispelling myths. 5. 5. Organize an ERG for People with Disabilities, or if your company has limited ERGs, be sure to include people with disabilities.
  • 30. Recommendations to Help You Meet OFCCP Affirmative Action Rules Related to People with Disabilities…continued 5. 6. Create a centralized budget for accommodations so that unit budgets are not affected. 6. 7. Maintain an Accommodations’ Log. 7. 8. Join your local Business Leadership Network (BLN) or serve on an employment service provider’s Employer Advisory Committee or Board of Directors. 9. Create relationships with organizations assisting people with disabilities to become employed, e.g., Vocational Rehabilitation, service providers, school transition programs 10. Participate in Disability Mentoring Day or other mentoring programs, and more formal Internship Programs. 11. Become a Ticket to Work Employer Partner: www.cessi.net/ttw/employer/partners.html
  • 31. 2010 Top10 Companies for Disability No. 1: IBM No. 2: Ernst & Young No. 3: Procter and Gamble No. 4: Aetna No. 5: KPMG No. 6: Cisco Systems No. 7: SC Johnson No. 8: Eli Lilly & Co. No. 9: Merck & Co. No. 10: Sodexo
  • 32. 2010 Top10 Companies for Disability  All have at least one resource group for employees with disabilities versus 76% of the DiversityInc Top 50; Organizations with ERGs have fewer EEOC charges, according to Cornell University’s EARN Program  All offer dependent-care benefits (including childcare and eldercare) versus 94% of the DiversityInc Top 50  All feature images and/or video of people with disabilities on their corporate websites, compared with 80% of the DiversityInc Top 50  Eighty percent offer alternative career tracks for parents or others with long-term family-care issues; 62% of the DiversityInc Top 50 do so  Eighty percent have mandatory diversity training for all employees versus 64% of the DiversityInc Top 50
  • 33. BLN Three-Part Initiative Based on Annual Survey Results:  Educate BLN Employer Members  Educate Other Employers in the Community  Encourage Employment, and Organize Internships and Mentoring Opportunities
  • 34. Disability Friendly Business Certification Is Your Company Disability Friendly? Bringing Disability to the Forefront of Diversity www.NationalCTC.com Supported By:
  • 35. Companies that Participated in Developing the Certification Program:  Blue Cross and Blue Shield of Florida Federal Reserve Bank of Atlanta (Jacksonville Branch)  Holland and Knight Law Firm  Great Florida Bank  Baptist Health South Florida  Merrill Lynch  Citigroup  Home Depot  SunTrust Bank  Bromberg & Associates
  • 36. Disability Friendly Business Certification Developed by Business for Business A Cooperative Project of the Miami-Dade and First Coast Business Leadership Networks (BLNs) and the National Certification and Training Center, A Division of Wilson Resources, Inc. (WRI) The purpose of the Disability Friendly Business Certification Program is to recognize businesses for their outstanding efforts to include and meet the needs of employees and customers with disabilities.
  • 37. Disability Friendly Business Certification Benefits to Employers Bringing Disability to the Forefront of Diversity www.NationalCTC.com  Assure your company is “disability friendly”  Assist federal contractors to meet Affirmative Action requirements of the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) for the recruitment of qualified workers with disabilities  Promote your company as “disability-friendly” and attract the attention of the largest minority group in the country  Internally and externally promote your company’s commitment to diversity, and a positive work environment
  • 38. Disability Friendly Business Certification Benefits to Employers Bringing Disability to the Forefront of Diversity www.NationalCTC.com Certified Businesses Receive:  A framed certificate and the Disability Friendly Business logo to be posted on the business’ website, emails, stationery and other corporate printed materials  Disability Friendly Business window stickers  Posting of the names of all the Certified Disability Friendly Businesses on the National Certification and Training Center website: www.NationalCTC.com
  • 39. Disability Friendly Business Certification “In the process of completing the Disability Friendly Certification Program Application, and taking a very close look at the required dimensions, we saw that there were a number of areas where we could really improve…We also increased our education efforts and conducted more training on disability etiquette for our workforce.” Margaret Downey CSX, International Transportation Company
  • 40. Disability Friendly Business Certification Example of a CSX Email Example of a Federal Signature Reserve Bank of Atlanta Email Signature Staffing Specialist – Military Recruiting & Diversity FRB Atlanta, Jacksonville Branch 500 Water Street 5th Floor, J400 Jacksonville, FL 32202
  • 41. “I want to challenge every employer here to hire a person with disabilities this year -- and another one next year, and the year after that. This effort isn’t charity or good corporate citizenship – it’s just smart business.” -- Former Florida Governor Jeb Bush
  • 42. Contact Information Leslie Wilson President/CEO Wilson Resources, Inc. 1747 Amberwynd Circle West Palmetto, FL 34221 Phone: 941/729-9673 Email: lesliew@wilres.com Websites: www.wilres.com www.NationalCTC.com