- Inclusion@Work Overview
- Lead the Way: Inclusive Business Culture
- Build the Pipeline: Outreach & Recruitment
- Hire (& Keep) the Best: Talent Acquisition & Retention Processes
- Ensure Productivity: Reasonable Accommodations
- Communicate: External & Internal Communication of Company Policies & Practices
- Be Tech Savvy: Accessible Information & Communication Technology
- Measure Success: Accountability & Self-identification
Inclusion@Work: A Framework for Building a Disability-Inclusive Organization
What’s the third largest market segment in the U.S.? The answer might surprise you. It’s not a particular race, gender, or cleverly named age cohort. It’s people with disabilities. The size of this population—more than 50 million strong—surpasses Hispanics, African Americans and Asian Americans, as well as Generation X and teens. Add in their families and friends, and you’re looking at billions of dollars in purchasing power.
Want a slice? Any smart business owner would. As with any customer segment, one of the best ways for a company to tap into it is to ensure it is represented in its workforce.
Inclusion@Work provides a path. Developed with input from a range of employers with exemplary track records in disability employment, the Inclusion@Work Framework is an internationally award winning multimedia policy tool that outlines seven core components of a disability-inclusive workplace, along with a menu of strategies for achieving them.
Please note that some of the strategies described in Inclusion@Work are requirements for federal contractors covered by Section 503 of the Rehabilitation Act. However, none of the strategies included in the Inclusion@Work Framework create any new legal requirements for employers, or change current ones. Rather, they are common-sense guidelines that can work in any workplace.
Lead the Way: Inclusive Business Culture
Commitment at all levels of an organization is critical to creating and maintaining a diverse and inclusive work environment. Establishing an inclusive business culture begins with leadership at the highest levels, including top executives and boards of directors. Managers and supervisors, and particularly human resources staff and other personnel involved in hiring decisions, must also understand the role they play in facilitating an inclusive environment. Of course, communicating the goal of an inclusive workplace to all employees—and indicating what they can do to help—is also important.
- EARN Training: Lead the Way Inclusive Business Culture Slide Deck (PDF)
- Webinar – Coming soon!
One action company leaders can take is to adopt formal expressions of commitment and intent related to the recruitment, hiring, retention and advancement of qualified individuals with disabilities, including veterans with disabilities. Successful approaches used by both large and small employers include:
- Making equal employment opportunity for individuals with disabilities an integral part of the company’s strategic mission.
- Implementing a comprehensive, continual series of equal employment opportunity initiatives and building a related infrastructure, with leadership as the catalyst.
- Developing and communicating policy statements and other illustrations of the company’s commitment to disability diversity and inclusion. Policy statements may:
- Affirm the company’s commitment to equal employment opportunity for qualified people with disabilities and taking affirmative steps to recruit, hire, retain and advance them at all levels;
- Provide for an audit and reporting system of efforts to attain equal employment opportunity and eliminate discrimination;
- Assign responsibility for ensuring disability inclusion and diversity to a person or office for implementation;
- Express commitment to recruit, hire, retain and advance persons with disabilities at all levels;
- Ensure that all personnel actions are administered without regard to disability and all employment decisions are based solely on valid job requirements; and
- State that employees and applicants with disabilities will not be subjected to harassment, intimidation, threats, coercion or discrimination because they have engaged in activities such as filing a complaint or participating or assisting in an investigation into one.
- Establishing an enterprise-wide team consisting of executives, managers and employees with disabilities to support and advance the recruiting, hiring, retention and advancement of individuals with disabilities. This team may also function as a disability-focused employee resource group (ERG) or affinity group.
- Distributing an equal employment opportunity policy statement to all employees, by prominently posting the policy statement in all human resources offices and using all channels available, including online, both internally and externally (for example, distributing reasonable accommodation procedures to all managers, supervisors and other personnel responsible for processing reasonable accommodation requests, as well as the entire workforce).
- Seeking input (for example, using employee surveys, focus groups, discussions and ERG or affinity groups) regarding the existence of an accessible and disability-inclusive workplace environment.
- Including disability within the company’s diversity and inclusion policies and activities. This strategy includes using the words “disability” and “people with disabilities” in statements defining the company’s diversity and inclusion policies, inviting disability organizations and people with disabilities to the company’s diversity and inclusion events, and recognizing that talent with disabilities are part of the company’s other diverse communities (including racial and ethnic minorities, veterans and the LGBTQ community).
- Encouraging workers with disabilities and other employees to identify barriers and individual and systemic concerns without fear of reprisal, and also providing mechanisms to allow them to provide this information anonymously or confidentially.
- Establishing a universal policy providing workplace flexibility and accommodations for all applicants and employees, with and without disabilities, including using telework and flextime options, if appropriate.
- Implementing work-life programs and initiatives to help employees balance work and non-work responsibilities.
- Developing emergency management plans that specifically address the needs of employees with disabilities. In addition to providing practical guidelines for emergency managers and employees, such plans should address communication and distribution, employer and first responder responsibilities, employee self-determination and emergency notification channels.
- EARN’s Primer on Disability Inclusion
- EARN’s Mental Health Toolkit: Resources for Fostering a Mentally Healthy Workplace
- EARN’s Toolkit for Establishing and Maintaining Successful Employee Resource Groups
- Expressing a Commitment to Disability Inclusion
- Building an Inclusive Workforce: A Four-Step Reference Guide to Recruiting, Hiring and Retaining Employees with Disabilities
- Campaign for Disability Employment (CDE)
- National Disability Employment Awareness Month (NDEAM)
- U.S. Department of Labor Office of Disability Employment Policy – Employer Page
For State Governments
- Work Matters: A Framework for States on Workforce Development for People with Disabilities
- Disability Employment State Statute and Legislation Scan
- A Joint Resolution or Executive Order to Encourage States to Be Model Employers of People with Disabilities
- A Better Bottom Line: Employing People with Disabilities/Blueprint for Governors
- State Policy Options for Employing People with Disabilities
- Final Report on Best Practices for the Employment of People with Disabilities in State Government
Build the Pipeline: Outreach & Recruitment
“Where can I find talent with disabilities?” Companies have expressed concern that one of the greatest barriers they face to advancing disability inclusion is the inability to find qualified candidates. The key is effective outreach and recruitment. To effectively build a pipeline of applicants with disabilities, your company can develop relationships with a variety of recruitment sources. Such relationships can be formed through formal partnerships as well as meetings and ongoing contact regarding job openings and candidates. The investment will be well worth the effort. Not only will your company secure access to talent that it otherwise may have overlooked, it will also benefit from other supports that can assist in effectively integrating people with disabilities into your workforce.
- EARN Training: Outreach and Recruitment Slide Deck (PDF)
- Webinar: Building the Pipeline: Successful Strategies for Recruiting & Hiring People with Disabilities
Different types of recruitment sources to consider are listed below, with links provided under Resources.
- Public resources, such as American Job Centers (AJCs), state vocational rehabilitation (VR) agencies and community rehabilitation programs, state employment agencies, Employment Networks (ENs) established under the Ticket to Work program, independent living centers (ILCs), the U.S. Department of Labor Veterans’ Employment and Training Service (VETS) and U.S. Department of Veterans Affairs regional offices.
- Private resources, which may include professional organizations, consulting services and companies with expertise in disability.
- Educational institutions, among them community colleges, universities and other institutions of learning and/or training, including those that offer programs for individuals with specific disabilities. Most college campuses have designated offices for students with disabilities, and these should be contacted for recruitment purposes in addition to career services.
- Internship and work experience programs, including those designed for students with disabilities, such as (but not limited to) the Workforce Recruitment Program for College Students with Disabilities (WRP), Career Opportunities for Students with Disabilities (COSD) Career Gateway, Disability:IN Mentorship Exchange, the Viscardi Center’s Emerging Leaders Program and Project SEARCH.
- Nonprofit entities and social service agencies, including labor organizations, service providers operated by and for individuals with disabilities, and other such groups that may provide referrals as well as technical assistance on employment practices, including accommodations.
- Peer networking, which can produce referrals from your own business networks and help you learn what strategies and partnerships other employers use as sourcing pipelines. A local Disability:IN affiliate can connect you to a larger peer network.
Strategies to attract and recruit qualified individuals with disabilities include:
- Hold formal and informal briefing sessions (preferably on company premises) with representatives from recruiting sources. Integral components of briefings include company tours; explanations of current and future job openings and position descriptions; explanations of the company’s selection process; recruiting literature; and a description of opportunities for formalizing arrangements for referrals of applicants.
- Establish formal arrangements for referral of applicants with representatives from recruitment sources, following up with sources and providing feedback on which applicants were interviewed and hired.
- Establish formal training (and deliver it to company employees responsible for recruitment) on how and why to hire individuals with disabilities.
- Provide an accessible online application and use targeted recruitment and social networking sites so that job seekers with disabilities can learn about the company and its hiring initiatives.
- Join employer networking groups, such as Disability:IN or one or more of its local affiliates, that recognize and promote best practices in hiring, retention and promoting individuals with disabilities.
- Post job announcements on accessible web-based “job boards” that specialize in identifying qualified individuals with disabilities (including veterans with disabilities), in disability-related publications, and with specific disability service organizations.
- Participate in career fairs targeting individuals with disabilities, including veterans with disabilities.
- Engage current employees or an employee resource group (ERG) as referral sources and ask for referrals who would make good job candidates and include employees with disabilities on company recruitment teams.
- Build a talent pipeline for youth and young adults with disabilities (transitioning high school students and college students) through mentoring, internships and work experience programs.
- Leverage resources that identify job applicants with disabilities, including databases of individuals with disabilities who previously applied to the company but were not hired and training and internship programs.
- Attract qualified individuals with disabilities through local chapters of organizations operated by and for individuals with disabilities.
- Develop specific and targeted strategies for recruiting, hiring and integrating veterans with disabilities, including wounded returning service members, and implement internal training on these strategies.
- Designate a coordinator or team responsible for targeted outreach programs, including websites, schools and employment assistance programs serving people with disabilities.
- Ensure involvement of existing employees with disabilities in all recruitment activities and processes, for example, at job fairs and on recruitment teams and interview panels.
- EARN Recruitment & Hiring Webpage
- EARN Finding Candidates with Disabilities Webpage
- Talent Acquisition Portal (Council of State Administrators of Vocational Rehabilitation/National Employment Team)
- Disability and Veterans Community Resources Directory
- Workforce Recruitment Program
- Career Opportunities for Students with Disabilities
- Project SEARCH
- Disability:IN Mentorship Exchange
- National Business & Disability Council (NBDC) Emerging Leaders Internship Program for College Students with Disabilities
- Employment Networks
- American Job Centers
- State Vocational Rehabilitation Agencies
- Independent Living Centers
Hire (& Keep) the Best: Talent Acquisition & Retention Processes
- EARN Training: Hire (and Keep) the Best: Talent Acquisition and Retention Process Slide Deck (PDF)
- Webinar: Hiring & Keeping the Best: Creating Effective Talent Acquisition & Retention Processes
In addition to taking steps to attract and recruit qualified individuals with disabilities, businesses should review their policies and processes across the employment lifecycle to determine whether they facilitate or impede the hiring, retention and advancement of individuals with disabilities, including veterans with disabilities. Such policies and processes include:
- Qualification Standards
- Job Announcements
- Hiring Process, in General
- Special Initiatives for Youth with Disabilities
- Career Development and Advancement
For all employers, it is important to have a central and clear process for requesting accommodations that is readily accessible to applicants (on your recruiting website and materials) and existing employees. Strategies related to this process are explored in detail under Ensure Productivity: Reasonable Accommodation Policies and Procedures.
Examples of strategies employers can use related to qualification standards include:
- Reviewing the company’s eligibility criteria and any company-specific qualification standards for positions to identify and revise those that are unnecessarily restrictive and potentially exclude people with disabilities.
- Assisting hiring managers in the identification of the essential functions of positions to ensure applicants have the requisite knowledge, skills and abilities to successfully perform the functions, with or without reasonable accommodations.
- Reviewing human resource processes and their implementation on an annual basis and making necessary modifications or improvements, when appropriate.
Examples of strategies employers can use related to job announcements include:
- Indicating in job announcements that the company encourages applications from qualified individuals with disabilities. The announcement may include the universal access symbol for emphasis, as well as communicating the company’s intent to make reasonable accommodations for qualified job applicants and employees with disabilities. (It is important to note that for federal contactors covered by Section 503 of the Rehabilitation Act, prescribed language must be used in job announcements.)
- Drafting clear, understandable job announcements that explain in plain language the required qualifications and duties of the job and note the availability of reasonable accommodations and contact information for requesting them.
Hiring Process, In General
Examples of strategies employers can use related to the general hiring process include:
- Adopting a hiring policy that includes disability among the positive selection factors.
- Ensuring that the hiring manager documents reasons for the non-selection of any pre-qualified candidates with disclosed disabilities.
- Providing opportunities for practice interviews for job seekers with disabilities referred by community-based organizations who meet qualification standards, as a way of identifying potential candidates for current or future job vacancies.
- Implementing a mechanism for hiring managers to provide feedback on applicant interviews.
- Ensuring that job offers are not rescinded for inappropriate reasons.
- Using job fairs as hiring events.
- Ensuring representation of existing employees with disabilities in the onboarding process, for example, as part of orientation presentations and welcome committees.
- Designating sufficient staff to handle any disability-related issues that arise during the application and selection processes and providing such individuals with sufficient training, support and other resources to carry out their responsibilities. Such responsibilities include:
- Ensuring that disability-related questions from the public regarding the company’s application and selection processes are answered promptly and correctly, including questions about reasonable accommodations;
- Processing requests for reasonable accommodations by applicants during the application and placements processes; and
- Overseeing any other programs designed to increase hiring of individuals with disabilities.
Career Development and Advancement
Examples of strategies relating to career development and advancement include the following:
- Adopting a promotion policy that includes disability among the positive selection factors.
- Reviewing accommodation records to identify qualified employees with disabilities who may be qualified for promotions or desirable transfers.
- Providing training and career enhancement opportunities, including apprenticeship programs, on-the-job training, developmental assignments, job shadowing, mentoring and tuition reimbursement for employees. These strategies should include opportunities to facilitate upward mobility for employees at lower pay levels.
- Providing career enhancement/leadership development opportunities, including reviewing employee development programs to ensure that no barriers exist for employees with disabilities.
- Providing training to leadership, managers and line staff about new strategies such as workforce flexibility, including flexibility around job tasks (job restructuring, job sharing and job creation).
- Ensuring that advertisements for training/workshops offering career development include language advising of the provision of reasonable accommodations.
- Monitoring the composition of participants in training and mentoring programs and tracking and reporting participation rates.
Examples of strategies and practices relating to retention include:
- Adopting disability management and prevention programs (stay-at work and return-to-work programs).
- Conducting studies that identify and implement methods of collecting feedback on the needs and interests of employees with disabilities, including hosting regular focus groups and allowing for the submission of anonymous surveys.
- Working with the company’s disability employee resource group (ERG) to identify specific strategies for improving the retention numbers.
- Adopting retention plans and strategies based on information obtained from surveys and exit interviews.
- Developing and disseminating a procedures manual related to the retention of employees with disabilities.
- Developing and implementing a plan to review proposed terminations to ensure disability accommodations were considered, when appropriate.
- Conducting exit interviews, and in the case of employees with disclosed disabilities, asking if their decision to leave is in any way related to disability.
- Analyzing and monitoring terminations of employees and reporting to HR or other appropriate office on a quarterly basis.
- EARN Retention & Advancement Webpage
- EARN Stay at Work/Return to Work Webpage
- EARN Workplace Flexibility Webpage
- EARN’s Toolkit for Establishing and Maintaining Successful Employee Resource Groups
- EARN Fact Sheet: Fostering Disability-Inclusive Workplaces Through Employee Resource Groups
- EARN Publication: Professional Development and Advancement of Employees with Disabilities
- Inclusive Internship Programs: A How-To Guide for Employers
- U.S. Department of Labor ApprenticeshipWorks Video Series
Americans with Disabilities Act (ADA), as Amended by the ADA Amendments Act (ADAAA)
(Title 1 – Equal Employment Provisions)
- Regulations (Part 1630 of Title 29 of the Code of Federal Regulations)
- The ADA: Your Responsibilities as an Employer
- The ADA: A Primer for Small Business
- Technical Assistance Manual: Title I of the ADA
- Questions and Answers on the Final Rule Implementing the ADA Amendments Act of 2008
- Questions and Answers for Small Businesses: The Final Rule Implementing the ADA Amendments Act of 2008
- Fact Sheet on the EEOC’s Final Regulations Implementing the ADAAA
- Veterans and the ADA: A Guide for Employers
- Selected Enforcement Guidance and Other Policy Documents on the ADA
Business Membership Organizations
Ensure Productivity: Reasonable Accommodations
Some individuals with disabilities may need “reasonable accommodations” to perform the essential functions of a job. An accommodation is considered any modification or adjustment to a job or work environment that enables a qualified person with a disability to apply for or perform a job.
- EARN Training: Ensuring Productivity Reasonable Accommodations Slide Deck (PDF)
- EARN Webinar: Ensuring Productivity: Reasonable Accommodation
Examples include putting blocks of wood under desk legs to raise it for someone who uses a wheelchair or a sign language interpreter for meetings for a person who is deaf. Reasonable accommodations may include flexible work arrangements such as flextime or telework. According to the Job Accommodation Network (JAN), more than half of all workplace accommodations cost nothing. Furthermore, JAN’s statistics show that most employers report financial benefits in the form of reduced insurance and training costs and increased productivity.
Federal law and regulations define employers’ obligations to provide reasonable accommodations. Employers should consider the policies, procedures and administrative mechanisms they use to ensure effective and efficient implementation of reasonable accommodations. Examples include:
- Developing, implementing and communicating written reasonable accommodations policies.
- Post on Intranet and public website.
- Include policies not required by federal law and regulation such as:
- If an employee with a known disability is having difficulty performing his or her job and it is reasonable to conclude that the problem is related to the known disability, confidentially inquiring whether this is the case. Then, if the employee responds affirmatively, confidentially asking if he or she needs an accommodation.
- In addition to providing work task-related assistance as a reasonable accommodation, providing daily personal care-related assistance (such as help using the restroom, eating or removing and putting on outerwear) during work hours.
- Developing, implementing and communicating written procedures for processing requests for reasonable accommodations.
- Post procedures on Intranet and public website.
- Communicate procedures using an accessible format.
- For companies using online application systems, post a notice on the human resources webpage or online application portal that notifies job applicants who may need a reasonable accommodation to perform the functions of a job that they may be entitled to one under federal and/or state law.
- Establishing an administrative mechanism for minimizing the cost of an accommodation being assigned to a line manager’s budget, such as a centralized funding source (sometimes referred to as a “centralized accommodation fund”).
- Establishing an administrative mechanism or centralized source of expertise (appointing a specific individual and/or establishing an office) for assessing, evaluating and providing reasonable accommodations (including assistive technology) to ensure the effectiveness and efficiency of the reasonable accommodation process.
- Providing training for executives, managers and line staff about new strategies and devices, such as telework, flextime and assistive technologies.
- Ensuring that both managers and employees are aware that they may contact JAN to receive confidential, free advice and technical assistance on workplace accommodations.
- Creating an online system for tracking accommodations in order to document success.
- Allowing line managers to authorize reasonable accommodations, with team review of denials and a requirement that all denials be signed by upper level management.
- Assigning a full-time director of disability services or workplace supports to coordinate accommodations strategies.
- EARN Reasonable Accommodations Webpage
- Job Accommodation Network (JAN)
- Employers’ Practical Guide to Reasonable Accommodation Under the Americans with Disabilities Act (ADA)
- Workplace Accommodations Toolkit
- Sample Reasonable Accommodations and Equality Opportunity Policy Statement
- Sample Reasonable Accommodations Forms & Checklists
- Benefits and Costs of Accommodations: Low Cost, High Impact
- Small Employers and Reasonable Accommodation
Communicate: External & Internal Communication of Company Policies & Practices
- EARN Training: Communication of Company Policies & Practices Slide Deck (PDF)
- Webinar – Spread the Word: Communicating Your Organization’s Commitment to Disability Inclusion
To maximize a company’s ability to attract talent with disabilities, it is important to communicate to the public its commitment to employing individuals with disabilities and having an inclusive and diverse work environment, including subcontractors and vendors. Examples of successful external communication strategies and practices include:
- Including individuals with visible disabilities when employees are pictured in customer, promotional or recruitment advertising.
- Sponsoring and participating in job fairs that target job seekers with disabilities.
- Informing disability organizations about company-sponsored career days, youth motivation/mentoring programs and related community activities.
- Distributing information about relevant disability company policies and priorities to subcontractors, vendors and suppliers and requesting their support, and when feasible, requiring it via contract.
- Communicating with union officials and/or employee representatives about the company’s policies and seeking their cooperation, if the company is a party to a collective bargaining agreement.
- Posting the company’s policy statements regarding disability inclusion and reasonable accommodations; special recruitment and hiring initiatives; and targeted internship, mentoring and job shadowing programs on its public website.
Strong external communication strategies and outreach and recruitment initiatives will be more effective if they are accompanied by internal support from supervisory and management personnel and are understood by co-workers, some of whom may have had only limited contact with individuals with disabilities. Internal communication and other strategies targeting managers, supervisors and co-workers can foster awareness, acceptance and support among all levels of staff within the company. Examples of successful internal communication strategies and practices include:
- Establishing an office that delivers a holistic approach to disability program management by bringing together the operational components of reasonable accommodations, case work, policy, oversight and education.
- Establishing a disability employee resource group (ERG) aligned with the company’s diversity and inclusion program and inviting existing employees with disabilities as well as employees with family members or friends with disabilities. The purpose of this group should include helping to identify policies and procedures that support a positive work environment for people with disabilities and informing the company about outreach avenues and marketing to the disability market. As with all ERGs, it should have direct access to company leadership.
- Publicizing the company’s commitment in its internal publications (e.g., intranet, employee newsletters/magazines).
- Publishing a newsletter or newsletter articles with metrics about progress on achieving goals and related resources.
- Including images of employees with disabilities in employee handbooks and other internal publications that feature photographs of employees.
- Including disability-specific policies regarding internal communications and information dissemination in the employer’s policy manual and employee handbook.
- Conducting special meetings, orientations and training programs with executives, management, supervisory personnel, union officials and employee representatives to communicate the commitment of the company and its leadership to fostering a disability inclusive corporate culture and work environment.
- Enabling individuals with disabilities to be represented within the company’s decision-making bodies, including its Board of Directors.
- Establishing a policy that all managers and supervisors share responsibility for the successful implementation of the company’s inclusion policy and ensuring that they are held accountable through their performance evaluation plans.
- As part of the company’s Employee Assistance Program (EAP), adopting disability management and prevention programs, with the goal that workers who become injured or ill remain part of the workforce.
- Adopting a recognition and awards program acknowledging individuals responsible for achieving progress and positive outcomes related to disability employment.
- EARN’s Expressing a Commitment to Disability Inclusion Webpage
- EARN Fact Sheet: Fostering Disability-Inclusive Workplaces Through Employee Resource Groups
- EARN Toolkit: Establishing and Maintaining Successful Employee Resource Groups
- EARN Training Center for Disability Employment & Inclusion
- Job Accommodation Network (JAN) Multimedia Training Microsite
- Campaign for Disability Employment (CDE)
Be Tech Savvy: Accessible Information & Communication Technology
The development, procurement, lease, maintenance and use of information and communication technology (ICT) are central to the operation of businesses today. The Internet has dramatically changed the way that businesses conduct work and communicate with the public, including how individuals apply for jobs.
- EARN Training: Be Tech Savvy Accessible Information and Communication Technology Slide Deck (PDF)
- Webinar – Coming soon!
To fully participate in the workforce, applicants and employees with certain types of disabilities (such as those with limited vision and hearing) must have access to and use of information and data that is comparable to the access and use by applicants and employees without these types of disabilities. For example, if an online application system is not accessible, some applicants with disabilities can never “get through the front door.”
Furthermore, once an individual with a disability is on board, if he or she is not provided with accessible ICT, this omission may limit his or her ability to develop the skills needed to be productive and advance in employment. Accessible ICT is about virtual access, and today, it is as essential to facilitating disability inclusion as physical accessibility features, such as ramps and elevators.
Promising business practices regarding accessible ICT include the development of comprehensive strategic action plans that include the following:
Leadership and Team Approach
- Securing leadership at the highest levels of the company to facilitate “buy-in” and establish and sustain corporate commitment to accessible ICT.
- Establishing a network of individuals responsible for implementation (e.g., an accessibility team comprising managers across divisions, including human resources, information and communication technology, procurement, education and training, financial and marketing, and the Americans with Disabilities Act (ADA) and Americans with Disabilities Act Amendments Act (ADAAA) compliance).
- Making the business case for ensuring that technology used by the business is accessible to the largest possible number of applicants, employees and customers.
Needs Assessments, Feedback and Priorities
- Considering all the ICT used or offered and making a list of those platforms, devices and applications.
- Evaluating accessibility by testing ICT applications with automated accessibility testing tools and by considering the user experience of applicants, employees and customers.
- The accessibility evaluation includes an automated accessibility testing tool to evaluate conformance with Web Content Accessibility Guidelines (WCAG) 2.0 A and AA;
- Tests are conducted manually by users with different disabilities to identify any accessibility barriers not otherwise apparent through automated testing; and
- User testing includes individuals who are blind or have low vision, individuals who are deaf or hard of hearing, and individuals who have physical disabilities affecting manual dexterity.
- Providing for feedback from website and mobile applications’ visitors on how website accessibility can be improved. Examples of feedback methods include an email address and a toll-free phone number to contact representatives knowledgeable about the website/ICT accessibility policy.
- Establishing a process and adopting criteria that can be used for setting priorities.
Formal Policies, Practices and Procedures
- Adopting and implementing a website/ICT accessibility policy to include:
- ICT policies, technical accessibility standards, evaluation and testing, feedback, training and guidance, technical assistance and a responsible individual/office;
- Contact information for employee responsible for ensuring that the ICT purchased, maintained or used by the company is readily accessible to and usable by individuals with disabilities and instructions on how to file a complaint;
- Posting on its public website;
- Distribution to all employees in accessible formats; and
- Distribution to all contractors who design, develop, maintain or otherwise have responsibility for its websites.
- Adopting specific technical ICT accessibility standards and functional performance criteria (e.g., WCAG 2.0 A and AA) regarding software applications and operating systems, web-based intranet and internet applications, telecommunication products, video and multimedia products, self-contained closed products (e.g., copiers and printers) and computers.
- Adopting accessible online application systems that include website integration, job posting and distribution tools, application and resume submission, communication between applicants and employer, resume extraction and management, candidate search and selection processes and communication regarding a job offer or rejection.
- Providing outsourcing guidelines to suppliers and business partners, including copies of the ICT accessibility guidelines, and ensuring that contracts stipulate suppliers will, where relevant, apply ICT accessibility standards.
- Establishing clear procurement policies, including a solicitation policy that states ICT should be accessible, indicates which accessibility standards apply and provides for inspection and acceptance of deliverables based on those standards.
- Delineating the respective roles and responsibilities of key personnel, including the chief acquisition officer, chief information officer and chief accessibility officer.
- Conducting training for in-house staff, including program managers, contracting and procurement officers, software developers, web developers, and video and multimedia developers, including IT help desk staff to include:
- WCAG 2.0 A and AA accessibility requirements, for all employees and contractors who design, develop, procure, maintain, or have other responsibilities related to ICT;
- Identifying “best practices” describing steps and resources for implementing the website/ICT accessibility policy; and
- Reaching sufficient personnel to handle feedback provided by individuals with disabilities.
- Deploying accessible ICT throughout the company by, for example, establishing a mechanism for centralized expertise and/or funding.
Evaluation and Accountability
- Appointing a Chief Accessibility Officer who reports directly to a high-ranking official and is:
- Knowledgeable about the accessibility policy and legal requirements;
- Responsible for coordinating implementation of the website/ICT accessibility policy;
- The contact person for content providers regarding accessibility issues relating to its websites, mobile applications, platforms, and accessibility best practices guidance; and
- Responsible for ensuring that the accessibility best practices guidance includes guidance on the accessibility requirements.
- Appointing a cross-functional committee charged with monitoring and maintaining conformance of the websites and other ICT. Functions of the committee include assisting and reporting to the Chief Accessibility Officer.
- Retaining an independent Website Accessibility Consultant who is knowledgeable about accessible website development. This independent consultant’s duties include:
- Advising the covered entity on how to conform its website and mobile applications to WCAG 2.0 A and AA;
- Verifying that its website and its mobile applications conform to WCAG 2.0 A and AA through a written accessibility evaluation, including recommendations to improve the accessibility of the website and mobile applications; and
- Establishing the criteria for selecting testers with disabilities and reviewing the results of the tests.
- Notifying managers and employees about the company’s ICT accessibility policy.
- Involving individuals with disabilities and experts in the development, implementation and evaluation of policy.
- Establishing measurable objectives and benchmarks, including checklists, scorecards and grid-based tracking documents.
- Designing and implementing data collection and continuous improvement strategies, including tracking and reporting systems and regularly scheduled reporting.
Measure Success: Accountability & Self-identification
While the adoption of written policies, practices and procedures is necessary to enhance employment opportunities for qualified talent with disabilities, the ultimate objective is ensuring their effective implementation and, hopefully, success.
- EARN Training: Measure Success Accountability and Self Identification Slide Deck (PDF)
- Webinar: Coming soon!
Best business practices include putting systems in place to ensure accountability and continuous improvement relating to:
- Establishing Accountability Measures
- Self-Identification, if Appropriate
- Establishing Accountability and Continuous Improvement Mechanisms
- Designating Responsible Individuals
Oftentimes, “people don’t know what they don’t know.” It is critical that companies extend professional development opportunities to employees in all offices, divisions and departments. Specific examples of training strategies that have proven successful include:
- Providing initial and regular refresher training on disability-related issues to all personnel, particularly those involved in the recruitment, hiring, promotion and retention processes (e.g., understanding legal requirements, disability inclusion awareness, retention and return-to-work strategies, overcoming stereotypes and other attitudinal barriers, reasonable accommodation procedures and targeted hiring programs).
- Incorporating training on disability-related issues as a regular and ongoing component of the company’s diversity and inclusion initiatives and learning and development strategies.
Establishing Accountability Measures
Many business management experts believe that “what gets measured gets done.” Specific strategies and practices that your company can use to measure its progress toward creating an inclusive workplace include establishing annual quantitative goals, objectives and benchmarks related to:
- Outreach to and recruitment (including referrals) of talent with disabilities;
- Hiring, retention and advancement of people with disabilities; and
- Sponsored educational, training, recreational and social activities that are inclusive of and/or focused on disability issues.
Self-Identification, if Appropriate
For federal contractors subject to Section 503 of the Rehabilitation Act of 1973, below are examples of strategies related to self-identification:
- Ensuring an efficient and accessible process for self-identification, as required for federal contractors subject to Section 503 of the Rehabilitation Act. (It is important to note that employers are prohibited from inquiring about disability in most other circumstances.) This process includes:
- Inviting applicants to voluntarily self-identify as an individual with a disability at both the pre- and post-offer stage and inviting employees to voluntarily identify as a person with a disability every five years, using language prescribed by the Office of Federal Contract Compliance Programs (OFCCP);
- Ensuring that self-identification information is collected by (and kept confidential and maintained in a data analysis file within) the appropriate human resources office and not provided to interviewing, testing or hiring officials.
- Communicating the definition of “disability” with examples. (One of the reasons employees with disabilities do not self-identify is that they may not realize they meet the definition of disability.)
- Providing employees with the option to self-identify within a secure/confidential online system where they maintain changes, for example, to tax deductions and pay check allocations.
- Assigning the disability employee resource group (ERG) a key role in communicating the importance of self-identification. For example, an ERG representative might talk about the value of self-identification during onboarding presentations.
- Launching a company-wide communications plan encouraging employees to update their personal information. For example, rather than sending a one-time message, consider continuing to use events throughout the year, such as an employee engagement survey, to remind employees to check that their information is still current.
Establishing Accountability and Continuous Improvement Mechanisms
Accountability and continuous improvement mechanisms are necessary to ascertain whether current policies, practices and procedures are effective and whether the company is making progress in improving employment opportunities for persons with disabilities. Examples of accountability and continuous improvement strategies that have proven successful include the following:
- Auditing, reviewing and reporting annually all employment-related activities:
- Job posting, recruitment, advertising and job application procedures, including testing;
- Hiring, promotion, upgrading, awards of tenure and layoffs;
- Rates of pay and any other forms of compensation, including fringe benefits;
- Job assignments, job classifications, job descriptions and seniority lists;
- Sick leave, leaves of absence and other leave;
- Training, apprenticeships, attendance at professional meetings and conferences; and
- Any other terms, conditions and privileges of employment.
- Conducting annual self-assessments, including identifying trends and/or issues needing more attention:
- Tracking information related to the provision of reasonable accommodations that could be used to assess the effectiveness of accommodations and the process;
- Tracking data relating to the representation of individuals with disabilities in the workforce to ascertain trends, including the efficacy of recruitment, hiring, retention and promotion initiatives; and
- Establishing a complaint tracking and monitoring system to identify areas needing systemic improvements.
- Seeking input from employees with disabilities regarding implementation of policies and strategic plans using employee surveys, focus groups and discussions with employee resource and advisory groups.
- Based on these reviews and assessments, developing strategic plans that include proactive steps and the implementation of specific actions necessary to address any noted deficiencies.
- Providing regularly scheduled reports to company leaders and/or other high-ranking managers regarding implementation of the company’s strategic plans, including completion dates and managers who are accountable and responsible for various action items.
- Establishing a complaint resolution process that is efficient, fair and impartial, including a system for identifying, monitoring and reporting significant trends reflected by complaint processing activity.
- Having adequate and accurate information collection systems in place that are integrated into the company’s information management infrastructure.
Designating Responsible Individuals
Designation of authority and responsibility is of central importance to enhancing and securing implementation of disability employment policies and practices. Specific examples of strategies and practices that have proven successful include:
- Assigning and defining the scope of responsibility for implementation to specific individuals, for example, establishing a position to ensure coordination of disability policy and accommodations. This person would be involved in critical workplace and human resources decisions and have regular access to senior management.
- Identifying the responsible individual(s) in internal and external communications.
- Providing top management support (including budgets) and, if appropriate, staff to manage implementation. For example, this support includes employing personnel with the training and experience to conduct barrier and workforce analyses (including data collection and tracking systems). It also includes training of managers, supervisors and equal employment opportunity staff.
- Explaining to managers and supervisors how performance elements included in their performance plans related to the recruitment, hiring, advancement and retention of persons with disabilities will be assessed.
- Disability Employment TrackerTM: Sponsored by the National Organization on Disability (NOD) in partnership with the National Business and Disability Council (NBDC), this tool helps companies, including but not limited to federal contractors, assess their disability hiring efforts. It runs on an annual cycle.
- Disability Equality Index: This benchmarking tool, jointly sponsored by the American Association of People with Disabilities (AAPD) and Disability:IN, offers businesses the opportunity to receive an objective score on disability inclusion policies and practices.
Section 503 of the Rehabilitation Act (Section 503)
- EARN Encouraging Self-Identification Webpage
- EARN Fact Sheet: Do Ask, Do Tell: Encouraging Employees with Disabilities to Self-Identify
- Section 503 of the Rehabilitation Act of 1973, as amended (29 USC Sec. 793) (1993)
- Regulations (Part 60-741 of Title 41 of the Code of Federal Regulations)
- Highlights of New Section 503 Regulations Effective March 2014
- Fact Sheet on New Section 503 Regulations Effective March 2014
- Training Webinars on New Section 503 Regulations Effective March 2014
- FAQs on New Section 503 Regulations Effective March 2014
- Voluntary Self-Identification of Disability Form
- Checklist for Compliance with Section 503 of the Rehabilitation Act of 1973
Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA)
- VEVRAA (38 USC Sec. 4212)
- Regulations (Part 60-300 of Title 41 of the Code of Federal Regulations)
- Highlights of New VEVRAA Regulations Effective March 2014
- Fact Sheet on New VEVRAA Regulations Effective March 2014
- FAQs on New VEVRAA Regulations Effective March 2014
- Training Webinars on New VEVRAA Regulations Effective March 2014
- Hiring Benchmark Database