AAAA Files Comments on Labor Department Disability Rules

AAAA Files Comments with the US Department of Labor

On September 21, 2010 the American Association for Affirmative Action (AAAA) filed comments in response to the Advance Notice of Proposed Rulemaking (ANPRM) published by the U.S. Department of Labor's Office of Federal Contract Compliance Programs. The OFCCP is seeking input into its plans to enhance the nondiscrimination and affirmative action protections of Section 503 of the Rehabilitation Act of 1973. In its ANPRM, the OFCCP asked members of the public to respond to a series of questions ranging from current practices to promote outreach and recruitment of individuals with disabilities to a proposal to require affirmative action goals based on the Executive Order 11246 regulatory model.

In the comments, AAAA expressed its appreciation to the Department of Labor for the opportunity to comment on the ANPRM and noted that since 1974, the mission of the association has been two-fold: to provide professional development opportunities for its membership and to advocate for equal opportunity through affirmative action. Many of the AAAA membership consists of colleges and universities and many are federal contractors. Thus, the association was justified in submitting comments.

In essence, the AAAA commended the Department for "pushing the envelope" on disability employment opportunities, but recommended that much more data gathering was necessary before requiring affirmative action goals for persons with disabilities. This is particularly true in the area of higher education, which would require information regarding the terminal degrees of persons with disabilities who seek faculty positions. Currently, those data are scarce. The association recommended that the Department also enhance the enforcement of current regulations regarding recruitment and outreach. If OFCCP revives the Equal Opportunity Survey, it may also wish to consider adding questions related to disability issues.

For a copy of the Association's comments please click here: http://library.constantcontact.com/doc204/1101929144254/doc/Vhm3Isqfzhbfmrim.pdf