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.

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Best business practices include putting systems in place to ensure accountability and continuous improvement relating to:

• Training
• Establishing Accountability Measures
• Self-Identification, if Appropriate
• Establishing Accountability and Continuous Improvement Mechanisms
• Designating Responsible Individuals

Training

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:

1. 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).
2. 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:

1. Outreach to and recruitment (including referrals) of talent with disabilities.
2. Hiring, retention and advancement of people with disabilities,
3. 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:

1. 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.
2. 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.)
3. Providing employees with the option to self-identify within a secure/confidential online system where they maintain changes, for example, to tax deductions and paycheck allocations.
4. 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.
5. 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:

1. 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.
   • Any other terms, conditions and privileges of employment.
2. 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 people with disabilities in the workforce to ascertain trends, including the efficacy of recruitment, hiring, retention and promotion initiatives.
   • Establishing a complaint tracking and monitoring system to identify areas needing systemic improvements.
3. 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.
4. 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.
5. 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.
6. 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.
7. 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:

1. Assigning and defining the scope of responsibility for implementation to specific staff members, 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.
2. Identifying the responsible individual(s) in internal and external communications.
3. 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.
4. 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.