Although the Society for Human Resource Management agrees with the goal of hiring individuals with disabilities, it submitted comments stating that the proposal by the Department of Labor to revise federal contractors' affirmative action plans a burden that will increase costs without ensuring further opportunities for people with disabilities.

This stance, which was submitted to the Office of Federal Contract Compliance Programs, also includes SHRM's support of the proposed goals, including bettering outreach to individuals with disabilities.

"Measuring progress through onerous paperwork requirements and inherently unreliable data does not advance the OFCCP's stated goals and, indeed, only detracts from federal contractors' current efforts to provide meaningful employment opportunities and supportive environments for individuals with disabilities and other protected groups," according to the SHRM statement.

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Based on section 503 of the Rehabilitation Act of 1973, the DOL proposal amends affirmative action regulations, and these apply to all federal contractors and subcontractors employing at least 50 employees and one or more federal contracts valued at $50,000 or more. SHRM, which represents nearly 260,000 members, including HR professionals employed by federal contractors, says the new regulations are "a departure from the agency's traditional view that affirmative action plans should be a useful management tool. Replacing that flexibility with a checklist of very specific 'gotcha' items is not likely to encourage employment of individuals with disabilities and instead only will serve to undermine the underlying premise of Section 503 — which is that the capabilities of any individual with a disability be examined on a case-by-case basis and not be based on stereotypes or common misperceptions about a condition or impairment."

SHRM's comments were submitted along with the College and University Professional Association for Human Resources. These comments include recommendations allowing the OFCCP to hit its goals without burdening federal contractors. SHRM also offered to partner with the DOL to accomplish its goals.

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