There is a very good reason why the OFCCP regulations require federal contractors and subcontractors to re-survey employees for disability status every five years. Disability is a status that CAN change. One unfortunate accident or a positive diagnostic test result can change this overnight. Over time, we may inevitably develop a disability as we age. An employee that was hired two years ago may report a change in disability status for a variety of reasons. Collecting up-to-date information is necessary for federal contractors to see how they are tracking to their 7% utilization goal. The consequence of not doing the re-survey is most likely going to be a Conciliation Agreement where the federal contractor will be subject to monitoring by OFCCP for a period that could last for as much as two years and be required to submit reports over that time period showing that the re-survey is being completed. Another, and which poses a more significant potential liability, is that it may be used as anecdotal evidence in a discrimination or failure-to-accommodate employment claim.
You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.