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Debra Milstein Gardner has addressed this issue below in her response to a question labelled "Self Identification Responses." I would encourage you to read her comments there. In many ways, it's neither OFCCP nor consultants in this field who have discouraged companies from doing as you have suggested. It is employment attorneys who have strongly discouraged organizations from showing employees who have declined to self-identify as individuals with disabilities. Employment attorneys have been concerned that treating someone as an individual with a disability who has not specifically self-identified as such may create some form of liability for an organization should there be a discrimination complaint filed by such an individual. OFCCP might prefer that you count an applicant who self-identified as an individual with a disability as an individual with a disability when that person is hired (though it is not perfectly clear what the agency's position is in this regard), and you might prefer to do so to improve your data metrics. However, your attorney might raise concerns. And frankly, that's your attorney's job: to help to protect you from liability. That means my advice on your question is basically this: what you want to do seems entirely sensible and logical, but you would be well served to discuss this issue with your attorney before moving forward.
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