September 08, 2026
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Category: Disability, Accommodations, and Leaves

Fourth Circuit Cautions Employers Against Parsing Religious Beliefs

A divided Fourth Circuit allowed an employee to proceed with a Title VII claim challenging her employer’s denial of her religious exemption from a COVID-19 vaccination requirement. The decision illustrates the risk an employer takes in denying an employee’s religious accommodation request because the employer considers the employee’s stated belief insufficiently religious. The employee tied her objection to her belief...
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September 02, 2026
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Category: Affirmative Action and DEI

CWC Roundtable Examines OFCCP’s New Regulatory Framework

The practical implications of OFCCP's new framework and the future of disability self-identification for federal contractors were the dominant topics at the members-only roundtable held by the Center for Workplace Compliance (CWC), our affiliated nonprofit membership association. The September 1 roundtable discussed three new OFCCP actions: rescission of Executive Order 11246 rules, significant changes to the Section 503 disability affirmative action...
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August 26, 2026
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Category: Affirmative Action and DEI

OFCCP Asks OMB To Eliminate Form CC-305

The Office of Federal Contract Compliance Programs has asked the Office of Management and Budget for emergency authorization to eliminate Voluntary Self-Identification of Disability Form (Form CC-305). Federal contractors currently use Form CC-305 to invite applicants and employees to voluntarily report their disability status. OFCCP’s request follows a recent rulemaking through which it modified its regulations implementing the nondiscrimination and affirmative action...
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August 26, 2026
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Category: Disability, Accommodations, and Leaves

Fourth Circuit Faults Employer’s Reliance On Unpaid Leave In ADA Accommodation Case

Employers considering reassigning an employee under the ADA may not rely on unpaid leave when suitable work is available, a federal appeals court ruled. The Fourth Circuit revived an ADA failure-to-accommodate claim against an employer that kept an employee on unpaid leave even though he had been cleared for less demanding work after he could no longer perform his physically demanding job....
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August 10, 2026
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Category: Disability, Accommodations, and Leaves

Eighth Circuit Shows Why ADA Accommodation Doubts Should Trigger Process, Not Assumptions

The Eighth Circuit upheld summary judgment for an employer that denied an employee’s request for closer parking and later terminated him for repeatedly violating its parking policy. The court concluded that the interactive process broke down because the employee never gave the employer the requested medical documentation explaining his limitations or need for an accommodation. In this case, internal emails...
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July 23, 2026
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Category: Affirmative Action and DEI

OMB Approves Section 503 Recordkeeping Requirements And Form CC-305

The White House Office of Management and Budget has approved the Voluntary Self-Identification of Disability Form (Form CC-305) through July 31, 2029, while OFCCP decides whether to retain disability self-identification requirements. Current DOL regulations require federal contractors to use Form CC-305 to invite applicants and employees to voluntarily report their disability status. OMB’s approval simply ensures that DOL’s recordkeeping requirements...
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May 14, 2026
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Category: Disability, Accommodations, and Leaves

OFCCP Updates Form CC-305 Expiration Date

DOL’s Office of Federal Contract Compliance Programs has updated its Voluntary Self-Identification of Disability (Form CC-305) to a May 31 expiration date. Form CC-305 had expired April 30, but employers were permitted to continue using it after that date. Contractors may, at their discretion, update their forms or continue using the expired forms carrying an April 30 expiration date until OMB formally approves an extension.   Contractors should continue to comply with OFCCP’s regulations to invite employees and applicants...
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April 10, 2026
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Category: Disability, Accommodations, and Leaves

Court Finds PWFA Triggered By Informal Notice; May Require Waiver Of Essential Functions

A federal district court has denied summary judgment on a Pregnant Workers Fairness Act failure-to-accommodate claim, finding that informal notice suffices to trigger the need for HR action. In King v. Legacy Hospice, the court held that informal written notice to HR can establish an employee’s “known limitation” even if the employee does not comply with the employer’s preferred accommodation process...
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April 09, 2026
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Category: Disability, Accommodations, and Leaves

Proposed FY27 Budget Would Move VEVRAA And Section 503 Enforcement To New DOL Civil Rights Office

The White House has proposed creating an Office of Civil Rights at the Labor Department to enforce Section 503, VEVRAA, and most whistleblower laws. The President’s proposed FY 2027 budget, which was submitted to Congress April 3, would transfer enforcement of Section 503 of the Rehabilitation Act and the Vietnam Era Veterans’ Readjustment Assistance Act to DOL’s new Office of...
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March 25, 2026
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Category: Disability, Accommodations, and Leaves

EEOC Reaches $15 Million, Three Year Deal Over COVID 19 Vaccine Accommodation Claims

The EEOC entered into a three-year, $15 million conciliation agreement with a global technology company to resolve class allegations that the company denied religious and disability accommodation requests under its COVID-19 vaccination policy and terminated employees who refused to get vaccinated. The agreement requires the company to update its EEO policies, provide annual staff training on religious and disability discrimination, and report...
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