Comments To The OFCCP - Sep.2010

Comments To The OFCCP - Sep.2010

Office of Federal Contract Compliance Programs

I appreciate the opportunity to provide input to how the OFCCP might further support employment for people with disabilities.

As background, in June 2008, I am a person with a significant disability caused by Cerebral Palsy. I retired from Wells Fargo as a Sr. Vice President to, start a business called Abilicorp. Abilicorp is a disability-focused employment company that does staffing and placement. It also provides on-going support services such as mentoring, benefits counseling and adaptive technology assessment and sales. Abilicorp is one of the first Disabled Owned Business Enterprise to be certified by the US Business Leadership Network (USBLN). Abilicorp is now collaborating with Computer Technologies Program (CTP). CTP is a program I co-founded in 1975 that trains people with disabilities in IT related fields.

First, OFCCP should adopt the same requirements for persons with disabilities and Disabled Owned Business Enterprises that are used for women and minorities. This includes the obligation to conduct quantitative analyses and establish measurable goals and benchmarks for hiring, retaining, and advancing in employment persons with disabilities. It also includes the obligation to give priority to Disabled Owned Business Enterprises when contracts are awarded. As you know, the updated American Community Survey (ACS) provides current, discrete, valid, and reliable statistical data regarding persons with disabilities that is comparable to the data used for establishing goals for women and minorities. Parity with other protected classes in terms of the obligation to develop measurable goals and benchmarks is critical. I learned at Wells Fargo that if you don’t count, you don’t count.

Second, Strengthen Section 503 regulations to require mobile devices as well as Intranet and Internet sites used by federal contractors to be fully accessible to and usable by persons with disabilities, including accessible online application systems. In today’s world, accessible technology is a crucial factor impacting employment opportunities for people with disabilities. It is interesting that one of my last projects at Wells Fargo was to manage the group that developed and implemented mobile banking. Although Wells Fargo now has over 2 million customers using mobile banking, I cannot use it because there are no accessible mobile devices.  It is now time for action—meaningful and effective affirmative action for people with disabilities should be a right, and that right must be enforced.