Washington, D.C., August 11 – This past week, the nonpartisan disability advocacy nonprofit RespectAbility submitted comments to the US Department of Labor (DOL) regarding the possibility of adding new supplemental disability data questions to the Current Population Survey (CPS).
Administered by the Census Bureau for the Bureau of Labor Statistics (BLS), the basic monthly CPS is “the source of official government statistics on the unemployment rate and other labor market measures.” Although it has existed since the 1940s, it only began tracking disability status in June of 2008. The subsequent data has “revealed large disparities in labor market outcomes between people with and without disabilities,” but lacked the specific information that could be used to help understand and address these disparities. As a result, the Census Bureau and BLS have conducted three supplemental surveys to the CPS regarding disability employment issues (2012, 2019, and 2021), and plan to conduct a fourth in 2024.
On June 24, the Department of Labor published a notice stating that they were “seeking information from the public… to gather information to aid in revising this [fourth] CPS Disability Supplement and to inform its general disability employment research agenda.”
RespectAbility made suggestions for new questions to ask, as well as new answer options for existing questions, such as including “reliance on family members” as a category of transportation commuting modes, in order to collect a more nuanced dataset which takes into account the experiences common for those with disabilities.
“Opportunities for members of the public and the disability community to weigh in on governmental data collection efforts are so important,” said Ollie Cantos, RespectAbility’s Chairman. “With more people with disabilities entering the workforce and earning an income than ever before, now is a crucial time to increase data collection efforts. This in turn will help improve policy making and ultimately help more people with disabilities who want to work, can work, and are striving to live a better life.”
In addition to the data being collected on the COVID-19 pandemic’s implications for telework, RespectAbility also flagged Long COVID as an area that warrants further investigation and attention from the DOL. A common thread through the responses was intersectionality – a concept at the core of RespectAbility’s mission – highlighting the compounding barriers to employment faced by disabled women and people of color.
Visit the Federal Register website to review the full announcement and proposed disability data questions.
RespectAbility’s full testimony is presented online and below:
To: Office of Disability Employment Policy, U.S. Department of Labor
From: The Board of Directors, Senior Leaders and Staff Members, RespectAbility
Re: Public Comments on Request for Information on Current Population Survey Disability Supplement 2024
Date: August 5, 2022
Dear Assistant Secretary for Disability Employment Policy Williams,
Thank you very much for your leadership, your commitment, and your efforts advancing opportunities for Americans with disabilities. This RFI reflects a significant opportunity before both the federal government and advocates for better disability employment policy. Since the 1990s and improving significantly after 2008, the Census Bureau has collected key data points on disability issues via the American Community Survey. Likewise, the Current Population Survey (CPS) has long collected discrete data points on the disability status of many Americans.
That said, these data points have limits in terms of the precision and clarity that they provide. The Department of Labor’s new effort to improve the collection of data points on wages earned, hours worked, workplace barriers, employment services, and reasonable accommodations is laudable. To help advance our mutual goals, the RespectAbility team has developed and drafted the following feedback in response to the Request for Information on Current Population Survey Disability Supplement 2024 Agency Docket Number DOL-2022-0002.
A new data supplement is critically necessary given the huge growth in labor force participation rates seen among workers with disabilities in the past year. Indeed, labor force participation rates for working-age people with disabilities are now higher than they were before the COVID-19 pandemic. That means that there are thousands of new workers with disabilities earning an income and advancing their careers. This also means that there are more data points to collect, which in turn, will help the future development of disability employment policy in support of the economic aspirations of the approximately 22 million working-age people with disabilities living in America today.
1. Should the question about difficulty completing current work duties (location 1003-1004) be rephrased in any way? Should the response options be altered?
2. Should there be more extensive questions about past work experience than the single one (location 1005-1006) previously used?
Yes. While there is clear utility in the single question as written, there are two additional data points that could be captured via this question. First, can the question be framed to denote if someone is a first-time worker with a disability, i.e., had no work experience prior to their current job? Second, can the supplement question be updated to also ask about previous work experience contributing to family businesses or other more informal work arrangements?
3. Should the question on departure from a job (location 1007-1008) due to disability distinguish between voluntarily leaving a job and being terminated from a job in the response options?
Yes. RespectAbility supports denoting if someone voluntarily left their job, if they were subject to an involuntary resignation, or if they were terminated outright.
Barriers to Employment
4. Should the set of questions about barriers to employment (locations 1009- 1010 through—1025-1026), also be asked of those currently employed and/or those who are not identified as having a disability?
Yes, it should be asked of those currently employed. Likewise, RespectAbility believes that it will be a benefit to tracking those who are not identified as having a disability to track and understand intersectional concerns around race, gender, and age.
At the same time, there would be value in including a question about stigma as a barrier to employment. Past research suggests that stigmas around different types of disabilities, such as mental health conditions, remain an underestimated barrier to successful employment outcomes. Given the stated purpose of adding supplemental disability questions to the Current Population Survey, this is a perfect opportunity to capture new data points on stigma as a barrier.
5. Should the categorization of barriers (locations 1009-1010 through 1025-1026) be altered in any way, whether by adding to, removing, or rephrasing the existing categories?
“Need for special features at job” is unclear and implies accommodation to be a “special” addition. Specify the need for assistive technology or unfulfilled accommodations as barriers instead.
Given the past two years of the pandemic and the millions of Americans just beginning to experience long-COVID symptoms that can rise to the level of being a disability, there would be value in digging further here. For example, a supplemental question could be added about whether someone acquired their disability since 2020 or as a direct result of a COVID infection.
6. Should the question asking about ability to work in the absence of barriers (location 1027-1028) consist of a set of questions, with the response to each recorded separately for each type of barrier identified in the preceding set of questions?
1027-1028 needs to be expanded upon – consider questions about desire to work and self-perceived ability to work. Additionally, make sure to control for bias.
Employment Services and Vocational Rehabilitation
7. Should the categorization of employment services (locations 1029-1030 through 1055-1056) be altered in any way, whether by adding to, removing, or rephrasing the existing categories?
Yes. Given the wide range of changes to the nation’s workforce development precipitated by the Workforce Innovation and Opportunity Act (WIOA), there is great need for more detail on the impact of various employment services on outcomes for workers with disabilities. A question should be added that gives the respondent the chance to specify what employment services they felt were ultimately most helpful in finding employment.
8. Should the response options be altered for the corresponding set of questions (locations 1031-1032, 1035-1036, 1039-1040, 1043-1044, 1047-1048, 1051-1052, and 1055-1056) asking, of those who received assistance from a particular type of employment service, how helpful these services were?
As difficult as measuring the helpfulness of services can be, it is important to do so. Obviously, the ability to gain employment following received assistance is the clearest metric. However, there is value in capturing whether the recipient of services felt that those services were delivered in a respectful way, if they were “helpful,” or if they resulted in successful employment. Further research is clearly warranted in this case.
9. Should the categorization of job accommodations (locations 1059-1060 through 1075-1076) be altered in any way, whether by adding to, removing, or rephrasing the existing categories?
10. Should there be any questions asked about past requests for job accommodations, prior to the job in the current workplace?
Yes, especially regarding involuntary dismissal and whether reasonable accommodations were denied due to employer costs. Perhaps a further question should be added about the length of time between when an accommodation was requested and when it was finally implemented.
Commuting and Work Hours
11. Should the categorization of transportation commuting modes (locations 1079-1080 through 1099-1100) be altered in any way, whether by adding to, removing, or rephrasing the existing categories?
In terms of this question, it is also worth adding “reliance on family members” as a category of transportation commuting modes.
12. Should there be any questions about how telework/work-at-home options have changed since the onset of the COVID-19 pandemic?
Yes, ask about the flexibility of work-at-home options as a positive accommodation versus a hindrance to productivity.
13. Should the categorization of reasons for work-at-home (locations 1109-1110 through 1127-1128) be altered in any way, whether by adding to, removing, or rephrasing the existing categories?
Allow for multiple affirmative responses in this section. At the same time, there may be value in trying to test whether return to office plans are helping or hurting individuals’ employment aspirations and employment seeking behaviors.
16. Are there any gaps in existing information about disability employment that have not been addressed by the questions contained in the past disability supplements but that could be considered for this future CPS Disability Supplement?
Work often looks different for people with disabilities than for nondisabled people. Key indicators to track include informal and gig work/contracted work, as well as tracking GoFundMe contributions. To have a complete idea of disabled people’s economic affairs, all three aspects should be considered.
Regarding “Not in Labor Force All – civilians 15 years old and over who are not classified as employed or unemployed. These persons are further classified by major activity: retired, unable to work because of long-term physical or mental illness, and other. The “other” group includes, for the most part, students and persons keeping house. Persons who report doing unpaid work in a family farm or business for less than 15 hours are also classified as not in the labor force” (p4-5):
It may be worth tracking disabled people in unpaid work as well as keeping house. Disabled people, especially women with disabilities, are often unpaid contributing family workers and/or involved in care work within the household.
People with disabilities want to work, can work, and are striving to work more than ever before. As such, RespectAbility has consistently advocated that decision-makers in the workforce development system expand their collection of data on the employment efforts of workers with disabilities. As of Spring 2022, the labor force participation rate for working-age people with disabilities is now 2 full percentage points higher than it was before COVID-19. According to the Bureau of Labor Statistics, people with disabilities now have a 37.8 percent labor force participation rate, compared to 77.2 percent of those without disabilities. This means that many more Americans with disabilities are striving to work and it is critical that new data points be captured about their experiences. The supplemental questions discussed in Agency Docket Number DOL-2022-0002 RIN: 1230-ZA01 will help to do exactly that. We are eager to see what the Department of Labor does with this RFI and how it informs future work. Please let us know if there is anything that we can do to help this work move forward.
Thank you for everything that you do!
These comments were prepared thanks to the hard work and close attention of RespectAbility’s Apprentices, Staff, and Board Members. Special credit is due to current Apprentices Adina Karten, Gabrielle Zwi and Jessensia Leaphart who have been active contributors to our organization’s work on policy advocacy, civic engagement and advancing disability inclusion. They represent future leaders who will have a substantial impact on the opportunities and aspirations of millions of Americans with disabilities.
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