Rehabilitation Act of 1973

The Rehabilitation Act of 1973 is the predecessor to the ADA and remains the operative law for federal employees, federal contractors, and recipients of federal financial assistance. Where the ADA covers private employers with 15+ employees, the Rehabilitation Act covers the federal sector and entities that take federal money. Most large U.S. employers are covered by both because they hold federal contracts above the Section 503 threshold.

Key Sections of the Rehabilitation Act

Section 501: prohibits disability discrimination in federal employment and requires affirmative action by federal agencies. Section 503: requires affirmative action by federal contractors with contracts over $10,000 and prohibits disability discrimination. Section 504: prohibits disability discrimination in programs and activities receiving federal financial assistance. Section 508: requires federal agencies and contractors to make electronic and IT accessible.

Section 503 and Federal Contractor Obligations

Federal contractors with contracts over $10,000 must take affirmative action to employ qualified individuals with disabilities. Contractors with 50+ employees and contracts over $50,000 must develop written affirmative action programs. OFCCP enforces these requirements.

Rehabilitation Act vs. ADA

The ADA covers private employers (15+) and uses similar definitions of disability and reasonable accommodation. The Rehabilitation Act covers federal sector and contractors. Most analysis under one applies to the other; the procedural and remedy paths differ. See ADA for the private-employer side and discrimination framework.

Building Rehabilitation Act Compliance for Federal Contractors

Develop written AAP if required. Conduct annual disability self-identification surveys. Maintain reasonable accommodation procedures. Train hiring managers on disability-inclusive practices. Coordinate with onboarding for accommodation requests. OFCCP reference: dol.gov/agencies/ofccp.