building a disability-inclusive workplace [webinar]

Building a Disability-Inclusive Workplace

April 15, 2015

1

Susanne Bruyère Director, Employment & Disability Institute (EDI) [email protected]

This webinar is sponsored in part by the Cornell University Employer Practices RRTC funded through a grant from the U.S. Department of Education, National Institute on Disability and Rehabilitation Research (Grant No. H133B100017). The contents of the webinar do not necessarily represent the policy of the Department of Education or any other federal agency, and you should not assume endorsement by the Federal Government (Edgar, 75.620 (b)). The views presented are not necessarily endorsed by Cornell University or the National Institute on Disability and Rehabilitation Research (NIDRR).

Participants Will Learn: •  What new regulations will require of employers •  What current data tells us about areas where individuals with

disabilities perceive the occurrence of workplace exclusion; •  Workplace policies that contribute to a disability- inclusive

environment; •  Types of environments in which employees with disabilities are

comfortable asking for accommodations and disclosing their disabilities.

•  The critical role supervisors play in creating a disability inclusive environment

•  How companies can self-assess their effectiveness in moving toward a truly disability-inclusive workplace

2© 2015 Cornell University, ILR School, Employment and Disability Institute

The big picture

Sec.on 503 Who must comply: Employers with federal contract or subcontract of >$10,000 Who has rights: Anyone with a disability as defined by ADAAA

VEVRAA Who must comply: Employers with federal contract or subcontract of >$100,000 Who has rights: Several categories of veterans, including “disabled veterans”

Both •  Took effect March

24, 2014 •  Enforced by OFCCP

of the US DOL

Where do People Perceive Discrimination Occurs?

4

Most Common Issues Cited on ADA Charges: 2005-2010

Condition Percent of Charges Discharge 58.4 Reasonable Accommoda7on 28.2 Terms and Condi7ons 19.8 Harassment 14.8 Discipline 8.6 Hiring 6.7

Note: a charge may cite one or more issues.

Von Schrader, S. (2011). Calculations from EEOC Charge Files. RRTC on Employer Practices Related to Employment Outcomes Among Individuals with Disabilities. Ithaca, NY: Cornell University, ILR School, Employment and Disability Institute.

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Most Common Specific Conditions Cited on ADA charges: 2005-2010 Condition Percent of Charges

Orthopedic/Structural Back Impairment 9.3 Non-‐paraly7c Orthopedic Impairment 6.9 Depression 6.0 Diabetes 4.6 Heart/Cardiovascular 3.6 Anxiety Disorder 3.5 Cancer 3.2 Hearing Impairment 3.1 Manic Depression (Bi-‐Polar) 3.1

Note: a charge may cite more than one basis. Non-specific conditions were not included in the table: Other Disability 26.7%; Retaliation 17.7%; Regarded as Disabled 12.8% Record of disability 4.8%; Other 3.6%

Von Schrader, S. (2011). Calculations from EEOC Charge Files. RRTC on Employer Practices Related to Employment Outcomes Among Individuals with Disabilities. Ithaca, NY: Cornell University, ILR School, Employment and Disability Institute.

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More ADA Charges Cited by Those With Non-obvious Disabilities

Von Schrader, S. (2011). Calculations from EEOC Charge Files. RRTC on Employer Practices Related to Employment Outcomes Among Individuals with Disabilities. Ithaca, NY: Cornell University, ILR School, Employment and Disability Institute. 7

© 2015 Cornell University, ILR School, Employment and Disability Institute

0

1

2

3

4

5

6

7

2005 2006 2007 2008 2009 2010

Per

cent

of C

harg

es Depression

Diabetes

Anxiety disorder

Bi-Polar/Manic Depression

PTSD

Benefits of Inclusive Climates

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Benefits of Inclusive Climates 1.  Across multiple samples, data show members of

historically marginalized groups (e.g., women, ethnic minorities, people with disabilities, aging workers) experience less discrimination and overall better work experiences in inclusive units

2.  The demographic-based differences in experiences of “fit,” perceived fairness, harassment, engagement perceived organizational support that are commonly seen disappear in inclusive units, thereby enabling better group functioning

–  Higher cohesion, better information exchange –  Less conflict and miscommunication –  More creative; higher financial performance 9

Nishii, L. & Bruyere, S. (2009). Protecting employees with disabilities from discrimination on the job: The role of unit managers.

Inclusive Climates – Three Dimensions

10

•  Do employment practices perpetuate stereotypes by favoring members of some demographic groups over others?

•  In order to “buy” message of inclusion, employees have to perceive HR practices to be fair

Fairness of employment practices

•  Does the culture value integration of differences or expect assimilation to dominant norms?

•  Can employees enact and engage their “whole” selves? •  Is there an expectation that everyone is both a teacher and learner?

Cultural integration of differences

•  Are perspectives of diverse workforce actively sought and incorporated into decision making and core operational processes?

•  Do employees and managers share a common commitment to working through differences as a source of insight and skill?

Inclusion in decision-making

Nishii, L. & Bruyere, S. (2009). Protecting employees with disabilities from discrimination on the job: The role of unit managers.


Perceptions of HR Practices •  Perceived fairness of work arrangements and HR

practices for employee –  Perceived fairness is significantly lower for employees with

disabilities, compared to employees without disabilities –  Biggest differences for perceived fairness of job responsibilities

and access to valuable mentors –  Among people with disabilities, perceptions of fairness of HR

practices were higher when their supervisor(s) had friends with disabilities

•  Procedural and interactional justice experienced during accommodation process

–  Significantly lower for employees with disabilities –  Perceptions of interactional justice are more important than

procedural justice (for predicting commitment and satisfaction)

11Disability Case Study Research Consortium, 2008. Conducting and Benchmarking Disability Inclusive Employment Policies, Practices, and Procedures. Funded by the Office of Disability Employment Policy of the U.S. Department of Labor, grant/contract #E-9-4-6-0107.


Perceptions of Climate for Inclusion Fairness of employment practices

When employees perceive the organization is effective at hiring people with disabilities, supporting disability networks, and including disability in diversity policy, they perceive employment practices to be fairer overall.

Openness of the work environment Managers’ perceptions of the openness of the work environment predict discrimination experienced by employees with disabilities.

Inclusion in decision-making The more inclusive the decision-making environment, the more psychologically empowered employees feel, the more they feel supported and valued by the organization, and the less conflict they experience in their group.

12

Disability Case Study Research Consortium, 2008.

Experiences Are Better In Inclusive Units

Individuals with disabilities who work in inclusive climates report significantly

–  Greater success at having their accommodation requests granted

–  Greater coworker support of their accommodations –  Better experiences of procedural and interactional

justice during accommodations –  Lower levels of disability harassment/discrimination –  Higher organizational commitment and satisfaction –  Lower turnover intentions

13Nishii, L. & Bruyere, S. (2009). Protecting employees with disabilities from discrimination on the job: The role of unit managers.

Experiences Are Better for Employees With Disabilities Who Enjoy High Quality

Relationships With Their Managers

•  Individuals with disabilities who are included in their manager’s “in-group” report: –  Higher fit between skills and demands of job –  Higher empowerment –  Fairer treatment during the accommodation process –  Higher organizational commitment, satisfaction, and

willingness to engage in citizenship behaviors –  Lower turnover intentions

14Nishii, L. & Bruyere, S. (2009). Protecting employees with disabilities from discrimination on the job: The role of unit managers.


Managers’ Role is Critical •  Managers are key to the experiences of persons with

disabilities in the workplace •  Managers’ perceptions of organizational motivation for

disability inclusion (true inclusion interests rather than legal compliance) positively impacts disability climate

•  In both private and federal sectors, disability disclosure most often occurs with the manager or co-workers, rather than with HR, and therefore education and training about how to deal with disability disclosure is imperative to fostering inclusive workplace culture

15

Nishii, L., & Bruyère , S. (2014). Inside the workplace: Case studies of factors influencing engagement of people with disabilities. Research Brief. Ithaca, NY: Cornell University Employment and Disability Institute, Employer Practices RRTC.


Impact of Managers’ Perceptions on Employees with Disabilities

When managers perceive that disability practices are adopted merely to comply with legal pressures or keep up with industry trends, team members with disabilities who report to them have less positive experiences: •  Less likely to perceive disability practices as effective •  More likely to report experiencing problems as a result

of requesting an accommodation •  Less likely to perceive the workplace as inclusive

Nishii, L., & Bruyere, S. (2013). Inside the workplace: Case Studies of Factors Influencing Engagement of People with Disabilities. A research brief to summarize a presentation for a state of the science conference entitled Innovative Research on Employment Practices: Improving Employment for People with Disabilities held October 22-23, 2013 in Crystal City, MD.


What are Employers Doing?

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Workplace Policies for Disability Inclusion •  Survey of U.S. human resource (HR) professionals •  Over 250,000 SHRM members; stratified sample

across industries and org. sizes •  Online/phone based survey focused on:

o  Recruitment and Hiring o  Accessibility and Accommodation o  Retention and Advancement o  Barriers, Metrics and Training

•  Data collected fall of 2011 •  Response rate: 23% (n=662)

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Erickson, W. von Schrader, S. Bruyère, S & VanLooy, S. (2013). The Employment Environment: Employer Perspectives, Policies, and Practices Regarding the Employment of Persons with Disabilities. Rehabilitation Counseling Bulletin. doi: 10.1177/0034355213509841


Barriers to Employment or Advancement

50%

35%

30%

23%

19%

16%

13%

9%

9%

9%

Lack of qualified applicants

Lack of related experience

Lack of requisite skills and training

Supervisor knowledge of accomm.

Cost of accommodations

Attitudes/stereotypes

Productivity and performance

Additional cost of supervision

Cost of training

Attendance of people with disabilities

19Erickson, W. von Schrader, S. Bruyère, S & VanLooy, S. (2013). The Employment Environment: Employer Perspectives, Policies, and Practices Regarding the Employment of Persons with Disabilities. Rehabilitation Counseling Bulletin. doi: 10.1177/0034355213509841


Recruitment and Hiring Policies and Practices

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47%

57%

58%

59%

61%

53%

43%

42%

41%

39%

Yes No

Includes people with disabili.es explicitly in its diversity and inclusion plan.

(n = 567 )

Requires sub-‐contractors/suppliers to adhere to disability nondiscrimina.on requirements.

(n = 525)

Has rela.onships with community organiza.ons that promote the employment of people with disabili.es.

(n = 568)

Ac.vely recruits people with disabili.es. (n = 574)

Trains HR staff and supervisors on effec.ve interviewing of people with disabili.es.

(n = 580)

Cornell/SHRM 2011 Employer Survey


Recruitment and Hiring Policies and Practices

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18%

20%

27%

27%

40%

82%

80%

73%

73%

60%

Yes No

Includes progress toward recruitment or hiring goals for people with disabili.es in the performance appraisals of senior

management. (n = 547)

Par.cipates in internships or similar programs that target people with disabili.es.

(n =525)

Has explicit organiza.onal goals related to the recruitment or hiring goals for people with disabili.es in the performance

appraisals of senior management. (n = 540)

Takes advantage of tax incen.ves for hiring people with disabili.es (e.g., Small Business Tax Credit, Architectural/ Transporta.on Tax

Deduc.on, or Work Opportuni.es Tax Credit). (n = 467)

Has senior management that demonstrates a strong commitment to disability recruitment and hiring.

(n =555)



Accessibility and Accommodation Policies and Practices

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65%

68%

73%

73%

75%

35%

32%

27%

27%

25%

Yes No

Has an established grievance procedure to address reasonable accommoda.on issues. (n = 582)

Requires training for supervisors on legal requirements of disability non-‐discrimina.on and accommoda.on. (n = 585)

Has a designated office or person to address accommoda.on ques.ons. (n = 613)

Allows an employee to exceed the maximum dura.on of medical leave as an accommoda.on. (n = 557)

Evaluates pre-‐employment occupa.onal screenings to ensure they are unbiased. (n = 547)



Accessibility and Accommodation Policies and Practices

23Cornell/SHRM 2011 Employer Survey

20%

30%

47%

63%

80%

70%

53%

37%

Yes No

Has a centralized accommoda.ons fund (i.e., company-‐wide fund to provide accommoda.ons for people with disabili.es).

(n = 505)

Has a formal (i.e., wrijen, documented) decision-‐making process for the case-‐by-‐case provision of accommoda.ons. (n

= 558)

Provides advance no.ce to job applicants that reasonable accommoda.ons are provided during the job applica.on

process. (n = 552)

Regularly reviews the accessibility of its on-‐line applica.on system to people with visual, hearing, finger, dexterity, and

cogni.ve impairments. (n = 481)


Retention and Advancement Policies and Practices


18%

42%

59%

81%

82%

58%

41%

19%

Yes No

Has a structured mentoring program to support employees with disabili.es. (n = 578)

Employees are invited to confiden.ally disclose whether they have a disability (e.g., staff surveys). (n = 580)

Has a return-‐to-‐work or disability management program for employees who are ill/injured or become disabled. (n = 595)

Encourages flexible work arrangements for all employees (e.g., flex.me, part-‐.me, telecommu.ng). (n = 599)

Retention and Advancement Policies and Practices


9%

13%

14%

17%

91%

87%

86%

83%

Yes No

Includes progress toward reten.on and advancement goals for employees with disabili.es in the performance

appraisals of senior management. (n = 542)

Has a disability-‐focused employee network (e.g., an employee resource group or affinity group). (n = 581)

Offers special career planning and development tools for employees with disabili.es. (n = 572)

Has explicit organiza.onal goals related to reten.on and advancement of employees with disabili.es. (n = 543)

Do HR policies and practices matter?

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Effects of selected practices on hiring PWDs

Organizations with: Increased likelihood of hiring: •  Internships for PWDs : 5.7 times •  Strong senior management commitment: 4.8 times •  Explicit PWD organizational goals : 4.1 times •  Actively recruiting PWD: 3.2 times •  Including PWD in diversity & inclusion plan: 3.2 times •  Relationships with community orgs: 2.7 times

27Erickson, W., von Schrader, S., Bruyère, S., VanLooy, S., & Matteson, D. (in press). Disability-inclusive employer practices and hiring of individuals with disabilities. Journal of Rehabilitation Research, Policy and Education.

Disability Disclosure and Inclusive Workplaces

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Disability Disclosure as an Index of an Inclusive Workplace

•  Organizations are increasingly concerned with accurately capturing the proportion of their employees who have a disability.

•  Their ability to do this is dependent in large part on the willingness of employees to disclose that they have a disability.

•  Little is known about the factors that influence disclosure.

•  Results of recent Cornell/AAPD study 29


“Very Important” Factors When Deciding to Disclose a Disability to an Employer

Emerging Employment Issues for People with Disabilities: Disability Disclosure, Leave as a Reasonable Accommodation, Use of Job Applicant Screeners by Sarah von Schrader, Valerie Malzer, William Erickson, Susanne Bruyère. http://digitalcommons.ilr.cornell.edu/edicollect/1288

Persons with a disability (N=598)

Need for accommodation 68.2 Supportive supervisor relationship 63.5 Disability friendly workplace 56.8 Active disability recruiting 50.5 Knowing of other successes 49.9 Disability in diversity statement 48.9 Belief in new opportunities 40.7


“Very Important” Factors When Deciding NOT to Disclose a Disability to an Employer

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Persons with a disability (N=598)

Risk of being fired/not hired 73.0 Employer may focus on disability 62.0 Risk of losing health care 61.5 Fear of limited opportunities 61.1 Supervisor may not be supportive 60.1 Risk being treated differently 57.8 Risk being viewed differently 53.8 No impact on job ability 44.0 Desire for privacy 27.9


Percent Who Disclosed in Current or Most Recent Job

33

74.1 80.1

88.1

0

20

40

60

80

100

Not Apparent Somewhat Apparent

Very Apparent



Percent Who Disclosed at Different Points in the Employment Process

34

39.3

24.9

35.8

50.6

34.1

15.3

0

10

20

30

40

50

60

During recruitment During interview After being hired

Not/somewhat apparent Very apparent



Percent Who Experienced Negative Consequences of Disclosure

35

10.6

26.9

6.9

19.8

0

5

10

15

20

25

30

Immediate consequences Longer-term consequences

Not/somewhat apparent Very apparent

von Schrader, S. Malzer, V., Erickson, W., & Bruyère , S. (2010). Emerging Employment Issues for People with Disabilities: Disability Disclosure, Leave as a Reasonable Accommodation, Use of Job Applicant Screeners.


Accommodation Requests Across our surveys, about 50% of people with disabilities had requested accommodation •  Less than 3% reported not requesting accommodation

because of fear of negative consequences. •  For private sector, “Knowledge of unsuccessful

requests by others” was ranked highest reason (this was lowest worry for public sector).

•  Federal employees most feared “limitations on future opportunities.”

•  “Being treated differently by supervisor” was the second most important fear for both groups.

36Sources: Nishii & Bruyère (2013, 2014), Rubineau (2013). Presentations on unpublished survey data

Under what conditions are employees more likely to disclose their disability?

When cues in their organizational environment indicate it is safe to do so:

1 Perceived fairness of HR practices

2 Pro-disability climate

3 Perceived management commitment to disability

4 Perceptions that disability advisory/employee resource group is effective

37 Nishii, L., & Bruyere, S. (2013). Inside the workplace: Case Studies of Factors Influencing Engagement of People with Disabilities. A research brief to summarize a presentation for a state of the science conference entitled Innovative Research on Employment Practices: Improving Employment for People with Disabilities held October 22-23, 2013 in Crystal City, MD.

•  Company offers flexible work opportunities •  Disability awareness/anti-stigma training offered

to all employees •  “HR personnel who are familiar with disabilities,

accommodations and understand it is a goal for companies.”

•  “Knowing the employer has a fair system in place to resolve complaints.”

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Choosing to Disclose: Other Important Factors



Choosing to Disclose:

Other Important Factors (cont.)

•  Accessible workplace building and facilities •  Organization supports diversity more generally •  “Data presented on hiring and promotion of

people with disabilities” •  “Participation and support by employers in

community awareness events/activities”

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Creating an Environment that Encourages Disclosure

Demonstrate disability inclusiveness through:

–  Actively recruiting people with disabilities –  Conducting disability awareness training for staff –  Enacting flexible workplace policies –  Having fair systems to address complaints –  Creating accessible workplaces –  Fostering supportive supervisor-staff relationships –  Including disability in the diversity statement

40von Schrader, S. Malzer, V., Erickson, W., & Bruyère , S. (2010). Emerging Employment Issues for People with Disabilities: Disability Disclosure, Leave as a Reasonable Accommodation, Use of Job Applicant Screeners. http://digitalcommons.ilr.cornell.edu/edicollect/1288

Creating an Environment that Encourages Disclosure

Avoid: – Focusing on disability – Treating employees with disabilities differently

in relation to: •  Interpersonal interactions • Opportunities for advancement • Performance reviews • Hiring/termination

41von Schrader, S. Malzer, V., Erickson, W., & Bruyère , S. (2010). Emerging Employment Issues for People with Disabilities: Disability Disclosure, Leave as a Reasonable Accommodation, Use of Job Applicant Screeners. http://digitalcommons.ilr.cornell.edu/edicollect/1288

Promising Practices to Promote Inclusion

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Positive Workplace Culture Factors Disability-friendly cultures have: •  Top management support for the employment of people

with disabilities •  An emphasis upon a business case for employing people

with disabilities •  Disability initiatives aligned with corporate strategy •  Disability philosophy that focuses on abilities rather than

upon disability •  Systematic accommodation policies and procedures •  Systems to address supervisors’ and coworkers’

negative attitudes and concerns

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Colella & Bruyere, 2010, p. 494, 496, citing Legnick-Hall, 2007.

Positive Workplace Culture Factors (con’t)

•  Partnerships with community resources and schools to recruit people with disabilities.

•  Affinity groups, task forces, and information clearinghouses related to disability.

•  Employee diversity training and orientations that address disability issues.

•  Systems to monitor the progress of individuals with disabilities within the organization.

•  Means of publicizing the achievements of people with disabilities.

•  Procedures for examining personnel policies that could stimulate the hiring of more people with disabilities.

44

Colella & Bruyere, 2010, p. 494, 496, citing Legnick-Hall, 2007.

Ways to Benchmark Progress

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Metrics

What are organizations measuring?


% Organizations tracking disability metrics

47

32

29

23

18

17

14

11

0 5 10 15 20 25 30 35

Data on accommoda7ons (e.g., types and/or costs)

Number of job applicants hired

Number of job applicants

Employee reten7on and advancement

Grievances from employees with disabili7es

Compensa7on equity

Turnover rate for employees with disabili7es

Erickson, W. von Schrader, S. Bruyère, S & Sara VanLooy, S. (2013) The Employment Environment: Employer Perspectives, Policies, and Practices Regarding the Employment of Persons with Disabilities. Rehabilitation Counseling Bulletin http://rcb.sagepub.com/content/early/2013/11/14/0034355213509841.full.pdf

Metrics Tracked by Organizations

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65

60

46

41

29

23

18

14



Employee reten.on and

Compensa.on equity

By Disability

Erickson, W. von Schrader, S. Bruyère, S & Sara VanLooy, S. (2013) The Employment Environment: Employer Perspectives, Policies, and Practices Regarding the Employment of Persons with Disabilities. Rehabilitation Counseling Bulletin http://rcb.sagepub.com/content/early/2013/11/14/0034355213509841.full.pdf

Coming Soon An Online Tool - BenchmarkABILITY

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Related Publications Erickson, W. von Schrader, S. Bruyère, S & VanLooy, S. (2013). The Employment Environment: Employer Perspectives, Policies, and Practices Regarding the Employment of Persons with Disabilities. Rehabilitation Counseling Bulletin. Published online before print November 14, 2013, doi: 10.1177/0034355213509841

Erickson, W. von Schrader, S. Bruyère, S & VanLooy, S. Disability-Inclusive Employer Practices and Hiring of Individuals with Disabilities. Rehabilitation Research, Policy, and Education (manuscript in preparation) . Ithaca, NY, ILR School, Employment and Disability Institute, Employer Practices RRTC.

Golden, T. P., Bruyere, S., Karpur, A., Nazarov, Z., VanLooy, S., & Reiter, B. (2012). Workforce development policy: Unrealized potential for Americans with disabilities. Rehabilitation Research, Policy, and Education Journal. Hallock, K., Jin, X., & Barrington, L. (2013). The Pay Gap and the Total Compensation Gap by Disability Status. Working Paper. Ithaca, NY, ILR School, Institute for Compensation Studies. Hallock, K., Jin, X., & Barrington, L. (2013). The Role of Tasks and Skills in Explaining the Disability Pay Gap . Working Paper. Ithaca, NY, ILR School, Institute for Compensation Studies. Karpur, A. (2013). Impact of employer-provided health insurance on job mobility among people with disabilities. Working Paper. Ithaca, NY, ILR School, Employment and Disability Institute, Employer Practices RRTC. Karpur, A. (In preparation). Job-mobility among workers with disabilities: Role of employer paid health insurance. Health Services Research. Karpur, A., & Bruyere, S. M. (2012). Healthcare expenditure among people with disabilities: Potential role of workplace health promotion and implications for rehabilitation counseling. Rehabilitation Counseling Bulletin, 56 (1), 7 – 22. Nishii, L., & Bruyère , S. (2014). Inside the workplace: Case studies of factors influencing engagement of people with disabilities. Research Brief. Ithaca, NY: Cornell University Employment and Disability Institute. The Conference Board (2013). Leveling the Playing Field: Attracting, Engaging, and Advancing People with Disabilities. Available online at -- h[p://digitalcommons.ilr.cornell.edu/edicollect/1292/ von Schrader, S., Malzer, V., Bruyère , S. (2013). Perspectives on disability disclosure: The importance of employer practices and workplace climate. Employer Responsibilities and Rights Journal. DOI: 10.1007/s10672-013-9227-9. von Schrader, S., Malzer, V.,. Erickson, W. & Bruyere, (2013). Absence and Disability Management Practices for an Aging Workforce. Available at: http://digitalcommons.ilr.cornell.edu/edicollect/1320/ von Schrader, S., & Nazarov, Z. (in press). Employer Characteristics Associated With Discrimination Charges Under the Americans With Disabilities Act. Journal of Disability Policy Studies.

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Cornell Related Online Resources •  Employer Practices RRTC Project

http://employerpracticesrrtc.org/ •  U.S. EEOC Disability Charge tabulations online tool

http://www.disabilitystatistics.org/eeoc/ •  Employer Practices Disability and Compensation Catalog

http://www.disabilitystatistics.org/eprrtc/codebook.cfm •  Employer Assistance Resource Network

http://www.askEARN.org •  Cornell Online Repository of Related Publications

http://digitalcommons.ilr.cornell.edu/edicollect/ •  Tips for Human Resource (HR) Professionals

http://www.hrtips.org/

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building a disability-inclusive workplace [webinar]

Recruiting & HR

disabilityinclusive

record of disability

employment outcomes

national institute

ada charges

eeoc charge files

obvious disabilities

ilr school