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Notice of Funding Opportunity - AbilityOne and 14(c) Subminimum Wage

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National Council on Disability

An in-depth look at the AbilityOne Commission and 14(c) subminimum wage

Overview Information

Notice of Funding Opportunity
April 24, 2019– Announcement of Funding Opportunity for a Cooperative Agreement

Authority:  Section 401, Title IV of the Rehabilitation Act of 1973, as amended.

Application materials are available at: and

You may also request application materials by writing to:                                

Amy Nicholas
Attorney Advisor
National Council on Disability
1331 F Street, NW Suite 850
Washington, DC  20004 or by e-mail request:

Full Proposal Deadline(s) (due by 5:00 p.m. local time): June 5, 2019

Late applications will not be considered.

Deliver all materials to:

National Council on Disability
1331 F Street, NW, Suite 850
Washington, DC   20004
ATTN: Amy Nicholas

Maximum amount available for this project: Up to $100,000

All potential applicants are eligible to apply

Cost sharing is not required

The estimated period of performance is 8 months

Project Summary

This report will take an in-depth look at the AbilityOne program and NCD’s concerns pertaining to 14(c) certificates. NCD released a white paper in February 2019 which was a cursory look at the AbilityOne program ( This report will pick up where the white paper ended and will include an in-depth review of how AbilityOne functions and interacts with its Central Nonprofit Agencies (CNAs) and Non-Profit Agencies (NPAs). NCD expects any proposal submitted in response to this solicitation to include how it will obtain data needed to determine the prevalence of 14(c) certificate holders among AbilityOne providers; how it will set up a partnership with the Department of Labor Office of Disability Employment and Policy (ODEP) to gather and provide concrete data showing the impact of varying scenarios pertaining to persons with disabilities and employers; and what methods will be used to examine each CNA individually. NCD also expects the final report developed by the contractor to examine what has been done to improve transparency since the 898 Advisory Panel Subcommittee to Eliminate Waste Fraud and Abuse called for improved transparency of the AbilityOne Program in July 2018.The contractor will develop recommendations and promising practices for federal agencies, state and local municipalities with the goal of improving employment outcomes for people with disabilities. 

Agency Contact:

Amy Nicholas, Attorney Advisor, National Council on Disability, 1331 F Street, NW, Suite 850, Washington, DC  20004, telephone (202) 272-2008, e-mail:

Award Information

Anticipated Type of Award:  Cooperative Agreement

Estimated Number of Awards: 1

Anticipated Funding Amount: Up to $100,000

This funding opportunity is contingent on fiscal year 2019 and 2020 federal funding availability

Proposal Preparation and Submission Instructions

Proposals must be submitted by the following date (due by 5 p.m. submitter's local time): June 5, 2019.

Proposal Review Information

Review Criteria:  National Council on Disability approved criteria.  Please see the full text of this solicitation for further information.

Award Administration Information

Award Conditions:  Please see the full text of this solicitation for further information. 

Reporting Requirements:  Additional reporting requirements apply.  Please see the full text of this solicitation for further information.

Background Narrative: 

NCD’s role is to advise Congress, the President, and other policymakers on disability policy and practices that enhance equal opportunity for people with disabilities to achieve economic self-sufficiency, independent living, and inclusion and integration into all aspects of society. NCD fulfills this role in part by releasing reports which evaluate the efficacy and legality of federal programs in relation to disability rights laws. In 2012, NCD released: National Council on Disability Report on Subminimum Wage and Supported Employment ( in which we recommend phasing out the practice of paying a person with a disability subminimum wages. We followed up with a 2018 report titled: National Disability Employment Policy, from the New Deal to the Real Deal: Joining the Industries of the Future ( That report focused on providers and agencies who have transitioned away from a sheltered workshop model to Competitive Integrated Employment (CIE) and provides promising practices for agencies ready to transition their employees to CIE. Our most recent release in February 2019 was a cursory look at the AbilityOne program ( and offered early recommendations to modernize an employment model that has not been changed since the 1970s.

Substantive Topics

This report will look at the multiple layers of the AbilityOne Commission including the Commission’s role and involvement with CNAs and NPAs and the prevalence of 14© certificate holders among AbilityOne providers. This report is intended to provide concrete data illustrating the impact of the varying employment scenarios that pertain to persons with disabilities and employers. The contractor is to include its methodology in collecting the quantifying data in its proposal submission. The contractor will be required to collaborate with the Department of Labor Office of Disability Employment Policy during the data collection process.

Key Questions to Be Answered

Any proposal submitted in response to this solicitation will explain how it will obtain data required to answer the following questions:            

The following questions should be addressed to AbilityOne’s Central Nonprofit Agencies (CNAs); SourceAmerica, National Industries for the Blind (NIB), and American Foundation for the Blind (AFB). All data collection for NIB and SourceAmerica should be bifurcated to easily compare and highlight operational differences.

How many employees have transitioned to CIE and what type of jobs have they attained?

Explain the relationship of program fees paid to CNAs by NPAs in detail and provide supporting data.

CNAs are required to facilitate distribution of orders from AbilityOne to NPAs with an emphasis on employment growth. How is this facilitated? And what are the penalties if orders are not distributed or followed?

How many employees are paid subminimum wage?

The following questions should address the business structure between the entities involved in the AbilityOne program:

Discuss the hierarchy and structure of AbilityOne with its CNAs in detail and the relationship of the CNA with AbilityOne.

Discuss the hierarchy and structure of CNAs with NPAs. NCD is specifically looking for detailed descriptions of the relationship between the two entities from CNA to NPA as well as NPA to CNA.

Discuss what type of interaction AbilityOne has with NPAs? How does AbilityOne communicate/interact with its NPAs? Is AbilityOne restricted from communicating directly with NPAs? If so, please describe the restriction.

CNAs are required to provide annual employment growth plans. The growth plan should address a number of elements based on market research and analysis which includes placement of employees in indirect labor, supervision, management or competitive employment. To whom do they submit the reports?

The contractor should obtain data from these reports to discern actual employment growth progress. Data recorded for the report should reflect at the very minimum the percentage of employees placed in supervisory or management roles and competitive integrated employment.

The following questions should be addressed to the AbilityOne Commission:

In the cooperative agreement between AbilityOne and its CNAs, is there language that restricts CNAs from freely discussing operating procedures with interested parties? If so, what are those restrictions?

What is the standard language in cooperative agreements between the CNAs and NPAs regarding its role and responsibilities with each other? Oversight? Communication?

How does the AbilityOne requirement of 75% direct labor hours correlate with the Americans With Disabilities Act (ADA), Olmstead and current disability civil right laws?

What impact does the AbilityOne direct work hour requirement have on individual states which mirror the JWOD requirements in awarding state contracts?

How does the AbilityOne program distribute, encourage, educate and engage employees with disabilities to the availability of competitive integrated employment? What types of labor are 14(c) certificates used for? Are benefits counselors available for employees wishing to transition?

What measures has the AbilityOne Commission taken to address the vulnerabilities discussed by the 898 Advisory Panel?

*Specifically, conflicts of interest pertaining to eligibility, since the determination of eligibility to participate as an employee of AbilityOne is made by NPAs – as such, an NPA functions as both the employer and the provider of employment support services.

*Amending the Javits Wagner O’Day act (JWOD) to better align with current disability laws like the ADA, Olmstead and Workforce Innovation and Opportunity Act (WIOA).

*A moratorium on Fair Labor Standards Act (FLSA) 14© certificates issued to NPAs.

What specific recommendations have been put forth by the 898 Advisory Panel and has AbilityOne implemented any of the recommendations?

What is the reason for the monetary disparity between employee wages and profit? Only 18.6% of $3.3 billion in federal purchases go to wages paid to employees who are ‘blind or severely disabled’.

What actions has the AbilityOne Commission taken since the 2013 GAO report to increase transparency when dealing with the CNAs?

Describe the responsibilities of AbilityOne’s Office of Inspector General (OIG)?

How is the commercialization of the sale of AbilityOne products on Amazon affecting private business? Does the use of AbilityOne contracts give NPAs an undue commercial advantage?

Examine and explain why there is such a high percentage of AbilityOne providers who are also 14© certificate holders?

The following questions should be addressed to NPAs

Please list the top 50 NPAs and state which CNA manages them. How many of them use 14(c) certificates?

What are the requirements of an NPA?

What oversight and governance exists to ensure an NPAs conformance to AbilityOne requirements?

What criteria is needed to become and remain an NPA? How does one lose NPA status?


NCD expects the contractor to interview/communicate with specific members of the disability community that may have opposing views and present all of the disability community’s concerns within this report. NCD is interested in making sure all viewpoints are presented, while still reflecting NCD’s long standing view on subminimum wage.

Any proposal submitted in response to this solicitation will explain how it will obtain data required by this solicitation.     

NCD expects any responding proposal to address how, and with whom, it will partner with an independent nonbiased third-party to conduct and collect data on the economics of 14© sheltered workshops versus Competitive Integrated Employment (CIE).  Data from this section will be the first deliverable in this agreement and will need to be submitted to NCD no later than September 15, 2019. NCD also expects the proposal to show how it will work with the Department of Labor Office of Disability Education and Policy (ODEP) to attain and examine the following data:

Quarterly reports on CNA program fees. Salaries and benefits, travel, lobbying and related expense

A cost analysis of 14© workshops income sources. Where does the workshop receive their funds? Include both private and public sources. What costs are incurred by the provider? What does the employee receive in return? Is the provider/contractor receiving income from multiple sources? (Via use of contracts, Medicaid, SSI, transportation costs, residential services).

Specific number of AbilityOne employees who have transitioned into competitive integrated employment and the average length of time it took for the transition.

The following data collection should reflect the financial impact to the individual and the community throughout a typical lifespan. Attain numbers showing the cost of:

A person in a 14© workshop (supports required and money spent).

A person placed in CIE (supports required and money spent).

Monies required to transition someone from a sheltered workshop to CIE.

Benefits and needed supports to maintain a person in CIE.

The average income of a person working in CIE.

Persons with disabilities in CIE still on federal benefits.

Resources accessed through federal benefits for the person with a disability?

Other resources the employee is receiving.

State resources used for person placed in CIE and the states return on investment. 


  • NCD wants to ensure there is stakeholder involvement in the findings and recommendations. The inclusion of people with disabilities must be integral to the planning, development, and execution of this project.  At least one section of the report should focus on stakeholder input, but input should be integrated throughout.
  • The report will be formatted as a standard NCD report with an executive summary. A cohesive, final report will incorporate the findings and conclusions that can be drawn from the examination and include specific recommendations.
  • Any successful proposal must demonstrate knowledge of work in this area, including the prior work of NCD and propose a plan for building on existing work so as to produce new information and not duplicate work already accomplished.
  • NCD reports must be totally accessible to all people with disabilities at all iterative stages of its drafting and editing. All graphs and charts must have full text descriptions embedded as alt-text and ensure that it is Section 508 compliant. If you are drafting a report or paper for NCD, you must submit your drafts and final version in an electronic Word and PDF format.


This study will culminate in a final report which will incorporate the findings and conclusions that can be drawn from the examination and include specific recommendations to improve the employment and economic self-sufficiency outcomes of persons with disabilities.

The deliverables for this project will include:

  • A detailed preliminary framing paper and outline of the final report.
  • A revised detailed framing paper and outline of the final report.
  • Specified data deliverable described above due no later than September 15, 2019.
  • An initial draft report incorporating the findings, conclusions, and recommendations that can be drawn from the examination.
  • A second draft report which will incorporate the findings, conclusions, and recommendations that can be drawn from the examination and incorporating recommended revisions derived from NCD staff, Council members, and external peer reviews.
  • A final report incorporating recommended revisions derived from NCD staff, Council members, and external technical reviews.
  • Development of a 1-2 page “Report Highlights” document, which succinctly and in plain language encapsulates the report’s scope and purpose, major findings, and recommendations, and contains a link to the full report at the bottom. For an example of a Reports Highlights Page, refer to:

The final report must also document the methodology, findings, and recommendations and must include a separate section containing the recommendations, organized according to the entity to which they are directed.  All assertions of fact must be substantiated in endnotes and presented in the format of the Chicago Style Manual.

Any methodology used to obtain stakeholder input must allow for open-ended discussions between stakeholders, as opposed to soliciting answers to specific, predetermined questions.  While the use of data from existing surveys is permitted, conducting surveys for purposes of this study is strongly discouraged.  The inclusion of people with disabilities must be integral to the planning, development, and execution of this project.  The report should also reflect NCD’s view that the disability community is heterogeneous, with diverse needs and perspectives, and those perspectives should be included.

Eligibility Information

All potential applicants are eligible to apply.

Cost-sharing is not required.

Other Eligibility Criteria:  Proposals that merely offer to conduct a project in accordance with the requirements of the Government’s scope of work will not be eligible for award.  Proposals that do not comply with NCD’s Document Access Requirements, as specified below, will not be considered for award.

Award Information

NCD expects to make 1 award with an anticipated funding amount of $100,000.00


Due Dates

Full proposals must be submitted by the following date (due by 5 p.m. submitter’s local time): June 6, 2019.

The proposal must be prepared in two parts: A 'Technical Proposal' and a 'Business Proposal. Each of the parts shall be separate and complete in itself so that evaluation of one may be accomplished independently of evaluation of the other. The technical proposal must not contain reference to cost; however, resource information, such as data concerning labor hours and categories, materials, subcontracts, etc., must be contained in the technical proposal so that your understanding of the scope of the work may be evaluated. It must disclose your technical approach in sufficient detail to provide a clear and concise presentation that includes, but is not limited to, the requirements of the technical proposal instructions.

The proposal must be signed by an official authorized to bind your organization. You must submit an original and 1 copy of your technical proposal and an original and 1 copy of your business proposal, including an e-mailed/electronic Word file copy of the technical and business proposal, to:

Amy Nicholas

Attorney Advisor

National Council on Disability
1331 F Street, N.W., Suite 850
Washington, DC 20004-1107

You may, at your discretion, submit alternate proposals, or proposals which deviate from the requirements; PROVIDED, that you also submit a proposal for performance of the work, as specified in the statement of work. These proposals may be considered if overall performance would be improved or not compromised and if they are in the best interest of the Government. Alternate proposals, or deviations from any requirements of this funding opportunity, must be clearly identified.

The Government will evaluate proposals in accordance with the evaluation criteria set forth in this request for proposals.

It is understood that your proposal will become part of the official contract file.

This solicitation does not commit the government to contract for any work or services whatsoever. Respondents are advised that the United States (US.) Government will not pay for any information or administrative costs incurred in response to this solicitation notice.  All costs associated with responding to this solicitation notice will be solely at the responding party’s expense. It is the responsibility of the interested parties to monitor and sites for additional information.

Proposals which merely offer to conduct a program in accordance with the requirements of the Government’s scope of work will not be eligible for award. You must submit an explanation of the proposed technical approach in conjunction with the tasks to be performed in achieving the project objectives.

A detailed work plan must be submitted indicating how each aspect of the statement of work is to be accomplished. Your technical approach should be in as much detail as you consider necessary to fully explain your proposed technical approach or method. The technical proposal should reflect a clear understanding of the nature of the work being undertaken.

The technical proposal must include information on how the project is to be organized, staffed, and managed. Information should be provided which will demonstrate your understanding and management of important events or tasks. You must explain how the management and coordination of consultant and/or subcontractor efforts will be accomplished.

The technical proposal must include a list of names and proposed duties of the professional personnel, consultants, and key subcontractor employees assigned to the project. Their resumes should be included and should contain information on education, background, recent experience, and specific requirement related or technical accomplishments. The approximate percentage of time each individual will be available for this project must be included. The proposed staff hours for each of the above individuals should be allocated against each task or subtask for the project.

The technical proposal must provide the general background, experience, and qualifications of the organization. Similar or related contracts, subcontracts, or grants should be included and contain the name of the customer, contract or grant number, dollar amount, time of performance, and the names and telephone numbers of the contracting officer’s technical representative or project officer and contracting/grants officer.

The technical proposal must contain a discussion of present or proposed facilities and equipment which will be used in the performance of the contract.

The technical proposal must be prepared and submitted in the following format:

1. Abstract (no more than 2 pages)

A two-page summary shall be provided abstracting the proposal contents (e.g., objectives, activities, expected outcomes) in language understandable to an informed layperson. The narrative should be limited to no more than 250 words.

2. Table of Contents

3. Introduction (no more than 20 pages)

Offerors shall summarize, in their own words, the purposes and objectives of the project to demonstrate their complete understanding of NCD’s intent and requirements. This section also should contain a specific statement of any interpretations, questions, qualifications, limitations, deviations, or exceptions to the Solicitation's scope of work and the extent to which the offeror’s proposal can be expected to meet the requirements set forth in the scope of work.

4. Procedural Plan (no more than 40 pages)

This section shall fully describe the theoretical and technical approaches the offeror will employ in complying with each task in the scope of work. While a general statement of strategy is appropriate, the offeror shall be specific in describing the manner in which the overall review will be conducted, and the intended approach to the design.

5. Management Plan and Schedule (no more than 15 pages)

The management plan shall show the feasibility of implementing the offeror’s resources. The offeror shall present a time chart that specifies the amount of time (in person days) each staff member will commit to implementing each task. The plan shall present a clear description of the working relationships among personnel. Finally, the plan shall contain a method for insuring the timely and successful completion of each work task.

6. Personnel

Personnel with major responsibilities shall be listed by name, title, position, academic background, relevant experience, responsibilities with the project, and the extent to which this commitment is assured. This section should include specific time commitments of staff to other projects, both Federal and non-Federal. Consultants who have agreed to serve on the project should be similarly identified and assurances of their commitment included. The Project Director shall be committed for no less than approximately 60 percent of the contract. Vitae for all principal personnel, including consultants, should be appended to the proposal. Each curriculum vitae should be limited to not more than two (2) pages and should emphasize areas of experience directly relevant to this work statement.

7. Organization Experience

This section shall describe the offeror’s pertinent experience and qualification in conducting work of a similar nature. Offerors shall offer evidence of not more than 5 previous related assignments, including the names and telephone numbers of client project offices who would be able to comment on the offeror’s performance of those assignments. Summaries (not to exceed one page) of related work shall be included. References to products resulting from these related activities shall also be included.

8. Resources/Facilities/Equipment

This section shall identify those resources (other than personnel), facilities, and equipment (e.g., library holdings, computer hardware, and software) available for use in conducting this project. Offeror should address accessibility for persons with disabilities.

9. Current Contractual Obligations

Each offeror will be required to outline both Federal and non-Federal contractual obligations existing during the course of his award for all projects involving personnel who will be assigned to this project. Such organizations/agencies must be identified by name and the percentage of work time allotted to these projects by personnel committed to the proposed project must be provided.

10. Issues and Associated Data Items

When responding to the Tasks, when identifying what should receive emphasis, careful consideration should be given to the issues identified, their associated data items, and the statement of products desired in the Final Report.

All information provided by NCD must be returned to NCD upon completion of the analysis and no later than 10 working days after the completion of the contract. The information may not be reproduced or released without the prior written permission of NCD.

11. Rights in Data, Copyright, and Disclosure

a. Data – The term data as used here includes written reports (progress, draft, and final), electronic format and work of any similar nature that is required under any resulting Cooperative Agreement to perform this project.  It does not include the contractor’s financial reports, or other information incidental to contractor administration. Data submitted to and accepted by the NCD under the cooperative agreement shall be the property of the NCD, and NCD shall have full and unlimited rights to use such data for any purpose in whatever manner deemed desirable and appropriate, including making it available to the general public. Such use shall be without any additional payment to the contractor. Data may be published as the property of NCD without giving authorship to the contractor.

b. Copyright – The contractor relinquishes any and all copyrights and/or privileges developed under any Cooperative Agreement. The contractor shall not include in the data any copyrightable matter without the written approval of NCD, unless the contractor provides the NCD with the written permission of the copyright owner for the NCD to use the matter.

c. Disclosure – The contractor agrees not to divulge or release any information, reports or recommendations developed or obtained in connection with the performance of any Cooperative Agreement with NCD, and not otherwise available to the public, without the prior approval of the NCD.

d. Final approval of deliverables

All final deliverables are the product of NCD and require acceptance and approval by NCD.  NCD reserves the right to make substantive edits to any final deliverables.

12. Award Information

The Government will make award to the responsible offeror(s) whose offer conforms to the solicitation and is most advantageous to the Government, cost or price and other factors considered. For this solicitation, technical quality is more important than cost or price. As proposals become more equal in their technical merit, the evaluated cost or price becomes more important. As the technical merit and the evaluated cost or price become essentially equal, other factors may become a determining factor.

Upon notification of intent to award, the Contractor will be expected to:

*Develop and submit a timeline and deliverables schedule that will be used to guide the conduct of the study and monitor the work;

*Develop and submit a payment schedule chart to be used for installment payments of the award;

*Meet with select NCD staff and board members at a pre and post award meeting.

13. Reporting

Throughout the project, the Contractor and Contract Officer will conduct mutually agreed upon weekly teleconference calls and/or biweekly meetings, set-up and arranged for by the Contractor, to include other project staff members, NCD staff and, as appropriate, selected project advisors and NCD board members.   The Contractor will also provide monthly electronic progress reports to the NCD Agreements Coordinator.  The contractor will also present to the full Council at a quarterly Council meeting and should factor the travel expenses into the project budget.

Business Proposal

The business proposal should contain a detailed budget for the project and the certifications and representations required by OMB Circular A-110. 

Note:  For each type of entity, there is a set of Federal principles for determining allowable costs. Allowability of costs shall be determined in accordance with the cost principles applicable to the entity incurring the costs. Thus, allowability of costs incurred by State, local or federally-recognized Indian tribal governments is determined in accordance with the provisions of OMB Circular A–87, “Cost Principles for State and Local Governments.” The allowability of costs incurred by non-profit organizations is determined in accordance with the provisions of OMB Circular A–122, “Cost Principles for Non-Profit Organizations.”

The allowability of costs incurred by institutions of higher education is determined in accordance with the provisions of OMB Circular A–21, “Cost Principles for Educational Institutions.” The allowability of costs incurred by hospitals is determined in accordance with the provisions of appendix E of 45 CFR part 74, “Principles for Determining Costs Applicable to Research and Development Under Grants and Contracts with Hospitals.” The allowability of costs incurred by commercial organizations and those non-profit organizations listed in Attachment C to Circular A–122 is determined in accordance with the provisions of the Federal Acquisition Regulation (FAR) at 48 CFR part 31.

Technical Evaluation Criteria

Evaluation criteria will score proposals with a maximum of 100 points, divided as follows:

1. A clear understanding of the nature of the work (20 points)

The proposal presents a clear understanding of the tasks required and the importance, quality and reliability of those tasks. The proposal will present the rationale/interpretation of the project approach.

2. Procedural Plan (30 points)

The proposal contains evidence of a fully described technical approach to comply with each of the tasks in the scope of work. The proposal is consistent with the goals, objectives, compliance requirements, and is practical in terms of producing needed information, analysis and recommendations.

3. Management Plan and Schedule (20 points)

The degree to which the project team, including any use of consultants, is organized, managed, and motivated to accomplish effective and efficient implementation of all tasks to be completed. The proposal budget is appropriate to the administration of the project. The time frame is realistic. Plans and schedules to assure smooth cooperation with the NCD staff involved are evident. The proposal clearly identifies who will be key personnel and includes a table showing the number of person-days by tasks for each of the key personnel.

4. Personnel (15 points)

The proposal provides evidence of the specific qualifications and skills of staff and consultants to be assigned to this project, and their experience and familiarity with the topic, including relevant laws, regulations, procedures and practices in the Federal Government. Skills in writing and conducting research should also clearly demonstrated.

5. Organizational Experience (15 points)

The degree to which the overall experience and past performance of the offeror in executing similar projects should be described. Evidence of related assignments should be detailed. Offeror shall present evidence of related assignments, including the names and telephone numbers of previous project officers who would be able to comment on the offeror’s performance of those assignments.

Project Start Date

The projected start of the cooperative agreement is June 15, 2019, with the first deliverable due September 15, 2019. The projected first complete draft of the report is due to NCD by January 7, 2020. The projected final draft of the report is due to NCD by April 1, 2020.

Furthermore, the vendor will be expected to arrange and conduct weekly teleconference calls with NCD staff and board members, will provide monthly progress reports to NCD staff, and will also be expected to meet with select NCD staff and Board Members upon the awarding of the contract.  The vendor is also responsible for reasonable accommodations at any meetings, events, forums, focus groups, etc. (i.e. sign language interpreters, CART reporters, and other such providers, as well as documents or other materials that are made available in public forums), associated with this agreement.

The contractor will also present in person to the full Council at a quarterly Council meeting and should factor the travel expenses into the project budget.

Finally, the vendor is expected to develop and submit a “timeline and deliverables and payment schedule” chart which will be used to guide the conduct of the research.

Formatting Guidelines

NCD reports must be totally accessible to all people with disabilities at all iterative stages of its drafting and editing. All graphs and charts must have full text descriptions embedded as alt-text and ensure that it is Section 508 compliant. If you are drafting a report or paper for NCD, you must submit your drafts and final version in an electronic Word and PDF format. You must adhere to NCD's formatting and style standards. Details regarding NCD’s additional formatting and style standards follow below.  


Style Guide

NCD utilizes the Chicago Style Manual for its reports and papers and employs the author-date system of documentation. A copy of the manual can be viewed online with accompanying resources at:


Within the Chicago Style Manual, NCD employs the author-date system of documentation. Examples of this citation style format (in-text and in the references) can be viewed at:


NCD reports must be totally accessible to all people with disabilities at all iterative stages of its drafting and editing. All graphs and charts must have full text descriptions embedded as alt-text and ensure that it is Section 508 compliant. If you are drafting a report or paper for NCD, you must submit your drafts and final version in an electronic Word and PDF format.


Text and covers should be created and printed with the highest contrast possible. This includes text in all graphics, figures, tables, and charts.


Use Arial, 12-point. Italics should be used sparingly, not for full sentences or paragraphs or recommendations. Do not use small caps.

Line Spacing

The body of the report or paper should be spaced with 1.5 line spacing.

The Letter of Transmittal, references, endnotes, appendices, etc. should be single spaced.

Paper Size

Set paper size to 8.5" x 11".


Set standard one inch (1") margins on all sides.


Use block style. Begin paragraphs without tabbing in. Text should be in single column format. Use a double space between paragraphs.


Use left justified (ragged right).

Smart Quotes and Apostrophes

Use smart quotes and apostrophes.


Chapters should start on odd-numbered pages, which fall on the right side.

Headers and Footers

Delete unnecessary headers and footers.

Widows and Orphans

Do not have widows or orphans.

Web Addresses

Make all Web addresses hyperlinks.

Style Heads

Utilize Microsoft Word default style for headers (and subheaders) so that readers can easily track the progression of the report or paper and so that the report or paper can be made easily navigable with a table of contents. 

Do not use caps or small caps in the headers. Double space between headers and text.

Spacing after Periods

Use one space after a period at the end of a sentence and one space after colons and question marks.


All documents use endnotes in Arial. 12-point font and single spaced.

Page Numbering

Page numbering will be centered at the bottom of each page. Blank pages require page numbers. Begin ordinal page numbering on the Letter of Transmittal page, which is always page 1 (suppress page number of that page). All pages are numbered consecutively from 1-999 including appendices. Do not use roman numbering or alpha/numeric numbering in any parts of the document, including appendices.

Contents Page

Create a table of contents (TOC) using Microsoft Office Word’s TOC feature. This includes page numbers for chapters and major section headings. Type all text in regular font. Do not bold entire page.

NCD Editorial Style Requirements


Use active voice (within reason)

Serial comma

Numbers: one-nine, 10 and above

As a general default, use people first language throughout, including but not limited to:

  • “people with disabilities” [[not “persons” or “individuals with disabilities”]]
  • “people without disabilities,” [[not disabled, handicapped, impaired, or nondisabled]]
  • “people with [particular disability] or “a person with a disability, including, but not limited to:
    • “people with intellectual disabilities” [[not intellectually disabled]]
    • “people with mental illnesses” [[not people who are mentally ill]]
    • “people with physical disabilities” [[not the mobility impaired]]
    • “people with learning disabilities” [[not the learning disabled]]
    • “people with a mental illnesses” [[not mentally ill people]]

Use current acceptable terminology including, but not limited to:

  • “intellectual disability” [[not mental retardation or MR]]
  • “seniors” or “people who are aging” [[not the elderly or the aged]]
  • “youth” or “young people with disabilities” [[not disabled youth, etc.]]

Use terminology preferred by particular disability subpopulations:

  • “Deaf and Hard of Hearing” as a noun, with capitalization [[not people who are deaf and hard of hearing]]
  • “autistic” as an adjective or a noun [[not people who have autism]]
  • “little people” or “little person” [[not dwarf / dwarves]]

NCD has determined that the terminology used in its 2000 report, “People Labeled with Psychiatric Disabilities,” best captures the identity and experiences of the population (also called people with mental illnesses,” “mental health consumers,” “psychiatric survivors,” and a number of other terms). However, because the field uses such a wide diversity of terms, including terms used by people with psychiatric disabilities themselves, NCD documents (papers, reports, and so forth) can include a variety of terminology used by people quoted herein. The exceptions are the need to edit and remove terms considered detrimental to the community, NCD’s mission, and ensuring the use of “people first” language.

Use [a bracket] to show language revisions/edits (including where the changes were made within otherwise quoted material) in order to meet NCD’s requirements identified in this document

Use “people from diverse cultures,” “people from diverse racial background,” “people of color” and so forth [[not minorities or minority groups]]

When referring to people who have been consistently or historically overlooked, segregated, disregarded, or simply not included, please consider use of generic terms like “marginalized” or “under-served.”

1990s (not 1990’s)

Punctuation NEVER comes after a closing quotation mark or an endnote/footnote number.

Due to or Because of? “Due to” modifies nouns and is generally used after some form of the verb to be (is, are, was, were, etc.). Jan's success is due to talent and spunk (“due to” modifies success). “Because of” should modify verbs. Ted resigned because of poor health (“because of” modifies resigned).

Generally, use “between” for two, and “among” for three or more.

Legal Cases/Bills/Laws, etc:

H.R. 2457

S. 1322

P.L. 106-515

Italicize names of court cases

Get rid of small caps used in notes

Word List:

Administration (presidential)

closed captioning

Congress, not the Congress

data indicates (treat data as singular)

decision making

Department (capped referring to a U.S. Department)



Executive Order


Federal Government


health care (n, um*)

home- and community-based (um)

interagency (closed up)


multi (close up)


National Council on Disability [[not Disabilities]]

NCD, not the NCD

non (close up)

percent, not %, unless in tables or parentheses



the President








Supreme Court, the Court




Use population group names from current Census Bureau listing.

In titles, cap prepositions of 5 or more letters.

*um=unit modifier, meaning two words used as an adjective


Reviews of proposals submitted to NCD are solicited from peers with expertise in the substantive area of the proposed project. These reviewers are selected by NCD staff charged with the oversight of the review process. Care is taken to ensure that reviewers have no conflicts with the proposer. Special efforts are made to recruit reviewers from non-academic institutions, minority-serving institutions, or adjacent disciplines to that principally addressed in the proposal.

All proposals are carefully reviewed by at least three other persons outside NCD who are experts in the particular field represented by the proposal.

Reviewers will be asked to formulate a recommendation to either support or decline each proposal. The NCD staff assigned to manage the proposal's review will consider the advice of reviewers and will formulate a recommendation.

A summary rating and accompanying narrative will be completed and submitted by each reviewer. In all cases, reviews are treated as confidential documents. 

Notice of Award

NCD will notify the applicant by telephone, e-mail, and/or letter.  This notification will begin negotiations for a Cooperative Agreement.  The letter is not authorization to begin performance. Notification of the award will be made to the submitting organization by Amy Nicholas, an NCD Attorney Advisor. Organizations whose proposals are declined will be advised as promptly as possible. Verbatim copies of reviews, not included identifying names or information about proposal reviewers, will be made available upon request. 


Inquiries regarding this study should be made to:

Amy Nicholas at


Overview and Purpose

The National Council on Disability (NCD) is an independent federal agency comprised of a team of Presidential and Congressional appointees, an Executive Director appointed by the Chair, and a full-time professional staff. The purpose of NCD is to promote policies, programs, practices, and procedures that guarantee equal opportunity for all people with disabilities regardless of the nature or significance of the disability and to empower people with disabilities to achieve economic self-sufficiency, independent living, and inclusion and integration into all aspects of society.

Specific Duties

The current statutory mandate of NCD includes the following:

• Reviewing and evaluating, on a continuing basis, policies, programs, practices, and procedures concerning individuals with disabilities conducted or assisted by federal departments and agencies, including programs established or assisted under the Rehabilitation Act of 1973, as amended, or under the Developmental Disabilities Assistance and Bill of Rights Act, as well as all statutes and regulations pertaining to federal programs that assist such individuals with disabilities, to assess the effectiveness of such policies, programs, practices, procedures, statutes, and regulations in meeting the needs of individuals with disabilities.

• Reviewing and evaluating, on a continuing basis, new and emerging disability policy issues affecting individuals with disabilities in the Federal Government, at the state and local government levels, and in the private sector, including the need for and coordination of adult services, access to personal assistance services, school reform efforts and the impact of such efforts on individuals with disabilities, access to health care, and policies that act as disincentives for individuals to seek and retain employment.

• Making recommendations to the President, Congress, the Secretary of Education, the director of the National Institute on Disability and Rehabilitation Research, and other officials of federal agencies about ways to better promote equal opportunity, economic self-sufficiency, independent living, and inclusion and integration into all aspects of society for Americans with disabilities.

• Providing Congress, on a continuing basis, with advice, recommendations, legislative proposals, and any additional information that NCD or Congress deems appropriate.

• Gathering information about the implementation, effectiveness, and impact of the Americans with Disabilities Act of 1990 (ADA) (42 U.S.C. § 12101 et seq.).

• Advising the President, Congress, the commissioner of the Rehabilitation Services Administration, the assistant secretary for Special Education and Rehabilitative Services within the Department of Education, and the director of the National Institute on Disability and Rehabilitation Research on the development of the programs to be carried out under the Rehabilitation Act of 1973, as amended.

• Providing advice to the commissioner of the Rehabilitation Services Administration with respect to the policies and conduct of the administration.

• Making recommendations to the director of the National Institute on Disability and Rehabilitation Research on ways to improve research, service, administration, and the collection, dissemination, and implementation of research findings affecting people with disabilities.

• Providing advice regarding priorities for the activities of the Interagency Disability Coordinating Council and reviewing the recommendations of this council for legislative and administrative changes to ensure that such recommendations are consistent with NCD’s purpose of promoting the full integration, independence, and productivity of individuals with disabilities.

• Preparing and submitting to the President and Congress an annual report titled National Disability Policy: A Progress Report.


In 1995, NCD was designated by the Department of State to be the U.S. government’s official contact point for disability issues. Specifically, NCD interacts with the special rapporteur of the United Nations Commission for Social Development on disability matters.

Consumers Served and Current Activities

Although many government agencies deal with issues and programs affecting people with disabilities, NCD is the only federal agency charged with addressing, analyzing, and making recommendations on issues of public policy that affect people with disabilities regardless of age, disability type, perceived employment potential, economic need, specific functional ability, veteran status, or other individual circumstance. NCD recognizes its unique opportunity to facilitate independent living, community integration, and employment opportunities for people with disabilities by ensuring an informed and coordinated approach to addressing the concerns of people with disabilities and eliminating barriers to their active participation in community and family life.

NCD plays a major role in developing disability policy in America. In fact, NCD originally proposed what eventually became the ADA. NCD’s present list of key issues includes improving personal assistance services, promoting health care reform, including students with disabilities in high-quality programs in typical neighborhood schools, promoting equal employment and community housing opportunities, monitoring the implementation of the ADA, improving assistive technology, and ensuring that people with disabilities who are members of diverse cultures fully participate in society.

Statutory History

NCD was established in 1978 as an advisory board within the Department of Education (P.L. 95-602). The Rehabilitation Act Amendments of 1984 (P.L. 98-221) transformed NCD into an independent agency.

National Council on Disability
1331 F Street, NW
Suite 850
Washington, DC 20004

For General Information:
202-272-2004 Voice
202-272-2074 TTY
202-272-2022 Fax