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Frequently Asked Questions
Q1 - WHAT EXACTLY IS "REASONABLE ACCOMMODATION?"
A1 - Reasonable Accommodation is the removal of a work place barrier for people with disabilities to allow them the opportunity to apply for employment, perform the essential functions of a job or, to enjoy equal benefits/privileges of employment.
Q2 - WHO IS ELIGIBLE FOR REASONABLE ACCOMMODATION?
A2 - ONLY applicants or employees who are disabled in accordance with the Rehabilitation Act of 1973 amended, EPA Policy and Procedures for Reasonable Accommodation are eligible for reasonable accommodation consideration.
Q3 - WHO IS DISABLED UNDER THE REHABILITATION ACT?
A3 - Under the Rehabilitation Act an individual is "disabled" if the person has a physical or mental impairment that substantially limits a major life activity of that person; has a history of such an impairment, or; is regarded as having such an impairment. It is important to note that persons "regarded as" are not eligible for reasonable accommodation because, essentially, there is nothing to accommodate.
Q4 - ARE SPECIFIC MEDICAL IMPAIRMENTS INCLUDED AS DISABLING?
A4 - NO! there are no specific impairments included as per se disabling conditions. The medical condition MUST fall within at least one of the three prongs of the definition in answer #3 above.
Q5 - WHO COORDINATES THE REASONABLE ACCOMMODATION POLICY AND PROCEDURES?
A5 - The coordination of the program is the responsibility of the National Reasonable Accommodation Coordinator, Office of Civil Rights. There are Local Reasonable Accommodation Coordinators within the ten regions and RTP, Las Vegas and Cincinnati labs to assist with the implementation within these areas.
Q6 - MUST ALL REASONABLE ACCOMMODATION REQUESTS BE MADE IN WRITING?
A6 - NO! All requests, either oral or in writing, must be processed. The agency is required to track all reasonable accommodation requests and procedures provide written reporting mechanisms. For the purpose of tracking reasonable accommodations it is expected that all oral requests be put in writing in accordance with the instructions in the procedures.
Q7 - HOW ARE REASONABLE ACCOMMODATION REQUESTS PROCESSED?
A7 - An employee may submit a reasonable accommodation request to anyone in his/her supervisory chain of command or to the National or Local Reasonable Accommodation Coordinators. It is strongly advised that requests be submitted and processed by the employee's first line supervisor.
Q8 - ARE THERE SPECIFIC TIME LIMITS FOR GRANTING OR DENYING A REASONABLE ACCOMMODATION REQUEST?
A8 - YES! Each procedure outlines specific time limits from the point at which the request is made and a decision to grant or deny is made. The procedures identify a maximum time limit of 25 days. However, many accommodation requests can be granted or denied prior to the conclusion of the 25 days and should be processed accordingly. An example of the need to process in less than the maximum 25 days would be when an applicant who is deaf requests a sign language interpreter for a job interview he/she has in 2 weeks. This request must be processed immediately in order for this applicant to be appropriately accommodated for the job interview.
Q9- WHEN MAY EPA REQUEST MEDICAL DOCUMENTATION?
A9- EPA may request medical documentation when there is a need to determine if the person has a disability where the disability or need for accommodation is not obvious; may ask for supplemental documentation if the original documentation submitted does not clearly explain the nature of the disability, including functional limitations, major life activities affected or need for reasonable accommodation.
Q10- WHEN MAY EPA NOT REQUEST MEDICAL DOCUMENTATION?
A10- EPA may not request medical documentation where both the disability and the need for reasonable accommodation are obvious, or; the individual has already provided the agency with sufficient information to document the existence of the disability and the functional limitations imposed by the disability on that individual.
Q11- IS EPA REQUIRED TO INFORM AN INDIVIDUAL OF THE DECISION MADE REGARDING THEIR REASONABLE ACCOMMODATION REQUEST?
A11- YES! It is required when a decision regarding the individual's request is made, that the applicant or employee be informed in writing. The denial of reasonable accommodation must include the specific reason why the request was denied and inform the person of their rights to appeal as well as other available avenues of redress. Standard language regarding this notification is included in the Agency's Reasonable Accommodation Procedures.
Q12- ARE AGENCIES REQUIRED TO TRACK REASONABLE ACCOMMODATION REQUESTS?
A12- YES! The EPA Reasonable Accommodation Procedures outline the specific information that must be tracked in accordance with EEOC guidelines. This information is tracked by the National Reasonable Accommodation Coordinator. The Procedures also outline how medical information received as a result of the reasonable accommodation process is maintained by the National Reasonable Accommodation Coordinator in a confidential manner in accordance with applicable laws and regulations.
Q13- MUST REASONABLE ACCOMMODATION REQUESTS BE MADE AT A SPECIFIC TIME?
A13- NO! Under the Rehabilitation Act, the duty to provide reasonable accommodation is an ongoing one. Thus, an individual with a disability must be permitted to request accommodation whenever he/she chooses. That request will then trigger EPA's obligation to start the process laid out in our procedures.
Q14- WHAT DO I DO WHEN I DON'T KNOW WHAT TO DO????
A14- Again, each region and the three labs in Cincinnati, Las Vegas and RTP have designated Local Reasonable Accommodation Coordinators (LORACs) to assist management and employees with this process. The National Reasonable Accommodation Coordinator services all metropolitan Washington DC employees with the reasonable accommodation process. To receive a list of these LORACs or to find out who you should contact, please call Bill Haig, National Reasonable Accommodation Coordinator, Office of Civil Rights at 202-564-7959 or haig.william@epa.gov.