### Servicing Human Resources Office (SHRO) and Fire Management Office (FMO) role in the Interagency Wildland Firefighter Medical Qualification Standards Program (IMSP) Waiver/Accommodation Process

Bureau/Agency position descriptions and manuals define the role of the
SHRO as providing operational human resources services. The SHRO, or
designated staff, serves as an employment officer, responsible for
assisting management, applicants and incumbents in the areas of
staffing, classification, employee relations, etc. Bureaus/Agencies
delegate employment officer authority to management position(s), who
then re-delegate this authority to the SHRO.

Prior to the implementation of the IMSP each Bureau/Agency utilized the
SF-78, Certificate of Medical Examination, for the physical examination
process for applicants/incumbents who participate in arduous wildland
firefighting. A common practice was to forward the completed SF-78 to
the SHRO, who reviewed the physician conclusions and if "No limiting
conditions for this job" was indicated, the SHRO signed the SF-78 as
employment officer and the individual was hired and, or in the case of
an incumbent, allowed to participate in arduous wildland firefighting.
If "Limiting conditions as follows" was indicated, the SHRO met with
agency management to determine whether reasonable accommodation could be
made. The SF-78 was filed and maintained in the Employee Medical Folder
(EMF) in the SHRO system of records.

The IMSP continues the role of the SHRO in the medical
examination/clearance process (based on past practices and direction
from OPM, the Code of Federal Regulations, Department Manuals,
Delegations of Authority, and Agency Implementation Guides (see
attached)) by notifying the SHRO when an applicant/incumbent is
medically disqualified (Not Cleared). The IMSP continues the role of the
SHRO to meet with agency management to determine whether a
waiver/accommodation can be made.

The SHRO is a valuable partner with the IMSP and is responsible for
advising/assisting management and the applicant/incumbent through the
waiver/accommodation process by:

-   Reviewing/analyzing the applicant/incumbent request (including
    supporting documentation) for a waiver/accommodation;

-   Preparing and forwarding the draft waiver/accommodation memo to the
    IMSP staff;

-   Receiving concurrence/nonconcurrence decision on the draft
    waiver/accommodation memo from the IMSP staff and finalizing the
    appropriate memo; and,

-   Assisting management with employment decision(s)
    (reassignment/removal) that will withstand third party review
    (grievance, MSPB, EEOC) when the waiver/accommodation request was
    denied at the 1^st^ and/or 2^nd^ level of the waiver/accommodation
    process.

The FMO is also a valuable partner with the IMSP and is responsible for
assisting the SHRO and the applicant/incumbent during the
waiver/accommodation process by:

-   Providing the SHRO with subject matter expertise on the duties and
    responsibilities of an arduous wildland firefighter;

-   Providing supporting documentation on the applicant/incumbent
    qualifications, training, and experience; providing possible
    mitigations of the medical non-clearance issue; and,

-   Assisting the SHRO with employment decision(s)
    (reassignment/removal) when the waiver/accommodation request was
    denied at the 1^st^ and/or 2^nd^ level of the waiver/accommodation
    process.

**OPM/GOVT-10 PERSONNEL MANAGEMENT OFFICE**

**Employee Medical File System Records,**

**System location: a.** For current employees, records are located in
agency medical, personnel, dispensary, health, safety, or other
designated offices within the agency, or contractors performing a
medical function for the agency.

Note 1.---The records in this system are records "owned" by the Office
of Personnel (Office) management and should be provided to those Office
employees who have an official need or use for those records.

**Categories of records in the system:**

**a.** Medical records, forms, and reports completed or obtained when an
individual applies for a Federal job and is subsequently employed;

**b.** Medical records, forms, and reports completed during employment
as a condition of employment . . .

**Purpose(s): h.** To ensure that all relevant, necessary, accurate, and
timely data are available to support any medically-related employment
decisions affecting the subject of the records (e.g., in connection with
fitness-for-duty or disability retirement decisions).

**Title 5 CFR Part 339, Medical Qualification Determinations:**

**Section 339.101 Coverage.** This part applies to all applicants for
and employees in competitive service positions; and to excepted service
employees when medical issues arise in connection with an OPM regulation
which governs a particular personnel decision, for example, removal of a
preference eligible employee in the excepted service under part 752.
***and***

**Section 339.102** **Purpose and effect. (b)** Personnel decisions
based wholly or in part on the review of medical documentation and the
results of medical examinations and evaluations shall be made in
accordance with appropriate parts of this title.

**DM Part 373**, **Reasonable Accommodation for Individuals with
Disabilities; Chapter 15. Section 15.6 Responsibilities**. **C.** The
Servicing Human Resources Officer (HRO) is responsible for providing
operational human resources services to the bureau/office. The HRO, or
designated staff, serves as the employment officer and is responsible
for conducting job analyses on vacancies to ensure that the knowledge,
skills and abilities identified are related to the essential functions
of the job, and that barriers are removed from the hiring process. The
HRO is responsible for training human resources specialists who are
involved in the application process to recognize requests for reasonable
accommodation and handle them in accordance with this chapter.

**FS IMSP Implementation Guide:**

**HR IMSP Waiver/Accommodation Specialist**

-   Provide expertise to FMOs in initial waiver/accommodation process in
    conjunction with Interagency IMSP Staff.

-   Coordinate with FMO and employee during waiver/accommodation process

-   Develop, with FMO, the final draft waiver/accommodation memo and
    forward to Interagency IMSP Staff Office

**Fire Management Officer -- Forest & District**

-   Coordinate with HR IMSP Waiver/Accommodation Specialist and District
    employee during waiver/accommodation process

**IMSP website: http://www.nifc.gov/medical_standards/index.htm**