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I. OVERVIEW 

The Commission follows all applicable legal authorities in providing reasonable 

accommodations to employees or applicants who require them due to disability or 

sincerely held religious beliefs. This policy establishes the procedures and practices for 

reasonable accommodation requests.

II. DEFINITIONS

Appropriate official: An individual who can receive a reasonable accommodation request. 

This includes:

• An employee’s supervisor 

• A manager, deputy office head, or office head in an employee’s chain of command

• The Reasonable Accommodation Coordinator

• Any agency employee with whom an applicant has contact in connection with the 

application for employment process

Deciding official: An individual who has authority to determine whether a requested 

accommodation will be provided.

• For accommodations with no cost to the Commission, the deciding official may be 

the requester’s supervisor, deputy office head, or office head in the employee’s chain 

of command or the Reasonable Accommodation Coordinator.

• For accommodations with a cost within his or her delegated procurement authority, 

the Reasonable Accommodation Coordinator is the deciding official. 

• For accommodations with a cost that exceeds the delegated procurement authority 

of the Reasonable Accommodation Coordinator but within the delegated 

procurement authority of the Secretary, the Reasonable Accommodation 

Coordinator is the deciding official, with written approval from the Secretary.

PRC POLICY: 

REASONABLE 

ACCOMMODATION

Issued By:

Effective Date:

Reissue Dates:

Policy #:

Stacy Ruble

September 18, 2013

July 3, 2017

October 3, 2018

March 1, 2019

HR-019
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• For accommodations with a cost that exceeds the delegated procurement authority 

of the Secretary, the Reasonable Accommodation Coordinator is the deciding official, 

with written approval from the Chairman.

Disability: A physical or mental impairment that substantially limits one or more major life 

activities (including, but not limited to, caring for oneself, performing manual tasks, seeing, 

hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, 

reading, concentrating, thinking, communicating, and working) or operation of a major 

bodily function (including, but not limited to, functions of the immune system; normal cell 

growth; digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine, 

and reproductive functions) of an individual. The definition of disability should be 

construed broadly and in line with the rules of construction in the Rehabilitation Act and 

42 U.S.C. § 12102(4).

Essential functions: Job duties that are so fundamental to the position that the individual 

cannot do the job without being able to perform them.

Personal Representative: A family member, friend, health professional, or other 

representative who can make a reasonable accommodation request on behalf of a 

requester.

Reasonable accommodation: The provision of conditions, equipment, or environment that 

enable a qualified individual to effectively perform the essential functions of his or her job,

to enjoy equal benefits and privileges of employment, or to be considered for employment.

Reasonable Accommodation Coordinator: The HR Specialist serves as the Reasonable 

Accommodation Coordinator for the Commission. 

Request: Any communication in which an individual expresses that he or she needs the 

Commission to provide or to change an aspect of the application process, job, or benefit of 

employment because of a disability. No other information is needed to initiate the process, 

and a request does not have to include any special words such as “reasonable 

accommodation,” “disability,” or “Rehabilitation Act.” A doctor or personal representative 

can make a request on a requester’s behalf. 

Requester: A qualified individual (an employee or applicant) who makes a request, or for 

whom a doctor or personal representative makes a request, for reasonable accommodation 

as set forth in this policy.

Qualified individual: An individual who, with or without reasonable accommodation, can 

perform the essential functions of the employment functions of the position that the 

individual holds or desires.

Timeframe: All time limits in this policy are computed in business days. 
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Undue hardship: An action requiring significant difficulty or expense, when considered in 

light of the nature and cost of the accommodation and its impact on the expenses, 

resources, and operation of the Commission.

III. REASONABLE ACCOMMODATION PROCEDURE

A. Initiating a Request

Requests can be made at any time, either orally or in writing. The requester must notify 

an appropriate official that he or she needs a change to an aspect of the application 

process, job, or a benefit of employment because of a disability. The requester need not 

have a particular accommodation in mind when making a request. 

When an individual requires a reasonable accommodation on a recurring basis (e.g., the 

assistance of sign language interpreters or readers), a formal request, either oral or 

written, must be made for the first requirement only. For subsequent need for the same 

accommodation, the requester should provide as much advance notice as possible, but

not less than 5 business days. 

When an appropriate official receives a request, he or she should provide the requester

with written acknowledgement of the request using the Confirmation of Request for 

Reasonable Accommodation (see Confirmation, Appendix A) and send a copy to the 

Reasonable Accommodation Coordinator.

If the receiving appropriate official is the requester’s supervisor, deputy office head, or 

office head in the employee’s chain of command and the requested accommodation 

does not have any associated costs to the Commission, the receiving appropriate official 

can approve the request directly. The appropriate official should notify the Reasonable 

Accommodation Coordinator of his or her intent to grant the accommodation via email, 

and follow the procedures for granting a request in the Section D below. 

The Commission’s obligation to consider a request begins when the request is made to 

an appropriate official. The Commission may not refuse to process a request for 

reasonable accommodation, and a reasonable accommodation may not be denied based 

on a belief that the accommodation should have been requested earlier.

The processing of the request must begin as soon as it is received. The Reasonable 

Accommodation Coordinator will reply to the requester with a tracking number for the 

request, via email or via US Mail if no email address is available, within 2 business days 

of the date of the request. The reply will also include the name of the deciding official 

and inform the requester that they can contact the deciding official or the Reasonable 

Accommodation Coordinator to discuss the request at any time. 
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The process for requesting personal assistance services, the process for determining 

whether such services are required, and the agency's right to deny such requests when 

provision of the services would pose an undue hardship, are the same as for reasonable

accommodations. Personal assistance services are those that help individuals who, 

because of targeted disabilities, require assistance to perform basic activities of daily 

living (e.g. eating and using the restroom), but the services are not related to their job 

performance (see Appendix D for Personal Assistance Services Procedures.)

This policy will be posted on the Commission’s public website and on the intranet for 

access by employees and applicants for employment, and will be made available in an 

accessible format (a format which meets an individual’s particular need) when 

requested. The request can be made to the Reasonable Accommodation Coordinator, 

whose information will also be posted.

B. The Interactive Process

The Commission employs an interactive process to evaluate requests during which the 

deciding official will communicate with the requester, the requester’s supervisor (if the 

deciding official is not the requester’s supervisor), and the Reasonable Accommodation 

Coordinator (if necessary) regarding the specific limitation, problem or barrier; 

potential effective accommodations; and choice among accommodation options when 

available. The deciding official will propose a reasonable accommodation if the 

requester has not proposed one. If the requester proposes an accommodation that is 

not effective or would pose an undue hardship, the deciding official will continue the 

interactive process, exploring alternatives until an accommodation is found or a 

determination is made that no accommodation is available. When an employee makes a 

request for reasonable accommodation that involves performance of the job, the 

deciding official will work with the requester’s supervisor to determine if an 

appropriate accommodation can be provided to meet the individual’s needs and enable 

the individual to perform the essential functions of the position.

The deciding official should follow the following three-part analysis when evaluating 

the request:

1. Determine if the requester is a qualified individual with a disability. 

2. Determine if the accommodation is needed to: enable a qualified employee with 

a disability to perform the essential functions of his or her position; enable an 

employee with a disability to enjoy equal benefits and privileges of employment 

as a similarly situated employee without a disability; or enable a qualified 

applicant with a disability to be considered for the position he or she desires. 

3. Determine what effect the accommodation will have on the employee’s ability to 

perform the essential functions of his or her position and any undue hardship 

the accommodation may impose on the Commission. 

The deciding official is required to consult with the Reasonable Accommodation 

Coordinator before denying an accommodation or providing an accommodation other 
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than the specifically requested accommodation. The Reasonable Accommodation 

Coordinator, in turn, will consult with the Secretary and the Office of the General 

Counsel. 

Deciding officials must ensure that individuals with disabilities are not excluded from 

employment due to the anticipated cost of a reasonable accommodation. To ensure that 

requests for accommodation are not denied for reasons of cost (if the resources 

available to the Commission as a whole would enable it to provide an effective 

reasonable accommodation without undue hardship), the Commission funds 

reasonable accommodation out of the central budget (not out of a department’s 

budget), and provides the Reasonable Accommodation Coordinator as a trained 

resource to ensure that the officials who decide requests for accommodation or make 

hiring decisions must consider all resources available to the Commission as a whole, 

excluding those designated by statute for a specific purpose that does not include 

reasonable accommodation. The Commission will provide this policy to all deciding 

officials who grant or deny requests for accommodation or who make hiring decisions 

to ensure that they know how to arrange for the use of agency resources to provide the 

accommodation.

The Commission recognizes that there is a range of possible types of accommodations, 

including (but not limited to):

• Making physical modifications to the workplace

• Acquiring equipment or adaptive devices, modifying existing equipment, or

modifying policies

• Providing sign language interpreters, readers, or other personal services

• Granting leave (paid accrued leave or permitting unpaid leave)

• Using work flexibilities such as telework and alternative work schedules

• Exceptions to the Commission dress code

Reassignment to a vacant position for which an employee is qualified, and not just 

permission to compete for such position, is a reasonable accommodation. Reassignment 

to an existing vacant position for which the requester is qualified will be considered 

only if no other accommodation would enable the employee to perform the essential 

functions of his or her current job, or if all other possible accommodations would 

impose undue hardship. All available vacancies at the Commission are posted on the 

Commission website under Employment. The Reasonable Accommodation Coordinator 

is responsible for consulting with the requester, the supervisor, and the Human 

Resources team to determine whether a requester is qualified for a particular job or 

whether the requester would need reasonable accommodation to perform the essential 

functions of a new position.

1. Requesting Additional Information

If the reason for a requester’s need for accommodation is not obvious or already 

known, the deciding official may request documentation which is reasonably 

necessary to establish that the requester is an individual with a disability and needs 
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the accommodation requested. The request for documentation should focus on the 

requester’s need for accommodation. The deciding official will inform the 

Reasonable Accommodation Coordinator of the need for this information. To ensure 

the confidentiality of medical information, all requests for medical information will 

be made by the Reasonable Accommodation Coordinator. This request will be made 

in writing. If an individual has already submitted documentation in connection with 

a previous request for accommodation based on the same disability, the individual 

should inform the Reasonable Accommodation Coordinator immediately. 

Once the deciding official requests additional information, the time for responding 

to the request pauses until the requester provides adequate documentation. The 

deciding official will evaluate temporary measures to assist the employee during 

any processing delay, including instituting an interim solution while awaiting 

reasonably requested medical information. 

The following are examples of the types of medical information that may be 

requested: 

• The past, present, and expected future nature, severity, and duration of the 

impairment (e.g., functional limitations, symptoms, side effects of any 

treatments, etc.)

• The activities that are limited by the impairment

• The extent of the limitations

• Why the reasonable accommodation is required

• How the reasonable accommodation will assist the requester to apply for a 

job, perform the essential functions of his or her job, or enjoy the benefits of 

the workplace

In determining whether documentation is necessary to support a request for 

reasonable accommodation and whether a requester has a disability within the 

meaning of the Rehabilitation Act, the deciding official will follow, in consultation 

with the Reasonable Accommodation Coordinator (and the Office of the General 

Counsel as needed), the principles set forth in the Americans with Disability Act 

(ADA) Amendments Act of 2008. The Reasonable Accommodation Coordinator will 

ensure that requests for medical documentation are not so broad as to include 

genetic information (to preclude a violation of the Genetic Information 

Nondiscrimination Act).

It is the responsibility of the requester to provide sufficient information to support 

his or her request. Depending on the request, the documentation does not 

necessarily have to come from a health care provider; medical information supplied 

by the requester may be sufficient to address the request. 

If the information submitted in response to the initial request for medical 

documentation does not clearly explain the nature of the disability or the need for 

reasonable accommodation, the Reasonable Accommodation Coordinator may 

request supplemental documentation. The Reasonable Accommodation Coordinator
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will explain to the requester why the initial documentation is insufficient and what

additional information is needed. The requester can provide the information, sign a 

limited release to allow the Reasonable Accommodation Coordinator to submit a list 

of specific questions to the requester’s health care provider, have a medical 

professional of the deciding official’s choosing contact the requester’s health care 

provider, or have the medical information reviewed by a health care provider of the 

deciding official’s choosing at the Commission’s expense. 

If the supplemental documentation does not result in sufficient information, the 

Reasonable Accommodation Coordinator may request the requester be examined by

a health care provider of the Reasonable Accommodation Coordinator’s choice at 

the Commission’s expense, and explain that failure to do so may result in a denial of 

the request. The Reasonable Accommodation Coordinator will consult with the 

Secretary and the Office of the General Counsel when requesting such an 

examination. 

2. Timelines

Except in cases of extenuating circumstances, the Commission will provide a 

resolution within 30 business days of the receipt of the request by an appropriate 

official. Implementation of the accommodation will commence within 15 business 

days from the date of the decision, and the deciding official will provide the 

requester with a schedule for implementation if it will require longer than 15 

business days to complete. The time begins to run when the accommodation is first 

requested.

When a particular reasonable accommodation can be provided in less time than the 

30 business days allowed, the failure to respond promptly to the request might 

result in a violation of the Rehabilitation Act. 

Extenuating circumstances are those that could not reasonably have been 

anticipated or avoided in advance of the request for accommodation, or that are 

beyond the Commission’s ability to control (such as backordered equipment, the 

vendor typically used for goods or services has unexpectedly gone out of business, new 

staff needs to be hired or contracted for, or an accommodation involves the removal of 

architectural barriers). When extenuating circumstances are present, the time for 

processing a request for reasonable accommodation and providing the 

accommodation will be extended as reasonably necessary. Extensions will be 

limited to circumstances where they are absolutely necessary and only for as long as 

required to deal with the extenuating circumstance. The requester will be notified of 

any extenuating circumstances and given a revised time frame for the resolution of 

his or her request. The deciding official will also confer with the requester and other 

necessary officials to consider providing temporary measures during any period 

where extenuating circumstances have resulted in delay. 
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This policy requires the use of expedited processing time for time-sensitive 

requests. The Commission will provide a resolution of an expedited request as 

quickly as possible, but not to exceed 5 business days. For example, if a request is 

made to enable an individual to apply for a job, or to enable an employee to attend a 

meeting scheduled to occur soon, the officials involved will make every possible 

effort to resolve the request in time to meet the deadline. 

As stated in Section III.B.1, when additional information is requested, the time for 

responding to the request pauses until the requester provides adequate 

documentation. The Commission is not expected to adhere to its usual timelines if a

requester’s health professional fails to provide needed documentation in a timely 

manner. 

3. Accommodation Resources

The Commission has attached the appendix from the EEOC Policy Guidance on 

Executive Order 13164: Establishing Procedures to Facilitate the Provision Of Reasonable 

Accommodation (Policy Guidance), EEOC No. 915.002 (October 20, 2000), which is a

non-exhaustive list of relevant resources which the requester and the approving official 

can consult to identify and evaluate possible accommodations (see Appendix C).

C. Granting a Request

A deciding official may offer an accommodation without making a disability 

determination. 

The deciding official will give a Resolution of Reasonable Accommodation Request (see 

Appendix B) to the requester and discuss implementation of the accommodation. If the 

request is approved but the accommodation cannot be provided immediately, the 

deciding official will inform the requester in writing of the projected time frame for 

providing the accommodation.

If the deciding official grants an accommodation other than the one specifically 

requested, the Resolution of Request (Resolution) will include the reasons for the denial 

of the requester’s specific requested accommodation and why the deciding official

believes the chosen accommodation will be effective. The deciding official will give a 

Resolution to the requester and discuss the reason(s) for granting an accommodation 

other than the one requested. 

The Resolution also provides information about the individual’s right to request 

reconsideration (discussed below), file an EEO complaint, or take other action. The 

Resolution also includes information about the availability of alternative dispute 

resolution (ADR).

The Resolution must be provided in an accessible format when requested. A copy of the 

Resolution is retained in the requester’s reasonable accommodation file.
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D.Denying a Request

The deciding official will give a Resolution to the requester and discuss the reason(s) 

for the denial. The Resolution must include specific reason(s) for the denial. The 

Resolution must include, and the deciding official must explain, specifically why the 

accommodation would result in undue hardship or why it would be ineffective.

The Resolution also provides information about the individual’s right to request 

reconsideration (discussed below) or file an EEO complaint. If a requester wishes to file 

an EEO complaint pursuant to 29 C.F.R. part 1614, he or she must contact an EEO 

counselor within 45 calendar days from the date of receipt of the written resolution or a 

verbal response (whichever comes first). Consult the Commission’s EEO policy for more 

details. 

The Resolution also includes information about the availability of Alternative Dispute 

Resolution (ADR) (see Section F below).

The right to file an EEO complaint will be lost pursuant to 29 C.F.R part 1614 unless the 

requester initiates contact within the 45 calendar day timeframe, regardless of whether 

the requester participates in ADR.

The Resolution must be provided in an accessible format when requested. A copy of the 

Resolution is retained in the requester’s reasonable accommodation file.

E. Request for Reconsideration

Upon receipt of a Resolution indicating a denial or grant of an accommodation other 

than the specific accommodation requested, the requester may make a written request 

for reconsideration to the Reasonable Accommodation Coordinator, including any new 

or additional information not previously considered, within 10 business days. If the 

Reasonable Accommodation Coordinator is the deciding official, the request for 

reconsideration will be submitted to the Secretary. 

The Reasonable Accommodation Coordinator or secretary will issue a written decision

granting or denying the request for reconsideration using the Resolution of Reasonable 

Accommodation Request form (see Appendix B) within 10 business days of receipt of 

the request. Before the Reasonable Accommodation Coordinator upholds a prior denial, 

such denial will be reviewed by the secretary or the chairman, in consultation with the 

Office of the General Counsel, prior to it being finalized.
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F. Alternative Dispute Resolution (ADR)

When a reconsideration request is denied, the use of ADR is strongly encouraged to 

reach a resolution. 

ADR is a method to settling workplace disputes before the disputes progress to formal 

EEO complaints, grievances, or legal procedures. ADR is voluntary and takes place in a 

neutral, non-threatening location. It is facilitated by trained, certified mediators or 

contractors. Both sides are given a chance to state their case and come to a mutually 

agreeable resolution. ADR sessions are confidential. 

Requests for ADR shall be made in writing to the Secretary who will initiate the ADR 

process. Although it is perfectly acceptable to identify a neutral third-party within the 

Commission to serve as a facilitator during ADR, the Commission may also contract 

with a neutral, outside party that can facilitate the ADR. 

The determination of whether to grant ADR in a particular case is within the discretion 

of the secretary, in consultation with the Office of the General Counsel. ADR may not be 

appropriate in some cases. 

IV. REASONABLE ACCOMMODATION FOR 

RELIGIOUS BELIEFS AND PRACTICES

Requests for accommodations must be made to an appropriate official and must include 

the need for the accommodation and indicate that it is being requested due to a conflict 

between religion and work. The appropriate official will notify the Reasonable 

Accommodation Coordinator of the request in writing (preferably via email). An 

employee’s supervisor, the deputy office head, or office head in the employee’s chain of 

command may grant a no-cost accommodation directly after notifying the Reasonable 

Accommodation Coordinator in writing that they intend to do so.

If the supervisor, the deputy office head, or office head in the employee’s chain of command 

is unsure whether a no-cost request should be granted or believe a no-cost request should 

be denied, the supervisor, the deputy office head, or office head in the employee’s chain of 

command should refer the request to the Reasonable Accommodation Coordinator. The 

Reasonable Accommodation Coordinator will work with the requester and the requester’s 

supervisor to evaluate the feasibility of the accommodation, and grant or deny the request.

If the Reasonable Accommodation Coordinator has a bona fide doubt about the basis for 

the request, he or she may make a limited inquiry into the facts and circumstances of the 

requester’s claim. Factors that will be considered in evaluating the sincerity of the belief at 

issue include, but are not limited to: 
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• Whether the requester has behaved in a manner markedly inconsistent with the 

professed belief

• Whether the accommodation sought is a particularly desirable benefit that is likely 

to be sought for secular reasons

• Whether the timing of the request renders it suspect (e.g., it follows an earlier 

request by the requester for the same benefit for secular reasons)

• Whether the Commission otherwise has reason to believe the accommodation is not 

sought for religious reasons

Accommodation requests shall be granted if the belief or practice is religious, sincerely 

held, and can be accommodated without more than a minimal cost or burden to the 

Commission. The Reasonable Accommodation Coordinator may grant an accommodation 

without making a religious determination. The Reasonable Accommodation Coordinator is 

required to consult with the Office of the General Counsel before denying a request. 

If the accommodation is denied or an alternate accommodation is offered, a requester may 

follow the procedure set forth in the Request for Reconsideration section above to request 

review of the decision. 

V. COMMISSION PROTOCOLS

A. Confidentiality

All information obtained in connection with the reasonable accommodation process 

(including any medical information, the fact that an accommodation has been requested 

or approved, and information about functional limitations) must be kept confidential. 

All information must be kept in a reasonable accommodation file separate from the 

individual’s personnel file, and any Commission employee who obtains or receives such 

information is strictly bound by confidentiality requirements.

Commission employees cannot share details of the disability with any other 

Commission employee, other than details necessary to provide the reasonable 

accommodation. The Reasonable Accommodation Coordinator may share these details 

with other deciding officials in conjunction with granting or denying the request. Office 

heads, managers, and other management officials do not have a right to details 

regarding the requester’s medical condition. Rather, management officials will be 

provided with the information necessary to make a reasonable accommodation 

decision.

In addition to disclosures of information needed to process a request for 

accommodation, or implement an accommodation, other disclosures of information are 

permitted as follows:

• First aid and safety personnel may be informed, when appropriate, if the 

disability might require emergency treatment or assistance in evacuation.
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• Government officials may be given information necessary to investigate the 

Commission’s compliance with the Rehabilitation Act.

B. Records Management

After a reasonable accommodation request is granted or denied, the Reasonable 

Accommodation Coordinator should log the information into the reasonable 

accommodation reporting system, which tracks the following information:

• Number of reasonable accommodations, by type, that have been requested and 

whether those requests have been granted or denied

• The name of the deciding official for each accommodation request

• Jobs (occupational series, grade level, and Commission office) for which 

reasonable accommodations have been requested

• Types of reasonable accommodations that have been requested for each of those 

jobs

• Number of reasonable accommodations, by type, that have been approved, and 

the number of accommodations, by type, that have been denied

• Number of requests for reasonable accommodation, by type, that relate to the 

benefits or privileges of employment, and whether those requests have been 

granted or denied

• Reasons for denial of requests for reasonable accommodation

• Amount of time taken to process each request for reasonable accommodation

• Sources of technical assistance that have been consulted in trying to identify 

possible reasonable accommodations

Records related to a particular requester will be maintained in a separate reasonable 

accommodation file for the duration of the requester’s tenure at the Commission. Other 

records, including records in the reasonable accommodation reporting system, will be 

maintained in accordance with the Commission’s records policy. 

The Reasonable Accommodation Coordinator will annually analyze the information 

collected to measure the performance of the reasonable accommodation program, 

determine areas that require further training or revisions to the procedures, and 

measure and provide information on the efficiency and effectiveness of the policy.

The Commission will retain the information used to track the Commission’s 

performance with regard to reasonable accommodation for at least 3 years and will be 

able to provide said information to the Equal Employment Opportunity Commission 

upon request. 
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VI. REFERENCES

• Americans with Disabilities Act of 1990

• Executive Order 13164

• Genetic Information Nondiscrimination Act of 2008

• The Americans with Disabilities Amendments Act of 2008

• The Rehabilitation Act of 1973

• Title VII of the Civil Rights Act of 1964

• Policy Guidance on Executive Order 13164: Establishing Procedures to Facilitate the 

Provision Of Reasonable Accommodation (Policy Guidance), EEOC No. 915.002 

(October 20, 2000)

• Equal Employment Opportunity Commission, Office of Federal Operations, Practical 

Advice for Drafting and Implementing Reasonable Accommodation Procedures 

Under Executive Order 13164

• Equal Employment Opportunity Commission, Reasonable Accommodation policy 

tips for small businesses, www.eeoc.gov

• Equal Employment Opportunity Commission Enforcement Guidance: DisabilityRelated Inquiries and Medical Examinations of Employees Under the Americans 

With Disabilities Act (July 27, 2000)

• Equal Employment Opportunity Commission Enforcement Guidance on Reasonable 

Accommodation and Undue Hardship Under the Americans With Disabilities Act 

(revised October 17, 2002)

VII. APPENDICES

Appendix A: Confirmation of Request for Reasonable 

Accommodation (Template)

Appendix B: Resolution of Reasonable Accommodation 

Request (Template)

Appendix C: Reasonable Accommodation Resource List

Appendix D: Personal Assistance Services Procedures
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Appendix A: Confirmation of Request for Reasonable 

Accommodation (Template)

The receiving appropriate official will use this email template to confirm receipt of a 

reasonable accommodation request (either oral or written).

TO: Requester

CC: Reasonable Accommodation Coordinator

DATE: [Insert Date Here]

DATE OF REQUEST: [Insert Date Request Received Here]

SUBJECT: Confirmation of Request for Reasonable Accommodation

1. Accommodation requested [Insert information about the request. Be as specific as 

possible, e.g,. adaptive equipment, change in schedule.]

2. Reason for request

3. Is the request time-sensitive? If so, please explain.

4. Contact name, telephone number, and email address

The Reasonable Accommodation Coordinator will contact you within 2 business days to 

provide a tracking number for your request, and inform you who the deciding official for 

your request will be. 
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Appendix B: Resolution of Reasonable Accommodation 

Request (Template)

The deciding official will use this email template to provide the decision resolving the 

reasonable accommodation request. If the deciding official is not the Reasonable 

Accommodation Coordinator, the deciding official must send a copy to the Reasonable 

Accommodation Coordinator for recordkeeping purposes.

TO: Requester [Insert name of individual requesting reasonable accommodation]

FROM: Deciding Official [Insert name of deciding official]

DATE: [Insert date here]

DATE OF REQUEST: [Insert date request received here]

TRACKING NUMBER: [Insert tracking number of request here]

SUBJECT: Resolution of Reasonable Accommodation Request

1. Accommodation(s) requested:

2. Accommodation(s) is (indicate resolution):

o Approved as specifically requested

o Approved but different from original request*

o Denied

*If the approved accommodation is different from the one(s) originally 

requested, identify the alternative accommodation(s):

a. If an alternative accommodation was offered, indicate whether it was:

_____ Accepted

_____ Rejected

b. Request denied because: (may indicate more than one reason)

o Requester does not have a disability as defined under the Rehabilitation 

Act

o Accommodation ineffective

o Accommodation would cause undue hardship

o Medical documentation inadequate

o Accommodation would require removal of essential function

o Other (Please identify) ___________________________________

c. Detailed reason(s) for denial (Must be specific, e.g., why accommodation 

would be ineffective or cause undue hardship):

d. If the deciding official offered an accommodation that is different from the 

one originally requested, explain: (1) the reasons for offering a different 

accommodation than the accommodation originally requested; and (2) why 

the alternative accommodation would be effective.

You have the right to ask for reconsideration of this decision by submitting a written 

request within 10 business days to the Reasonable Accommodation Coordinator to 

reconsider the denial. Please include any new or additional relevant information that was 

not previously considered with regard to this request. Before the Reasonable 

Accommodation Coordinator upholds the initial denial, such a denial will be reviewed by a 

second-level reviewer (either the secretary or the chairman) prior to it being finalized. 
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If you are dissatisfied with the reconsideration, the following options might be 

available to you:

Alternative Dispute Resolution may be available. Requests for ADR shall be made in writing 

to the secretary who will determine if ADR is appropriate and initiate the ADR process or 

inform you that ADR is not available.

If you wish to file an EEO complaint pursuant to 29 C.F.R. part 1614, contact an EEO 

counselor within 45 calendar days from the date of receipt of the written resolution or a 

verbal response (whichever comes first). Consult the Commission’s EEO policy for more 

details. 

For adverse actions over which the Merit Systems Protection Board has jurisdiction, you 

may initiate an appeal to the MSPB within 30 calendar days of an appealable adverse 

action as defined in 5 C.F.R. part 1201.3.
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Appendix C: Selected Reasonable Accommodation Resources

• U.S. Equal Employment Opportunity Commission

1-800-669-3362 (Voice) 1-800-800-3302 (TT)

https://www.eeoc.gov/

The EEOC's Publication Center has many free documents on the Title I employment 

provisions of the ADA, including both the statute, 42 U.S.C. § 12101 et seq., and the 

regulations, 29 C.F.R. § 1630. In addition, the EEOC has published a great deal of 

basic information about reasonable accommodation and undue hardship. The three 

main sources of interpretive information are: (1) the Interpretive Guidance 

accompanying the Title I regulations (also known as the "Appendix" to the 

regulations), 29 C.F.R. pt. 1630 app. §§ 1630.2(o), (p), 1630.9; (2) Enforcement 

Guidance on Reasonable Accommodation and Undue Hardship Under the Americans 

with Disabilities Act, 8 FEP Manual 405:7601 (1999); and (3) A Technical Assistance 

Manual on the Employment Provisions (Title I) of the Americans with Disabilities Act, 

8 FEP Manual (BNA) 405:6981, 6998-7018 (1992) (Technical Assistance Manual). 

The Technical Assistance Manual includes a 200-page Resource Directory, including 

federal and state agencies, and disability organizations that can provide assistance 

in identifying and locating reasonable accommodations.

The EEOC also has discussed issues involving reasonable accommodation in the 

following guidances and documents: (1) Enforcement Guidance: Preemployment 

Disability-Related Questions and Medical Examinations at 5, 6-8, 20, 21-22, 8 FEP 

Manual (BNA) 405:7191, 7192-94, 7201 (1995); (2) Enforcement Guidance: 

Workers' Compensation and the ADA at 15-20, 8 FEP Manual (BNA) 405:7391, 7398-

7401 (1996); (3) Enforcement Guidance: The Americans with Disabilities Act and 

Psychiatric Disabilities at 19-28, 8 FEP Manual (BNA) 405:7461, 7470-76 (1997); 

(4) Fact Sheet on the Family and Medical Leave Act, the Americans with Disabilities 

Act, and Title VII of the Civil Rights Act of 1964 at 6-9, 8 FEP Manual (BNA) 405:7371, 

7374-76 (1996); and (5) Enforcement Guidance: Disability-Related Inquiries and 

Medical Examinations of Employees Under the Americans with Disabilities Act at 20, 

22, 23, 24-5, 8 FEP Manual (BNA) 405:7701, 7711, 7712-14, 7715-16 (2000).

Finally, the EEOC has a poster that employers and labor unions may use to fulfill the 

ADA's posting requirement.

All of the above-listed documents, with the exception of the Technical Assistance 

Manual and the poster, are also available through the Internet at www.eeoc.gov. All 

of these documents provide guidance that applies to federal agencies through the 

Rehabilitation Act of 1973, 29 U.S.C. § 791.

• Job Accommodation Network (JAN)

1-800-232-9675 (Voice/TT)

http://janweb.icdi.wvu.edu/
18

A service of the President's Committee on Employment of People with Disabilities. 

JAN can provide information, free-of-charge, about many types of reasonable 

accommodations.

ADA Disability and Business Technical Assistance Centers (DBTACs)

1-800-949-4232 (Voice/TT)

The DBTACs consist of 10 federally funded regional centers that provide 

information, training, and technical assistance on the ADA. Each center works with 

local business, disability, governmental, rehabilitation, and other professional 

networks to provide current ADA information and assistance, and places special 

emphasis on meeting the needs of small businesses. The DBTACs can make referrals 

to local sources of expertise in reasonable accommodations.

• Registry of Interpreters for the Deaf

(301) 608-0050 (Voice/TT)

http://www.rid.org/

The Registry offers information on locating and using interpreters and 

transliteration services.

• RESNA Technical Assistance Project

(703) 524-6686 (Voice) (703) 524-6639 (TT)

http://www.resna.org/

RESNA, the Rehabilitation Engineering and Assistive Technology Society of North 

America, can refer individuals to projects in all 50 states and the 6 territories 

offering technical assistance on technology-related services for individuals with 

disabilities. Services may include:

o Information and referral centers to help determine what devices may assist a 

person with a disability (including access to large data bases containing 

information on thousands of commercially available assistive technology 

products)

o Centers where individuals can try out devices and equipment

o Assistance in obtaining funding for and repairing devices

o Equipment exchange and recycling programs
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Appendix D: Personal Assistance Services Procedures

The purpose of this document is to establish the Postal Regulatory Commission 

(Commission) procedures on handling requests for Personal Assistance Services (PAS) in 

accordance with 29 C.F.R. §1614.203(d)(5) and the Rehabilitation Act of 1973.

On January 3, 2017, the Equal Employment Opportunity Commission (EEOC) amended the

regulations implementing Section 501 of the Rehabilitation Act of 1973; the law prohibits

the federal government from discriminating in employment on the basis of disability and 

requires it to engage in affirmative action for people with disabilities. This amendment

requires federal agencies to provide Personal Assistance Services (PAS) to individuals who

need them because of certain disabilities. 

The final rule requires Federal agencies to provide "personal assistance services" (PAS) as

a form of affirmative action. PAS provide employees with targeted disabilities "assistance 

with performing activities of daily living that an individual would typically perform if they 

did not have a disability, and that is not otherwise required as a reasonable 

accommodation, including, for example, assistance with removing and putting on clothing, 

eating, and using the restroom." PAS must be performed by a personal assistance service 

provider. In addition, PAS must be provided to employees who need them when they 

telework under an agency's telework policy or telework as a reasonable accommodation or 

when needed because of job-related travel. An employee receiving PAS in the office or 

while teleworking must still request PAS for job-related travel as the Commission will not 

necessarily know that PAS is required for travel simply because an employee regularly 

receives PAS while at the worksite or while teleworking. It is also possible that an 

employee may require different PAS for travel than usually required. Since PAS for jobrelated travel are also considered a form of reasonable accommodation, requests for these 

services will be handled as requests for reasonable accommodation.

Employees do not need to determine if what they need is a reasonable accommodation or 

PAS; they should simply contact their supervisor or HR and explain what they need. HR will 

determine whether the request is for reasonable accommodation or PAS and proceed 

accordingly.

The Commission must provide PAS if an employee requires them because of a "targeted 

disability", and provision of these services would, together with any reasonable 

accommodations required, enable an employee to perform the essential functions of a 

position the individual holds or desires, and provision of such services would not impose 

an undue hardship on the Commission. The Commission is prohibited from taking any 

adverse action against job applicants or employees based on their need, or perceived need, 

for PAS. 

The Commission has designated HR to conduct the interactive process, request medical 

information as necessary, and determine whether to grant or deny PAS. HR handles all 

requests for PAS, even those requests made to a supervisor or manager.
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REQUESTING PERSONAL ASSISTANCE SERVICES

Requesting PAS is similar to requesting a reasonable accommodation. An individual may 

request PAS by informing their supervisor or Human Resources (HR) that he or she needs 

assistance with daily life activities because of a medical condition. The individual does not 

need to mention Section 501 or the EEOC’s regulations explicitly, or use terms such as

“PAS” or “affirmative action” to trigger the agency’s obligation to consider the request.

HR oversees the Commission’s PAS program. HR will process requests for PAS in a prompt

and efficient manner in accordance with the time frames set forth in these procedures. If a 

request is given to a supervisor rather than directly to HR, the supervisor should forward 

the request to HR (HR@prc.gov) within two business days.

HR will contact the employee within 10 business days after the request is made (even if the 

request is initially made to someone else) to begin discussing the PAS request. HR will ask 

the employee what types of PAS he or she needs using the same type of informal, 

interactive process used for reasonable accommodation (see Reasonable Accommodation 

Policy). 

Communication is a priority throughout the entire process, but particularly where the 

specific limitation, problem, or barrier is unclear. Both the requestor and the decision 

maker should work together to identify effective PAS.

HR will complete processing of the request within 30 business days, absent extenuating 

circumstances, after the request was first received by either HR or another designated 

individual. Completion of processing includes provision of PAS, if granted. The 30-day 

period may be extended if medical documentation is requested and/or if there are 

"extenuating circumstances." "Expedited processing" may sometimes be required.

APPROVAL OF PERSONAL ASSISTANCE SERVICES

If a request for PAS is granted, HR will provide the requestor with a written explanation of 

the PAS to be provided, and discuss implementation of the PAS. If the request is approved 

but the PAS cannot be provided immediately, HR will inform the individual in writing of the 

projected time frame for providing the service(s).

DENIAL OF PERSONAL ASSISTANCE SERVICES

If a request for PAS is denied, HR will provide the requestor with a written explanation of 

the reason(s) for the denial, to include why the PAS would result in an undue hardship.
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SELECTING A PAS PROVIDER

The Commission may use federal employees, independent contractors, or a combination of 

employees and contractors to perform personal assistance services. If the Commission is 

hiring a PAS provider who will be assigned to a single individual, and if that individual 

prefers a particular provider, then the Commission will give primary consideration to the 

employee’s choice to the extent permitted by law. However, it may not be possible to honor 

the individual’s preference in all cases.

INQUIRIES

Managers, employees or applicants wanting further information concerning these 

procedures may contact HR via e-mail at HR@prc.gov.