Reasonable 

Accommodations 

NATIONAL COUNCIL ON DISABILITY

REASONABLE ACCOMMODATION POLICY 

PROCESSING REQUESTS FOR REASONABLE ACCOMMODATION 

1. PURPOSE. To establish policies and procedures for the processing of 

requests for reasonable accommodation at the National Council on Disability 

(NCD). 

2. SCOPE. The provisions of this Order apply to all NCD employees and 

applicants with disabilities. 

3. AUTHORITY. 

a. Executive Order 13164, July 26, 2000. 

b. Title I of the Americans with Disabilities Act of 1990, 42 U.S.C. 12101-12117. 

c. Rehabilitation Act of 1973, 29 U.S.C. 701 et reg. 

d. Equal Employment Opportunity Commission (EEOC) Policy Guidance on 

Executive Order 13164: Establishing Procedures to Facilitate the Provision of 

Reasonable Accommodation, October 20, 2000. 

e. Federal Sector Equal Employment Opportunity, 29 C.F.R. § 1614, November 

9, 1999. 

4. DEFINITIONS. 
Qualified Individual with a Disability. An individual with a disability is qualified 

if (1) he/she satisfies the requisite skill, experience, education and other jobrelated requirements of the position; and (2) he/she can perform the essential 

functions of the position, with or without reasonable accommodation. 

Reasonable Accommodation. Any change in the work environment or in the 

way things are customarily done that would enable a qualified individual with a 

disability to enjoy equal employment opportunities. 

Undue Hardship. If a specific type of reasonable accommodation causes 

significant difficulty or expense, then the agency does not have to provide that 

particular accommodation. Determination of undue hardship must be made on 

case-by-case basis, considering factors such as the nature and cost of the 

reasonable accommodation needed and the impact of the reasonable 

accommodation on the operations of the agency. 

d. Essential Functions. Those job duties that are so fundamental to the position 

that the individual cannot do the job without performing them. A function can be 

"essential" if, among other things, the position exists specifically to perform that 

function; there are a limited number of other employees who could perform the 

function; or the function is specialized and the individual is hired based on ability 

to perform. Determination of the essential functions of a position must be done 

on a case-by-case basis so that it reflects the job as actually performed. 

e. Extenuating Circumstances. Extenuating circumstances are factors that 

could not reasonably have been anticipated or avoided in advance of the request 

for the accommodation. When there is a delay in processing a request for, or 

delivering, a reasonable accommodation, the agency must investigate whether 

there are temporary measures that could be taken to assist the individual with a 

disability. 

5. POLICY. It is the policy of the NCD to ensure requests for reasonable 

accommodation are handled in an effective and expeditious manner. It is the 

obligation of NCD to provide reasonable accommodation to qualified employees 

and applicants with disabilities, unless to do so would cause undue hardship to 

NCD. Within this framework, NCD has the following objectives: 

a. To enable the individual employee to perform the essential functions of the 

position, or to gain access to the workplace. 

b. To enable an applicant with a disability to have an equal opportunity to 

participate in the application process and to be considered for a job. 

c. To allow an employee with a disability an opportunity to enjoy equal benefits 

and privileges of employment as are enjoyed by other similarly situated 

employees without disabilities. 
ASSIGNMENT OF RESPONSIBILITIES. 

Executive Director. The Executive Director, or designated official, shall: 

Ensure a continuing affirmative application and vigorous enforcement of the 

policy and procedures contained in this order. 

Provide sufficient resources for program implementation to ensure efficient and 

successful processing of requests for reasonable accommodation. 

Recognize and reward individuals who have demonstrated superior efforts in 

supporting the spirit of the law. 

Manage requests for reasonable accommodation and, where appropriate, 

determine which management officials will handle the request. Provide 

reasonable accommodation in a prompt, fair and efficient manner. 

Maintain the records related to an employee's request for accommodation in 

accordance with the Federal records disposition schedule. Ensure that medical 

records are kept confidential and maintained in files separate from the 

individual's official personnel file. 

Prepare annually a summary statistical report. 

Request relevant supplemental medical information if documentation 

submitted does not clearly explain the nature of the disability, reason for 

reasonable accommodation, or does not clarity how the requested 

accommodation will assist the applicant/employee to perform the essential 

function of the job. 

Provide orientation, training, and advice to managers and supervisors regarding 

the implementation of the policies and procedures in this order. 

Determine appropriate actions and coordinate with appropriate office directors 

and decision-makers involved ensuring timely completion of individual requests. 

Recommend alternatives to address specific requests. 

NCD Serving Personnel Office(GSA, Agency Liaison Division) 

The personnel specialist shall: 

Process requests for reasonable accommodation from applicants during the 

recruitment and application process, as needed. 

Make vacancy announcements available to applicants/employees with 

disabilities. 
Ensure that all vacancy announcements include a statement of reasonable 

accommodation, to ensure compliance with Executive Order 13078. Support the 

Office of Personnel Management initiatives to increase the representation of 

people with disabilities in the federal workforce. 

Assist the Executive Director with reassignments if reassignment is deemed as a 

reasonable accommodation in accordance with EEO regulations and laws. 

Employees and Applicants. An employee or applicant shall: 

Initiate a request for reasonable accommodation orally or in writing in accordance 

with procedures listed below. 

Provide sufficient information and documentation, such as a description of the 

accommodation requested, and an explanation of how it would enable an 

employee to perform the job or assist an applicant in the selection process. 

When required, provide relevant medical information related to the functional 

impairment and the requested accommodation when the disability and/or need 

for accommodation is not obvious. 

PROCEDURES

An employee or applicant with a disability, family member, health professional or 

other representative who is acting on behalf of the employee/applicant may 

initiate a request for reasonable accommodation orally or in writing. An 

individual's oral request will start the reasonable accommodation process. 

However, for record keeping purposes, the requestor shall complete the form at 

Appendix A. 

The request begins when the individual makes that request to Executive Director 

or, in connection with the application process. 

After receiving a request, the Executive Director will take a proactive approach in 

searching out and considering possible accommodations, including consulting 

appropriate resources for assistance. Suggested resources, which are available 

to help both management officials and the requestor to identify possible 

accommodations, are listed at Appendix D. Unless there are extenuating 

circumstances, within 20 business days from the date the request was initially 

made to the management official the accommodation should be provided. In 

certain circumstances, time limits for processing requests for and providing 

reasonable accommodations should be expedited or as short as reasonably 

possible, and should not wait for the full 20 days. Expedited processing might be 

necessary where, for instance, the reasonable accommodation is needed to 

enable an individual to apply for a job; or the reasonable accommodation is 

needed for a specific activity that is scheduled to occur shortly. 
If medical documentation is necessary, the Executive Director will prepare the 

request for medical documentation with input from the requestor, in accordance 

with EEOC policy guidance on Executive Order 13164. 

If there are extenuating circumstances that will in either processing a request for, 

or delivering a reasonable accommodation, the Executive Director must notify the 

requestor promptly and keep the employee informed of the approximate date on 

which the agency may complete the process or issue a decision. The Executive 

Director will investigate the possibility of temporary measures that could be taken 

to assist the requestor. Any changes or developments should be communicated 

promptly to the requestor. 

Upon the granting/denial of the request for reasonable accommodation, the 

Executive Director will complete the "Reasonable Accommodation Information 

Report" (Appendix B) and maintain it for future reporting. 

When the decision-maker denies the request, the requestor will be informed in 

writing of the denial (See Appendix C), and explain the reasons of denial and 

procedures for reconsideration. The denial notice will clearly specify reasons for 

the denial: for example, why the medical documentation is inadequate to 

establish that the individual has a disability or needs reasonable accommodation; 

why the requested accommodation would not be effective; or why the 

accommodation would pose an undue hardship to the agency. The Executive 

Director will notify the requestor that he/she has a right to file an EEO complaint, 

and may have rights to pursue MSPB appeal. 

a. For an EEO complaint, pursuant to 29 CFR § 1614, contact an EEO 

counselor through Agency Liaison Division within 45 days from the date of 

the notice of denial of reasonable accommodation; or 

b. Initiate an appeal to the Merit Systems Protection Board within 30 days of 

an appealable adverse action, as defined in 5 CFR § 1201.3. 

Within five business days upon receipt of the denial notice, the requestor wishes 

to request reconsideration of this decision may submit the request to the 

Chairperson or Executive Director to reconsider his/her denial. New evidence 

and sound justification should be presented to support this request. The 

Chairperson/Executive Director will issue a decision on reconsideration within 10 

business days after receipt of the individual's request for reconsideration. 

Pursuing reconsideration and any informal dispute resolution procedures does 

not toll the time limits for initiating statutory claims. 

c. Any applicant or employee for employment who believes he/she has been 

discriminated against on the basis of race, sex, color, religion, national 

origin, age, mental or physical disabilities, and/or reprisal in an 

employment matter, must contact an EEO counselor within 45 calendar 
days of the date of the matter to be discriminatory or, in the case of 

personnel action, within 45 days of the effective date of the action. The 

aggrieved person will be offered EEO counseling or an opportunity to 

participate in the NCD Alternate Dispute Resolution (ADR) Program. 

ADDITIONAL GUIDELINES.

a. Request for Reassignment. 

Reassignment will only be considered if no accommodations are available to 

enable the employee to perform his or her current job, or if the only effective 

accommodation would cause undue hardship. 

In considering whether there are positions available for reassignment, the 

Executive Director will work with both the Agency Liaison Division staff and the 

employee requesting the accommodation to identify possible vacant positions. 

The Agency Liaison Division staff is responsible for conducting the search for a 

reassignment, and will focus on positions which are equivalent to the employee's 

current job in terms of pay, status, grade level, and other relevant factors. If there 

is no vacant equivalent position, the agency will consider vacant lower level 

positions for which the employee with a disability is qualified. 

Reasonable accommodation may be made to a vacant position outside of the 

employee's commuting area if the employee is willing to relocate. As with other 

transfers not required by management, NCD will not pay for the employer's 

relocation costs. 

b. Medical Information. 

The Executive Director has a right to request relevant supplemental medical 

information if the information submitted does not clearly explain the nature of the 

disability, or the need for the reasonable accommodation, or does not otherwise 

clarify how the requested accommodation will assist the employee to perform the 

essential functions of the job or to enjoy the benefits and privileges of the 

workplace, or, in the case of an applicant, assist him or her with the application 

process. The Executive Director has a right to have medical information reviewed 

by a medical expert of the NCD's choosing at the agency's expense. 

If the Executive Director believes that medical information is necessary in order 

to evaluate a request for reasonable accommodation, he/she will make a request 

to the requestor of the reasonable accommodation to obtain such information. 

Where medical documentation provided by an employee requesting 

accommodation is insufficient, the Executive Director will explain to the employee 

why the documentation is insufficient and to identify the information still needed. 

The agency's request for medical information will follow the requirements set 

forth in the EEOC's Enforcement Guidance: Disability-Related Inquiries and 
Medical Examinations of Employees under the Americans with Disabilities Act 

(available on EEOC's internet sites. 

If, after a reasonable period of time, there is still not sufficient information to 

demonstrate that the individual has a disability and needs a reasonable 

accommodation, the Executive Director may request that the individual 

requesting accommodation be examined by a physician selected by the agency. 

c. Information Tracking. 

The Executive Director ensure that medical records are kept confidential, 

meaning maintained in files separate from the employee's official personnel file, 

and to whom and under what circumstances medical information may be 

disclosed, subject to the exceptions listed in the EEOC regulations. 

The Executive Director maintains the records related to an employee who has 

requested accommodation for the duration of the employee's tenure with agency. 

The agency will also retain for at least three years, and be able to provide to the 

EEOC, information or any cumulative records used to track the agency's 

performance with regard to reasonable accommodation. 

EFFECTIVE DATE. This policy will become effective upon approval of the 

National Council on Disability. 

 

APPENDIX A - Request for Reasonable Accommodation 

APPENDIX B - Reasonable Accommodation Information Report 

APPENDIX C - Denial of Reasonable Accommodation Request 

APPENDIX D - Recruitment Resources 

Appendix A 

 REQUEST FOR 

REASONABLE ACCOMMODATION 

Date of Request: 

1. Name of Employee/Applicant: 

___________________________________________ 

2. Telephone no. ____________________________ 

3. Office/Organization: 

___________________________________________________ 
4. ACCOMMODATION REQUESTED. Please be as specific as possible 

(e.g., adaptive equipment, reader, interpreter.) 

5. REASON FOR REQUEST. (If accommodation is time-sensitive, please 

explain.) 

________________________________________________________________

________ 

Signature Date 

________________________________________________________________

________ 

Name of Management Official/Supervisor, Signature Date 

RETURN FORM 

Case No.:_________ Signature:______________________ 

Date:_____________ 

All requests for accommodation will be handled in a prompt and expeditious 

manner. All records of reasonable accommodation must be kept confidential. 

Appendix B 

 REASONABLE ACCOMMODATION INFORMATION REPORT 

Name of Employee/Applicant: 

Position Title: 

Office: 
Telephone: 

1. Date of Request: 

2. Reasonable accommodation needed for (check one): 

( ) Application Process 

( ) Performing job functions or accessing the work environment 

( ) Accessing a benefit or privilege of employment (e.g., attending a training 

program or special event) 

3. Types of reasonable accommodation requested (e.g., adaptive equipment, 

staff assistant, removal of architectural barrier). 

4. Types of reasonable accommodation provided (if different from what was 

requested). 

5. Reasonable accommodation (check one) 

 Approved _________________Date 

 Denied _________________Date 

(If denied, attach copy of the written denial letter/memo) 

6. Date reasonable accommodation provided; 

7. If time limits outlined in the reasonable accommodation procedures were not 

met, please explain why. 
8. Explain the medical information and documents required to process this 

request, if applicable. 

9. Sources of technical assistance, if any, consulted in trying to identify possible 

reasonable accommodations (e.g., Job Accommodation Network, Disability 

Program Manager, and Disability Organization). 

Comments: 

Submitted by: _______________________ Telephone 

No.:_________________ 

ATTACH COPIES OF ALL DOCUMENTS OBTAINED OR DEVELOPED IN 

PROCESSING THIS REQUEST 
Appendix C 

DENIAL OF REASONABLE ACCOMMODATION REQUEST 

(Must complete items 1-4) 

To: (Name of the requestor) 

Type(s) of reasonable accommodation requested: 

Request for reasonable accommodation denied because (may check more than 

one box): 

Accommodation ineffective 

Accommodation would cause undue hardship 

Medical documentation inadequate 

Accommodation would require removal of an essential function Accommodation 

would require lowering of performance or production standard 

Other (please identify) ____________________________ 

Detailed reason(s) for the denial of reasonable accommodation (must be specific, 

e.g., why accommodation is ineffective or causes undue hardship): 

If the requester proposed one type of reasonable accommodation which is being 

denied, but rejected an offer of a different type of reasonable accommodation, 

explain both the reasons for denial of the requested accommodation and why 

you believe the chosen accommodation would be effective. 

If an individual wishes to request reconsideration of this decision, he/she may 

take the following steps: 

First, ask the decision maker to reconsider his/her denial. Additional information 

may be presented to support this request. 
If the decision maker does not reverse the denial and the decision maker was the 

Executive Director; the individual can ask the Chairperson to do so. 

If an individual wishes to file an EEO complaint, or pursue MSPB grievance 

procedures, he /she must take the following steps: 

For an EEO complaint, pursuant to 29 CFR § 1614, contact an EEO counselor 

through Agency Liaison Division within 45 days from the date of the notice of 

denial of reasonable accommodation; or 

For a collective bargaining claim, file a written grievance in accordance with the 

provisions of the agency's collective bargaining agreement; or 

Initiate an appeal to the Merit Systems Protection Board within 30 days of an 

appealable adverse action, as defined in 5 CFR § 1201.3. 

Name and Signature of Deciding Official: 

____________________________________ 

Date: _____________________ 

Appendix D 

SELECTED RESOURCES FOR 

LOCATING REASONABLE ACCOMMODATIONS 

1. U.S. Equal Employment Opportunity Commission 

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

www.eeoc.gov/ 

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 1520, 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 Sheer on the Family and 

Medical Leave Act the Americans with Disabilities Act. and Title VII of the Civil 

Rights Act of 1964 at 6-99 8 FEP Manual (BNA) 405-7371, 7374-76 (1996), and 

(5) Enforcement Guidance Disability-Relayed 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). 

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

Manual, 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. 

2. Job Accommodation Network (JAN) 

1-800-232-9675 (Voice) 

www.janweb.icdi.wvu.edu

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

accommodations. 

3. 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. 

4. Registry of Interpreters for the Deaf 

(301) 608-0050 (Voice/IT) 

www.rid.org

The Registry offers information on locating and using interpreters and 

transliteration services. 

5. RESNA Technical Assistance Project 

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

territories offering technical assistance on technology-related services for 

individuals with disabilities. 

6. U.S. Department Of Labor, Employment Policy Programs Employment 

Assistance Referral Network (EARN) 

866-EarnNow (866-327-6669) 

Monday through Friday 9.00 am to 10:00 PM, EST 

www.earnworks.com 

Computer/Electronic Accommodations Program (CAP) 

5111 Leesburg Pike, Suite 810 

Falls Church, VA 22041 

703-681-3976 

www.tricare.osd.mil/cap/ 

CAP provides assistive technology accommodations and services to persons 

with disabilities at the Department of Defense (DOD) and other Federal agencies 

at no cost to the requesting organization. CAP provides accommodations for 

individuals with hearing, visual, dexterity, cognitive and communication 

disabilities. CAP has been granted the authority to provide assistive technology, 

devices, and services to any department or agency in the Federal Government 

upon the request of the head of the agency. 

Sign Interpreter Associates, Inc. 

301-946-9710 

www.signlanguage.com 

Materials and Information 

Making Materials and Information Available and Accessible to Individuals 

with Disabilities 

This policy is being established to clarify the obligations of the National Council 

on Disability (NCD) regarding Section 504 of the Rehabilitation Act of 1973, as 

amended, to make its materials accessible and available to individuals with 

disabilities. 

 It will also set forth possible strategies to assist in implementing this policy. 
NCD hopes that this information will aid staff at all levels in the planning and 

production of materials in alternative formats for persons with sensory 

impairments, whenever necessary. 

This document is intended to cover anyone who might benefit from the activities 

of the NCD, whether as: 

• An employee, 

• An individual communicating with the agency or participating in NCD 

activities, 

• Or anyone benefiting in some other way from the agency’s activities. 

Background 

Section 504 of the Rehabilitation Act of 1973, as amended, and its implementing 

regulations, at 34 CFR Part 105, prohibit Federal agencies from denying persons 

with disabilities access to or the benefits of programs and activities, on the basis 

of their disability. 

Under these regulations, NCD is to provide material to individuals with disabilities 

in an accessible format if the material would ordinarily be made available to other 

individuals in printed or audiovisual forms, unless the NCD can demonstrate that 

doing so would constitute a fundamental alteration in the agency's program, or 

would require the agency to undertake undue financial and administrative 

burdens. 

34 C.F.R. 105.20 and 105.40. 

 

Policy-Materials and Information 

Policy Statement 

The National Council on Disability (NCD) will make all of its printed and 

audiovisual materials available to individuals with disabilities in a format that will 

enable them to have equal access to the information. 

These individuals include, but are not limited to: employees, applicants, program 

participants, personnel of other Federal entities and members of the public who 

have disabilities. 
Public Information 

All documents issued by NCD will be available in alternative formats, unless this 

process would result in a fundamental alteration in the nature of a program or 

activity or in undue financial and administrative burdens. 

Subject to these limitations, the agency will provide these materials in the format 

most usable to the requestor, which can include Braille, audio cassette, largeprint, reader assistance, or electronic file on computer disk. 

The agency will take steps to ensure that, if possible, there is no lag time 

between the issuance of the standard printed version of a document and its 

accessible version. The choice of format will vary with the material in question, 

and will be decided upon by NCD at the time publications are planned for 

release. 

All materials published by NCD will prominently display a notice that the material 

is available in alternative formats, which may include Braille, large-print, reader 

assistance, or electronic file on computer disk. 

In addition, NCD shall take steps to provide information to the general public 

about the availability of documents in accessible formats, and to provide such 

information at display booths and on publication request forms. 

Audiovisual Presentations 

All films and videos produced and shown by NCD will be opened-captioned. In 

addition to open captioning, closed captioning will be possible in certain 

circumstances. All attempts will be made to have films and videos captioned. 

However, as a last result, an interpreter will be present when needed at the 

showing to members/staff of any film or video that is not captioned. 

Strategy 1 

Discussion 

In seeking to implement this assessable materials policy, NCD must adopt 

strategies that will ensure continued compliance through the effective allocation 

of staff, funds, and other resources that may need to be available for this 

purpose. 

The following are possible strategies that will help to ensure that NCD 

information will be available to individuals with disabilities in accessible formats. 
These strategies are in no way all inclusive, but they will help to establish the 

resources that would be available to produce materials in accordance with the 

above policy. 

In addition, these strategies will help ensure that there is an administrative 

structure available through which funds can be allocated to meet accessibility 

needs, and also to ensure that no undue burden is created for any entity. The 

concept of undue burden not only makes common sense, but satisfies the legal 

standard. 

Strategy #1 

NCD will designate a person with responsibility to oversee the implementation of 

this and other disability-related policies. 

This individual will work to establish a smooth mechanism for the production and 

distribution of materials in alternative formats. 

This individual will be available to provide technical assistance on accessibility 

and related issues, as necessary. 

This person has the responsibility to provide the Executive Director with a copy of 

the public document sufficiently in advance of distribution to allow preparation in 

accessible formats. 

These time lines will be determined by the Executive Director and by internal 

deadlines if the alternative format is produced internally or by production time 

lines contractually specified between NCD and producers of alternative-format 

documents. 

Thus, if it takes a production facility ten days to produce alternate versions of a 

document, the time line will be at least ten days before distribution is to 

commence. 

Strategies 2 through 6 

Strategy #2 
NCD will be responsible for the cost of producing accessible materials for 

distribution to individuals with disabilities from the budget used for producing the 

materials for general distribution. 

For materials of national significance and/or wide distribution, including those 

affecting several programs or offices, NCD will provide a central budget 

allocation. 

Strategy #3 

NCD will develop Task Order contracts for the brailing, recording, and captioning 

of NCD materials. 

Strategy #4 

For meeting the accessibility needs of in-house employees with disabilities, NCD 

will develop a mechanism for the prompt evaluation of individual equipment 

needs and the timely provision of appropriate equipment and materials for inhouse personnel with disabilities. 

This evaluation/acquisition process will be coordinated by the Executive Director. 

Strategy #5 

NCD will produce (in house) in Braille, short materials such as agendas, 

telephone lists, memoranda, brochures/information packets, etc. 

Documents producible by such facilities would be of relatively small size 

(between 1 and 25 print pages) and in small volume (1 to 20 copies). 

The production of lengthy documents, and/or documents requiring volume 

production, and the recording and captioning of materials, would of necessity 

need to be produced outside NCD via a contract with a professional facility. 

Strategy #6 

NCD will evaluate the need to reproduce in alternate formats NCD documents 

issued prior to this document. 

Accessibility for Individuals with Disabilities 
Introduction 

This policy is being proposed to clarify the National Council on Disability's 

obligations under Section 504 of the Rehabilitation Act of 1973; as amended, 42 

U.S.C. 794 (Section 504), to make all of its meetings accessible to individuals 

with disabilities. 

Background 

Section 504 states that no individual with a disability shall be "excluded from 

participation in, be denied the benefits of, or be subjected to discrimination under 

any program or activity receiving Federal financial assistance or under any 

program or activity conducted by any Executive agency" solely on the basis of his 

or her disability. 

Ensuring that all programs and activities are accessible to individuals with 

disabilities means that all facilities, services, and information must be readily 

accessible and usable by persons with disabilities. 

The agency is responsible for furnishing auxiliary aids necessary to afford an 

individual with a disability an equal opportunity to participate in, and enjoy the 

benefits of, a program or activity, by arranging for interpreters services, assistive 

listening devices or other similar services or devices. 

Meetings, conferences, seminars, hearings, focus groups and other NCD 

sponsored events must be accessible to persons with disabilities, including 

employees, participants, and members of the public. 

Accessibility at meetings includes accessible communications and materials, and 

accessible facilities for persons with mobility impairments. 

Meetings referred to in this paper include the following: 

(1) Official agency meetings on Federal property; 

(2) Meetings conducted by agency officials on non-Federal 

property; 

(3) Meetings conducted by contractors of the agency, acting on 

behalf of the agency. * 

In addition, this paper will comment upon meetings attended by agency officials 

on non-Federal property. 
Meetings Conducted by Contractors 

Footnote 

Although contractors may conduct meetings that are supported by NCD funds, 

they do not generally act on behalf of the agency and are therefore not covered 

under this policy statement. Contractors are, however, subject to Section 504 for 

federally assisted programs, 34 CFR Part 104 and are, under those separate 

regulations, required to make their meetings accessible to individuals with 

disabilities. Of course, to the extent a contractor does conduct a meeting on 

behalf of the agency, this policy statement would apply in that limited situation. 

Toward this end, the agency or contractor organizing a federally conducted 

meeting ("the organizer") will be responsible for locating, planning and using sites 

that are readily accessible, or making contracts or other procurement 

arrangements to make sites accessible before the time of a meeting. 

In long-term planning of meetings, seminars and conferences, the organizer will 

write into the contract that the meeting rooms, restrooms, and other facilities to 

be used as part of the meeting and services provided by the site will be 

accessible to individuals with disabilities. In addition, it should be written into the 

contract that the organizer will reserve the right to cancel any contract if a 

hotel/site does not make the services and facilities accessible within a specified 

period of time prior to the conference/meeting. 

When planning a federally conducted meeting, organizers should be aware when 

selecting a location for the meeting that the accessibility of facilities may vary 

depending on whether the property is publicly or privately owned and when it was 

constructed. Access to a federally conducted meeting is still governed, however, 

by regulations at 34 CFR Part 105. Therefore, organizers must ensure that the 

site chosen for the location of a meeting meets the accessibility standards 

governing the agency’s programs and activities, i.e. that the program or activity, 

viewed in its entirety, is readily accessible by individuals with disabilities. 

It is the responsibility of the meeting organizers to provide auxiliary aids in order 

to ensure accessible communication for individuals with disabilities who wish to 

participate in, or in other ways benefit from, the meeting. Such auxiliary aids 

should include, for example, providing materials in alternate formats, providing 

sign-language interpreters, etc. Please refer to the agency’s Policy Statement on 

Making Materials and Information Available and Accessible to Individuals with 

Disabilities for further information on this subject. 

During the course of inviting participants and confirming participation, efforts 

must be made by both the organizer and the site reservations desk to notify 
participants what materials or visual aids will be used and where and how the 

facilities are accessible. 

Also, the meeting must determine what, if any, auxiliary aids are required by 

individuals, either before or during the meeting, in order to have access to the 

meeting. This information is to be shared with the meeting site and the 

organizers. 

Agency officials are encouraged, at the time of accepting an invitation, to make 

an official appearance or presentation at major public meetings or events that are 

not conducted by or on behalf of the agency, to state the agency's commitment to 

the inclusion of all individuals and to inquire as to the event's efforts to address 

accessibility for individuals with disabilities. 

Agency officials should consider the accessibility of the meeting to individuals 

with disabilities, in addition to the significance of the meeting or event to the 

agency interests, in deciding whether to participate. 

Policy Strategies 

Discussion 

This policy outlines the requirements for assuring equal access to agency 

meetings for persons with disabilities. 

The following strategies are suggested as possibilities that will help to ensure 

that accessible meetings under Section 504 are made standard operating 

procedure. 

Strategy #1 

A "check-list" will be developed by the Executive Assistant to assist persons in 

planning meetings by ensuring that all accessibility issues and requests for 

auxiliary aids are considered at the time a meeting is being planned. 

In the meantime, meeting organizers should confirm with the meeting site that 

the facilities and services planned for the meeting are accessible to persons with 

disabilities and that meeting participants are asked whether they need any 

auxiliary aids in order to make the meeting accessible. 

Strategy #2 

A requisition form used by the agency will indicate the accessibility of facilities 

and the type of auxiliary aids required. 
Strategy #3 

A list of local facilities that are accessible to persons with disabilities will be 

developed by the Executive Assistant. 

Common Formats 

Note 1 

Accessible materials and media include Brailed materials, audio recordings, 

large-print formats; materials read aloud by individuals skilled in this task, open 

and closed captioning of films and videos, real-time graphic displays, audiodescribed films and videos, and electronic media such as computer disks. 

Note 2 

Unless NCD is providing materials in an accessible format upon the specific 

request of an individual, the agency is responsible for determining which format 

generally is most suited to the needs of individuals with disabilities. 

The agency always should give primary consideration to the use of the form 

preferred by an individual who may make a request for a document in a specific 

format, although the agency has some discretion in selecting the format provided 

as long as it ensures effective communication with the individual. 

Note 3 

When the agency is preparing accessible-format publications' for a potentially 

large distribution, e.g., a pamphlet explaining program participation opportunities 

or benefits, or a brochure outlining a new initiative, NCD should select the format 

that is likely to be usable by the largest number of people. 

These formats are generally audiotapes for persons with vision impairments or 

other disabilities that prevent the use of conventional printed materials, and 

open-captioned videotapes for persons who are deaf or hard of hearing or have 

other disabilities that prevent the use of uncaptioned videos. 

However, as stated, the agency must give primary consideration to the choice of 

format requested by an individual with a disability, unless the agency can 

demonstrate that the format requested is not feasible because it would require 

fundamental alteration in the nature of the program or would result in an undue 

burden. 
Mark S. Quigley 

Director of Communications 

National Council on Disability 

1331 F Street, NW Suite 850 

Washington, DC 20004