UNCLASSIFIED 

UNCLASSIFIED 

 

 

National Reconnaissance Office 

Business Function 80, Oversight 

Directive 80-3, Equality & Inclusion 

Instruction 80-3-3, Reasonable Accommodations Process 

9 September 2021 

Version 5.0 

 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

2 

UNCLASSIFIED 

TABLE OF CONTENTS 

NRO INSTRUCTION (NI) 80-3-3 CHANGE LOG................................ 3

SECTION I – INTRODUCTION ............................................. 4

SECTION II – REASONABLE ACCOMMODATIONS PROCESS DOCUMENTATION ......... 4

Governing NBF ........................................................ 4

Description .......................................................... 4

Instruction Points of Contact ........................................ 5

Support Systems and Information Tracking ............................. 5

Process Narrative .................................................... 5

Interactive Process ................................................ 5 

Initiating a Reasonable Accommodation .............................. 6 

Medical Information ................................................ 7 

Confidentiality .................................................... 8 

Time Limits ........................................................ 9 

Reassignment ...................................................... 10 

Denials ........................................................... 11 

Tracking .......................................................... 11 

Costs and Resources ............................................... 12 

SECTION III – PROCESSING RA REQUESTS ................................ 12

Process Flow Diagram ................................................ 14

Table 1: Risk & Internal Control Table ............................. 15

SECTION IV – CONFIGURATION CONTROL .................................. 15

APPROVING SIGNATURE ................................................. 15

APPENDIX A – PROCESS FLOW DIAGRAM LEGEND ............................ 16

APPENDIX B – GLOSSARY AND ACRONYM LIST .............................. 17

APPENDIX C – RESOURCES .............................................. 25

APPENDIX D – REFERENCES/AUTHORITIES ................................. 26

APPENDIX E – SAMPLE REASONABLE ACCOMMODATION WRITTEN DENIAL ......... 27

APPENDIX F – SAMPLE REASONABLE ACCOMMODATION REQUEST ................ 29
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

3 

UNCLASSIFIED 

NRO INSTRUCTION (NI) 80-3-3 CHANGE LOG 

Revision Date Revised By Pages 

Affected Remarks 

0 9 Sep 15 Office of 

Equality & 

Inclusion 

(OE&I) 

All Initial Release 

1 29 April 

2019 

OE&I & 

Accommodations 

Program (AP) 

All 

2 24 Feb 

2020 

OE&I All Admin changes 

to remove 

duplicate 

information and 

improve 

readability 

3 18 Dec 

2020 

OE&I All Admin changes 

in response to 

EEOC 

recommendations

4 29 Apr 

2021 

OE&I 5, 6, 12, 

15, and 17 

Admin changes 

to reflect 

pronoun 

consistency and 

updates to 

links 

5 9 Sept 

2021 

OE&I All Changes to 

reflect 

compliance with 

Regulations and 

EEOC Feedback 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

4 

UNCLASSIFIED 

SECTION I – INTRODUCTION 

 In accordance with the National Reconnaissance Office (NRO) 

Governance Plan, NRO Business Function (NBF) 80, and NRO Directive 

(ND) 80-3, this NRO Instruction (NI) sets forth the procedural 

implementation guidance and provides applicable information in 

addenda. All NRO personnel1 who perform tasks or have duties specific 

to the Reasonable Accommodations (RA) Process will comply with this 

NI. When the work to be performed under an NRO contract must comply 

with this NI, the program office shall list this NI as a reference 

document in the contract statement of work. 

SECTION II – REASONABLE ACCOMMODATIONS PROCESS DOCUMENTATION 

The sub-sections that follow detail the RA Process. 

 Governing NBF 

NBF 80, Oversight

Description 

 Pursuant to Section 501 of the Rehabilitation Act of 1973, as 

amended, federal executive branch agencies are prohibited from 

discriminating against a qualified individual with disabilities (IWD). 

Executive Order 13164 further requires all Federal Agencies to 

establish procedures on handling requests for reasonable 

accommodations (RA). Under the law, NRO must provide an RA to 

qualified NRO personnel or qualified applicants with disabilities, 

unless to do so would cause undue hardship. Accommodation decisions 

are made based on NRO personnel or the applicant’s abilities and 

essential functions of the position. Upon request by an applicant or 

NRO personnel, the procedures for RAs will be provided in an 

accessible format. 

 This instruction applies to applicants and NRO personnel who meet 

the definition of a qualified individual with a disability (QIWD) in 

need of an RA. Contractor personnel performing work under NRO 

contracts in contractor facilities should follow their employer’s 

procedures; however, if the employer does not have prescribed 

procedures, contractor personnel may reach out to their government 

point of contact for guidance. All requests for accommodation made 

through/by the contractor’s employer will be coordinated between the 

Office of Equality & Inclusion (OE&I) Accommodations Program (AP) 

staff and the contractor’s employer to ensure that any agreed-upon 

accommodation meets NRO requirements. 

 

1 For purposes of this document, NRO personnel and the term “NRO Total 

Workforce” are interchangeable and defined as permanent NRO civilians (i.e., 

NRO Cadre), Department of Defense (DoD) and Intelligence Community civilians 

assigned or detailed to the NRO, and contractors performing work under NRO 

contracts in NRO facilities.
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

5 

UNCLASSIFIED 

 The Director of the NRO has designated the OE&I to oversee and 

manage the RA process and Personal Assistance Services (PAS) agencywide. The Director, OE&I has delegated the management of RA and PAS 

requests to the Chief, (C/AP). OE&I is the responsible office for 

this instruction and a resource available on behalf of the NRO and any 

of its external locations, foreign or domestic.2 The RA process is 

interactive and implemented in a manner consistent with the 

Rehabilitation Act of 1973 and EEOC implementing regulations @ 29 CFR 

1614.203 to ensure equal opportunity of every individual who requests 

an accommodation. 

Instruction Points of Contact 

NRO Personnel: Chief, AP, 850-2561, 

Email: OEI-Accommodations@nro.ic.gov 

Military personnel: Chief, Military Equal Opportunity, 850-5775, 

Email: MEO@nro.ic.gov 

Military personnel are not covered under the Rehabilitation Act 

or the EEOC’s implementing regulations. Military personnel can 

receive a RA for a documented disability when the RA request is a 

computer or electronic accommodation. With a signed/recommended 

document by their Primary Care Manager, military personnel (active 

duty, reserve, and guard) may submit an accommodation request through 

the Computer Accommodations Program. See Appendix C. 

Medical Portable Electronic Device: Office of Security & 

Counterintelligence, OSCI-FISD-PTSB-MPED@nro.ic.gov. 

 

Ergonomic or wellness items may be requested directly through the 

Office and Desktop Wellness Supplies Ordering Site. This service is 

available to NRO personnel.3 Items available include: adjustable 

desk, ergonomic chair, standing mat, screen cover/anti-glare, Mouse 

pad, wrist guard, footrest, and document holder. 

Support Systems and Information Tracking 

 NRO Management Information System and the Equal Accessibility 

Services Environment (EASE) 

Process Narrative 

 

Interactive Process

 Communication is a priority and is encouraged through the entire 

RA process. Thorough discussion begins between the Office of Human 

 

2 Supervisors and managers may work directly with NRO personnel requesting 

ergonomic or wellness items as outlined in this issuance. 

3 Individuals at other NRO locations, outside the WMA, may contact their 

applicable facilities, furniture, or nurse’s program for guidance. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

6 

UNCLASSIFIED 

Resources (OHR) and the applicant or between NRO personnel, AP staff, 

and supervisors. Communication should include a review and analysis 

of the job functions to establish essential functions of the job, 

identification to barriers to performance, the individual’s precise 

limitations resulting from the disability, and the potentially most 

effective accommodations that would allow the individual to overcome 

the limitations. Ongoing communication is important when the specific 

limitation is not obvious, the barrier is unclear, or alternative or 

additional RAs are being considered. 

 During the interactive process, several factors to consider 

include: a) if the individual is found to have met the definition of 

a QIWD and is thereby eligible for an RA, b) the effect on the 

individual’s performance, c) personal preferences of the individual d) 

time needed to complete the tasks, and e) the cost of the 

accommodation. Temporary accommodations may be agreed upon until an 

effective RA is attained. 

 The interactive process may require information sharing with 

other Agency officials only when those officials have a legitimate 

need to know in order to fulfill the RA request. 

Initiating a Reasonable Accommodation 

 

 Generally, an applicant or NRO personnel must let the NRO know 

that an adjustment or change concerning some aspect of the application 

process, the job, or a benefit of employment for a reason related to a 

medical condition, is needed. 

 A requestor4 may request an RA orally, in writing, or via the 

EASE5 application to: 1) a supervisor or manager in the requestor’s 

chain of command, 2) OE&I AP staff, 3) any individual connected with 

the Agency’s application process, or 4) any other individual 

designated by the agency to accept such requests. A requestor may 

request an accommodation at any time even if the individual has not 

previously disclosed the existence of a disability and need not have a 

particular accommodation in mind before making a request. Requests 

may be made on behalf of an individual by a family member, qualified 

health provider, or other representative. 

 Once a request is approved for the first time, the requestor may 

obtain the accommodation by notice to an appropriate individual or 

OE&I/AP staff (e.g., the requestor’s supervisor). Requests likely to 

need repeat services (e.g. a sign language interpreter) are tracked as 

separate ‘event driven’ requests using the EASE application. 

Requestors who have recurring or on-going requests for an RA (e.g., 

the assistance of sign language interpreters or readers) do not need 

to fill out a written form to document the need for an accommodation 

or otherwise make a formal request each time that particular 

 

4 A requestor is an individual making an RA request.

5 EASE is an internal Agency repository for the receipt, tracking, and 

processing of RA requests made by NRO personnel. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

7 

UNCLASSIFIED 

accommodation is needed. The requestor should give appropriate 

advance notice, where feasible, each time the recurring accommodation 

is needed, unless arranged to do otherwise. 

 The RA process begins as soon as the oral or written request for 

accommodation is made by, or on behalf of, the individual. As such, 

it is vital that requests made to NRO personnel, authorized to receive 

requests, be made known to the OE&I AP staff within three (3) business 

days. NRO personnel may initiate an RA or make requests through an 

individual’s manager or supervisor. When requests are received, 

contact must be made to a member of the AP staff to ensure that the 

request enters into the RA process described in this Instruction. 

 Supervisors who receive RA requests may seek clarity from the 

requestor about the request. Supervisors should not rely on 

assumptions about an impairment to determine if the requestor is a 

QIWD. Examples of how to recognize a request for an RA may include: 

 a. Michelle tells her supervisor, “I’m having trouble 

getting to work at my scheduled starting time because of the antidepressants I take.” This is a request for a RA. Whether, or not, 

Michelle is ultimately entitled to an accommodation, the agency must 

start to consider the request. 

 b. An applicant who is vision-impaired asks for assistance 

with the agency’s application materials. This is a request for a RA 

and triggers the agency’s obligation to engage in its RA process. 

 c. If the supervisor is unable to provide the RA or cannot 

determine whether an RA is necessary, the supervisor should contact 

OE&I/AP staff immediately. 

 

 Applicants may initiate an RA through the individual associated 

with hiring/recruitment process. The NRO OHR’s Recruitment Group (RG) 

will contact OE&I/AP staff regarding an accommodation request. 

OE&I/AP staff will follow up with the RG within three (3) business 

days to discuss the needs of the applicant. 

 An IWD may designate a representative to submit an RA request on 

their behalf. When a representative makes a request, the OE&I AP 

staff should confirm the request with the IWD to ensure that an 

accommodation is desired. 

Medical Information

 Pursuant to EEOC Guidance and 29 C.F.R. Part 1614, when the 

disability and the need for accommodation is obvious or when the 

individual has already provided sufficient information to document the 

existence of the disability and functional limitations has been 

provided, NRO personnel will not request medical information. 

Additionally, the request for medical information is limited. Only 

information relevant to the disability at issue will be considered 

when making a decision about the requested reasonable accommodation. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

8 

UNCLASSIFIED 

 Specifically, medical information will not be requested where: 

 

a. The requestor’s disability and need for accommodation 

are obvious; or 

b. The NRO has determined the requestor has already 

provided sufficient information/medical documentation to determine the 

existence of a disability and their functional limitations. 

 Conversely, if the disability and the need for an accommodation 

is not obvious, or if the individual has not provided sufficient 

information to document the existence of the disability and functional 

limitations, the Agency may require the requestor to provide medical 

information, or supplemental medical information, as needed, that is 

sufficient to explain: 

a. The nature of the individual’s disability; 

b. The need for an RA (the limitations created by the 

disability, and how they impact an essential function of the position 

or limit access to the benefits and privileges of employment); 

c. How the requested accommodation, if any, will assist 

the individual to apply for a position, perform the essential 

functions of the position, or enjoy the benefits and privileges of the 

workplace. 

 The AP staff may require medical documentation, that is provided 

by the individual, be reviewed by the NRO Medical Director. The 

review, if needed, is at NRO’s expense. NRO recognizes the timeframe 

set forth in this issuance for providing/denying an accommodation does 

not stop when the NRO Medical Director is reviewing medical 

documentation. If an individual prefers to employ an outside medical 

professional to review the medical documentation instead, any expenses 

associated or incurred will be at the expense of the individual 

requesting the RA. Additionally, the NRO will be not be expected to 

adhere to its usual time frames if an individual’s health professional 

fails to provide needed documentation, in a timely manner.

Confidentiality

 Pursuant to 29 CFR 1630-14, medical information, obtained by the 

AP staff, must be collected and maintained on separate forms, in 

separate medical files, treated as confidential medical records6, and 

must be kept separate from and not included in the IWD’s personnel 

records. 

 

6 Confidential medical records refer to all information obtained regarding an 

applicant or employee’s medical condition or history. Documentation of an 

individual’s diagnosis or symptoms is confidential medical information and 

protected under the Privacy Act of 1974.
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

9 

UNCLASSIFIED 

 Additionally, there are limited circumstances when the Agency may 

disclose confidential medical information to certain individuals to 

include: 

 

 a. Supervisors and managers who need to know about 

necessary restrictions on the work or duties of the employee and about 

the necessary accommodation(s); 

b. First aid and safety personnel if the disability might 

require emergency treatment; 

c. Government officials when necessary to investigate the 

agency’s compliance with the Rehabilitation Act; 

d. In certain circumstances, workers’ compensation offices 

or insurance carriers; 

e. DoD Component equal employment opportunity (EEO) 

officials to maintain records and evaluate and report on the agency’s 

performance in processing reasonable accommodation requests. 

Time Limits 

 Once the Agency receives the RA request, by, or on behalf of the 

individual requesting an RA, a decision to approve or deny a request 

will be made no later than 10 business days. 

 In most cases, the AP staff will notify the QIWD of an approved 

accommodation within 10 business days, an expectation as to the date 

the QIWD can expect the implementation or provision of the 

accommodation within 45 calendar days, or 30 business days, or a 

justification for denying any requested accommodation. This 

notification will be provided to the requestor in an accessible 

format. 

 Execution of the request is completed in a timely, efficient, and 

fair manner, excluding extenuating circumstances. However, when 

possible, and in collaboration with the requestor and other 

stakeholders, requests may be executed in less than the timelines set 

forth in this issuance. Expedited processing of requests will be made 

available, excluding extenuating circumstances. Failure to provide 

the accommodation in a prompt manner may be a violation of the 

Rehabilitation Act of 1973, as amended. Normally, a QIWD should 

expect an approved accommodation to be implemented within 45 calendar 

days, or 30 business days, following receipt of the request. If 

extenuating circumstances justify delays in processing requests beyond 

the designated time limit, the QIWD must be informed of the status of 

the request and periodically updated as to when to expect the 

accommodation. A delay may be justified by circumstances that could 

not be reasonably anticipated or avoided in advance of a request, or 

are outside the AP’s ability to control (e.g., specialized equipment 

requiring vetting prior to use in the NRO or requiring supplemental 

medical documentation). A member of the AP staff will notify the 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

10 

UNCLASSIFIED 

individual or the RG, for an applicant, of the reason for a delay and 

keep the individual informed of the expected process date. If there 

is a delay in providing an approved request, an individual from the AP 

staff, in coordination with management or other resources, will 

provide an interim/alternative accommodation that allows the QIWD to 

perform some or all of the essential functions of the job. 

 An RA request from an applicant to engage in the applicant/hiring 

process must be approved and provided to the AP staff within three (3)

days. If the request is not feasible (because it would cause an undue 

burden on the Agency), the applicant should be advised and an 

alternative accommodation immediately explored. An alternative 

accommodation should be provided so that the applicant can engage in 

the application/hiring process. The decision as to the type of 

accommodation to be afforded is made by a collaborative process 

between OE&I AP staff and NRO’s OHR recruitment official responsible 

for the hiring action. 

Reassignment 

 Reassignment is a “last resort” form of an RA that will be 

provided. Reassignment to a vacant (equivalent) position for which an 

individual is qualified, and not just permission to compete for such a 

position, is an RA. If an appropriate accommodation cannot be 

identified to enable a requestor to perform the essential functions of 

the individuals’ current job, OE&I/AP staff consults with the OHR, NRO 

OGC, or other appropriate parties for alternative reassignment 

options. Reassignment is only available if the requestor is qualified 

for the work, if available, and can perform the essential functions of 

another position, with or without accommodation(s). 

 Reassignment is available only to NRO personnel and may be made 

only to a valid vacant position. A valid position is a position for 

which the Agency has a need and the Agency intends to fill the 

position. The law does not require that agencies create new 

positions, fill positions for which the Agency has no need, or move 

other personnel in order to create a vacancy for a QIWD to be placed. 

 After it is determined and documented that the QIWD cannot 

perform the essential functions of their current position because of a 

disability, and the Agency cannot otherwise accommodate the QIWD, 

authorized AP staff will ask the individual if they are willing to 

accept a reassignment. 

 If the individual will accept a reassignment, the AP staff will 

notify OHR and appropriate D/O. The OHR will work with the individual 

to determine positions for which the individual qualifies. To qualify 

for a vacant position, the QIWD must have the requisite skills, 

experience, education, and other job-related requirements necessary to 

fill the vacant position. The OHR must maintain a list of all valid 

vacancies considered for placement of the individual. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

11 

UNCLASSIFIED 

 If after a reasonable amount of time (no less than 30 days) has 

been exhausted to locate a position for the QIWD without success, the 

individual should be notified in writing of any other options 

available, including disability retirement, if eligible. 

Denials 

 If the individual is unable to confirm they are a QIWD, AP staff 

will prepare a written notice and provide it to the applicant (via 

OHR) or NRO personnel at the time of the denial, and in an accessible 

format when requested. 

 Where there has been a denial of a specifically requested 

accommodation but an offer to make a different accommodation, the 

decision letter should explain both the reasons for denying the 

accommodation requested and the reasons that the accommodation offered 

would be effective. 

 The written notice of denial of an RA will explain the procedures 

available for reconsideration and should inform the individual that 

they have the right to file an EEO complaint if they believe the 

denial discriminatory. 

 If an applicant or NRO personnel has additional information to 

provide in support of their request, or details a position or argument 

the NRO personnel believes was not properly considered by the 

recruiting official or supervisory decision-maker, the case file with 

additional information, along with the request for reconsideration, 

should be forwarded to OE&I/AP staff. OE&I will convene the NRO 

Review Advisory Board (NRAB)7. The applicant or NRO personnel must 

file a request for reconsideration within ten (10) business days from 

receipt of the written notice of denial to the applicant’s recruitment 

official or to the OE&I/AP staff. 

 The Board’s decision will be provided to the applicant (via OHR) 

or NRO personnel in writing by the C/AP. It will include instructions 

on how to file an EEO complaint, complete with guidance that the 

individual must contact an EEO counselor within 45 days of receipt of 

the denial. If the individual is dissatisfied with the Board’s 

decision on reconsideration and wishes to engage the EEO process, they 

must contact an EEO counselor within 45 days of receipt of the written 

correspondence from the Board. Participation in any other resolution 

process does not pause the running of the 45 days. 

Tracking 

 

 Individuals in the application process may reach out to their 

recruiting point of contact to request a status on the requested 

reasonable accommodation. NRO personnel may reach out to OE&I/AP 

 

7 The NRAB consists of OE&I Chief, AP, Office of General Counsel, Office of 

Security & Counterintelligence, Office of Human Resources, Communications 

Directorate, and Directorate leadership. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

12 

UNCLASSIFIED 

Staff; appropriate contact information for OE&I/AP staff is located on 

the Agency’s Intranet, to request a status on the requested RA. RA 

requests will record the following information: the specific 

reasonable accommodation; the job (occupational series, grade level, 

and agency component) sought by requesting applicant or held by the 

employee; whether the accommodation was needed to apply for a job, 

perform the essential functions of a job, or enjoy the benefits and 

privileges of employment; whether the request was granted or denied; 

the identity of the deciding official; the basis of the denial; and 

the number of days taken to process the request. 

Costs and Resources 

 Pursuant to subpart 1614 of Title 29, CFR, the budget of the NRO, 

as a whole, must be considered when determining whether the expense of 

a potential accommodation constitutes an undue hardship. Budget 

resources allocated by statute for a specific purpose that does not 

include RA are excluded. It is unlikely that cost will be a basis for 

denying a request for an RA. 

 The NRO is not required to provide RAs that would impose an 

undue hardship on the operation of the agency. An undue hardship 

means that a specific accommodation would require significant 

difficulty or expense. This determination, which must be made on a 

case-by-case basis and is fact-specific. 

SECTION III – PROCESSING RA REQUESTS 

 1.0 Requestor submits a request, orally or in writing, at any 

time, for an RA 

 1.1 AP staff establishes a case file in EASE 

 2.0 AP begins the interactive process with the requestor 

 3.0 AP determines eligibility for an RA 

 3.1 Military personnel are referred to Chief, MEO for 

processing, thereby closing any action by OE&I/AP staff. 

 3.2 NRO personnel requests are processed through the AP. 

 3.3 Applicant requests are processed through the AP; 

however, applicant requests are coordinated through the OHR. OHR 

serves as the applicant point of contact and liaises between OE&I and 

the applicant. 

 3.4 Contractor requests may be processed through the AP. 

See Footnote 1. 

 4.0 AP staff reviews and renders a decision to approve or deny a 

request no later than 10 business days. Implementation of the request 

is completed within 45 calendar days, or 30 business days, absent 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

13 

UNCLASSIFIED 

extenuating circumstances. If the request is approved, go to step 

6.0. 

 4.1 Prior to denial of a request, AP staff will work with 

the requestor to offer an alternative RA. If the alternative RA is 

accepted, go to step 5.0. 

 

 4.1.1 If an appropriate accommodation cannot be 

identified to enable a requestor to perform the essential functions of 

the individual’s current job, OE&I/AP staff will consult with OHR, NRO 

OGC, Medical personnel, and/or other appropriate parties for 

alternative reassignment options (see Section on reassignments). 

 4.1.1.2 The AP staff may determine to approve a RA, in 

consultation with appropriate Directorates or Offices (i.e. NRO 

Communications Directorate, OGC, Office of Security & 

Counterintelligence, OHR, or the requestor’s management), that 

otherwise is inconsistent with an existing policy. 

 5.0 The requestor accepts the RA, or proposed alternative. 

 6.0 The NRO/AP, implements the RA within 45 calendar days, or 30 

business days, absent extenuating circumstances8. 

 7.0 The AP staff follows up with the requestor within 14 business 

days after implementation to verify the effectiveness of the RA. 

 

 

 

 

8 An extenuating circumstance is defined as factors that could not reasonably 

have been anticipated or avoided in advance of the request for the 

accommodation. See Appendix B for additional information. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

14 

UNCLASSIFIED 

Process Flow Diagram 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

15 

UNCLASSIFIED 

Table 1: Risk & Internal Control Table 

Risk Internal Control

Complaints of discrimination 

arising from failure to provide 

a RA. 

Annual review of organization 

policies relative to EEO issues. 

Written documentation received from 

office detailing reason for any 

denial of RA. 

Coordination with applicable 

stakeholders as appropriate for each 

case. 

SECTION IV – CONFIGURATION CONTROL

All changes to the NI 80-3-3, Reasonable Accommodation Process 

require Director, OE&I approval. 

APPROVING SIGNATURE 

With the authority delegated by the NBF owner for Oversight, I 

confirm that this document provides a complete representation of the 

Reasonable Accommodations Process Instruction and that the document 

has been coordinated with stakeholders of the process. 

 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

16 

UNCLASSIFIED 

APPENDIX A – PROCESS FLOW DIAGRAM LEGEND 

 

 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

17 

UNCLASSIFIED 

APPENDIX B – GLOSSARY AND ACRONYM LIST 

Acronym or 

Term 

Definition

ADA Americans With Disabilities Act 

ADR Alternative Dispute Resolution 

AP Accommodations Program 

D/O Directorate or Office 

EASE Equal Accessibility Services Environment 

EEO Equal Employment Opportunity 

EEOC Equal Employment Opportunity Commission (non NRO) 

IWD Individuals with Disability 

NBF National Reconnaissance Office Business Function 

NI National Reconnaissance Office Instruction 

NMIS National Reconnaissance Office Management Information 

System 

NRAB NRO Review Advisory Board 

NRO National Reconnaissance Office 

OE&I Office Of Equality & Inclusion 

ORT OHR Recruitment Team 

QIWD Qualified Individual with a Disability 

Alternative 

Dispute 

Resolution 

ADR is a voluntary process which uses several methods, 

most commonly mediation or facilitation, to attempt 

resolution 

Benefits and 

privileges of 

federal 

employment 

“Benefits and privileges” of Federal employment may 

include, but are not limited to: DoD Componentsponsored training (whether provided by the DoD 

Component or an outside entity), services (e.g., 

employee assistance programs, credit unions, 

cafeterias, lounges, gymnasiums, auditoriums, 

transportation), social and professional functions, 

emergency evacuation plans, and workplace 

communications through e-mail, public address systems, 

or during meetings, whether that communication relates 

directly to performance of an employee’s essential job 

functions. 

Confidential 

Medical 

Information 

All information obtained regarding an applicant or 

employee’s medical condition or history. Documentation 

of an individual’s diagnosis or symptoms is 

confidential medical information and is protected under 

the Privacy Act of 1974. 

Disability A physical or mental impairment that substantially 

limits one or more of the major life activities of such 

individual; a record of such an impairment; or being 

regarded as having such an impairment. (1630 of Title 

29 CFR) 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

18 

UNCLASSIFIED 

Acronym or 

Term 

Definition

Equal 

Accessibility 

Services 

Environment 

RA database tool and records repository. 

Essential Job 

Functions 

The fundamental job duties of the employment position 

the individual with a disability holds or desires. 

Essential functions do not include marginal functions. 

A job function may be considered essential for any of 

several reasons, including but not limited to the 

following: 

The reason the position exists is to perform that 

function. 

There are a limited number of employees available 

among whom the performance of that job function can be 

distributed. 

The function may be highly specialized so that the 

incumbent in the position is hired for his or her 

expertise or ability to perform the particular 

function. 

Evidence of whether a particular function is essential 

includes, but is not limited to: 

The NRO’s judgment as to which functions are 

essential. 

Written job descriptions prepared before advertising 

or interviewing applicants for the position. 

The amount of time spent on the job performing the 

function. 

The consequences of not requiring the incumbent to 

perform the function. 

The terms of a collective bargaining agreement. 

The work experience of past incumbents in the job. 

 The current work experience of incumbents in 

similar jobs. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

19 

UNCLASSIFIED 

Acronym or 

Term 

Definition

Extenuating 

Circumstance 

Factors that could not reasonably have been anticipated 

or avoided in advance of the request for the 

accommodation. These can include situations in which 

equipment must be back-ordered or the vendor typically 

used by an agency has unexpectedly gone out of 

business. In addition, an agency will be not be 

expected to adhere to its usual time frames if an 

individual’s health professional fails to provide 

needed documentation, in a timely manner. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

20 

UNCLASSIFIED 

Impairments 

that 

substantially 

limits a major 

life activity 

An impairment is a disability within the meaning of 

this section if it substantially limits the ability of 

an individual to perform a major life activity as 

compared to most people in the general population. An 

impairment need not prevent, or significantly or 

severely restrict, the individual from performing a 

major life activity in order to be considered 

substantially limiting. Not every impairment will 

constitute a disability. 

It should easily be concluded that the following types 

of impairments will, at a minimum, substantially limit 

the major life activities indicated: 

Deafness substantially limits hearing. 

Blindness substantially limits seeing. 

An intellectual disability (formerly termed mental 

retardation) substantially limits brain function. 

Partially or completely missing limbs or mobility 

impairments requiring the use of a wheelchair 

substantially limit musculoskeletal function. 

Autism substantially limits brain function. 

Cancer substantially limits normal cell growth. 

Cerebral Palsy substantially limits brain function. 

Diabetes substantially limits endocrine function. 

Epilepsy substantially limits neurological function. 

Human Immunodeficiency Virus (HIV) infection 

substantially limits immune function. 

Multiple Sclerosis substantially limits neurological 

function. 

Muscular Dystrophy substantially limits neurological 

function. 

Major depressive disorder, bipolar disorder, posttraumatic stress disorder, obsessive compulsive 

disorder, and schizophrenia substantially limit brain 

function. 

The types of impairments described in this section may 

substantially limit additional major life activities 

not explicitly listed above. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

21 

UNCLASSIFIED 

Acronym or 

Term 

Definition

Interactive 

Process 

The process that offers the ability for AP and all 

applicable parties involved to maintain open and ongoing communication throughout the RA process. This 

interaction includes: explaining the RA process, 

offering alternative accommodations to requestor when 

necessary, or continuing dialogue between parties to 

obtain appropriate medical documentation when the 

disability or need for accommodation is not obvious. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

22 

UNCLASSIFIED 

Acronym or 

Term 

Definition

Major Life 

Activity 

In general, major life activities include, but are not 

limited to: 

Caring for oneself. 

Performing manual tasks. 

Seeing. 

Hearing. 

Eating. 

Sleeping. 

Walking. 

Standing. 

Sitting. 

Reaching. 

Lifting. 

Bending. 

Speaking. 

Breathing. 

Learning 

Reading. 

Concentrating. 

Thinking. 

Communicating. 

Interacting with others. 

Working. 

The operation of a major bodily function, include 

functions of the immune system, special sense organs 

and skin; normal cell growth; and digestive, 

genitourinary, bowel, bladder, neurological, brain, 

respiratory, circulatory, cardiovascular, endocrine, 

hemic, lymphatic, musculoskeletal, and reproductive 

functions. 

The operation of a major bodily function includes the 

operation of an individual organ within a body system. 

In determining other examples of major life activities, 

the term “major” shall not be interpreted strictly to 

create a demanding standard for disability. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

23 

UNCLASSIFIED 

Acronym or 

Term 

Definition

Mental 

Impairment 

Any mental or psychological disorder, such as an 

intellectual disability (formerly termed “mental 

retardation”), organic brain syndrome, emotional or 

mental illness, and specific learning disabilities 

Personal 

Assistance 

Services 

The term personal assistance services means assistance 

with performing activities of daily living that an 

individual would typically perform if he or she did not 

have a disability, and that is not otherwise required 

as a reasonable accommodation. Examples of personal 

assistance services include assistance with removing 

and putting on clothing, eating, and using the 

restroom. 

Physical 

Impairment 

Any physiological disorder or condition, cosmetic 

disfigurement, or anatomical loss affecting one or more 

body systems. 

Qualified 

Individual 

with a 

Disability 

An IWD who satisfies the requisite skills, experience, 

and education and other job related requirements of the 

employment position such individuals holds or desires, 

and who, with or without, reasonable accommodation, can 

perform the essential functions of such position. 

Reasonable 

Accommodation 

In accordance with Part 1630 of Title 29 CFR, 

Reasonable accommodation means: 

Modifications or adjustments to a job application 

process that enable a qualified applicant with a 

disability to be considered for the position such 

qualified applicant desires; or 

Modifications or adjustments to the work 

environment, or to the manner or circumstances under 

which the position held or desired is customarily 

performed, that enable an individual with a disability 

who is qualified to perform the essential functions of 

that position; or 

 Modifications or adjustments that enable a DoD 

employee with a disability to enjoy equal benefits and 

privileges of employment as are enjoyed by its other 

similarly situated employees without disabilities.
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

24 

UNCLASSIFIED 

Acronym or 

Term 

Definition

Request A request is a statement that an individual needs an 

adjustment or a change at work for a reason related to 

a medical condition. Below are examples of a request: 

An employee informs their supervisor that he or she 

is having trouble getting to work at the scheduled 

start time because the employee is undergoing medical 

treatments. 

A new employee, who uses a wheelchair, informs the 

DoD Component that the wheelchair does not fit under 

the office desk. 

Undue Hardship With respect to the provision of an accommodation, an 

undue hardship means significant difficulty or expense. 

The determination that a specific accommodation would 

impose an undue hardship must be based on an 

individualized assessment. Factors to be considered 

include: 

The nature and cost of the accommodation needed. 

The overall financial resources of the DoD Component 

facility making the reasonable accommodation, the 

number of persons employed at this DoD Component 

facility, and the effect on expenses and resources of 

the facility. 

The overall financial resources, size, number of 

employees, and type and location of facilities of the 

DoD Component. 

The overall financial resources of DoD as a whole, 

excluding resources designated by statute for a 

specific purpose that does not include reasonable 

accommodation. 

The type of operation or operations of the DoD 

Component, including the composition, structure, and 

functions of the DoD Component’s workforce. 

The impact of the accommodation on the nature of the 

operation or mission of the DoD Component, including 

the impact on the ability of other employees to perform 

their duties and the impact on the DoD Component 

facility’s operation or mission. 

 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

25 

UNCLASSIFIED 

APPENDIX C – RESOURCES 

Accommodations Program Website on NMIS: 

https://oei.nro.ic.gov/accommodations-program/

Accommodations Program group email address: 

OEI-Accommodations@nro.ic.gov 

Alternative Dispute Resolution email address: 

OmbudsandGrievance@nro.ic.gov

Computer Accommodations Program web address: 

http://www.cap.mil/WSM

Equal Accessibility Services Environment (EASE) link on NMIS: 

https://ease.nro.ic.gov/

Military Equal Opportunity email address: MEO@nro.ic.gov 

OS&CI F&ISD email address: 

OSCI-FISD-PTSB-MPED@nro.ic.gov. 

Office and Desktop Wellness link on NMIS: 

https://share.svc.nro.ic.gov/sites/MSO/OandDWellness/default.aspx

Equal Employment Opportunity Commission (EEOC) website: www.eeoc.gov; 

specifically, 1) EEOC Enforcement Guidance; Disability-Related 

Inquiries and Medical Examinations of Employees under the Americans 

with Disabilities Act (July 27, 2000), and 2) EEOC Enforcement 

Guidance on Reasonable Accommodations and Undue Hardship under the 

Americans with Disabilities Act (revised October 17, 2002). 

The Job Accommodation Network (JAN) (www.askjan.org), is a source of 

free, expert, and confidential guidance on workplace accommodations 

and disability employment issues. JAN is one of several services 

provided by the United States Department of Labor’s Office of 

Disability Employment Policy. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

26 

UNCLASSIFIED 

APPENDIX D – REFERENCES/AUTHORITIES (authorities moved as appropriate) 

a. 29 Code of Federal Regulations part 1630, Regulations to 

Implement the Equal Employment Provisions of the Americans with 

Disabilities Act. 

b. The Americans with Disabilities Act of 1990, as amended, and 

the Americans with Disabilities Act Amendments Act of 2008. 

c. Rehabilitation Act of 1973, as amended. 

d. Executive Order 13164, “Requiring Federal Agencies to 

Facilitate the Provision of Reasonable Accommodation,” July 26, 2000. 

e. DoD Directive 1020.01, “Nondiscrimination on the Basis of 

Handicap in Programs and Activities Assisted or Conducted by the 

Department of Defense,” March 31, 1982, as amended. 

f. DoD Directive 1020.02E, “Diversity Management and Equal 

Opportunity in the DoD,” June 8, 2015, as amended. 

g. DoD Directive 5124.02, “Under Secretary of Defense for 

Personnel and Readiness (USD(P&R)),” June 23, 2008. 

h. DoD Directive 5145.01, “General Counsel of the Department of 

Defense (GC DoD),” December 2, 2013, as amended. 

i. DoD Instruction 1020.04, “Harassment Prevention and Responses 

for DoD Civilian Employees,” June 30, 2020. 

j. NRO Governance Plan, Version 3.1, 9 August 2019. 

k. NRO Business Function 80, Oversight, Version 3.0, 

5 October 2018. 

l. NRO Directive 80-3, Equality & Inclusion, Version 2.0, 

1 June 2020. 

m. NRO Directive 100-4, Introduction and Use of Personally Owned 

Portable Electronic Devices and Personal Removable Media at NRO 

Facilities, 6 March 2020. 

n. NRO Instruction 80-3-2, Military Equal Opportunity Complaint 

Process, 9 September 2015. 

o. NRO Directive 80-8, Grievance Resolution, Ombuds, and 

Alternative Dispute Resolution, Version 2.0, 18 September 2020. 

p. NRO Instruction 80-8-2, Alternative Dispute Resolution, 

Version 1.0, 2 January 2020. 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

27 

UNCLASSIFIED 

APPENDIX E – SAMPLE REASONABLE ACCOMMODATION (RA) WRITTEN DENIAL 

1. Name: ____________________________ 

2. Accommodation(s) Requested: 

3. REASON(S) FOR DENIAL (may check more than one box) 

 Accommodation Ineffective 

 Accommodation Would Cause Undue Hardship 

 Medical Documentation Inadequate 

 Accommodation Would Require Removal of an Essential Job 

Function 

 Accommodation Would Require Lowering of Performance or 

Production Standard 

 Other (explain): 

4. DETAILED REASON(S) FOR THE DENIAL OF ACCOMMODATION 

If the individual proposed one type of RA, which is being denied, 

but rejected an offer of a different type of RA, explain both the 

reasons for denial of the requested accommodation and why AP 

believes the chosen accommodation would be effective. 

5. If an individual wishes to request reconsideration of this 

decision, they may make their request known to the NRAB. 

following steps: 

6. Pursuant to 29 C.F.R. § 1614, if a federal applicant or employee 

wishes to file an EEO complaint, they must contact an EEO 

counselor in the OE&I within 45 days from date of this notice of 

denial of reasonable accommodation. 

7. The Alternative Dispute Resolution process may be an option 

offered to a federal applicant or employee. For further guidance 

on the ADR process, please see ND 80-8 and NI 80-8-2. 

Name of Deciding Official: ________________________________ 

Signature of Deciding Official: ________________________________ 

Date reasonable accommodation denied: ________________________________ 

NEXT STEPS 

 Provide Additional Information 

 Meet to Discuss Other Accommodation Options 

 Explore Reassignment 

 Terminate Employment 

 Other: 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

28 

UNCLASSIFIED 

COMMENTS: 
UNCLASSIFIED 

NI 80-3-3, Reasonable Accommodation Process 

FY 2021 

29 

UNCLASSIFIED 

APPENDIX F – SAMPLE REASONABLE ACCOMMODATION REQUEST 

CLASSIFY APPROPRIATELY WHEN FILLED IN 

Equal Accessibility Services Environment (EASE) 

Reasonable Accommodation Request 

Requestor Information 

Last Name: 

First Name: 

NMIS User ID: 

Organization: 

Affiliation: 

Company: 

Office Location: 

Secure Phone: 

Non-Secure Phone: 

Alternate Phone: 

Consumer Information 

Last Name: 

First Name: 

NMIS User ID: 

Organization: 

Affiliation: 

Company: 

Office Location: 

Secure Phone: 

Non-Secure Phone: 

Alternate Phone: 

Supervisor Information

Name: 

Secure Phone: 

Non-Secure Phone: 

Request Information

Category: 

Type: 

Medical Diagnosis: 

Reason for Request: 

Time Sensitive Request: Yes or No

Self-Identification of Disability: Yes or No