National Guard Bureau (NGB)

Army and Air National Guard

Readiness Centers

NGB- Equity and Inclusion (NGB-EI) Office

Reasonable Accommodation Guide

July 2021

Procedures to Facilitate the Provision of Reasonable

Accommodation (RA)

Reasonable accommodation removes workplace barriers for individuals

with disabilities. Reasonable accommodation is available to qualified

employees, regardless if they are part-time, full-time, or job applicants
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Table of Contents

References 3

Purpose 3

Applicability and Scope 3

Policy 3-4

Definitions 4-7

Initiating Reasonable Accommodations Process 7-8

Requesting a Reasonable Accommodation and Personal

Assistance Services 8-10

NGRC’s and Satellite Offices Responsibilities 10-12

Confirming Documentation 12

Processing a Reasonable Accommodations (RA)

and Personal Assistance Services (PAS) Request 13-14

Assessing the Disability Claim 14-17

Time Limits 17-18

Medical Information 19-20

Decision to Grant Accommodate or Deny Accommodate 20

Reassignment Process 21

Denial of Reasonable Accommodation Process 21-22

Information Tracking 23-24

Agency Points of Contact 25

Reasonable Accommodation Resources 26-27

Attachments 27

Attachment 1: Request for Reasonable Accommodation or Personal

Assistance Services...................................................... 27-1

Attachment 2: Physicians Medical Assessment Form..........................27-2

Attachment 3: Documentation of Essential Functions Form................27-3

Attachment 4: Denial of Reasonable Accommodations Request ........ 27-4

Attachment 5: Reasonable Accommodation Information Report ........27-5

Appendix 1: Personal Assistance Services
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NATIONAL GUARD REASONABLE ACCOMODATION GUIDE

References

A. Section 501, Rehabilitation Act of 1973, as amended, 29 U.S.C.§ 791

B. Americans with Disabilities Act Amendments Act of 2008, Titles I and V

C. Executive Order 13164 of 26 July 2000

D. 29 Code of Federal Regulations § 1630

E. EEOC Management Directive 715 (MD-715), 1 October 2003

F. Equal Employment Opportunity and Diversity, Army Regulation 690-12, Appendix C, 12

December 2019

G. Equal Employment Opportunity and Affirmative Employment Programs, AFI 36-205, Chapter8,

1 December 2016

H. EEOC Enforcement Guidance: Reasonable Accommodation and Undue Hardship under the

Americans with Disabilities Act, 17 October 2002

I. Nondiscrimination on the Basis of Handicap in Programs and Activities Assisted or Conducted

by the Department of the Army, 15 December 1993

J. Executive Order 13548, 26 July 2010

Purpose

The purpose of this guide is to establish guidance, outline roles and responsibilities and implement

the provisions of the Reasonable Accommodations (RA) and Personal Assistance Service (PAS)

request.

Applicability and Scope

This guide applies to National Guard Readiness Centers (NGRC) in the National Capital Region

(NCR) and satellite field offices, it covers civilian personnel and military supervisors of civilian

personnel, all appropriated (APF) and non-appropriated (NAF) civilian employees and applicant(s)

for employment.

Policy

The NGRCs will provide this guide for reasonable accommodations to employees and all job

applicants in written and accessible formats as required. The NGRCs reasonable accommodation

policy is an important aspect of our commitment to create employment opportunities for individuals

with disabilities in accordance with References (A) to (J). Managers/supervisors are expected to

make every effort to provide reasonable accommodation to employees with disabilities, unless to

doing so would cause an undue hardship. Reassignment is an option of last resort. It is the NGB’s

policy to reassign a qualified employee with a disability in accordance with applicable references to 

a vacant, funded position within the agency. If the employee is unable to perform, the essential

functions of his/her present position with or without accommodation because of a disability and is

able to perform the essential functions of the identified position, with or without accommodation.
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In accordance with the Rehabilitation Act of 1973, 29 U.S.C. § 791, it is NGB’s policy to provide

reasonable accommodation to qualified employees or applicants with disabilities, unless to do so

would cause undue hardship to the agency. The NGRC’s are committed to providing reasonable

accommodations to NG employees and applicants for employment in order to ensure that

individuals with disabilities have full access to equal employment opportunities at all NG

enterprises. This means that the NGRC’s and satellite field offices provides reasonable

accommodation when:

 An applicant for employment with a disability needs an accommodation in order to be

considered for a job;

 A qualified employee with a disability needs an accommodation to enable him or her to

perform the essential functions of the job or to gain access to the workplace; and

 An employee with a disability needs an accommodation to enjoy equal benefits and

privileges of employment to those enjoyed by employees without disabilities.

NGRC’s Disability Program Manager (DPM) or the Disability Program Coordinator (DPC) will

assist management to process requests for reasonable accommodation and, when appropriate,

provide reasonable accommodations in a prompt, fair, and efficient manner.

This Guide reflects significant changes to the definition of “disability” under the Americans with

Disabilities Act (ADA) and to comply with Equal Employment Opportunity Commission

(EEOC) regulations on agency implementation of the Rehabilitation Act, 29 C.F.R. § 1614.203.

The NGRCs will apply the standards set forth in Title I of the ADA Amendments Act of 2008

(ADAAA) when determining whether and to what extent to provide reasonable accommodation

under the Rehabilitation Act. The ADAAA emphasizes that agencies should construe the definition

of disability in favor of broad coverage of individuals, making it easier for an individual seeking

protection under the ADA to establish that he or she has a disability within the meaning of the

statute.

In accordance with applicable EEOC regulation, 29 C.F.R. § 1614.203(d)(5), it is NGB’s policy to

provide access to personal assistance services (“PAS”) to individuals with targeted disabilities.

NGRCs will process requests and make determinations for PAS in the same manner as it processes

requests and makes determinations for reasonable accommodation.

Definitions:

A. Accessible: Enterable, operable, safely usable, or otherwise open to participation,

independently and with dignity, by a person with a disability. The term “accessible” can

apply to a work environment, service, program, etc.
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B. Appeal: A voluntary process through which an individual can request reconsideration of a

denial of a request for reasonable accommodation.

C. Applicant: A person who has applied, or would like to apply, for employment at

NGB/NGRCs.

D. Decision Maker: The NGRCs official with the authority to make a determination on

whether or not to provide an accommodation in a given circumstance. The decision maker

can be the Senior Leader, an immediate supervisor, an Office or Division Director, with

authority over the appropriate office or division, or the Director or Deputy Director of the

Office of Human Resources.

E. Denial: A determination by the decision maker to deny a request for a specific reasonable

accommodation where the decision maker does not offer an alternative reasonable

accommodation or where the requester declines an alternative reasonable accommodation

offered by the decision maker.

F. Disability: With respect to an individual, (1) A physical or mental impairment that

substantially limits one or more major life activities; (2) a record of such an impairment; or

(3) being regarded as having such an impairment, which means that the individual has been

subjected to an action prohibited by the ADA as amended because of an actual or perceived

impairment that is not both “transitory and minor.”

G. Employee. A person employed by the National Guard (Department of the Army or

Department of the Air Force).

H. Essential Functions: The fundamental job duties of the employment position the individual

with a disability holds or desires. The term “essential functions” does not include the

marginal functions of the position. A job function may be an “essential function” if, among

other things: (1) the reason the position exists is to perform that function; (2) there are a

limited number of other employees who could perform the function; and/or (3) the function

is specialized and the individual is hired based on his or her ability to perform that particular

function.

I. GINA: Genetic Information Nondiscrimination Act of 2008, Pub. L. 110-233.

J. Grant: A determination by the decision maker to approve either a request for a specific

reasonable accommodation or a reasonable accommodation other than that requested but

which both the requester and decision maker believe will be effective.

K. Individual: The applicant or employee for whom the accommodation is requested.
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L. Interactive Process: An informal process by which the NGRC DPM/DPC will communicate

with an employee or applicant who has requested a reasonable accommodation. This

process will identify the specific limitations resulting from the disability and potential

reasonable accommodations that could overcome those limitations.

M. Personal Assistance Services (PAS): 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 include, but are not

limited to, assistance with removing and putting on clothing, eating, and using the restroom.

Per EEOC Regulation, agencies need only provide PAS to individuals with “targeted

disabilities,” as defined below.

N. Physical or Mental Impairment: Any physiological disorder or condition, cosmetic

disfigurement, or anatomical loss affecting one or more body systems, such as the

neurological, musculoskeletal, special sense organ, respiratory (including speech organs),

cardiovascular, reproductive, digestive, genitourinary, immune, circulatory, hemic,

lymphatic, skin, and endocrine systems; or any mental or psychological disorder, such as an

intellectual disability (formerly termed “mental retardation”), organic brain syndrome,

emotional or mental illness, and specific learning disability.

O. Qualified: With respect to an individual with a disability, “qualified” means that the

individual satisfies the requisite skill, experience, education and other job-related

requirements of the employment position such individual holds or desires and, with or

without reasonable accommodation, can perform the essential functions of such position

P. Reasonable Accommodation: Modifications or adjustments to a job application process

that enables a qualified applicant with a disability to be considered for the position such

qualified applicant desires; 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; modifications or adjustments that enable an employee 

with a disability to enjoy equal benefits and privileges of employment as are enjoyed by its 

other similarly situated employees without disabilities.

Examples of accommodation include, but are not limited to:

a. Making existing employee facilities readily accessible to and useable by individuals

with disabilities;

b. Job restructuring;

c. Part-time or modified work schedules;

d. Reassignment to a vacant position (and not just permission to compete for such a

position);
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e. Acquisition or modifications of equipment or devices;

f. Appropriate adjustment or modifications of examinations, training materials, or

policies; and

g. Provision of qualified readers or interpreters.

Q. Requester: The person who requests the reasonable accommodation or PAS. The requester

can be the disabled applicant or employee, or a family member, healthcare professional, or

other representative of the disabled applicant or employee.

R. Targeted Disability: a disability that is designated as a “targeted disability or health

condition” on the Office of Personnel Management’s Standard Form 256 or that falls under

one of the first 12 categories of disability listed in part A of question 5 of the Employment

Opportunity Commission’s Demographic Information on Applicants form. Targeted

disabilities include, but are not limited to, deafness or serious difficultly hearing, blindness

or serious difficulty seeing even when wearing glasses, missing extremities, partial or

complete paralysis, significant mobility impairment, intellectual disability, and significant

psychiatric disorders.

S. Undue Hardship: a special or specified circumstance that partially or fully exempt a person

or organization from performance of a legal obligation so as to avoid an unreasonable or

disproportionate burden or obstacle.

Initiating the Reasonable Accommodation Process

Who Can Submit a Request for Reasonable Accommodation?

 An employee or an applicant for employment.

 A family member, friend, health professional, or other representative may request RA on behalf

of an individual with a disability.

Identify the Request for Reasonable Accommodation

 For tracking purposes, the Reasonable Accommodations Coordinator requires a request from 

either the RA requestor or the supervisor. This form can be provided in alternative formats if 

requested, however, the manager/supervisor cannot ignore an initial oral request. 

Management must engage in an informal interactive process to clarify what the employee 

specifically needs and identify the appropriate RA. Appendix A provides resources available 

to employers to help identify appropriate accommodations. (Attachment 1)
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 A request can be made in “plain English”. The Americans with Disabilities Act, Rehabilitation

Act, or the phrase “reasonable accommodation” does not have to be mentioned in order for a

request to be considered a request for RA.

 Once the RA request is communicated to/with the Supervisor, the Supervisor must submit the 

RA request to the RA Coordinator within two (2) business days, the RA Coordinator starts the

process.

 Supervisor/manager and RA Coordinator will hold interactive discussions with the employee

immediately and throughout the entire process as needed to assist in making the determination

whether the employee is a qualified individual with a disability and will determine if medical

documentation is necessary.

 An employee who requires a RA on a repeated basis (e.g., a sign language interpreter) does not

need to submit a new written request each time an accommodation is required.

 The RA request must include a statement for an adjustment or change at work to a reason

related to a medical condition.

 EXAMPLE 1. “I’m having trouble getting to work at my scheduled starting time

because of medical treatments I’m undergoing.”

 Do not disclose that an employee is receiving RA because it usually amounts to a disclosure

that the individual has a disability.

Requesting a Reasonable Accommodation

A request for reasonable accommodation is a statement that an individual needs an adjustment or

change in the application process, at work, or in a benefit or privilege of employment for a reason

related to a disability.

A person may initiate any request for reasonable accommodation orally or in writing at any time.

Doing so initiates the interactive process. The requester does not need to:

 Fill out any specific form in order to initiate the interactive process;

 Have a particular accommodation in mind before making his or her request;

 Use any special terms like “reasonable accommodation” or “disability” when making his or

her request.

In light of the above guidance, NG managers or supervisors and other employees should recognize

that a person might not always state a request for reasonable accommodation plainly.
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A request is any communication in which an individual asks or states a need for the NGRCs to

provide or to change something because of a medical condition. A person does not have to specify a

particular accommodation although it is helpful if he or she can suggest one. It is sufficient for the

individual requesting accommodation to state that some sort of change or assistance is required.

A manager or supervisor should know that a request for a reasonable accommodation could be 

a statement in “plain English” that an individual needs an adjustment or change in the

applicationprocess or at work for a reason related to a medical condition.

If an employee or applicant raises any of the following points, he or she is likely requesting a

reasonable accommodation:

 The person is talking about some type of medical condition that is impacting his or her

work;

 The person mentions some sort of physical/intellectual/psychiatric challenge that is

impacting his or her work;

 The person requests an adjustment or change to the workplace;

 The person openly discloses a disability or medical condition;

 The person states that he or she needs assistance performing a job function.

Whenever a supervisor or other employee is uncertain as to whether a person seeks reasonable

accommodation, he or she shall ask that person for clarification.

A requester does not need to have previously disclosed the existence of a disability prior to

requesting a reasonable accommodation.

An Applicant may request a reasonable accommodation from any Human Resources Specialist or

RA Coordinator, the selecting official, or any NGRC satellite RA Coordinator connected with the

staffing application process. In cases when an applicant does not make a request to a Human

Resources Specialist, the selecting official or NGRC RA Coordinator must forward the request to

the Office of Human Resources as soon as possible, but in any event, no later than two business

days after receiving the request.

An Employee may request a reasonable accommodation from one of the following officials:

 His or her immediate supervisor, as well as any another supervisor or manager in the

employee’s chain of command; or

 The Director or Deputy Director of the Office of Human Resources, or a designated Human

Resources Specialist; NGRC RA Coordinator or NGB-EI Disability Program

Manager/Coordinator.
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In cases when an employee does not make a request to the ultimate decision maker, the official who

receives the request will forward it to the appropriate decision maker as soon as possible, but in any

event, no later than two business days after receiving the request.

A family member, healthcare professional, or other representative may request a reasonable

accommodation on behalf of a National Guard (Army or Air) applicant or employee. Under such

circumstances, the requester should submit the request to the same persons to whom the employee

or applicant would make the request.

Any National Guard (Department of the Army Department of the Air Force) applicant or employee

may consult with the Director or Deputy Director of the Office of Human Resources, or a

designated Human Resources Specialist; NGB-EI Disability Program Manager/Coordinator for

further information or assistance in connection with requesting or processing a request for

reasonable accommodation.

NGRCs and Satellite Office Personnel Responsible for Handling Requests

Each organizational element shall designate those officials delegated principal responsibility for

identifying possible accommodations and for determining whether an accommodation will be provided.

The Decision-maker may differ depending on whether the request is initiated by an employee or an

applicant, or the type of accommodation being requested. As explained above, the NGRC staff member

who receives a request for reasonable accommodation must forward such request to the appropriate

decision maker as soon as possible, but in any event, no later than two business days after receipt.

For example, the Decision-maker could be as follows:

o the organizational element Human Resource Specialist responsible for the recruitment and/or

selection process if the request for accommodation is from an applicant;

o the organizational element Disability Program Manager if the accommodation requested is for

adaptive equipment, a reader or sign language interpreter, removal of an architectural barrier,

accessible parking, or materials in alternative formats;

o the head of the office or his/her designee where the accommodation requested involves

personnel actions; or

o if the requests are from an employee, the Decision-maker might be the employee's immediate

supervisor or the head of the office.

All decision makers must designate reserve officials who can continue receiving, processing, and

providing reasonable accommodations when the decision maker is not available.

To ensure that NGRCs handle reasonable accommodation requests consistently and fairly

throughout the organization, the decision maker shall inform, and consult with, the Office of

Human Resources and Facilities management when deemed necessary as to all such requests prior

to making a final decision.
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Responsibilities

NGB Equity and Inclusion (NGB-EI) Office shall:

 Communicate and implement NGRC’s policy for the processing of reasonable accommodation

requests.

 Allocate sufficient personnel to staff the reasonable accommodation function within NGRCs.

 Ensure that officials responsible for processing reasonable accommodation requests are trained

on program requirements, to include relevant legal principles/precedent.

 Ensure that all reasonable accommodation requests are processed within the applicable

timeframe.

Reasonable Accommodations Coordinator: (NGB-EI DPM)

 Manage and assist in coordinating all reasonable accommodation requests.

 Ensure that all reasonable accommodation requests are processed in accordance with applicable

references.

 Collaborate with supervisor(s) during the on-going, informal interactive discussion(s) with the

individual seeking an accommodation.

 Involve appropriate personnel who provide recommendations to the person responsible for

making the decision on a request for reasonable accommodation.

 Update the appropriate tracking and monitoring system for reasonable accommodation requests.

 Maintain all reasonable accommodation case files in a secure manner.

 Ensure the confidentiality of medical information. Access to this information is limited to a

need to know.

Managers and Supervisors shall:

 Immediately contact the RA Coordinator upon knowledge of or receipt for request for a

reasonable accommodation, within two (2) business days.

 Process all reasonable accommodation requests in accordance with the procedures outlined in

this guide.

 Maintain an open line of communication with the employee seeking an accommodation and

engage in on-going, informal discussion(s) with the employee during the reasonable

accommodation process.

 Management Official will determine the approval or denial of an RA

An Employee and/or Applicants for employment shall:

 Employees will immediately notify their first-level supervisor or the RA Coordinator when it is

determined that some form of reasonable accommodation is required in order to perform the

essential functions(s) of their position of record.

 Request a RA/PAS during the application process.
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 Request a RA when she/he knows that there is a workplace barrier that is preventing her/him,

due to a disability, from effectively competing for a position, performing a job, or gaining equal

access to a benefit of employment.

 Actively participate in the interactive discussion portion of the reasonable accommodation

process.

 Provide all documentation, to include medical documentation, if requested, as part of the

reasonable accommodation process.

Joint Human Capital Management (JHCM) shall:

 JHCM will be the first line of effort in providing Applicants for Employment with disabilities

the support required.

 Participation in the application process; RA or PAS must be provided to a qualified applicant

with a disability in order to have an equal opportunity to participate during the application

process.

 Hiring process; Inform all applicants for employment what the hiring process involves, e.g.,

interview, timed written test, or job demonstration; ask all applicants whether they will need a

RA for this process; and explain the RA procedures.

Confirming Documentation

Although an employee may initiate a reasonable accommodation request orally, for record keeping

purposes, and upon receiving any request other than one for assistive technology and/or services,

the decision maker should ask the employee (or someone acting on the employee’s behalf) to

complete the Confirmation of Request for Reasonable Accommodation or Personal Assistance

Services Form (Attachment 1). Should the employee fail to complete this form, the employee’s

immediate supervisor or the decision maker shall complete it on the employee’s behalf and seek the

employee’s consent before adding the form to the employee’s personnel file.

For any request in which the employee requests assistive technology and/or services, the decision

maker should request that the employee complete a CAP Accommodation Request online at

www.cap.mil or complete the form on the employee’s behalf.

NGRC’s RA Coordinator will begin processing a request for reasonable accommodation as soon as

it is communicated, whether or not the employee provides written confirmation as described in this

section.
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Processing Reasonable Accommodation Request

1. Once an applicant or employee (or a person acting on their behalf) makes a request for reasonable

accommodation, the requester and decision maker will begin the interactive process to determine whether

and to what extent the NGRC or satellite office will provide reasonable accommodation.

The decision maker will:

 Explain to the requester that he or she (i.e., the decision maker) will determine whether or

not the NGRC or satellite office will provide reasonable accommodation; and

 Describe the decision making process to the requester.

2. When a third party makes a request for accommodation on an individual’s behalf, the decision

maker should, if possible, confirm with the applicant or employee that he or she, in fact, wants a

reasonable accommodation before proceeding further with the interactive process.

3. Management must communicate with the requester early in the interactive process and

periodically throughout the process regarding his or her request to ensure the complete exchange of

relevant information. To track the processing of his or her request, the requester may at reasonable

intervals, ask that the decision maker describe the status of his or her request.

4. Ongoing communication is particularly important where the specific limitation, barrier, or

problem is unclear; when an effective accommodation is not obvious; or when the parties are

considering different possible reasonable accommodations.

5. As noted above, a supervisor should know that a request for a reasonable accommodation could

bea statement in “plain English” that an individual needs an adjustment or change in the 

application process or at work for a reason related to a medical condition. The request does not 

have to includethe terms “ADA” or “reasonable accommodation,” and the request does not have to 

be in writing, although the supervisor may ask for something in writing to document the request. A 

family member, friend, health professional, rehabilitation counselor, or other representative also 

may request a reasonable accommodation on behalf of an NGB employee with a disability.

6. The management or decision maker must take a proactive approach in searching out and

considering possible accommodations. To that end, and as explained above, the decision maker

shall consult with the Office of Human Resources with respect to all requests for reasonable

accommodation. The decision maker may consult with other appropriate offices and resources as

necessary, including the Office of the General Counsel, the Office of Information Resources

Management, the Administrative Services Office (including via submission of necessary

requisitions), and, in the case of assistive technology, devices, and services, the Department of

Defense’s Computer/Electronic Accommodations Program (“CAP”) . The requester should also

participate, to the extent possible, in identifying an effective reasonable accommodation.
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Coordination of Efforts

 When the RA Coordinator or Management official is made aware of the need for RA, 

coordination betweenthe RA Coordinator and Management will take place within two (2) 

business days. The initial email will include Attachments 1, 2, and 3.

 Requests for RA that will require funding by NGRCs will be analyzed and processed by the RA

Coordinator and when necessary Medical and Legal personnel. The employee’s responsible 

management official will make final approval or denial.

 If the employee deviates from the RA process and contacts the RA Coordinator prior to an

interactive discussion with their supervisor, the RA Coordinator will contact the supervisor of

the individual immediately upon receipt of request; the supervisor is best able to identify and

define the essential functions of a position.

 Supervisor/Manager will engage in the interactive process with the requesting employee. At

times, when an accommodation can be made without obligation of funding, supervisor/manager

may approve a request for RA. Supervisor/manager will complete Attachments 1 and 5, and

forward them to RA Coordinator within two (2) business days of approval for tracking and

oversight.

 Special circumstances may influence the timing of the RA process. The expedited processing of

a RA request may be appropriate in the following situations:

 The RA is needed to enable a person to apply for a job; or

 The RA is needed for a specific activity that is scheduled to occur shortly.

 The organization has thirty (30) business days to process a request. If unable to process the

request in 30 business days, the RA Coordinator will notify the supervisor who must document

and communicate in writing to the requestor reason for the delay. This time period does not

include waiting to receive information from the requestor/healthcare provider or the time it

takes to receive adaptive equipment.

ASSESSING THE DISABILITY CLAIM

Determine if the employee has a disability.

 An individual meets the Americans with Disabilities Act definition of “disability” that would

qualify them for reasonable accommodations if they have “a physical or mental impairment that

substantially limits one or more major life activities (sometimes referred to in the regulations as

an “actual disability”).” If a disability is not obvious to an employer, they can ask for medical

documentation from a health care provider to confirm the need for an accommodation.

(Attachment 2) All supporting medical documentation must be in English.
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 Does the employee have a physical or mental impairment that substantially limits one or more

of his/her major life activities?

 Physical Impairment. Any physiological condition or disorder, cosmetic disfigurement,

anatomical loss affecting one or more of the following body systems: neurological,

musculoskeletal, special sense organs, respiratory, cardiovascular, reproductive, digestive,

genitourinary, immune, circulatory, hemic, lymphatic, skin, and endocrine.

 Mental Impairment. Any mental or psychological disorder such as, intellectual disability,

organic brain syndrome, emotional or mental illness, and specific learning disabilities.

 Major Life Activity. Illustrative, non-exhaustive list of major life activities include caring

for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, speaking,

standing, lifting, bending, communicating, thinking, learning, breathing, sitting, reaching,

interacting with others, reading, concentrating, working. Major life activities also include

the operation of major bodily functions, such as functions of the immune system, special

sense organs and skin, normal cell growth, digestive, genitourinary, respiratory, circulatory

and cardiovascular functions.

 Exceptions. If an employee is currently using illegal drugs, to include illegal usage of legal

drugs such as prescription medications, the employee does not meet the definition of an

employee with a disability.

Determine if the Individual is a Qualified Individual with a Disability.

 A “qualified individual with a disability” is an individual who, with or without an

accommodation can:

 Perform the essential functions of the position in question.

 Meet the prerequisite skill, experience, education and other job-related requirements of the

position in question.

 Meet the criteria for appointment under one of the special appointing authorities for

individuals with disabilities.

Management and JHCM will:

 Determine if employee can perform essential functions of the positions.

 To be qualified for a position, an applicant or employee must be able to perform essential job

functions. Essential functions are job duties that are fundamental to the position, they are the

reason the job exists. Some of the factors for determining essential functions of a job include:
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 Whether the position exists specifically to perform these essential functions.

 The number of other employees who are available to perform the same job duties.

 The expertise or skills required to perform the essential functions.

 Can the employee perform the essential functions of the position, with or without an

accommodation?

 The essential functions of a job are not the marginal or infrequently performed tasks that

could be eliminated without altering the fundamental nature of the job.

 In some cases, an accommodation may involve restructuring a job or altering the

nonessential requirements of a particular position. Job restructuring includes modifications

such as:

 Reallocating or redistributing marginal job functions that an employee is unable to

perform because of a disability; and

 Altering when and/or how a function, essential or marginal, is performed.

NOTE: Remember that the goal of RA is to enable qualified individuals with disabilities to

perform the essential functions of their position and to enjoy equal employment opportunities,

unless doing so would impose an undue hardship on the operation of its programs and/or poses a

direct threat to the employee or others. At times, a Position Description does not capture all of

the essential functions of job. If necessary, a Documentation of Essential Functions form will

need to be completed by the Supervisor and the employee’s physician (Attachment 3).

FMLA Coordinator will: 

 Manage all documentation for Medical requests.

 Medical documentation may be required to assist in determining whether a person is a

qualified person with a disability. If appropriate and with the employee’s consent, an

examination by a medical specialist of the NGRCs choosing and expense may be required.

Confidentiality Requirements Regarding Medical Information.

 Under the Rehabilitation Act, medical information obtained in connection with the RA process

must be kept confidential. All medical information obtained in connection with a request must

be kept in a secure location in locked files separate from the employee’s official personnel file.

Any employee who obtains or receives such information is strictly bound by confidentiality

requirements and may disclose this information only as follows:
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 Management officials who need to know (including the decision maker who requested the

medical information be obtained) may be told about necessary restrictions of the work or

duties of the employee and about the accommodations necessary for the employee to

perform her/his duties. However, information about the employee’s general medical history

should only be disclosed if strictly necessary.

 Worker’s compensation offices or insurance carriers and EEO staff.

 First aid and safety personnel may be informed, when appropriate, if the employee might

require emergency attention or treatment because of the disability.

 Information may be given to government official or contractors assigned to investigate

agency compliance with the Rehabilitation Act.

Time Limits for Assessment:

It is the NGB’s goal to provide reasonable accommodations as quickly as possible to remove the

workplace barriers for an employee or applicant. Full and open communication between the

employee, the decision-maker, and the reasonable accommodation team (NGRCs/JHCM) is a

critical component of the accommodation process, and helps to ensure that there is a full exchange

of relevant information so the Organization can make appropriate decisions.

NGRC’s and satellite offices will process requests for reasonable accommodation and provide

reasonable accommodation, where appropriate, in as short a timeframe as is reasonably possible,

absent extenuating circumstances. The precise time necessary to process, a request will depend on

the nature of the accommodation requested and whether the RA Coordinator must obtain supporting

information.

Normal processing: The NGRC’s and satellite offices will process requests for reasonable

accommodations and provide accommodations, when appropriate, as soon as reasonably possible.

a. The process begins when an applicant or employee makes an oral or written request for

reasonable accommodation and not necessarily when the decision maker receives the written

confirmation of the request. All parties, however, should recognize that the time necessary to

process a request would depend on the nature of the accommodation requested and whether it 

isnecessary to obtain supporting information and medical documentation. 

Supervisors/decisionmakers should have backups designated to continue receiving and 

processing requests and providing reasonable accommodations when the supervisors/decision 

makers are unavailable.Decision makers should ensure that the individuals know who has

been designated as backup.
b. A supervisor or decision maker receiving a request for reasonable accommodation may be able to

grant the request immediately. Absent extenuating circumstances, the requested accommodation

should be provided or denied within 30 business days from the date the decision maker receives the

initial request. NGRC and satellite offices will not be expected to adhere to its usual timelines if an

individual’s health professional fails to provide needed documentation in a timely manner.

c. When a delay occurs in processing a request for or providing a reasonable accommodation, the

decision maker must notify the requester of the reason for the delay. Upon becoming aware of the

need for a delay, the decision maker must contact the DPM to determine whether a provisional

accommodation can be provided. A decision maker could consider a temporary job restructuring or

the use of equipment that might permit the individual to perform some of the functions of the job.

When all the facts and circumstances known to the agency make it reasonably likely that an 

individual will be entitled to a reasonable accommodation, but the accommodation cannot be 

provided immediately, the agency shall provide an interim accommodation that allows the 

individual to perform some or all of the essential functions of his or her job, if it is possible to do 

so without imposing undue hardship on the agency

d. The processing of reasonable accommodation requests may be expedited in appropriate cases.

Expedited processing might be necessary where, 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.

Examples of reasonable accommodation that the NGRC or satellite office in collaboration with the

RA Coordinator can easily can provide within the 30 business-day timeframe include:

 Providing a diabetic employee whose workstation is in an open area with four breaks a day

to test his or her blood sugar levels in private.

 Providing an employee with a learning disability with staff meeting agendas in sufficient

time for him or her to adequately prepare for the meeting.

Where the NGRC’s and satellite offices can provide a particular reasonable accommodation in less

than 15 business days, failure to provide such accommodation in a prompt manner may result in a

violation of the Rehabilitation Act.

e. “Extenuating circumstances” are situations that could not reasonably have been anticipated or

avoided in advance of the request for accommodation, or that are beyond the requester’s or decision

maker’s ability to control. 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 in which they are reasonably

necessary and only for as long as required to deal with the extenuating circumstance.

The following are examples of extenuating circumstances:

 Where it will take the NGRCs or satellite offices longer than 30 business days to acquire

necessary equipment or furniture due to the Federal Acquisition Regulations or CAP

requirements.

 Where a vendor is not able to provide necessary equipment or furniture within 30 business

days and no alternate vendor is available.

 Where an individual with a disability requires a trial period to test equipment or furniture to

ensure its effectiveness.

18
 Where the reasonable accommodation requires the removal of architectural barriers.

When extenuating circumstances are present, the decision maker must notify the requester as soon

as possible of the reason for any delay and the approximate date by which he or she may expect a

decision regarding their request.

Medical Information:

a. When the disability and/or need for accommodation is not obvious, the employee or applicant

seeking accommodation may be asked to provide appropriate medical information related to the

functional impairment and/or limitations at issue and the requested accommodation. Supplemental

documentation may be requested when the information already submitted is insufficient to

document the disability and/or the functional limitations. The decision maker should consider

providing an interim accommodation until medical documentation is received and a final decision is

made on a reasonable accommodation. Failure to provide necessary documentation when it has

been properly requested could result in a denial of reasonable accommodations.

b. Medical documentation contains PII and is sensitive information about an individual’s medical 

condition, and must be handled in a confidential manner. The decision maker must seek the

assistance of the DPM before obtaining any medical documentation. The DPM, in coordination

with the servicing labor counselor/agency attorney (as needed), will assist in obtaining appropriate

medical documentation.

c. Medical information will be requested only to the extent reasonably necessary to establish that

the requester is an individual with a disability and/or needs the requested accommodation and

provide information on the nature, severity, and expected duration of the impairment (for example,

functional limitations, symptoms, side effects of any treatments, and so forth); the activity or

activities the impairment limits; the extent to which the impairment limits the individual’s ability to

perform the activity or activities; and/or why the individual requires the particular accommodation

requested and how the accommodation will assist the individual to apply for a job, perform the

essential functions of the job, or have the benefits of the workplace.

d. Based on the medical documentation provided, the decision maker may elect to approve the

request for reasonable accommodation. On a case-by case basis, the decision maker may submit

medical documentation to the occupational medicine physician or other medical expert for

assistance in assessing functional abilities regarding that individual’s ability to perform a job, in

order to help the decision maker choose an effective reasonable accommodation. The information

should inform the medical authority of the nature of the job, the essential functions the individual

will be expected to perform, and any other information relevant to evaluating the request.

19
e. The medical authority may request supplemental medical documentation when the submitted

information is insufficient to document the existence of a disability and the need for reasonable

accommodation.

f. If the supplemental medical documentation does not result in sufficient information, the

organization may require the employee requesting the accommodation to be examined by a health

care professional of the organization’s choice at the activity’s expense.

Points to Remember:

 To determine whether the individual has a disability, an individualized assessment must be

made by medical professionals.

 Decisions cannot be made based upon personal knowledge of, or experience with, a particular

condition or generalizations based upon stereotypes or myths.

 Decisions made about RA, are very fact-specific and individualized. There is one condition

that does not necessitate this individualized assessment, AIDS or HIV positive. This

condition is considered disabling even if there are no symptoms.

 Once all relevant information has been obtained from the employee, the RA Coordinator must

conduct an analysis to determine whether the employee meets the definition of a qualified

individual with a disability and communicate the findings with management.

 The analysis and the management decision must be documented in writing by the RA

Coordinator and filed for the record in the case file.

DECISION TO GRANT ACCOMMODATE or DENY an ACCOMMODATE

Decisions to Grant an Accommodation.

 If the RA Coordinator determines that providing an accommodation is the appropriate course of

action, all reasonable alternatives to accommodate the individual in their current position will

be explored, e.g., assistive software/devices, modified furniture, location of desk, job

restructuring, telework, etc. The employee will be notified in writing,

 Hold an interactive discussion with the employee – they can advise the supervisor what she/he

thinks is needed to enable them to perform the job.

20
 Consult with other management officials, facilities, safety and/or medical personnel, to

determine whether the employee’s proposed accommodation is feasible and/or whether the

accommodation can be made.

 An employer must respond expeditiously (within 30 business days) to a request as a lack of

action amounts to a denial.

 The deciding official for RA is the employee’s Management Official or JHCM for applicants.

Reasonable Accommodation Options.

 Personal Items. The NGRCs are not required to provide personal use items, i.e., glasses, hearing

aids, wheelchairs.

 Select the accommodation that is the most appropriate for both management and the individual.

It does not need to be the best or most expensive, or even the one preferred by the employee. As

long as the accommodation is reasonable and enables the employee to perform the essential

functions of their position, it is acceptable.

Reassignment Process:

 Reassignment is the accommodation of last resort and is available only to employees, not

applicants. Supervisors/decision makers will consider a reassignment only if no reasonable

accommodations are available to enable the individual to perform the essential functions of

his/her current position, or if the only effective accommodation would cause undue hardship.

Reassignment may be made only to a vacant position. The organization will not create new

positions or displace employees from their jobs.

 The vacant position is considered available as long as a selection to fill the position has not been

made and no DOD Priority Placement Program matches are pending. An employee is qualified

for the identified reassignment if he/she satisfies the requisite skill, experience, education, and

other job-related requirements of the position and can perform the essential functions of the

position with or without reasonable accommodation. If the employee is qualified for the

position, he/she should be reassigned to it as a reasonable accommodation and not have to

compete for the position. If a reassignment is under consideration, the decision maker must

consult with the servicing CPAC and Staff Judge Advocate. The servicing CPAC will conduct a

vacancy search based on the employee’s expressed preference and qualifications. The decision

maker should explain to the employee why he/she cannot be accommodated in the current

21
position and that a reassignment is under consideration.

 The decision maker should determine the employee’s preferences with respect to the

reassignment, such as whether the employee is willing to be reassigned outside the facility or

outside the commuting area, including outside the geographical area and, if so, to what

locations; be reassigned to a different type of position he/she may be qualified for and, if so, to

what type(s); be reassigned to a different subcomponent of the department and, if so, to which

one(s); and be reassigned to a lower grade or pay band position if no position is available at the

current grade or pay band and, if so, down to what grade or pay band.

 The reassignment should not create an adverse personnel action or adversely affect the

employee’s career.

 If an employee is reassigned outside the local commuting area or to a different geographical

area, the employee must pay any relocation expenses unless the activity routinely pays such

expenses when granting voluntary transfers to other employees.

Denials of Reasonable Accommodations:

a. Decision makers must inform the DPM and Staff Judge Advocate before denying a request for

accommodation or the particular accommodation requested. The decision maker must provide

documentation that demonstrates the effort made to explore, with the requester, other options for

accommodation. The organization must obtain legal reviews for all proposed denials of a

reasonable accommodation or the particular accommodation requested before informing the

requester of the denial.

b. When the decision maker denies an individual’s request for an accommodation, he/she must

notify the requester of the denial in writing or other forms as requested. The notification must be in 

plain language and state the specific reason(s) 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 be ineffective, the reasons the decision 

maker believes the offered accommodation would be effective, or why the requested 

accommodation would pose an undue hardship). The written denial must identify the 

supervisor/manager and the office that made the decision and provide information about the 

individual’s right to file an EEO Complaint; the right to file an appeal with MSPB; the right to file 

a Union Grievance and invoke other applicable statutory or regulatory processes, including the 

availability of the informal Alternative Dispute Resolution (ADR) process. This form will be

available in an accessible format when requested.

c. Voluntary use of Alternative Dispute Resolution (ADR) is highly encouraged as an informal

dispute resolution process. Individuals may use this avenue to obtain prompt reconsideration of

the denied request for reasonable accommodation. For information on how to initiate the ADR

process, Army and Air National Guard civilian employees may contact the ADR point of contact

through the office of NGB/EI/CMD at (571) 296-4723.

22
d. The decision maker must complete the memorandum for the record documenting the denial of

accommodation request and submit it to the staff judge advocate along with a copy of the written

notification of denial.

e. In determining whether a proposed reasonable accommodation poses an undue hardship, the

decision maker, in consultation with the DPM and the labor counselor/agency attorney, must

consider the overall resources and options available to the NGBRCs, not just the budget or

resources of an individual segment, subcomponent, or division within the NG. The satellite field

offices will ensure individuals with disabilities are not excluded from employment due to the

anticipated cost of a reasonable accommodation if resources available to the organization as a

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

accommodation, would enable it to provide an effective reasonable accommodation without undue

hardship.

Information Tracking System(s):

a. The local EEO office will establish a system of recordkeeping to track the processing of requests

for reasonable accommodation. The decision maker who processed the accommodation request

must complete and submit information to the DPM. A Sample format is available in this appendix.

b. Records that contain medical information about a particular individual with a disability are

subject to the confidentiality restrictions and the organization’s recordkeeping systems must

ensure there are safeguards to ensure that those restrictions are adhered too.

c. At a minimum, the records related to an employee who requested a reasonable accommodation

should be maintained for the duration of the employee’s tenure to ensure that the employee is not

asked to provide medical information previously submitted. After the employee’s tenure, these 

records will be maintained in accordance with the NG’s records retention policies.

d. The EEO office will retain information or any cumulative records used to track the activity’s

performance with regard to reasonable accommodation for at least 5 years. Tracking performance

over a 5-year period is critical to enable the activity to assess whether it has adequately processed

and provided reasonable accommodations. Records may be used to determine whether it is

complying with nondiscrimination and affirmative action requirements imposed under Section

501 and to make such records available to the Equal Employment Opportunity Commission upon

their request.

e. Information is summarized in the annual MD 715 Report to the EEOC through the

State/Territory channels. On an annual basis, the “States” will report the following information as

partof the reporting process:

(1) The number of reasonable accommodations, by type, that have been requested for the

application process and whether those requests have been granted or denied.

23
24

(2) The specific reasonable accommodation requested, if any;

(3) The job (occupational series, grade level, and agency component) sought by the requesting 

Applicant or held by the requesting employee;

(4) 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;

(5) Whether the request was granted (which may include an accommodation different from the one 

requested) or denied;

(6) The amount of time taken to process each request for reasonable accommodation.

(7) The sources of technical assistance that was consulted in trying to identify possible

 reasonable accommodations.

(8) Relevant information will be examined during NGB-EI’s EEO Program reviews. NGB-EI’s

 review will evaluate the activity’s performance in responding to requests for Reasonable

 Accommodation. Reviews will include:

(9) The length of time it takes the satellite field office to respond to requests for different types

 of reasonable accommodations.

(10) Whether the satellite field office has been unable to provide any particular types of

 reasonable accommodations.

(11) Whether any satellite field offices consistently are not granting reasonable accommodations,

 and the various reasons for a denied request for reasonable accommodation.

(12) The identity of the deciding official.

Personal Assistance Services (PAS)

The process for requesting PAS, the process for determining whether PAS are required (including

whether the individual has a targeted disability), and Disability Program Manager’s right to deny a

request for PAS when providing PAS would pose an undue hardship, are the same as those for

requests for reasonable accommodation provided in this directive. These requests along with any

cost associated with them are to be included on the Tracking System(s).

NGRC’s and satellite offices will not provide PAS outside of the scope of working hours.
25

APPENDIX

Reasonable Accommodation Points of Contact:

NGB Office of Joint Human Capital Management

Katherine (Katie) Hauserman

National Guard Bureau - Human Resources (NGB-HR)

Civilian Management

Phone: (703) 607-9934

DSN: 327-9934

Email: Katherine.s.hauserman.civ@mail.mil

POC for Worker’s Compensation and Insurance matters

ANG Office of Human Resources

Ms. Tristin Pilat

NGB-HRC, HR Specialist

Telework: 810-347-4409

Tristin.pilat@us.af.mil

NGB-Equity and Inclusion Office

Ms. Ijigale Beltran

Disability Program Manager

Phone: (720) 341-5558

DSN: 612-9694

Email: Ijigale.beltran@us.af.mil

NGB-Equity and Inclusion Office

Ms. Jaqueline Ray-Morris

Special Emphasis Program Manager, DPM

Phone: (703) 607-1710

DSN: 327-1710

Email: Jacqueline.ray-morris.civ@mail.mil

NGB-EI Affirmative Employment Branch (AEP) Mailbox: ng.ncr.ngb-arng.mbx.eeo-aep
26

Additional Information Regarding Reasonable Accommodation

The Architectural Barriers Act (ABA) requires that buildings or facilities designed, constructed

(including additions), altered, leased, or financed by the United States after August 12, 1968 be

accessible to individuals with disabilities. For more information, check out the ABA website

https://www.access-board.gov

ADA Disability and Business Technical Assistance Centers (DBTACs)

Mid-Atlantic Center: (301) 217-0124 (Voice/TTY)https://adata.org/

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.

The DBTACs can make referrals to local sources of expertise in reasonable accommodations.

Department of Defense Computer/Electronic Accommodations Program (CAP)

(703) 614-8416 (Voice); (571) 384-5629 (Videophone)

http://www.cap.mil/

NGB has entered into an Interagency Agreement with the Department of Defense

Computer/Electronic Accommodations Program (“CAP”), which provides assistive technology,

devices, and services to people with hearing, visual, dexterity, cognitive/learning or communication

disabilities. NGB employees are therefore eligible for CAP services. The Office of Equity and

Inclusion in collaboration with Human Resources will annually review this directive to ensure it

remains consistent with the CAP agreement.

Job Accommodation Network (JAN)

(800) 526-7234 (Voice); (877) 781-9403 (TTY)

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

Jan is one of several services provided by the U.S. Department of Labor’s Office of Disability

Employment Policy. JAN consultants provide information, free-of-charge, about many types of

reasonable accommodations and other disability-related issues.

RESNA Technical Assistance Project

(703) 524-6686 (Voice); (703) 524-6639 (TTY)

http://www.resna.org/

The Rehabilitation Engineering and Assistive Technology Society of North America (RESNA)

offers certification, continuing education, and professional development guidance regarding the

knowledge and practice of rehabilitation and assistive technology.
27

Registry of Interpreters for the Deaf

(703) 838-0030 (Voice); (571) 257-3957 (Videophone)

http://www.rid.org/

The Registry of Interpreters for the Deaf offers information on locating and using interpreters and

transliteration services.

U.S. Equal Employment Opportunity Commission (EEOC)

(800) 669-4000 (Voice); (800) 669-6820 (TTY)

http://www.eeoc.gov/

The EEOC’s Publication Center (https://www.eeoc.gov/eeoc/publications/index.cfm) provides

numerous guidance and technical assistance documents on disability discrimination and the ADA,

including with respect to federal sector employment specifically.

ATTACHMENTS

(NGB-EI will endeavor to revise any form identified below, if possible and as necessary, to

accommodate an individual with disabilities.)

Attachment 1: Request for Reasonable Accommodation or Personal Assistance Services Form

Attachment 2: Physicians Medical Assessment Form

Attachment 3: Documentation of Essential Functions Form

Attachment 4: Denial of Reasonable Accommodation Request Form

Attachment 5: Reasonable Accommodation Information Report
27-1

Attachment 1

Reasonable Accommodation Request

Date of Request:

Employee Name: Employee Email:

Job Title/Pay Grade: Position Description (#15 on SF-50):

Phone Number: Cubicle Number:

Supervisor Name: Supervisor Email:

Please provide the following information. Use additional pages or provide documentation as needed.

*NGB will provide the form in alternative formats if requested.

1. Identify your disability or physical or mental impairment(s) or limitation(s) (“Disability”):

2. Explain how your Disability impairs or limits your ability to perform assigned job duties:

3. Expected duration of the Disability:

4. Whatspecific accommodation(s) are you requesting, if known?

5. If you are not sure what accommodation is needed, do you have any suggestions about what options we

can explore? If yes, please explain or attach information.

6. Has a health care professional recommended a specific accommodation? Please describe or attach

documentation:

7. Is your accommodation request time sensitive? If yes, please explain.

8. If you are requesting a specific accommodation(s), how will that accommodation(s) assist you to perform

your job?
27-1

9. Have you had any accommodations in the past for this same limitation? If yes, what were they and how

did the accommodation(s) help you perform your job?

10. Please provide any additional information that might be useful in processing your accommodation

request. We will set up a time to meet to discuss your request.

Employee Signature and Date:

Supervisor Received RA Request Signature/Date:

Log Number (Assigned by RA Coordinator):

Please return this form to the RA Coordinator or e-mail to:

Ijigale.beltran@us.af.mil orJacqueline.ray-morris.civ@mail.mil
27-2

Attachment 2

Reasonable Accommodation Request

Physicians Medical Assessment Form

DATE:

Employee Name:

Employee DOB:

COMPLETED FORM MUST BE RETURNED TO EMPLOYER WITHIN 15 DAYS OF THE DATE OF THIS PACKET.

The above employee has requested a workplace accommodation, to enable the employee to perform the

essential functions of his/her position, either because of a disability as either defined under the Americans

with Disabilities Act (ADA ), as amended, or state law, or because the employee is pregnant and seeks an

accommodation under the applicable state pregnancy accommodation law. The information requested on

this form will assist us in making a determination regarding the employee’s request.

INSTRUCTIONS: The following form must be completed in detail and signed by the employee’s attending

medical provider. Please attach additional pages or records as needed. Do not provide information not

related to the employee’s ability to perform his/her job duties. Example: Do not identify an impairment if it

does not have an impact on employee’s ability to perform his/her job duties. IMPORTANT NOTICE

1. Please confirm you have examined the employee and are familiar with the employee’s medical history.

(Circle) Yes No

2. Is the employee released to return to work full time, full duty without the need for restrictions,

limitations, or accommodations? (Circle) Yes No

If yes, please state the employee’s full, unrestricted return to work date:

IF NO, PLEASE COMPLETE THE REMAINDER OF THIS FORM.

REGARDING GINA

The Genetic Information Nondiscrimination Act of 2008 (GINA) prohibits employers and other

entities covered by GINA Title II from requesting or requiring genetic information of employees

or their family members. In order to comply with this law, Reed Group is asking that you not

provide any genetic information when responding to this request for medical information.

“Genetic information,” as defined by GINA, includes an individual’s family medical history, the

results of an individual’s or family member’s genetic tests, the fact that an individual or an

individual’s family member sought or received genetic services, and genetic information of a

fetus carried by an individual or an individual’s family member or an embryo lawfully held by an

individual or family member receiving assistive reproductive services.
27-2

3. When can the employee return to work with restrictions or an accommodation? [Additional questions

regarding restrictions or accommodations below.]

4. Existence of impairment.

a. Does the employee have a physical or mental impairment(s)? (Circle) Yes No

b. Is the impairment open and obvious? (Circle) Yes No

If the employee’s impairment is open and obvious, do not answer questions 5-8; rather skip to question 9

and proceed from there.

5. Please list impairment(s), diagnosis and prognosis

Note: A physical or mental impairment under the ADA is:

Any physiological disorder, condition, cosmetic disfigurement, or anatomical loss affecting one or more of

the following body systems: Neurological, musculoskeletal, special sense organs, respiratory (including

speech organs), cardiovascular, reproductive, digestive, genitourinary, hemic and lymphatic, skin, and

endocrine; or

Any mental or psychological disorder, such as an intellectual disability, organic brain syndrome, emotional

or mental illness, and specific learning disabilities.

The disorder or condition is considered:

In its active state, even if presently in remission. (Examples: epilepsy, MS, asthma, cancer, bipolar

disorder.)

Without regard to the effects of mitigating measures such as prostheses, medication, etc., except

ordinary eyeglasses.

With consideration of the negative effects of treatment such as medication or other measures.

*The definition of a disability may differ slightly understate law.

6. Limitations on major life activities. If the answer to #4(a), is yes, does the employee’s impairment

substantially limit one or more major life activities? (Circle) Yes No

Note: Whether an impairment substantially limits the ability of an individual to perform a major life activity

is determined:

As compared to most people in the general population; and

Does not need to prevent, or significantly or severely restrict, the individual from performing a major life

activity – the impairment only needs to “substantially limit” the employee’s ability to perform the major

life activity.
27-2

□ Bending

□ Breathing

□ Caring for self

□ Concentrating

□ Eating

□ Hearing

□ Interacting with others

(describe):

□ Learning

□ Lifting

□ Performing manual tasks

□ Reaching

□ Reading

□ Seeing

□ Sitting

□ Sleeping

□ Speaking

□ Standing

□ Thinking

□ Walking

□ Working

□ Other(s)

□ Bladder

□ Bowels

□ Brain

□ Cardio-vascular

□ Circulatory

□ Digestive

□ Other(s) Describe:

□ Genitourinary

□ Hemic

□ Immune

□ Lymphatic

□ Musculoskeletal

□ Neurological

□ Operation of an organ

□ Reproductive

□ Respiratory

□ Sensory organs & skin

□ Endocrine

□ Normal cell growth

7. Limitations on major life activities (cont.). If the answer to #6 is yes, which major life activity(s) is/are

affected?

Check all major life activities that both (a) are affected by the employee’s impairment(s) and (b) restrict or

limit the employee’s ability to perform the employee’s job duties.

Major life activities – general life activities:

Major life activities – operation of major bodily functions:

8. Commencement of impairment(s). For the impairments identified above, when did the employee’s

impairment(s) commence? If there is more than one impairment, please specify the start date for each:

9. Performance of essential job functions. Does the employee’s impairment(s) limit his/her ability to

perform the essential functions of the employee’s position (as defined in the attached job description)

without any accommodation? (Circle) Yes No

If the answer is yes, please:

a. Identify which essential function(s) the employee is unable to perform without an accommodation:

b. Describe the manner in which the employee’s ability to perform each essential function is limited:

10. Accommodation(s). Please describe:
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NOTE: You must provide your best medical judgment, based on current information, as to the length of

time the employee will need an accommodation to perform his/her essential job functions.

11. Is there another accommodation(s) that you know of that will enable the employee to perform the

essential job functions? If so please describe:

Note: Reasonable accommodations may include such things as a modified work schedule, provision of

special equipment, workplace accessibility modifications, shifting of non-essential duties of the employee’s

position, and extended leave of absence to allow time for recovery, therapy, training, or other disabilityrelated needs.

a. How will the accommodation(s) assist the employee in performing the essential job functions?

b. Duration: For how long do you anticipate the employee will need the identified accommodation(s) to

perform the essential job functions?

(circle one) days/weeks/months/years; or permanent

NOTE: You must provide your best medical judgment, based on current information, as to the length of

time the employee will need an accommodation to perform his/her essential job functions.

12. Additional information. Are you aware of any other information that the employer should consider in

assessing whether the employee can perform the essential job functions with or without accommodation?

(Circle) Yes No

If yes, please describe below:

Provider Name (print):

Provider Signature:

Provider Practice/Specialty:

Provider ID#:

Provider Phone Number:

Provider Address:

Date:
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Attachment 3

Documentation of Essential Functions Form

Name of Employee: Title, Series, Grade of Position:

Directorate/Division/Branch:

To be completed by Supervisor To be completed by health care professional

Please identify the essential functions of the position in the space

below. Please include any requirements needed to perform the

essential functions of the position (e.g. physical requirements).

Please document any restrictions or limitations that may

impact the employee’s ability to perform the essential

functions of the position listed in the left column. Also,

include any reasonable accommodations that may allow

the individual to perform the essential functions of the

position.

Essential Function #1

Essential Function #2

Essential Function #3

Essential Function #4

Supervisors signature and Date Healthcare Provider Name, Signature and Date
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Attachment 4

Denial of Reasonable Accommodation Request Form

Log Number _ _

1. Individual Requesting Reasonable Accommodation 

2. Type(s) of accommodation requested:

3. Request for accommodation denied because (may check more than one box):

Accommodation would cause undue hardship

Medical documentation inadequate

Accommodation would require removal of one or more essential job functions

Other (Please Identify)

4. Detailed Reason(s) for the denial of a requested accommodation (Must be specific, e.g.,

why accommodation is ineffective or causes undue hardship):

5. If the individual 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 the chosen accommodation is effective.

6. An individual who disagrees with the denial of an accommodation request is encouraged to initiate

an Alternative Dispute Resolution (ADR) through any applicable ADR process established by theNGB.

7. If the individual wishes to file an EEO complaint, or pursue Merit Systems Protection Board (MSPB)

appeal and union grievance procedures, she/he must take the following steps. The time limits for

these steps apply whether or not the individual has initiated ADR:

 For an EEO complaint pursuant to 29 C.F.R. 1614, contact the Complaint

Management Branch, NGB-EI at (703) 601-6752 within 45 days from the date of

this notice of denial of accommodation request; or

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

the provisions of the Collective Bargaining Agreement to JHCM at (703)

607-5946

 Initiate an appeal to the MSPB within 30 days of an appealable adverse action as

defined in 5 C.F.R. § 1201.3 to JHCM at (703) 607-5946.
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Printed Name, Signature and Date of Deciding Official

___________________________________________

Employee Signature and Date Acknowledging Receipt
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Attachment 5

REASONABLE ACCOMMODATION INFORMATION REPORT

To be completed by manager/official who processed the accommodation request. Submit to local

Disabilities Program Manager (EEO Office). (Use additional sheets if necessary)

1. Request for accommodation: ☐ (Check one)

Approved

☐ Denied (Attach copy of the written denial memo sent to individual.)

2. Date reasonable accommodation requested:

3. Who received the request:

4. Date reasonable accommodation request referred to decision maker (i.e., supervisor, Office Director):

5. Name and position of Decision Maker:

6. Date request approved or denied:

7. Date reasonable accommodation provided (it different from date approved):

8. If time frames outlined in the Reasonable Accommodation Procedures were not met, please explain

why:

9. Job held or desired by individual requesting reasonable accommodation (include occupational

series, grade level or equivalent NSPS information and office):

10. 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)

11. Type(s) of accommodation requested (e.g., adaptive equipment, staff assistant, removal of

architecturalbarrier):

12. Type(s) of reasonable accommodation provided (if different from what wasrequested):

13. From what organization was adaptive equipment obtained?

14. Was medical information required to process this request? If yes, explain why.

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

accommodations(e.g., Job Accommodation Network, Computer/Electronic Accommodations

Program, disability organization, Disability ProgramManager).
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Name: 

Phone: Email Address: 
APPENDIX

Personal Assistance Services

1. Assistive Devices

People with disabilities have many assistive devices available to them. Under section 508 of the

Rehabilitation Act, as amended, any electronic and information technology procured by Federal

agencies must be accessible to employees and members of the public with disabilities; to the extent

it does not pose an undue burden. Such devices might ensure successful job performance; enabling

people with disabilities to perform tasks they would not otherwise be able to do or to increase the

quantity, quality, or efficiency of their work. Before purchasing any assistive equipment, the

agency should discuss what is needed and/or desired with the individual requesting the

accommodation.

In most cases, requests for Assistive Technology (AT) equipment and some services may be done

through the Department of Defense’s Computer/Electronic Accommodations Program (CAP) at

http://cap.mil at no charge to the federal agency or organization. For certain accommodations that

are out of CAP’s scope, Federal employers are authorized to purchase equipment if it is determined

that the use of the equipment is a reasonable accommodation that will enable an employee with a

disability to better perform his or her job. In certain cases, however, the Department of Veterans

Affairs or State Vocational Rehabilitation office may provide the assistive device to the individual

requesting a reasonable accommodation if the employee is already a client of that agency or office.

Readers, Interpreters, and Other Effective Communication Tools

One key component of reasonable accommodation is to ensure effective communication with

employees who have communication-related disabilities, such as those with vision, hearing, or

speech impairments. Agencies must provide appropriate "auxiliary aids and services" such as

qualified sign language interpreters, trained readers, computer-assisted real-time transcription

services, and alternate format documents (Braille, large print, audio cassette, or computer disk),

unless doing so would fundamentally alter the program or impose an undue hardship on the agency.

Readers: Persons who are blind or who have low vision may need trained readers to be able to

access information contained in otherwise inaccessible material. For instance, a lawyer who is

blind may need a trained reader to read aloud deposition transcripts and correspondence from

opposing counsel. Also, appropriate assistive technology, such as screen readers or Braille displays,

can make much computer based information accessible to someone who is blind or who has low

vision, thus reducing (though not necessarily eliminating) the employee's reliance on a trained

reader.

Interpreters: Persons who are deaf or hard of hearing and who use sign language may need

qualified sign language interpreters. A "qualified sign language interpreter" is someone that can

competently, accurately, and impartially interpret, both receptively and expressively, using any

specialized terminology necessary such that there is two-way communication in the employment

setting. Someone who is deaf and who does not know sign language may benefit from a qualified

oral interpreter in certain circumstances. Many people who are deaf learned to communicate using

American Sign Language (ASL), rather than English, as their primary means of communication.
ASL has a different vocabulary and syntax than English. While an employee who is deaf or hard of

hearing and who uses sign language may not need a qualified sign language interpreter dedicated to

his or her full-time use, qualified interpreters should be used in the following circumstances:

a. Employee orientations,

b. Staff meetings,

c. Training,

d. Whenever job duties change or when there is a new major assignment;

e. Meetings involving more than two people (it is extremely difficult to follow f.

group discussions by lip-reading),

f. Meetings to discuss annual or semi-annual performance evaluation, promotion eligibility,

or disciplinary action, and, if needed,

g. Whenever efficient and effective communication is important, or when verbal

communication will be lengthy, or if a person with a hearing impairment can show why

other forms of communication would be ineffective.

An employer might not need qualified sign language interpreters for relatively short routine

matters. In those cases, an employer might communicate with an employee who is deaf by

exchanging handwritten notes or typing back and forth on a computer keyboard or TTY.

Other Effective Communication Tools:

TTYs: A "TTY" (also known as a "teletype") is a device that allows someone who is deaf or hard

of hearing or someone with a speech impairment to communicate by telephone by sending and

receiving typed communications. The TTY user can communicate directly with someone else who

also uses a TTY, or with those who do not use TTYs by calling a relay operator who will voice the

disabled person's typed communication and then type the non-disabled person's spoken

communications. Agencies could provide training to all coworkers of persons who use TTYs in

how to make and receive calls using the relay system. The Federal Relay Service provides the

services at: http://www.federalrelay.us/tty

Video Phone (VP): A videophone is a telephone with a video display, capable of simultaneous

video and audio for communication which allows deaf and hard of hearing individuals to have

telephone conversations with hearing people. Using a VP with real-time video connection via the

internet, a Video Relay Service (VRS) interpreter relays the conversation between the two parties.

All calls are confidential and available 24/7. VP equipment and video relay services are offered by

vendors for free. Further information can be found at

https://www.nad.org/resources/technology/telephone-and-relay-services/video-relay-services/

Video Remote Interpreting (VRI): VRI enables Deaf/HH users to utilize an on-demand remote

sign language interpreting in order to facilitate communication between hearing individuals who

are in the same location (e.g. office, cubical, front desk, etc.).

Example: A deaf professional meets with a hearing co-worker and contacts the VRI in his tablet to

discuss logistic codes at his co-worker’s cubicle for about seven minutes.
Example: A hearing supervisor invites a deaf computer programmer to meet with him and another

co-worker to review new computer codes. The deaf individual contacts the VRI with her tablet and

bring it into the conference room to communicate with her supervisor and co-worker to finalize the

codes for 20 minutes.

Generally, VRI is suitable when an on-site sign language interpreter is not available to

accommodate the communication in person no more than 15 or 20 minutes, but no longer than 30

minutes.

Use of Untrained Co-workers as Readers or Interpreters: An employer should not rely on coworkers of persons with disabilities to act as readers or sign language interpreters, unless the coworkers are qualified to do this work and it falls within their job description. Even if co-workers

have learned rudimentary sign language through daily communication with the person who is deaf,

they are unlikely to be able to provide effective communication in an employment setting.

CART Computer Assisted Real-Time Transcription: CART makes verbal communication

accessible to persons who have a hearing impairment and who do not use sign language. It requires

a trained person, like a stenographer, to use special equipment to transcribe verbal communication

as it is taking place. The transcription may appear on a computer monitor or be projected onto a

screen. The service is similar to closed captioning of a live television program.

Alternate Format Materials: Agencies must provide alternate format materials or other auxiliary

aids and services to allow persons who have visual impairments to have full access to written

materials used in the course of their employment, including such things as employee manuals and

leave and earning statements. Alternate formats include Braille, large print, audiocassette

recordings, and electronic copies on computer disks.

Service Animal: Under the Americans with Disabilities Act (ADA), a Service animal is defined as

a dog that has been individually trained to do work or perform tasks for an individual with a

disability. The task (s) performed by the dog must be directly related to the person’s disability.

Many people with disabilities use a service animal in order to fully participate in every- day life.

Dogs can be trained to perform many important tasks to assist people with disabilities, such as

providing stability for a person who has difficulty walking, picking up items for a person who uses

a wheelchair, or alerting a person who has hearing loss when someone is approaching from behind.

TheADAmakes a distinction between psychiatric service animals and emotionalsupport

animals. If the dog has been trained to sense that an anxiety attack is about to happen and

take a specific action to help avoid the attack or lessen its impact, that would qualify as a

service animal. However, if the dog’s mere presence provides comfort, that would not be

considered a service animal under the ADA.

The dog must be trained to take a specific action when needed to assist the person with a

disability. For example, a person with diabetes may have a dog that is trained to alert him

when his blood sugar reaches high or low levels. A person with depression may have a

dog that is trained to remind her to take her medication. Or, a person who has epilepsy

may have a dog that is trained to detect the onset of a seizure and then help the person

remain safe during the seizure.
In situations where it is not obvious that the dog is a service animal, staff may ask only two

specific questions: (1) isthe dog a service animalrequired because of a disability? And (2)

what work or task hasthe dog been trained to perform? Staff are not allowed to request any

documentation for the dog, require that the dog demonstrate its task, or inquire about the

nature of the person’s disability. Further information can be found at:

https://www.ada.gov