Defense Threat Reduction Agency

Reasonable Accommodation 

Program

DESK REFERENCE GUIDE

Updated August 2022

HUMAN RESOURCES DIRECTORATE
Reasonable Accommodation

Page 1 of 19

TABLE OF CONTENTS

INTRODUCTION..........................................................................................................................2

REFERENCES...............................................................................................................................2

DISCUSSION................................................................................................................................ 3

Program Coverage ........................................................................................................................3

Eligibility ......................................................................................................................................3

Reporting.......................................................................................................................................3

PROCEDURES............................................................................................................................. 4

Designation of RA coordinator ....................................................................................................4

Requesting RA .............................................................................................................................4

Processing the RA Request for Employees..................................................................................5

Processing the RA Requests for Applicants Seeking Employment .............................................6

Engaging in the Interactive Process.............................................................................................6

Reasonable Accommodation Review Board................................................................................7

Requesting and Safeguarding Medical Information.....................................................................7

Timeframes for Processing RA Requests.....................................................................................8

Reassignment ...............................................................................................................................9

Vacant Position Searches...........................................................................................................10

Decision to Grant a RA Request ................................................................................................10

Decision to Deny a RA Request.................................................................................................10

Tracking and Reporting Requirements.......................................................................................11

Making a Request for PAS.........................................................................................................12

Denying a Request for PAS .......................................................................................................12

Confidentiality Requirements for PAS ......................................................................................13

Reporting Requirements for PAS...............................................................................................13

ACRONYMS............................................................................................................................... 15

DEFINITIONS.......................................................................................................................... 155

APPENDIX A............................................................................................................................ 156

APPENDIX B ............................................................................................................................ 157

APPENDIX C............................................................................................................................ 159
Reasonable Accommodation

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INTRODUCTION

The Defense Threat Reduction Agency (DTRA) Reasonable Accommodation (RA) program is 

designed to remove any barrier(s) which prevent individuals with disabilities (permanent or 

temporary) who are employees or applicants from applying for or performing jobs for which they 

are qualified. Equally important is to empower individuals with disabilities to maximize 

employment, economic self-sufficiency, and inclusion into society. This guide provides 

procedures for participation in the DTRA RA program.

The information in this guide applies to all civilian employees and applicants seeking 

employment within DTRA and takes precedence over all related internal standard operating 

procedures or guidance. Additional information can find on the DTRA internal website at 

https://dtra1portal.unet.dtra.mil/HR/CP/ra/default.aspx, and externally at 

https://www.dtra.mil/Work-With-Us/DTRA-Careers/Pay-and-Benefits/.

References

29 C.F.R. § 1614.203, Rehabilitation Act

Chapter 126 of Title 42, United States Code (U.S.C.)

Deputy Secretary of Defense Memorandum, “Access for People with Disabilities,” 

October 31, 2008

DoD Manual 8400.01, “Accessibility of Information and communications Technology (ICT),” 

November 14, 2017

DTRA Instruction 1100.2, “Telework Program, Change 2 effective October 29, 2020, as 

amended

DTRA Instruction 5505.3, “Defense Threat Reduction Agency Reasonable Accommodation,” 

December 10, 2007, hereby cancelled

EEOC “Enforcement Guidance: Reasonable Accommodation and Undue Hardship under the 

American's with Disabilities Act (ADA),” October 17, 2002

EEOC “Questions and Answers: Federal Agencies' Obligation to Provide Personal Assistance 

Services (PAS) under Section 501 of the Rehabilitation Act,” September 18, 2017

Executive Order 13164, “Requiring Federal Agencies to Establish Procedures to Facilitate the 

Provision of Reasonable Accommodation,” July 26, 2000

Public Law 93-112, “Rehabilitation Act of 1973,” as amended

Public Law 110-325, “ADA Amendments Act of 2008,” September 25, 2008 

Section 552a of Title 5, U.S.C.

Sections 701, Section 791, and Section 1630.1 (c) (4) of Title 29, U.S.C.
Reasonable Accommodation

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DISCUSSION

Program Coverage

The DTRA RA program provides modification(s) to the work environment that allows an 

employee to perform the essential functions of his or her position and/or to enjoy equal access to 

benefits and privileges of employment. The DTRA RA program also provides for modification 

to the application process allowing qualified individuals with a disability to apply for positions 

without barriers.

The DTRA RA program complies with United States Equal Employment Opportunity 

Commission (EEOC) regulations and federal law prohibiting federal agencies from 

discriminating against qualified individuals with disabilities. Under this law, Government 

agencies must provide RAs to qualified employees and job applicants with disabilities unless 

doing so causes an undue hardship. A qualified individual with a disability refers to an 

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

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

without RA, can perform the essential functions of such position. Effective January 3, 2018, the 

EEOC amended Section 501 of the Rehabilitation Act of 1973, requiring all federal agencies, to 

include DTRA, to offer Personal Assistance Services (PAS) to assist with daily living activities 

(i.e., putting on clothing, eating, using the restroom) for employees with “targeted disabilities” 

(i.e., blindness, deafness, spinal cord injury, etc.).

Eligibility

Eligibility to participate in the DTRA RA program is limited to permanent full-time and parttime Federal civilian employees or civilian applicants seeking employment within DTRA.

Military members assigned to DTRA seeking a RA must follow his/her Service specific rules for 

making such a request.

Contractor personnel are not eligible to participate in DTRA’s RA program. Contractors should 

contact his/her employer if he/she feels a RA is needed.

Reporting

The Director, Human Resources Directorate (HR), has overall responsibility for DTRA guidance 

and reporting requirements related to the RA program. HR will compile and maintain RA data 

to evaluate the Agency’s performance in responding to requests for RA, ensure compliance with 

EEOC regulations and federal laws, and submit report(s) to the EEOC, asappropriate.
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PROCEDURES

Designation of RA coordinator

The Director, HR designates a RA coordinator to serve as the program lead. The RA coordinator 

is responsible for reviewing all RA requests for employees and applicants; ensuring 

completeness of RA requests; determining whether an employee or applicant meets the definition 

of a qualified individual with a disability; consulting with Directorates and Staff Offices as 

necessary; and, providing guidance to all parties.

Requesting RA

The RA process begins when an individual with a disability, or their representative, request an 

adjustment or modification to the work environment or application process that will enable the 

employee or applicant to perform the essential functions of their position, to complete the 

application process, and/or to enjoy equal access to benefits and privileges of employment (e.g., 

Agency sponsored events, training).

A request for a RA may be made orally or in writing, at any time, by an employee or applicant, 

or the employee or applicant’s family member, health care professional or authorized 

representative. The individual making the request need only indicate the need for assistance 

based on a medical condition. The use of special words is not required (e.g., “accommodation,” 

“disability,” or “rehabilitation”).

When a request is made by someone other than an employee or applicant, the RA coordinator 

will confirm the request with the employee or applicant. In the event a third party acts as a 

representative for the affected individual, the third party must have written designation 

authorizing him or her to work on the requestor’s behalf.

Types of RA may include, but are not limited to:

• Ensuring facilities used by employees and applicants for employment are readily 

accessible and usable by individuals with disabilities;

• Restructuring jobs and/or modifying work schedules;

• Reassigning current employees to vacant positions;

• Acquiring or modifying equipment or devices;

• Making appropriate modifications to examinations, training materials, or policies; or

• Providing qualified readers or interpreters and/or other similar assistance.
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Processing the RA Request for Employees

A RA request may be submitted in writing or orally to any DTRA employee connected with the 

application process or an employee’s supervisor, another supervisor in the employee’s chain of 

command, or to the RA coordinator. The initial RA request may be made verbally; however, the 

RA request must be later documented using DTRA Form 123 found in the DTRA1 Forms 

Library SharePoint site: 

https://www.dtra.mil/Portals/61/Documents/DTRA_Careers/DTRA_123.pdf.

The timeframe for processing a request begins upon receipt (verbal or written), even when 

documentation is required later. The amount of time it takes to respond to a request for RA 

depends on the nature of the accommodation and whether medical documentation is needed to 

confirm the existence of an ADA disability and the need for a RA. When a RA request requires 

review or consultation, the supervisor will ensure the RA request is forwarded to the RA 

coordinator within 7 calendar days of receipt.

If an employee’s need for RA is not obvious or otherwise known, the employee may be asked to 

provide supporting medical documentation. The supervisor will identify the essential functions 

of the employee’s position. The supporting medical documentation will determine what the 

employee can or cannot perform because of the disability. Medical documentation in support of 

a RA request must come from an appropriate healthcare professional and must include sufficient 

information regarding the employee’s medical condition(s) and the functional limitation(s). The 

RA should explain:

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

impairment (e.g. functional limitation, symptoms, side effects of any treatments).

• The on-the-job activity or activities that the impairment limits, and the extent to which 

the impairment limits the employee’s ability to perform the activity or activities.

• The medical basis for any opinion that the employee requires a RA and how the RA will 

assist the employee in the performance of the essential functions of the position.

• Specific limitations associated with each major life activity (i.e., performing manual 

tasks, walking, standing, reaching, sitting, lifting, etc.).

• If teleworking addresses the medical condition sufficiently for the employee to continue 

performing the essential functions of the position, the RA must define the parameters of 

telework. (Note: If the RA request involves “full-time telework,” then the employee 

must complete an additional coordination, requiring approval of the Director, HR, per 

DTRA Instruction 1100.2).

• How the RA will assist in the performance of the essential functions of the position or to 

enjoy equal access to benefits and privileges of employment (e.g., Agency sponsored 

events, training).
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Failure on the part of the employee, or the employee’s designee, to cooperate in this process or 

provide sufficient documentation on whether he or she has a disability can result in a denial of 

RA.

Generally, an employee who has already been determined eligible for a RA will not be required 

to submit a separate written request for each subsequent occasion in which they will need the 

same or similar RA. When an individual requests a type of accommodation that will be needed 

on a repeated basis (e.g., a sign language interpreter, CART Services, or readers), DTRA may 

not require the individual to submit a written request for each time the accommodation is needed. 

If the RA is needed on a recurring basis, the employee may obtain the accommodation by 

notifying their supervisor to ensure arrangements are made without requiring a request in 

advance of each occasion. A supervisor and RA coordinator may reevaluate a RA based on nonpermanent conditions and make modifications per the medical documentation, as necessary.

If an employee needs PAS, the employee will describe the kind of assistance needed to perform 

activities of daily living for their “targeted disability” and will refer to “Making a Request for 

PAS” section of this Handbook for procedural guidance.

Processing the RA Request for Applicants Seeking Employment

Applicants seeking employment within DTRA may direct their RA request to the RA 

coordinator, designee, or to the individual contacting the applicant for an interview.

RA requests should include the applicant’s name, name of the hiring organization, a description 

of the RA being requested, and a brief description of the reason for the RA request which may be 

documented on the DTRA Form 123.

Engaging in the Interactive Process

An employee is not entitled to the exact RA he/she requests. The RA must allow the requesting 

employee to perform the essential function of his/her position that the employee is no longer able 

to perform. Therefore, once the RA request is made by the employee or applicant, he or she will 

work with the supervisor or hiring manager to identify potential RAs and explore the various 

options. The supervisor will engage the RA coordinator once the documentation (i.e., supporting 

medical documentation, DTRA Form 123, DTRA Form 259, Request for RA, description of RA 

for applicants, etc.) is gathered.

The requester, RA coordinator, supervisor or hiring manager must communicate early in the 

interactive process and periodically throughout the process with individuals who have requested 

the accommodation. Failure on the part of the requester to cooperate in the interactive process 

can result in a denial of the RA request. Failure on the part of supervisor to participate in the 

interactive process may potentially result in Agency liability.

The RA coordinator advises the supervisor and/or hiring manager; however, the supervisor 

makes the final decision on the RA for an employee and the hiring manager provides written
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communication to the applicant on his/her RA decision. Depending on the nature of the RA 

request, the RA coordinator, will consult with the Office of the General Counsel, DTRA’s Senior 

Medical Officer, and/or other Directorates and Staff Offices, as needed, to execute RAs. The RA 

coordinator will collaborate with the supervisor or hiring manager to promptly, effectively, and 

reasonably to accommodate a qualified employee with a disability. In extenuating 

circumstances, clearly visible or known disabilities will be evaluated expeditiously and given 

priority.

During the Interactive Process, supervisors who approve request for RAs must consider all 

resources available to the agency, including those resources through the DoD. Supervisors who 

approve the RA will communicate the final decision to the requestor. The requestor may reach 

out to the RA Coordinator at dtra.belvoir.hr.mbx.ra-coordinator@mail.mil. The HR will 

coordinate on how to arrange for the use of agency resources to provide the accommodation.

Reasonable Accommodation Review Board

The employee who is denied an RA, or is not given the RA he/she requests, may choose to 

appeal the decision to the Reasonable Accommodation Review Board (RARB).

Since each RA is unique and often requires guidance from various Directorates and Staff 

Offices, RARB members include, but is not limited to:

• Chief, Management and Employee Relations Division;

• RA Coordinator;

• Senior Medical Officer; and

• Agency Chief of Staff

The Chief, Management and Employee Relations Division serves as the RARB chair and will 

determine if ad hoc membership is required. The Office of the General Counsel will serve in an 

advisory role. 

Requesting and Safeguarding Medical Information

The RA coordinator may request additional medical information if the medical documentation 

does not clearly explain the nature of the disability, the need for RA, or how the RA will assist 

the employee in performing the essential functions of the job, enjoying the privileges of the 

workplace, or assisting an applicant with the application process. The RA coordinator may ask 

the employee, or employee’s designee, to provide medical documentation in support of a RA.

If the RA coordinator needs additional medical information in order to process a RA request, the 

RA coordinator must provide the employee or applicant with a written explanation of why the 

submitted medical documentation is insufficient and a description of what is needed.

At a minimum, acceptable medical documentation must establish the nature of the medical 

condition, the limitations the medical condition imposes, and the causal connection between the 
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medical condition and the inability to meet workplace expectations.
Reasonable Accommodation

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When additional medical documentation is needed, the RA coordinator can allow the individual 

an opportunity to provide the information from their personal healthcare professional. The RA 

coordinator may ask the individual to sign a limited release and then either submit a list of 

specific questions to the individual’s health care professional or have DTRA’s Senior Medical 

Officer contact the individual’s healthcare professional. If this does not result in sufficient 

information, the Agency may require the individual to submit to an independent medical

examination by a healthcare professional of the Agency’s choice and at the Agency’s expense.

Individuals should respond to requests for medical documentation within 15 calendar days after 

receipt of the RA request. An additional 15 calendar days may be granted for extenuating 

circumstances.

All medical information obtained in connection with the RA process must be kept confidential, 

must not be shared with others unless on a need-to-know basis, and must be appropriately 

protected from unlawful disclosure. Any employee who obtains or receives such information is 

strictly bound by these confidentiality requirements. Where medical information is disclosed, 

the RA Coordinator must inform the recipients about the confidentiality requirements that attach 

to the information. Restrictions apply to information and documents. The only circumstances 

under which medical information may be disclosed are:

• Providing identification of an employee’s functional limitations and what RAs have been 

approved to those who have a need-to-know;

• When requested by workers’ compensation officers or insurance carriers;

• Providing pertinent information to first aid and emergency personnel if the impaired 

individual requires emergency treatment; or

• Providing investigative services to ensure DTRA is in compliance with EEOC 

regulations.

Medical information or documentation of an employee’s impairment, disability, or RA, must be 

kept in a separate file from normal personnel records and be properly secured when not in use by 

the authorized parties. Records pertaining to RA requests are maintained for a period of 3 years. 

If the RA is needed on a recurring basis, then the RA records will be maintained for as long as 

the case is active.

DTRA may only make disability-related inquires and require medical examinations of 

employees if they are job-related and consistent with business necessity. Individuals cannot be 

asked to undergo a medical exam or be asked medical questions unless the agency has a 

reasonable belief, based on objective evidence, that: (1) an employee’s ability to perform 

essential job functions will be impaired by a medical condition; or (2) an employee will pose a 

direct threat due to a medical condition.

Timeframes for Processing RA Requests

Responses to RA requests for information will be provided by the RA coordinator, as soon as 

possible, absent extenuating circumstances, not later than 15 calendar days after receipt.
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Absent extenuating circumstances, requests for RA will be processed and a decision on the 

request will be provided within 30 calendar days of receiving all requested information. If there 

is a delay in issuing a written determination, the individual requesting RA must be issued written 

notification of the reasons for the delay. The maximum amount of time the agency has, absent 

extenuating circumstances, to either provide a requested accommodation or deny the request is 

60 days from when the accommodation is first requested.

If a request for a RA can be processed without supporting medical information, and there are no 

other extenuating circumstances, determinations will be made within 30 calendar days from the 

date the request is received. When extenuating circumstances are present, such as failure to 

provide requested medical information or the information specified, or where independent 

medical review is necessary, the time for processing a RA request will be extended as reasonably 

necessary. If the delay exceeds 45 calendar days from the date of the employee’s initial request, 

he or she will be notified in writing. When a particular reasonable accommodation can be 

provided in less than the maximum amount of time permitted under 29 CFR 

1614.203(d)(3)(i)(M), failure to provide an accommodation in a prompt manner may result in a 

violation of the Rehabilitation Act. DTRA 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.

If the RA cannot be provided immediately, the supervisor, in coordination with the RA 

coordinator, should inform the requester in writing of the projected timeframe for providing the 

RA. Temporary measures must be explored when there may be a delay in processing a request 

or implementing a RA. When all the facts and circumstances known to the agency make it 

reasonably likely that the individual will be entitled to an accommodation, but the 

accommodation cannot be provided immediately, the agency will provide the individual with an 

interim accommodation that allows the individual to perform some or all of the essential 

functions of the job, absent undue hardship. DTRA will take measures to avoid unnecessary 

delays (e.g. Contract with CAP, purchasing equipment). If a temporary accommodation is 

provided, the employee must be informed the accommodation is being provided only on a 

temporary, interim basis. Where there is a delay in either processing a request for or providing a 

reasonable accommodation, the supervisor/manager or hiring official must notify the individual 

of the reasons for the delay, including any extenuating circumstance that justify the delay.

In special circumstances expedited processing of a RA request may be required. Examples 

include when the RA is needed to enable an individual to apply for a job, to participate in a 

specific activity that is scheduled to occur on a specified date, or in cases involving safety issues.

Reassignment

Reassignment to a vacant position is a potential RA. In general, reassignment should be 

considered as a “last resort,” only when RA within the individual's current position is not 

possible, or would pose an undue hardship to the Agency. Reassignment is not available to 

applicants. In accordance with EEOC regulatory guidance, reassignment will be considered for 

an employee when:
Reasonable Accommodation

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• The employee, because of a disability, can no longer perform the essential functions of 

the position he or she holds, with or without RA.

• There is no available RA that would enable the employee to perform the essential 

functions of the position or if the only effective accommodation would cause undue 

hardship to the Agency.

• There is a vacant position for which the employee is qualified. The employee will be 

non-competitively reassigned into the vacant position. The vacant position must be 

equivalent to the employee’s current position in terms of pay, grade, benefits, 

geographical location, etc., unless the employee consents to being placed in a lower 

graded position and/or placed in a different geographical location.

Vacant Position Searches

Searches for vacant positions will be handled by the RA coordinator in coordination with the HR 

Services Division. The search will include positions that are anticipated to be vacant within 60 

calendar days of the initial request for a RA. This search does not obligate DTRA to wait 60 

calendar days to take appropriate action, only to consider vacancies that have been forecasted 

within 60 calendar days.

Decision to Grant a RA Request

When it is determined that a RA will be provided, the decision will be communicated in writing 

to the requesting individual and his or her authorized representative if one has been identified. 

If the supervisor grants a RA that was not agreed upon during the interactive process, the notice 

should explain the reason(s) for the denial of the requested RA and the reason(s) that he or she 

believes the chosen RA is more effective.

A supervisor is not required to provide the precise RA requested so long as the alternative 

accommodation is effective and does not create an undue hardship to the Agency, per EEOC 

regulations.

The RA coordinator will follow up with the employee or applicant to ensure the effectiveness of 

the RA.

Decision to Deny a RA Request

When the supervisor, in coordination with the RARB, determines that a RA request will be 

denied, this will be communicated in writing to the requesting individual, and his or her 

authorized representative. The explanation for the denial will be written clearly and in an 

accessible format, stating the specific reason(s) for the denial. All denial notices will be 

coordinated with the RARB and sent to the requesting individual by the RA coordinator.
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The reason(s) for the denial of a RA request may include, but are not limited to, the following:

• The requested accommodation would not be effective and an effective alternate RA was 

not identified.

• The requested accommodation would result in undue hardship and an effective alternate 

RA was not identified.

• The submitted medical documentation does not establish that the individual has a 

disability or needs a RA.

• The requested accommodation would require the removal of an essential function and an 

effective alternate RA was not identified.

• The requested accommodation would require the lowering of a performance or 

production standard and an effective alternate RA was not identified.

• The employee is successfully completing all the essential elements of his/her position and 

is therefore not a “qualified” individual with a disability.

The supervisor, in coordination with the RA coordinator, will provide a written notice of denial 

to inform the individual of his or her right to file an appeal. The individual may file an informal 

administrative grievance through the Management and Employee Relations office or use

DTRA’s formal Alternative Dispute Resolution (ADR) program to request reconsideration of an 

agency denial of reasonable accommodation. The individual may file an appeal with the RARB. 

He/she may file an EEO complaint with DTRA’s Equity, Diversity and Inclusion Office (EI), 

pursuant to 29 CFR 1614.106, and invoke other statutory processes, as appropriate. The 

individual must initiate contact with EI within 45 days of the denial, regardless of whether the 

applicant or employee participates in an informal dispute resolution process.

Employees and applicants are encouraged to voluntarily initiate a reconsideration to the RARB 

to obtain prompt reconsideration of denials of accommodation requests.

Tracking and Reporting Requirements

DTRA will keep records that it may use to determine whether it is complying with the 

nondiscrimination and affirmative action requirements imposed under Section 501. The agency 

will make such records available to EEOC upon EEOC’s request.

The RA coordinator will gather, track, and report:

• The number and types of RAs that have been requested, and whether those requests have 

been granted or denied.
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• The jobs, to include occupational series, grade level, position titles, etc., for which RAs 

have been requested.

• The reasons for denial of requests for RA.

• The amount of time taken to process each RA request.

• The sources of technical assistance that have been consulted in trying to identify possible 

RAs.

• The number of requests for reasonable accommodation, by type, that relate to the benefits 

or privileges of employment and whether they were granted or denied.

• The number and type of reasonable accommodation requested in the application 

processes and whether those requests were granted or denied.

• The identity of the deciding official.

Employees and applicants may contact the RA Coordinator or their supervisor for the 

Reasonable Accommodation Information Report found at Appendix C to track the processing 

of requests for RA.

Making a Request for Personal Assistance Services (PAS)

An employee may request a PAS by informing a supervisor, the RA coordinator, or other 

suitable representative that he or she needs assistance with daily life activities because of a 

medical condition. The employee does not need to mention Section 501 or EEOC regulations 

explicitly, or use terms such as “PAS” or “affirmative action” to trigger DTRA’s obligation to 

consider the request.

The RA coordinator will work with the employee to define PAS parameters to include:

• The employee’s targeted disability which makes him or her eligible for PAS.

• The type(s) of PAS (i.e., assistance with removing and putting on clothing, eating, using 

the restroom, pushing a wheelchair, etc.) required because of his or her targeted disability 

as defined by the treating health care provider.

• The extent to which PAS is needed for job-related travel, if applicable, but not including 

the commute to and from work, which is not covered under EEOC regulations.

• The extent to which PAS is needed for teleworking, if applicable.

• The extent to which PAS is needed for employer-sponsored trainings and events.
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• The extent to which a RA is needed to supplement the PAS, if applicable.

• The employee’s preference to a specific PAS provider, if applicable.

Denying a Request for PAS

DTRA is only required to provide PAS if the requesting employee is entitled under the EEOC’s 

affirmative action ruling. Therefore, DTRA will deny a request for PAS if:

• The requestor is not a DTRA employee;

• The requestor does not have a targeted disability;

• The targeted disability does not create a need for PAS;

• The requestor is not able to perform the essential functions of the job, even with PAS and 

any RAs;

• The requestor would create a direct threat to safety on the job, even with PAS and any 

RAs; or

• Providing PAS would impose undue hardship on DTRA.

Confidentiality Requirements for PAS

All medical information obtained in connection with PAS requests must be kept confidential and 

appropriately protected from unlawful disclosure. PAS requests must be kept confidential and 

must not be shared with others unless on a need-to-know basis. Any employee who obtains or 

receives such information is strictly bound by these confidentiality requirements per EEOC 

regulation and federal laws. The RA coordinator must maintain records for a period of 3 years. 

If the RA is needed on a recurring basis, then the RA records will be maintained for as long as 

the case is active.

Reporting Requirements for PAS

HR will compile and maintain PAS data to evaluate the Agency’s performance in responding to 

requests for PAS, ensure compliance with EEOC regulations and federal laws, and submit 

report(s) to the EEOC, as appropriate.

HR will establish a system of record keeping to track the processing of requests for reasonable 

accommodation. At Appendix C is the RA Information Report. The records related to the

employee that requested RA will be maintained at a minimum for the duration of the employee’s 

tenure. This will ensure that an employee is not asked to provide medical information previously
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submitted. Subsequent to an employee’s tenure, records must be maintained by the RA Program 

Manager in accordance with the DTRA’s records retention policies.
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ACRONYMS

ADA 

CAP 

CART 

DTRA

EEOC

Americans with Disability Act

Computer or Electronic Accommodation Program 

Communication access real time translation 

Defense Threat Reduction Agency

United States Equal Employment Opportunity Commission

HR 

EI 

PAS

RA

RARB

Human Resources Directorate 

Equity, Diversity and Inclusion 

Office Personal Assistance Services 

Reasonable Accommodation

Reasonable Accommodation Review Board
Reasonable Accommodation

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DEFINITIONS

Disability. Per the ADA Amendments Act of 2008, the basic definition of "disability" is an 

impairment that substantially limits one or more major life activities, a record of such an 

impairment, or being regarded as having such an impairment.

Essential Functions. The essential functions of a job are those job duties that are so 

fundamental to the position that the individual cannot do the job without being able to perform 

them. A function can be "essential" if, among other things: (a) the position exists specifically to 

perform that function, (b) there are a limited number of other employees who could perform the 

function if it were assigned to them or (c) the function is specialized and the incumbent is hired 

based on his/her ability to perform it.

Individual with a Disability. An individual with a disability is a person who (a) has a physical 

or mental impairment that substantially limits one or more of major life activities; (b) has a 

record of such impairment, or (c) is regarded as having such impairment.

Personal Assistant Services (PAS). PAS 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.

Qualified Individual with a Disability. A qualified individual with a disability is a person who

(a) satisfies the requisite skill, experience, education, and other job-related requirements of the 

position such individual holds or desires and (b) can perform the essential functions of the 

position, with or without reasonable accommodation.

Reasonable Accommodation (RA). RA is a modification or adjustment to a position, the work 

environment, or the application process that enables a qualified individual with a disability to 

attain the same level of performance of the essential duties of the job or to enjoy equal benefits 

and privileges of employment as are available to a similarly situated employee without a 

disability.

Reassignment. Reassignment is a form of RA that, absent undue hardship, is provided to 

employees (not applicants) who, because of a disability, can no longer perform the essential 

functions of the job, with or without RA. Reassignments are made only to vacant positions and 

for employees who are qualified for the new position, when no other RA exists.

Targeted Disabilities. Targeted disabilities are a subset of conditions that would be considered 

disabilities under the Rehabilitation Act. Qualified individuals with certain disabilities (e.g., 

paralysis due to spinal cord injury, blindness, missing limbs) face significant barriers to 

employment, which for some people may include lack of access to PAS in the workplace, that 

are above and beyond the barriers faced by people with the broader range of disabilities.

Undue Hardship. Undue hardship is a significant difficulty or expense and focuses on the 

resources and circumstances of the particular employer in relationship to the cost or difficulty or 

difficulty of providing a specific accommodation. Undue hardship refers not only to financial 

difficulty, but to reasonable accommodations that are unduly extensive, substantial, or disruptive, 

or those that would fundamentally alter the nature or operation of the business. An employer 

must assess on a case-by-case basis whether a particular reasonable accommodation would cause 

undue hardship. The resources of the Department of Defense must be considered when reviewing 

the cost of RAs.
Reasonable Accommodation

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APPENDIX A
Reasonable Accommodation

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APPENDIX B

Reasonable Accommodation Resources

United States Equal Employment Opportunity Commission. (800) 669-3362 (voice), (800) 

800-3302 (TTY).

1. The EEOC’s Publication Center has a great deal of basic information about reasonable 

accommodations and undue hardship. The main sources of interpretive information are:

a. The Interpretive Guidance accompanying the Title I regulations (also known as the

Appendix to the regulations), (See sections 1630.2(o) and (p), and 1630.9 of reference (q).)

b. Technical Assistance Manual on the Employment Provisions (Title I) of the ADA, 8

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

Assistance Manual includes a 200 page Resource Directory, including Government and state 

agencies and disability organizations, which can provide assistance in identifying and locating 

effective reasonable accommodations solutions.

2. The EEOC discusses issues involving reasonable accommodation in the following guidance 

and documents:

a. Enforcement Guidance: Pre-employment Disability-Related Questions and 

Medical Examinations, No. 915.002, October 10, 1995, at 5, 6-8, 20, 21-22, 8 FEP Manual 

(BNA)

405:7191, 7192-94, 7201 (1995).

b. Enforcement Guidance: Workers’ Compensation and the ADA at 15-20, 8 FEP Manual

(BNA) 405:7391, 7398-7401 (1996).

c. Enforcement Guidance: The ADA and Psychiatric Disabilities at 19-28, 8 FEP Manual

(BNA) 405:7461, 7470-76 (1997).

d. Fact Sheet on the Family and Medical Leave Act, the ADA, and Title VII of the Civil 

Rights Act of 1964 at 6-9, 8 FEP Manual (BNA) 405:7371, 7374-76 (1996).

e. Enforcement Guidance: Disability-Related Inquiries and Medical Examinations of

Employees under the ADA at 20, 22, 23, 24-5, 8 FEP Manual (BNA) 405:7701, 7711, 7712-14,

7715-16 (2000).

3. Job Accommodation Network (JAN). JAN is a free consulting service of the Office of 

Disability Employment Policy, U. S. Department of Labor designed to increase the 

employability of people with disabilities by; 1) providing individualized worksite 

accommodations solutions, 2) providing technical assistance regarding the ADA and other 

disability related legislation.

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

(800) 526-7234 (Voice)
Reasonable Accommodation

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(877) 781-9403 (TTY)

4. Computer/Electronic Accommodation Program (CAP). CAP provides assistive technology 

and services to people with disabilities, managers, supervisors, and IT professionals. CAP 

increases access to information and works to remove barriers to employment opportunities by 

eliminating the costs of assistive technology and accommodation solutions. CAP buys it, pays 

for it, and gets it to the users.

http://www.tricare.osd.mil/cap/

1700 N. Moore Street, Suite 1000

Arlington, VA 22209

(703) 614-8416 (Voice)

(571) 384-5629 (Videophone) 

(703) 697-5851 (Fax)

cap@mail.mil (Email)
Reasonable Accommodation

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APPENDIX C

Reasonable Accommodation Information Report

To be completed by manager/official who processed the reasonable accommodation. 

Submit to RA Program Coordinator. (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)

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 reason able accommodation (include 

occupational series, grade level/or equivalent information and Directorate ):

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 RA requested (e.g. adaptive equipment, removal of architectural barrier).

12. Type(s) of reasonable accommodation provided (if different from what was requested)

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, RA Manager).

Submitted by (Name, Organization, Phone, and Email Address):