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Issuing Unit: OAS

PPM Category: Human Resources

Document Number: 857

Date of Publication: 1/2/2018

Title: Reasonable Accommodations for Individuals with Disabilities

Work life: No

POLICY

The Farm Credit Administration’s (FCA or Agency) policy is to comply fully with all 

applicable legal authorities in providing reasonable accommodations to employees 

or applicants who require them due to disability. FCA is committed to providing 

reasonable accommodation to its employees and applicants for employment to

assure that individuals with disabilities enjoy full access to equal employment 

opportunities at FCA. FCA will provide reasonable accommodation:

• When an applicant with a disability needs an accommodation to have an equal 

opportunity to compete for a job; 

• When an employee with a disability needs an accommodation to perform the 

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

• When an employee with a disability needs an accommodation to enjoy equal 

access to benefits and privileges of employment (e.g., details, training, officesponsored events).

REFERENCES

• 12 U.S.C. § 2243 (§ 5.9 of the Farm Credit Act of 1971, as amended)

• Section 501 of the Rehabilitation Act of 1973, as amended, including the 

Americans with Disabilities Act Amendments Act of 2008, P.L. 110-325 (29 

U.S.C. § 791, et seq.)

• Regulations to Implement the Equal Employment Provisions of the Americans 

with Disabilities Act (29 CFR Part 1630)

• Regulations to Implement the Rehabilitation Act (29 CFR Part 1614.203)

• Title II of the Genetic Information Nondiscrimination Act of 2008 (P.L. 110-233)

• Regulations to Implement the Genetic Information Nondiscrimination Act (29 

CFR Part 1635)

• Equal Employment Opportunity Commission (EEOC): Practical Advice for 

Drafting and Implementing Reasonable Accommodation Procedures Under 

Executive Order 13164 (July 2005)

• EEOC Enforcement Guidance: Reasonable Accommodation and Undue 

Hardship Under the Americans with Disabilities Act (October 17, 2002)

• EEOC Policy Guidance on Executive Order 13164: Establishing Procedures to 

Facilitate the Provision of Reasonable Accommodation (October 20, 2000)
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APPLICABILITY

This policy applies to all FCA employees and applicants for employment with FCA.

DELEGATED AUTHORITY 

The Chief Operating Officer (COO) is authorized to approve implementing 

procedures and controls.

REPORTING REQUIRED

The Reasonable Accommodation Coordinator (RAC) will prepare an annual report 

for the Chief Executive Officer (CEO). The report will contain information as 

outlined in the procedures below.

APPROVED /s/ Date ___1/2/18______ 

Dallas P. Tonsager

 Board Chair and Chief Executive Officer 
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IMPLEMENTING PROCEDURES

Date of Issuance: 1/2/2018

1. DEFINITIONS

a) Reasonable Accommodation: Any change in the work environment or in the way 

things are customarily done that provides an equal employment opportunity to a

qualified individual with a disability. While there are some things that are not 

considered reasonable accommodations (e.g. removal of an essential job function or 

personal use items such as a hearing aid that is needed on and off the job), 

reasonable accommodations can cover a wide range of modifications and adaptations 

that enable an individual to apply for a job, perform a job, or have equal access to the 

workplace and employee benefits such as kitchens, parking lots, and office events. 

Common types of accommodations include:

-modifying work schedules

-granting breaks or providing leave

-altering how or when job duties are 

performed

-allowing telework 

-moving to different office space

-making changes in workplace policies

-removing and/or substituting a 

nonessential function

- providing technology assistance

-providing a reader or other staff to 

enable employees to perform their job 

functions, where the accommodation 

cannot be provided by current staff

-removing an architectural barrier, 

including reconfiguring work spaces

-providing accessible parking

-providing materials in alternative 

formats (e.g. Braille, large print)

b) Disability: Disability means:

• A physical or mental impairment that substantially limits one or more major 

life activities (an “actual disability”), or

• A record of such an impairment (“record of”), or

• Being regarded as having such an impairment.

The Rehabilitation Act does not require an employer to provide reasonable 

accommodation to an individual who only meets the “regarded as” definition of 

disability (bullet 3 above). An applicant or employee must meet either the “actual” 

definition or the “record of” definition (bullets 1 or 2 above) to be eligible for 

reasonable accommodation.

The definition of “disability” is to be interpreted broadly and does not require an 

extensive analysis. Examples of “major life activities” include, but are not limited to: 

caring for oneself; seeing; hearing; speaking; eating; walking; standing; lifting; 

bending; learning; thinking; communicating; sitting; interacting with others; and 

operation of a major bodily function.
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c) Qualified: Qualified, with respect to an individual with a disability, 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.

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

individual cannot do the job without being able to perform them. Determination of a 

position’s essential functions must be done on a case-by-case basis so that it reflects the 

job as actually performed, and not simply the components of a generic position 

description.

e) Undue Hardship: If a specific reasonable accommodation causes significant difficulty or 

expense for FCA, then the Agency does not have to provide that accommodation. 

Determination of undue hardship is always made on a case-by-case basis, considering 

factors that include the nature and cost of the reasonable accommodation needed and 

the impact of the reasonable accommodation on the operations of the Agency.

f) Interactive Process: A process which begins after a request for accommodation has 

been made, the interactive process is where the individual and the Agency

communicate to determine what, if any, accommodation should be provided. This 

means that the individual requesting the accommodation and the decision-maker must 

communicate with each other about the request, the precise nature of the problem that 

is generating the request, how a disability is prompting a need for an accommodation,

the functional limitations of the individual, and alternative accommodations that may 

be effective in meeting the individual’s needs. 

2) REQUESTS FOR REASONABLE ACCOMODATION

a) Initiating Request. A request for reasonable accommodation is a request that an 

individual makes for an adjustment or change at work, in the application process, or in a 

benefit or privilege of employment for a reason related to a medical condition. A 

request for reasonable accommodation begins the process. A reference guide for 

supervisors on handling requests for reasonable accommodations can be found in 

Appendix A.

A request does not have to use any special words, such as "reasonable 

accommodation," "disability," or "Rehabilitation Act." An individual with a disability 

may request a reasonable accommodation whenever he or she chooses, even if the 

existence of a disability has not been previously disclosed. The request may be made 

verbally or in writing.
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• An employee may make a reasonable accommodation request to his/her firstline supervisor; another supervisor or manager in his or her immediate chain of 

supervision; his or her Office Director; the EEOI Director; the RAC; or the Special 

Emphasis Disability Program Manager (SEDPM).

• An applicant may request a reasonable accommodation verbally or in writing 

from any FCA employee with whom the applicant has contact about the 

application process. 

• A family member, health professional, or other representative may request an 

accommodation on behalf of an FCA employee or applicant. The request should 

go to one of the same persons to whom the employee or applicant would make 

the request. Where possible, FCA will confirm with the employee or applicant 

that he or she in fact consents to the request for reasonable accommodation. 

b) Written Requests for Record Keeping Purposes

To enable FCA to keep accurate records about requests for accommodation, employees 

seeking a reasonable accommodation are asked to follow up a verbal or written request 

by submitting to the RAC a completed FCA Form 502, Confirmation of Request for 

Reasonable Accommodation (CRRA). If a reasonable accommodation request is made by 

a job applicant, the appropriate Office Director (or delegated manager or supervisor), or 

other FCA employees with whom the applicant has contact about the application 

process, can give him/her the FCA Form 502 to fill out. In such a case, the employee 

providing the form to the job applicant should immediately notify the RAC that a 

request was made and Form 502 was provided to the applicant. This written 

confirmation request is solely for FCA's recordkeeping purposes. FCA will begin the 

reasonable accommodation process when it receives a verbal or written request 

regardless of whether FCA Form 502 has been completed.

If an employee requires a reasonable accommodation on a repeated basis (for example, 

the assistance of sign language interpreters), that employee needs to submit the written 

request for recordkeeping purposes only the first time the accommodation is needed.

c) Determining the “Decision-Maker”

The FCA employee who is responsible for deciding whether to grant a request for 

reasonable accommodation is the "decision-maker." For accommodation requests from 

employees, the decision-makers will be Office Directors. To eliminate unnecessary 

levels of review, Office Directors are encouraged to delegate this authority to first-line 

supervisors or other managers or supervisors in the chain of supervision wherever 

possible. 

For reasonable accommodation requests from job applicants, the decision-maker will be 

the Office Director, or delegated manager or supervisor in the chain of supervision, for 

the Office where the applicant is seeking employment. 
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Decision-makers must designate acting decision-makers when they are not available to 

assure the required time frames are met. 

d) After a Request is Received

Any FCA employee receiving a request for accommodation (when he/she is not the 

decision-maker) should forward the request to the employee’s immediate supervisor, to 

the prospective immediate supervisor of the applicant, or to the RAC, who will then 

forward the request to the appropriate decision-maker. The request should be 

forwarded to the decision-maker as soon as possible but not more than four (4)

business days from the date the request is received. 

3. THE INTERACTIVE PROCESS

Once the decision-maker receives a request, before he or she begins to process it, he or 

she must immediately consult with the RAC about the request. The RAC will coordinate 

communications with the decision-maker to begin the interactive process with the 

requester to determine what, if any, accommodation should be provided. In the interactive 

process, the individual requesting the accommodation and the FCA decision-maker, as well 

as the RAC, must talk about the need for the request, the process for determining whether 

an accommodation will be provided, and any potential accommodation. The RAC is 

available to provide guidance to decision-makers and other employees involved in the 

reasonable accommodation process. Communication is a priority throughout the 

interactive process. 

The FCA decision-maker has the principal responsibility for identifying possible 

accommodations with assistance from the RAC. He or she will take a proactive approach in 

searching out and considering possible accommodations, including consulting appropriate 

resources for assistance. The employee requesting the accommodation should also 

participate to the extent possible in helping to identify an effective accommodation. 

Appendix B identifies resources available to help both the decision-maker and the individual 

requesting the accommodation to identify possible accommodations. 

To begin the interactive process, the FCA decision-maker will:

a) Provide an explanation as soon as possible to the applicant or employee that he/she will 

be the decision maker and describe the process. The RAC may also participate in this 

discussion.

b) Follow a three-part analysis when evaluating a reasonable accommodation request:

1. Determine if requester is a qualified individual with a disability (Section 5 below). 
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2. Determine if the accommodation is needed to enable a qualified employee with a 

disability to perform the essential functions of his/her position; enable an employee 

with a disability to enjoy equal benefits and privileges of employment as a similarly 

situated employee without a disability; or enable a qualified applicant with a 

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

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

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

accommodation may impose on the Agency.

c) Ongoing communication is particularly important where the specific limitation, problem, 

or barrier is unclear; where an effective accommodation is not obvious; or where the 

parties are considering different possible reasonable accommodations. In those cases,

where the disability, the need for accommodation, and the type of accommodation to 

be provided are clear, extensive discussion may not be necessary. Even so, the decisionmaker and the requesting individual should talk to each other to make sure there is a 

full exchange of relevant information. The RAC can also participate in this process as 

needed. 

d) There are specific considerations in the interactive process when responding to a 

request for reassignment.

1. Used as a last resort, reassignment to a funded, vacant position for which the 

employee (not applicant) is qualified is a possible reasonable accommodation.

2. Reassignment is a form of reasonable accommodation that, absent undue hardship, 

is provided to employees who, because of a disability, can no longer perform the 

essential functions of their job, with or without reasonable accommodation. 

Reassignments are made only to funded, vacant positions and for employees who 

are qualified for the new position. If the employee is qualified for the position, 

he/she will be reassigned to the job and will not have to compete for it. 

3. Reassignment will only be considered if no other effective accommodations are 

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

effective accommodation would cause undue hardship.

4. In considering whether and where there are positions available for reassignment, 

the decision-maker will work with the RAC and the individual requesting the 

accommodation to identify:

‒ All funded, vacant positions within the Agency for which the employee may be 

qualified, with or without reasonable accommodation; and

‒ All positions which the OAS has reason to believe will become vacant over the 

next 60 business days and for which the employee may be qualified.
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The Agency will first focus on positions that are equivalent to the employee's current 

job in terms of pay, status, and other relevant factors. If there is no vacant 

equivalent position, FCA will consider vacant lower level positions for which the 

individual is qualified.

5. Reassignment may be made to a funded, vacant position outside of the employee's 

commuting area if the employee is willing to relocate. As with other transfers not 

required by management, FCA will normally not pay for the employee's relocation 

costs. 

4. FCA STAFF RESPONSIBILITIES: PROCESSING REASONABLE ACCOMODATION REQUESTS

a) Office Directors

• Receive and process requests for reasonable accommodation from employees in 

their offices in accordance with these Implementing Procedures.

• To eliminate unnecessary levels of review, delegate authority for making 

decisions on requests for reasonable accommodation from employees in their 

offices, and from applicants for jobs in their offices, to first-line supervisors or 

other supervisors or managers in the chain of supervision wherever possible.

• Where they have not delegated decision-making authority, serve as decisionmakers on requests for reasonable accommodation from employees in their 

offices and from applicants for jobs in their offices.

• Consult with the RAC for guidance when they receive a request for reasonable 

accommodation for which they are the decision-maker before they begin 

processing the request.

• Obtain concurrence from the General Counsel before they make "undue 

hardship" determinations.

• Consult with the RAC and Office of General Counsel (OGC) prior to denying any 

request for reasonable accommodation.

• Provide second level of reconsideration when a decision-maker delegate denies 

a request for reasonable accommodation and an initial reconsideration request. 

• Within 10 business days of a final decision on a reasonable accommodation 

request, complete FCA Form 504, Reasonable Accommodation Information 

Reporting (RAIR) Form, and provide all records obtained or created during the 

processing of the request, including medical information received, to the RAC.

b) Managers and Supervisors

• Receive and process requests for reasonable accommodation from employees in 

their chain of supervision in accordance with these Implementing Procedures.
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• Where authority has been delegated to them, serve as decision-makers on 

requests for reasonable accommodation from employees in their chain of 

supervision and from applicants for jobs in their chain of supervision.

• As a decision-maker, consult with the RAC when they receive a request for 

reasonable accommodation, before they begin processing the request and 

regarding responses to requests.

• Obtain concurrence from the General Counsel before making "undue hardship" 

determinations.

• Consult with the RAC and OGC prior to denying any request for reasonable 

accommodation.

• Within 10 business days of a final decision on a reasonable accommodation 

request, complete FCA Form 504, RAIR Form, and provide all records obtained or 

created during the processing of the request, including medical information 

received, to the RAC.

c) Reasonable Accommodation Coordinator (RAC)

• Advise the decision-maker on each reasonable accommodation request before 

he/she begins processing it, and provide guidance on responding to requests.

• Upon receipt of an employee's or applicant's request, provide guidance to the 

employee or applicant about the process for requesting reasonable 

accommodation.

• Provide medical documentation request forms to the individual seeking a 

reasonable accommodation if the decision-maker decides that medical 

information is needed to evaluate the request.

• Receive completed medical documentation from health care providers and 

determine whether the disability requirement has been met for purposes of a 

reasonable accommodation request. Relay the disability determination to the 

decision-maker.

• Consult with OGC for guidance, as needed, on Agency reasonable 

accommodation requests. 

• Seek the concurrence of the General Counsel on any denial of a reasonable 

accommodation request based on undue hardship prior to a final decision being 

made.

• Maintain records on all reasonable accommodation requests in secure, locked 

files separate from employees' personnel files.

• Prepare an annual report on the number and types of reasonable 

accommodation requests as well as a qualitative assessment of the program, 

including any recommendations for improvement.
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d) Special Emphasis Disability Program Manager (SEDPM)

• Receive and forward to the RAC requests for reasonable accommodation from 

employees in accordance with these Implementing Procedures.

• Promote disability awareness through activities, articles and the annual 

observation of Disability Awareness Month in October.

e) Equal Employment Opportunity and Inclusion (EEO/I) Director

The EEO/I Director receives and forwards to the RAC requests for reasonable 

accommodation from employees in accordance with these Implementing Procedures. 

The EEO/I Director generally will not have substantive involvement in individual 

requests for reasonable accommodation, but may: 1) provide input regarding 

procedures and controls necessary to implement this policy after consultation with the 

RAC and OGC; and/or 2) arrange for mediation, if appropriate, to resolve a dispute over 

a reasonable accommodation request.

 f) Office of Agency Services (OAS)

• Ensure that Human Resources Specialists and other Agency staff involved in the 

reasonable accommodation application process are trained to recognize 

requests for reasonable accommodation and to handle such requests in 

accordance with all legal requirements and these Implementing Procedures.

• Ensure reasonable accommodation training is provided to all new managers and 

supervisors within one year of their becoming managers and supervisors, and to 

all employees at least every five years.

g) General Counsel

The General Counsel must concur with all denials of requests for reasonable 

accommodation based on undue hardship. If the General Counsel or the Deputy 

General Counsel is the decision-maker in such a denial or is the employee seeking the 

accommodation, the Chief Human Capital Officer (CHCO) must concur with the denial. 

 

h) Chief Operating Officer (COO).

The COO will be the second level of reconsideration when an Office Director, as the 

decision-maker, denies a request for reasonable accommodation and an initial 

reconsideration request. The COO will be the decision-maker on requests for reasonable 

accommodation submitted by any FCA employee who reports directly to him or her or 

to the CEO.
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i) Chief Executive Officer (CEO)

FCA's CEO will be the second level of reconsideration when the COO, as the decisionmaker, denies a request for reasonable accommodation and an initial reconsideration 

request. 

j) FCA Employees Who Receive Requests for Reasonable Accommodation from 

Applicants for FCA Employment

• Receive and forward to the RAC requests for reasonable accommodation from 

job applicants in accordance with these Implementing Procedures.

5. DETERMINING WHETHER THE REQUESTER HAS A DISABILITY: MEDICAL DOCUMENTATION

Before FCA grants a request for reasonable accommodation, the Agency must determine

whether an employee or applicant has a disability that requires a reasonable 

accommodation. The definition of “disability” is to be interpreted broadly and does not 

require an extensive analysis. 

In some cases, the disability and need for accommodation will be obvious. In other cases, 

the employee or applicant will have previously provided sufficient evidence of disability and 

the need for accommodation to FCA. In these cases, FCA will not seek any further medical 

information. However, when a disability and/or need for reasonable accommodation is not 

obvious or otherwise already known and the individual is requesting accommodation, FCA 

may require the individual to provide reasonable medical documentation about the 

disability and his/her functional limitations.

a) If a decision-maker believes that medical information is necessary to evaluate a request 

for reasonable accommodation, he/she will work with the RAC to request medical 

documentation from the employee or applicant. The request for medical 

documentation will be comprehensive so as to minimize the need for subsequent 

requests. However, this does not preclude subsequent requests, if they become 

necessary. The request will not seek information unrelated to the disability requiring an 

accommodation. FCA may consult with a medical consultant to determine the 

appropriate information to request. 

b) The RAC will provide the employee, applicant, or health care provider a written request 

for medical information, and provide information pertaining to the nature of the job, 

the essential functions the individual is expected to perform, and any other relevant 

information. 

Alternatively, the RAC, the decision-maker and the individual requesting the 

accommodation may agree that the individual will sign a limited release (see FCA Form 
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516), allowing FCA or its medical consultant to contact the individual's health care 

provider either directly or by submitting a list of specific questions.

c) The medical information should be returned to the RAC within 30 calendar days of the 

forms being provided to the requester. Once the RAC receives the medical information 

from the employee, applicant, or health care provider, the RAC will evaluate it and, if 

necessary, confer with the Agency's medical consultant and/or OGC to determine 

whether the individual is deemed to have a disability.

d) If the medical information initially provided is not sufficient to enable FCA to determine 

whether the individual is disabled and an accommodation is appropriate, the Agency 

may ask for further information. If this is necessary:

1. The RAC will explain to the individual seeking the accommodation, in specific terms, 

why the information provided is insufficient, what additional information is needed, 

and why it is necessary for a determination of the reasonable accommodation 

request.

2. The individual may ask his or her health care practitioner to provide the missing 

information directly to the RAC.

3. Alternatively, the RAC and the individual requesting the accommodation may agree 

that the individual will sign a limited release (see FCA Form 516), allowing FCA or its 

medical consultant to contact the individual's health care provider either directly or 

by submitting a list of specific questions.

4. If the individual and/or FCA are unable to obtain from the individual’s health care 

provider documentation sufficient to substantiate the existence of a disability and 

the need for reasonable accommodation, the RAC may, but is not required to,

request that a health care practitioner chosen by FCA examine the individual at 

FCA’s expense. 

5. The failure to provide appropriate documentation or to cooperate in FCA's efforts to 

obtain such documentation may result in a denial of the reasonable 

accommodation. An employee may renew the request at any time by providing 

appropriate documentation to the RAC.

e) Once the RAC has reviewed the medical documentation to determine whether the 

individual has a disability as defined herein, the RAC will notify the decision-maker of 

whether the individual has a disability and the individual’s impairments that require an 

accommodation based on the medical documentation. It will be within the discretion of 

the RAC as to whether specific medical information will be provided to the decisionmaker to the extent needed to determine an effective accommodation.
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6. CONFIDENTIALITY OF MEDICAL INFORMATION

The Rehabilitation Act requires that all "medical information," whether obtained through 

the reasonable accommodation process or otherwise, must be kept confidential. Medical 

information includes the fact that someone requests or is receiving an accommodation or 

has a disability, as well as any information concerning an individual's medical condition or 

history, regardless of whether the information was provided voluntarily or in response to a 

disability-related question.

Accordingly, every FCA employee who is involved in any capacity in processing a request for 

reasonable accommodation must maintain confidentiality regarding the request and may 

share information connected with such a request only as follows:

a) Any person involved in the processing of a reasonable accommodation request may 

share information as necessary in accordance with these Implementing Procedures.

b) Supervisors and managers who need to know may be told about necessary restrictions 

on the work or duties of the employee and about the necessary accommodation(s).

c) First aid and safety personnel may be told if the disability might require emergency 

treatment.

d) Government officials (for example, from the Equal Employment Opportunity 

Commission) may be given information necessary to investigate the Agency's 

compliance with the Rehabilitation Act.

e) The RAC may utilize information to prepare the annual reports required by this policy.

Notwithstanding the confidentiality requirement, the employee or applicant may voluntarily 

choose to disclose otherwise-confidential information. Moreover, any FCA employee may 

disclose information as directed by the employee or applicant seeking the reasonable 

accommodation when the employee or applicant provides a written, signed request 

expressly directing the FCA employee or the Agency to disclose such information.

FCA must ensure that all records it maintains on reasonable accommodation requests are 

kept in secure, locked files separate from employees' personnel files.

7. GENETIC INFORMATION NONDISCRIMINATION ACT of 2008

The regulations implementing the Genetic Information Nondiscrimination Act of 2008 

require employers that make a request for health-related information to warn the 

employee and/or health care provider from whom it requested the information not to 

provide genetic information, suggesting language such as the following:
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“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 an individual or family member of the 

individual, except as specifically allowed by this law. To comply with this law, 

we are 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.”

8. INSTANCES WHERE REQUESTER HAS NOT ESTABLISHED EXISTENCE OF DISABILITY

In certain instances, FCA may choose, in its discretion, to provide a workplace adjustment 

for employee comfort or productivity without determining whether the individual has a 

disability. In these instances, the Agency’s decision to provide the adjustment is not subject 

to the legal requirements governing reasonable accommodations. These instances will 

typically involve adjustments that can be readily and inexpensively provided.

9. TIMEFRAMES: PROCESSING REQUESTS AND PROVIDING REASONABLE ACCOMODATIONS

FCA processes requests for reasonable accommodation and provides accommodations, 

where they are appropriate, in as short a time frame as reasonably possible. FCA 

recognizes, however, that the time necessary to process a request will depend on the 

nature of the accommodation requested and whether additional medical information is 

necessary.

a) Decision within 20 Business Days. If an accommodation request does not require 

medical documentation from the employee/applicant and there are no extenuating 

circumstances, the decision-maker, with assistance from the RAC, will process the 

accommodation request and provide a decision within 20 business days from the date 

he or she receives the request. Where a particular reasonable accommodation can be 

provided in less than 20 days, failure to provide the accommodation in a prompt 

manner may result in a violation of the Rehabilitation Act.

b) Expedited processing. In certain circumstances, a request for reasonable 

accommodation may require an expedited review and decision that is shorter than the 

20 business days identified above. This includes where a reasonable accommodation is 

needed, for example:
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• To enable an applicant to apply for a job.

• To enable an employee to attend a meeting scheduled to occur soon.

 

c) Time Tolled When Medical Documentation is Requested. The 20-day decision period is 

not applicable when the decision-maker, in consultation with the RAC, believes it 

necessary to obtain medical information from the employee or applicant to determine 

whether the requesting individual has a disability and/or to identify the functional 

limitations. In this situation, the RAC will request the medical information from the 

employee or applicant as soon as possible after the decision-maker receives the request 

for accommodation, but before the expiration of the 20-day period. The need for 

documentation may not become apparent until after the interactive process has begun. 

d) After Receipt of Medical Documentation. Upon receipt and evaluation of acceptable 

medical documentation by the RAC, the decision-maker, in consultation with the RAC,

will make the accommodation decision within 10 business days, absent any extenuating 

circumstances as described below. 

e) Extenuating Circumstances. These are factors that could not reasonably have been 

anticipated or avoided in advance of the request for accommodation and are outside of 

the Agency’s 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. It is FCA's policy that extensions based on 

extenuating circumstances should be limited to circumstances where they are strictly 

necessary. All FCA staff are expected to act as quickly as reasonably possible in 

processing requests and providing accommodations. 

An extenuating circumstance covers limited situations in which unforeseen or 

unavoidable events prevent prompt processing and delivery of an accommodation. For 

example, FCA may not delay processing or providing an accommodation because a staff

member is unavailable.

Where extenuating circumstances are present, the decision-maker must notify the 

individual of the reason for the delay and the approximate date on which a decision, or 

provision of the reasonable accommodation, is expected. Any further developments or 

changes should also be communicated promptly to the individual.

f) Interim Accommodations. If there is a delay in providing an approved accommodation, 

the decision-maker will consult with the RAC to determine whether interim measures

can be taken to assist the employee. This could include providing the requested 

accommodation on a temporary basis or providing a less effective form of 

accommodation. 
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In addition, 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 so without imposing undue 

hardship on the agency.

FCA decision-makers, in consultation with the RAC, who approve such interim measures 

are responsible for assuring that they do not take the place of a permanent 

accommodation and that all necessary steps to secure the permanent accommodation 

are being taken. 

10. GRANTING REASONABLE ACCOMODATION REQUESTS

As soon as the decision-maker, in consultation with the RAC, determines that a 

reasonable accommodation will be granted, the decision should be immediately 

communicated to the individual in writing. If the accommodation cannot be provided 

immediately, the decision-maker must inform the individual of the projected time frame 

for providing the accommodation. The decision-maker, in consultation with the RAC, 

must ensure that the granted accommodation is provided within a reasonable

timeframe. Within 10 business days of the final decision granting the accommodation, 

the decision-maker must complete FCA Form 504 (RAIR) and send it to the RAC.

Any assistive technology or other equipment and materials provided to an employee as 

part of a reasonable accommodation are the property of FCA. Employees must return 

all equipment to the RAC upon separation from Federal service. 

Individuals are entitled to an effective accommodation but not necessarily the 

accommodation of their choice. Where the decision-maker, in consultation with the 

RAC, has offered to make an accommodation other than one requested by the 

individual, the decision-maker shall notify the individual of the reasons the decisionmaker believes that the chosen accommodation will be effective. If the individual 

rejects the alternate accommodation offered, the decision-maker must document that 

rejection on FCA Form 504.

11. DENIAL OF REASONABLE ACCOMODATION REQUEST

The decision-maker must first consult with the RAC and OGC before any decision denying 

a reasonable accommodation request is made. If the denial is based on undue hardship, 

concurrence from the General Counsel is required. The decision-maker must fill out FCA 

Form 503 (DRAR) and give it to the individual who requested the accommodation as soon 

as the denial decision is made. The explanation for the denial should be written in plain 

language, clearly stating the specific reasons for the denial.
17

Reasons for the denial of a request for reasonable accommodation may include the 

following, keeping in mind that the actual notice to the individual must include specific 

reasons for the denial: 

a) The requested accommodation would not be effective.

b) Providing the requested accommodation would result in undue hardship. Before 

reaching this determination, the decision-maker, must explore whether other 

effective accommodations exist which would not impose undue hardship and 

therefore can be provided. 

c) Medical documentation is inadequate to establish that the individual has a disability 

or needs a reasonable accommodation to be considered for a job; to perform the 

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

employment.

d) Requested accommodation would require the removal of an essential function.

e) The requested accommodation would require the lowering of an essential 

performance or production standard.

In addition, the written notice of denial must explain FCA's procedures for requesting an 

initial and second level of reconsideration. The notice should also inform the individual 

that if the second level of reconsideration sustains the denial, he or she has the right to 

file an EEO complaint or may have rights to pursue a Merit Systems Protection Board 

(MSPB) appeal. See Section 14 below.

12. REQUEST FOR RECONSIDERATION. FCA has a two-step reconsideration process for 

denials of requests for reasonable accommodation or for approvals of an accommodation 

other than the accommodation of choice.

If an individual wishes reconsideration, he or she should first ask the decision-maker to 

reconsider the decision. The individual may present additional information in support of 

his or her request. The decision-maker will decide a reconsideration request within 20 

business days of receipt of a written request for reconsideration. The decision-maker 

should consult with the RAC and the CHCO/OGC as appropriate. Once the reconsideration 

decision is made, the requester should be promptly notified of the decision with a copy to 

the RAC. The RAC will update FCA Form 504 with information on the reconsideration 

decision.

If the decision is sustained on initial reconsideration and the decision-maker is not an 

Office Director, the individual may seek a second level of reconsideration from the 
18

appropriate Office Director. The individual may present additional information in support 

of his or her request. The Office Director will decide on the request for reconsideration 

within 20 business days. The Office Director should consult with the RAC and the 

CHCO/OGC as appropriate. Once the second reconsideration decision is made, the 

requester should be promptly notified of the decision with a copy to the RAC. The RAC 

will update FCA Form 504 with information on the second reconsideration decision.

If the decision is sustained on initial reconsideration and the decision-maker is an Office 

Director, the individual may seek a second level of reconsideration from the COO. The 

individual may present additional information in support of his or her request. The COO 

will decide on the request for reconsideration within 20 business days. The COO should 

consult with the RAC and the CHCO/OGC as appropriate. Once the second 

reconsideration decision is made, the requester should be promptly notified of the 

decision with a copy to the RAC. The RAC will update FCA Form 504 with information on 

the second reconsideration decision.

If the decision is sustained on initial reconsideration and the decision-maker is the COO, 

the individual may seek a second level of reconsideration from FCA's CEO. The individual

may present additional information in support of his or her request. The CEO will decide 

on the request for reconsideration within 20 business days. The CEO should consult with 

the RAC and the CHCO/OGC as appropriate. Once the second reconsideration decision is 

made, the requester should be promptly notified of the decision with a copy to the RAC. 

The RAC will update FCA Form 504 with information on the second reconsideration 

decision.

An individual may bring an EEO or MSPB claim if the individual has utilized the process for

initial and second level reconsideration in accordance with Section 14 below.

13. INFORMATION MAINTENANCE, TRACKING AND REPORTING

Within 10 business days of a final decision on a reasonable accommodation request, 

decision-makers must complete FCA Form 504 (REASONABLE ACCOMMODATION 

INFORMATION REPORTING FORM), and provide all records obtained or created during the 

processing of the request, including medical information received, to OAS, Attention: 

Reasonable Accommodation Coordinator. The OAS will maintain employee 

accommodation records for the longer of the employee's FCA tenure or 5 years.

The RAC will prepare an annual report for the CEO. The report will contain the following 

information:

a) The number of reasonable accommodations, by type, and by job (occupational series, 

grade level, organization location) that have been requested in the application process 

and whether those requests have been approved or denied;
19

b) The number of reasonable accommodations, by type, and by job (occupational series, 

grade level, organization location) that have been requested by current employees to 

enable performance of the essential functions of their job and whether those requests 

have been approved or denied;

c) The number of requests for reasonable accommodations, by type, that relate to the 

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

denied;

d) The reasons for denial of requests for reasonable accommodation;

e) The amount of time taken to process each request for reasonable accommodation; 

and

f) The sources of technical assistance that have been consulted in trying to identify 

possible reasonable accommodations. 

In addition, the report will provide a qualitative assessment of FCA's reasonable 

accommodation program, including any recommendations for improvement of FCA's 

reasonable accommodation policies and procedures. 

14. RELATIONSHIP OF PROCEDURES TO STATUTORY CLAIMS

This policy is in addition to statutory protections for people with disabilities and the 

remedies they provide for the denial of requests for reasonable accommodation. 

Requirements governing the initiation of statutory claims, including time frames for filing 

such claims, remain unchanged. An individual who chooses to pursue statutory remedies 

for denial of reasonable accommodation must:

a) For an EEO complaint: Contact an EEO counselor within 45 days from the date the 

individual is notified that the second level of reconsideration has sustained the denial of 

the request for accommodation or has sustained the approval of an accommodation 

other than the accommodation of choice.

b) For an MSPB appeal: Initiate an appeal to the MSPB within 30 days of an appealable 

adverse action as defined in 5 C.F.R. 1201.3. 

15. SIGN LANGUAGE INTERPRETERS

When a hearing-impaired employee is known to need a sign language interpreter, the 

Agency must provide the interpreter for crucial events such as training, safety talks, 

discussions on work procedures, policies or assignments, and disciplinary actions, 

whether or not the employee asks for it. If such an event must occur in a time frame 

that does not permit the Agency to obtain an interpreter, the Agency must document 
20

both the need for the timing of the event and the attempts it has made to obtain an 

interpreter on FCA Form 503, Denial of Reasonable Accommodation Request. In 

addition, the Agency must ensure and document on the denial form that the hearingimpaired employee receives the information presented at the event in a thorough, 

appropriate, and timely fashion.

Approved:_________/s/___________________________ Date: ___1/2/18_________

William Hoffman

Chief Operating Officer
21

APPENDIX A

Summary of Reasonable Accommodation Process

An employee or someone on the employee’s behalf makes a verbal or written request for a reasonable 

accommodation. Whoever initially receives the request must forward it to the employee’s supervisor, who will 

forward it to the appropriate decision-maker (DM). The request must be given to the DM within 4 business days. 

The DM should provide requester with written acknowledgement of the RA request and copy the RAC. DM should 

also provide requester with explanation of process as soon as possible. (FCA Form 502, Confirmation of Request for 

Reasonable Accommodation, is completed by employee and sent to RAC.)

The DM: (1) receives the request for accommodation; (2) seeks guidance from the RAC; (3) engages in the 

interactive process; (4) reviews the request to determine if it is reasonable; and (5) works with the RAC to request 

medical documentation from the employee, if needed. The completed medical documentation goes to the RAC. 

The DM issues decision within 20 business days if no medical documentation is needed or within 10 business days 

following receipt and review of acceptable medical documentation by the RAC.

A decision denying the 

requested accommodation 

must explain the reason for 

denial. (General Counsel must 

concur if denial is based on 

undue hardship; OGC 

consulted for any other 

denials.)

(FCA Form 503, Denial of 

Reasonable Accommodation 

Request, completed by 

decision-maker)

A decision offering an 

accommodation other than 

what was requested must 

explain why the alternate 

accommodation was offered 

and why it will be effective.

A decision granting the proposed 

accommodation should be 

immediately communicated to 

the individual. If the 

accommodation cannot be 

provided immediately, the 

decision-maker must inform the 

individual of the projected time 

frame for providing the 

accommodation and must 

provide an interim 

accommodation to the extent 

possible. 

If Employee requests reconsideration from decision-maker, 

decision-maker has 20 business days to issue reconsideration 

decision.

If reconsideration decision is denied, employee may request a 

2nd level reconsideration. Appropriate Official has 20 business 

days to issue reconsideration decision.

The decision-maker will complete FCA Form 504, Reasonable 

Accommodation Information Reporting Form, and provide it to the RAC

within 10 business days of the final decision.
22

APPENDIX B

Selected Reasonable Accommodation Resources

Computer/Electronic Accommodations Program (CAP)

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

The Computer/Electronic Accommodations Program (CAP) provides assistive technology, 

devices, and services free of charge to Federal agencies, such as FCA, that have a partnership 

agreement with CAP, to enable the agencies to provide reasonable accommodation to 

employees with disabilities. CAP's mission is to ensure that people with disabilities have equal 

access to the information environment and opportunities throughout the Federal government. 

Form 479 (add link) should be completed to request assistive technology and services.

U.S. Equal Employment Opportunity Commission (EEOC)

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

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

of the Americans with Disabilities Act (ADA), including both the statute, 42 U.S.C. 12101 et seq. 

(1994), and the regulations, 29 C.F.R. 1630 (1997). In addition, the EEOC has published a great 

deal of basic information about reasonable accommodation and undue hardship. These 

documents are available through the Internet at http://www.eeoc.gov.

Job Accommodation Network (JAN)

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

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

A service of the U.S. Department of Labor’s Office of Disability Employment Policy. JAN can 

provide information, free-of-charge, about many types of reasonable accommodations.

ADA Disability and Business Technical Assistance Centers (DBTACs)

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

http://www.adata.org/

The DBTACs consist of 10 federally funded regional centers that provide information, training, 

and technical assistance on the Americans with Disabilities Act (ADA). Each center works with 

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

provide current ADA information and assistance, and places special emphasis on meeting the 

needs of small businesses. The DBTACs can make referrals to local sources of expertise in 

reasonable accommodations.

Registry of Interpreters for the Deaf

(301) 608-0050 (Voice/TT)

http://www.rid.org/

The Registry of Interpreters for the Deaf, Inc., (RID) is a national membership organization of 

professionals who provide sign language interpreting/transliterating services for Deaf and Hard 

of Hearing persons. RID advocates for the increased quality, qualifications, and quantity of 
23

interpreters. The Registry offers information on locating and using interpreters and 

transliteration services.

RESNA Technical Assistance Project

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

http://www.resna.org/

RESNA, the Rehabilitation Engineering and Assistive Technology Society of North America, can 

refer individuals to projects in all 50 states and the six territories offering technical assistance 

on technology-related services for individuals with disabilities. Services may include:

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

with a disability (including access to large data bases containing information on 

thousands of commercially available assistive technology products), 

• Centers where individuals can try out devices and equipment, 

• Assistance in obtaining funding for and repairing devices, and 

• Equipment exchange and recycling programs. 
24

CONFIRMATION OF REQUEST FOR REASONABLE ACCOMMODATION (FCA-502)

Completed by the Individual Requesting Reasonable Accommodation

Return form to the Reasonable Accommodation Coordinator (RAC), Office of Agency Services

Applicant’s or Employee’s 

Name

Telephone Office Date of 

Request

Today’s Date

ACCOMMODATION REQUESTED - Be as specific as possible, for example, adaptive equipment, 

reader, or schedule modification. If accommodation is time sensitive, please explain.

REASON FOR REQUEST – Identify substantial limitation of major life activity (see PPM definition of 

“disability” or consult with RAC if assistance needed).

FCA-502 (12/17)
25

DENIAL OF REASONABLE ACCOMMODATION REQUEST (FCA-503)

Completed by Decision-Maker for the Reasonable Accommodation Request

Return form to the individual requesting the reasonable accommodation and provide copy to 

the Reasonable Accommodation Coordinator , Office of Agency Services

Name of Individual Requesting Reasonable Accommodation

 

Type(s) of reasonable accommodation requested

 

Was the Reasonable Accommodation Coordinator or other FCA resources 

consulted prior to denial of the request?

 Yes No 

Request for reasonable accommodation denied because: May check more than one

Accommodation ineffective

Accommodation creates undue hardship 

Medical documentation inadequate

Accommodation requires removal of an essential function

Accommodation requires lowering of performance or production standard

Other (please identify) 

Detailed Reason(s) for the denial of reasonable accommodation. Must be specific 

and state why accommodation is ineffective or causes undue hardship

 

Steps to request reconsideration of the decision:

1. The individual asks the decision-maker to reconsider the denial. The individual may 

provide additional information to support this request. The decision-maker must 

respond to the request for reconsideration within 20 business days. 

2. If the decision (denial) is sustained:

‒ If the decision-maker is not an Office Director, the individual may seek a 

second level of reconsideration from the appropriate Office Director. The 

individual may present additional information in support of his or her request. 

The Office Director will respond to the request for reconsideration within 20 

business days.
26

‒ If the decision-maker is an Office Director, the individual may seek a second level 

of reconsideration from the Chief Operating Officer (COO). The individual may 

present additional information in support of his or her request. The COO will 

respond to the request for reconsideration within 20 business days.

Steps to pursue statutory claims:

1. EEO Complaint pursuant to 29 C.F.R. § 1614: The individual must contact an EEO 

Counselor within 45 days from the date the individual is notified that the second level 

of reconsideration has sustained the denial of the request for accommodation.

2. Merit Systems Protection Board (MSPB) Appeal: The individual must initiate an 

appeal to MSPB within 30 days of an appealable adverse action as defined in 5 

C.F.R. § 1201.3. 

If denial was based on undue hardship, concurrence by the General Counsel (if the General 

Counsel or Deputy General Counsel was decision-maker, concurrence by Chief Human 

Capital Officer):

Name

GENERAL COUNSEL Signature

Date

Name of Decision-Maker Signature

Date 

 

FCA-503 (12/17)

Return form to the individual requesting the reasonable accommodation and provide copy to the 

Reasonable Accommodation Coordinator , Office of Agency Services
27

REASONABLE ACCOMMODATION INFORMATION REPORTING FORM (FCA-504)

Completed by Decision-Maker for the Reasonable Accommodation Request

Attach copies of all documents obtained or developed in processing this request

Return form to the Reasonable Accommodation Coordinator (RAC), Office of Agency Services

Name of Individual Requesting 

Accommodation

Office

 

Job held or desired

(occupational series, grade level)

 

Reasonable accommodation: Check one

Approved

 Alternate Accommodation Approved

Denied If denied, attach copy of the Denial of Request form.

Date Request Received

 

Received By (Name)

 

Date Referred to DecisionMaker

 

Decision-maker

 

Date Approved or Denied

 

Date Accommodation Provided (if different from date 

approved)

 

Date of Initial 

Reconsideration Request

Decision on Initial Reconsideration Request

Date of Second 

Reconsideration Request

Decision on Second Reconsideration Request

If time frames outlined in Reasonable Accommodation Procedures were not met, 

please explain why.

 

Reasonable accommodation needed for: (check one)

 Application process

 Performing job junctions or accessing the work environment

 Accessing a benefit or privilege of employment i.e., attending a training program or 

social event
28

 

Type(s) of reasonable accommodation requested (for example, adaptive equipment, 

reader, removal of architectural barrier)

 

Type(s) of reasonable accommodation provided

 

Offer of Alternate Accommodation. 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 you believe the chosen accommodation would be effective.

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

 

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

reasonable accommodations, e.g., Job Accommodation Network, disability organization, 

Disability Program Manager)

 

Comments

 

Submitted by

 

Phone

 

FCA-504 (12/2017)

Attach copies of all documents obtained or developed in processing this request

Return form to the Reasonable Accommodation Coordinator (RAC), Office of Agency Service
29

AUTHORIZATION FOR RELEASE OF MEDICAL INFORMATION (FCA-516)

I, [Employee Name], hereby request and authorize my health care provider(s) to release 

pertinent medical information concerning my medical condition as it relates to my request 

for reasonable accommodations to my employer:

[Name]

OAS-HRD Reasonable Accommodation Coordinator

Farm Credit Administration

1501 Farm Credit Drive

McLean, VA 22102

Phone: 703-883-XXXX

Email: 

________________________________________________________________

Signature

_________________________________

Date 

FCA-516 (12/2017)