Appendix D

Federal Labor Relations Authority

PROCEDURES FOR PERSONAL ASSISTANCE SERVICES 

Procedures for Personal Assistance Services (PAS) allow employees with targeted disabilities to 

fully participate in the workplace by providing assistance with activities of daily living, such as 

eating, drinking, using the restroom, and putting on and taking off clothing. 

PAS allow employees with targeted disabilities to fully participate in the workplace by providing 

assistance with activities of daily living, such as eating, drinking, using the restroom, and putting 

on and taking off clothing. The Procedures for providing Personal Assistance Services (PAS) 

are also accessible on the FLRA’s website. 

Eligibility

The following conditions may entitle an employee to PAS: 

• The individual is a new or existing employee of the Agency and has a targeted disability.

• The employee requires such services because of his/her targeted disability (certain 

disabilities such as missing extremities and paralysis require assistance with basic 

activities of daily living like eating and using the restroom).

• The provision of such services would, together with any reasonable accommodation 

required under the Rehabilitation Act, enable the employee to perform the essential 

functions of his/her position, without posing a direct threat to safety; and

• Providing PAS will not impose an undue hardship on the Agency.

Not all employees with a targeted disability are entitled to PAS. Generally, such assistance is 

only necessary when it is obvious that an employee has a targeted disability (i.e. paralysis or 

missing limbs) and requires assistance with basic activities, like eating and using the restroom. 

In these situations, the Agency may not require the individual to provide medical documentation 

in support of their request. However, to determine whether a requesting individual is entitled to 

PAS and, if so, the nature of the required services, the Agency RAC should ask the employee 

what types of PAS he or she needs using the same type of informal, interactive process used for 

reasonable accommodation.

PAS do not help individuals with disabilities perform their specific job functions, such as 

services required as a reasonable accommodation to help an individual perform job-related tasks. 

For example, services provided as a reasonable accommodation, but not PAS, are sign language 

interpreters who enable individuals who are deaf to communicate with coworkers, and readers 

who enable individuals who are blind or have learning disabilities to read printed text. 
The Agency will provide PAS for employees to participate in employer-sponsored events, to the 

same extent as reasonable accommodations is provided.

Procedures for requesting PAS

• As with reasonable accommodation, an individual may request PAS by informing a 

supervisor, human resources professional, RAC, or other suitable individual that he or 

she needs assistance with daily life activities because of a medical condition. The request 

may be made orally or in writing. The individual does not need to mention Section 501 

or the EEOC’s regulations explicitly, or use terms such as “PAS” or “affirmative action” 

to trigger the Agency’s obligation to consider the request.

• A request for PAS may be made by a family member, health professional, or other 

representative on the individual’s behalf with the individual’s consent. The RAC will 

confirm the request, when necessary, with the person with the disability.

• As with reasonable accommodation, to enable the Agency to maintain accurate records of 

requests for PAS, the requestor is asked to confirm the request by completing the Request 

for Reasonable Accommodation, Appendix A and submit it to the designated RAC. The 

Agency will address PAS requests promptly even if the requestor does not complete the 

Request form.

PAS Providers

• PAS must be performed by a personal assistance service provider. The Agency has the 

discretion to use Federal employees, independent contractors, or a combination of 

employees and contractors. For services performed by Federal employees, the Human 

Resources Division will consult with the appropriate point of contact (e.g., employee’s 

supervisor, the RAC) prior to determining the terms and conditions of employment. PAS

may also be provided by an employee’s family member who is hired as a professional 

PAS provider, either as a contractor or Federal employee.

• Resources for PAS providers include local vocational rehabilitation offices, American 

Job Center, centers for independent living, home care agencies, and the individual with 

requests PAS. If the Agency decides to hire a full-time/part-time PAS provider, 

applicants for PAS provider positions may be found in the same way that applicants for 

other positions are located - by advertising the opening on USAJOBS and other jobposting sites.

• If an individual that provides PAS is unavailable, the PAS providers must notify the 

Agency point of contact of any absences as soon as possible, so that they can make 

alternative arrangements. For example, contracting with different providers on a shortterm basis, the schedules of shared PAS providers, or allowing the individual to telework 

if the employee can work at home without the need for PAS provided by the Agency.
Granting request for PAS 

As with reasonable accommodations, the RAC has the responsibility for processing requests for 

PAS. As soon as a decision has been made to provide PAS to an employee, the RAC will assist 

the deciding official in arranging the service. As part of the interactive process, and in 

consultation with the Human Resources and /or Contracting, the RAC will assist the deciding 

official in determining the most appropriate source for PAS based on the employees’ needs and 

available resources as prescribed in Sub-Section 1(c) (i) above. The deciding official is 

responsible for providing the decision in writing to the requestor. The Agency will maintain a 

copy of the decision in the same manner records are maintained for requests for reasonable 

accommodations.

Denial of request for PAS

• Procedures for denying a request for PAS are the same as the reasonable 

accommodations (See Appendix A). The Agency is only required to provide PAS if the 

requesting employee is entitled as prescribed in Sub-Section 1(a) above. Therefore, a 

request for PAS may be denied if: 

o The requestor is not an employee of the Agency;

o The requestor does not have a targeted disability;

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

o The requestor is not able to perform the essential functions of the job, even with 

PAS and any reasonable accommodations; 

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

any reasonable accommodations; or 

o The PAS would impose undue hardship on the Agency.

• Under the new regulations, the term “undue hardship” has the same meaning that it has in 

the reasonable accommodation context. Granting a request for PAS will impose undue 

hardship on an Agency if it would result in “significant difficulty or expense.” The 

regulations emphasize that, as with reasonable accommodation, the determination of 

whether granting an individual’s request for PAS would impose “significant” difficulty or 

expense must take into account all resources available to the Agency as a whole.

• The number of individuals with the types of disabilities that require assistance in 

activities of daily living and who will apply for federal employment is very low. 

However, in the unlikely event that the resources available to the Agency as a whole are 

insufficient to grant a particular individual’s request for PAS, the Agency may deny the 

request on the grounds that it would impose an undue hardship.

 
Confidentiality 

As with reasonable accommodations, the Rehabilitation Act prohibits the disclosure of medical 

information except in certain limited situations. Generally, information that is otherwise 

confidential under the Rehabilitation Act may be shared only with individuals involved in the 

PAS process who need to know the information to consider PAS for a specific individual.