Navigating the Reasonable Accommodation Request Process: Policies, Procedures, and Resources
- Heather MacLeod
- Jun 1
- 6 min read
The process of requesting reasonable accommodations is an essential right for employees and job applicants with disabilities, ensuring they can perform their job duties and participate fully in the workplace. This guide outlines the steps involved in initiating a request for accommodations, engaging in the interactive process with supervisors, and understanding the key policies and procedures that govern these requests. From understanding Federal and Department of Defense regulations to exploring specific branch-specific policies, this document provides a comprehensive overview of how individuals with disabilities can navigate the accommodation process to ensure they have equal access to employment opportunities.
Initiating a Request
Employees or applicants can request accommodations verbally or in writing to their supervisor, the EEO Office, or the Civilian Personnel Advisory Center (CPAC). Clearly specify the type of accommodation needed and the condition requiring it. Sharing the impact of the reasonable accommodation requested can also give your employer insight as to why you are requesting the reasonable accommodation. You can share your own ideas for a reasonable accommodation and also as the employer for their possible ideas.
If putting your request in writing or a typed form, be sure to include dates and the names or office you are submitting the request to so that you have documentation of your request. Sending your request via email will also document the request.
Participating in the Interactive Reasonable Accommodation Request Process
Once you have requested a reasonable accommodation, expect to engage in a collaborative discussion with your supervisor or the EEO Office to identify effective accommodations. Expect those at the interactive process to ask questions and remember that it should be a collaborative experience for both parties.
Awaiting a Timely Decision
After the interactive process, you wait for a decision. Decisions are typically made within 30 calendar days of the request. It is common to receive a response in writing with a formal tone.
Keeping It Confidential
All information related to the request is kept confidential. This means all information related to your medical need, impairment, disability, religious beliefs, or other needs expressed will not be shared with those who do not have a need to know or who are outside the process for requesting a reasonable accommodation.
What If My Reasonable Accommodation Request Is Denied?
If your request for reasonable accommodation is denied, follow these steps:
Request a Written Explanation: Ensure the denial decision is provided in writing, including specific reasons to support the denial. Ask for any alternative accommodations to be considered.
File an Informal EEO Complaint: Contact the EEO Office within 45 calendar days of the denial or discriminatory action. The EEO Office will assign a counselor to attempt an informal resolution.
File a Formal EEO Complaint: If the issue is not resolved informally, file a formal complaint within 15 days of the closure of the informal process.
Request for Reconsideration: Submit a reconsideration request to your chain of command, Human Resource representative, or the Reasonable Accommodation Coordinator.
File a Complaint with the EEOC: File a complaint with the Equal Employment Opportunity Commission (EEOC) within 180 days of the denial or discriminatory action.
Revisiting and Reassessing Your Reasonable Accommodations
A government agency has the right—and in many cases, the obligation—to periodically revisit and reassess your reasonable accommodation. This process is meant to ensure that your accommodation remains effective, appropriate, and aligned with both your needs and the operational needs of the agency.
Several factors can trigger this reevaluation. Changes to your medical condition, improvements or declines in your ability to perform certain tasks, or updates to medical documentation may prompt the agency to review whether the current accommodation is still the most suitable option. In addition, agencies must also respond to shifts in their operational environment. For example, office space realignments, changes in telework policies, or evolving mission requirements may require the agency to take a fresh look at all accommodations to ensure they remain feasible and effective within the new context.
A common situation that requires a reevaluation is when an employee's job duties change. If your role is modified—whether through a promotion, reassignment, restructuring, or expansion of responsibilities—you may need to request new or updated reasonable accommodations to address those new job functions. Since accommodations are tailored to help you perform the essential functions of your current position, any change to those functions could mean the existing accommodation may no longer fully meet your needs. In these cases, it is essential to engage in the interactive process again to determine what, if any, adjustments are necessary to continue supporting your ability to perform effectively.
It is also important to note that when accommodations such as full-time remote work are approved, your physical office space could be reallocated. Agencies are tasked with managing resources wisely, and leaving office space unused when an employee is permanently or primarily remote is not an efficient use of government facilities. This space may be reassigned to meet the needs of other staff or organizational functions. However, this decision is strictly an operational consideration and is not a reflection on you or your performance.
Ultimately, the purpose of revisiting your reasonable accommodations is to balance your needs with the evolving needs of the agency, ensuring you can continue performing your duties successfully while the agency maintains operational efficiency and resource stewardship.
Policies Surrounding Reasonable Accommodaitons
Remember, the policies governing reasonable accommodation (RA) for Army civilian employees, including those at USAG Humphreys and within the Eighth Army, are primarily based on federal statutes, Army regulations, and DoD policies. There are so many, it can be overwhelming, but knowing your rights is half the battle. Keep in mind that many policies have been removed to comply with the Executive Order regarding Diversity, Equity, and Inclusion and are currently being rewritten and reconsidered for approval.
Federal Laws Protecting Employee Rights in the Workplace
Section 504, Rehabilitation Act of 1973: This Federal law requires federal agencies to provide reasonable accommodations for qualified individuals with disabilities. It mandates that agencies ensure equal employment opportunities unless providing the accommodation causes undue hardship.
Americans with Disabilities Act Amendments Act (ADAAA): This Federal law updates and strengthens protections for people with disabilities. It clarifies the definition of “disability” to ensure more people are covered under the law. The ADAAA also makes it easier for individuals to qualify for disability protections in areas like employment and public services.
Equal Employment Opportunity Commission (EEOC) Guidance: This Federal law is a set of rules and recommendations that help employers understand and comply with anti-discrimination laws. It provides clarity on how to handle workplace issues related to discrimination, harassment, and retaliation. The guidance ensures that employees' rights are protected and that employers can make fair decisions in the workplace.
Website: https://www.eeoc.gov/
DoD Policies and Programs Protecting Employee Rights in the Workplace
DoD Instruction 1350.02 DoD Equal Opportunity Program: Provides additional protections against disability discrimination within the Department of Defense.
DoD Instruction 1400.25, Volume 1614: This instruction outlines the process for providing RA to civilian employees and applicants with disabilities. It also details confidentiality requirements and the interactive process.
Computer/Electronic Accommodations Program (CAP): CAP is the Department of Defense’s centrally funded reasonable accommodation program that provides assistive technology (AT) and services to DoD civilian employees with disabilities and wounded, ill, and injured Service members. You can complete the Workplace Disability Needs Assessment, request accommodations, and more.
Website: https://www.cap.mil/
Branch-Specific Policies
Army Regulation (AR) 690-12: Equal Employment Opportunity and Affirmative Action: This AR establishes the Army’s commitment to EEO principles, including providing RA to individuals with disabilities. It also requires supervisors and managers to engage in the interactive process promptly.
Army Regulation (AR) 600-7: Unlawful Discrimination on the Basis of Disability in Programs and Activities Receiving Federal Financial Assistance From or Conducted By the Department of the Army: This AR makes it illegal for programs or activities funded by the Department of the Army to discriminate against people because of their disability. It ensures that individuals with disabilities have equal access to services and opportunities in these programs. It also includes provisions for accommodating disabilities in the workplace.
Army Policy and Procedures for Reasonable Accommodation and Personal Assistance Services for Individuals with Disabilities:
Air Force Instruction (AFI) 36-2706: Equal Opportunity Program: This instruction outlines the Air Force's policies and procedures for promoting equal opportunity, preventing discrimination, and supporting affirmative action efforts for all service members and civilian employees.
Navy Equal Opportunity (EO) Program OPNAVINST 5354.1F: This former instruction outlined the Navy's policies and procedures for ensuring equal opportunity and preventing discrimination within the Navy. This instruction is currently not available. It has been removed in DONI to comply with the Executive Order regarding DEI. The Navy has stated that they will upload the revision of this directive once it has been approved.
Other Resources
Job Accommodation Network:
Website: https://askjan.org/
JAN's Searchable Online Accommodation Resource (SOAR): This system is designed to let users explore various accommodation options for people with disabilities in work and educational settings. These accommodation ideas are not all-inclusive. If you do not find answers to your questions, please contact JAN directly. The staff of experienced consultants is happy to discuss specific accommodation needs in a confidential manner.
Website: https://askjan.org/soar.cfm
USAG Humphreys EEO Website
8th Army EEO Website:
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