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United States Department of the Interior 

                                      FISH AND WILDLIFE SERVICE     
                                               Washington, D.C. 20240

                                                                                                                                                   AUGUST 6, 1998

To: Service Directorate 
From: Deputy Director 
Subject: Reasonable Accommodation 
Section 501 of the Rehabilitation Act of 1973 requires Federal agencies to provide reasonable accommodations to employees and applicants. Accordingly, the Service has developed a Policy On Reasonable Accommodations For Persons With Disabilities (attached).

The attached Policy describes procedures to be followed when any Service employee or applicant for employment requests an accommodation for a known disability. Please direct any questions to Jerome M. Butler, Ph.D., Chief Office for Human Resources, on (202) 208-3195. Thank you.

                                                                                                  /s/ John G. Rogers


1.  Policy
2. Purpose
3. Applicability
4. Definitions
5. Responsibilities
a.  Director
b.  Chief, Office for Human Resources
c.  Chief, Division of Personnel Management
e.  Employees and Applicants
6. Explanation of Reasonable Accommodation
a.  Overview
b.  Reasonable Accommodation Assessment
7. Means of Reasonable Accomodation
8. Factors Considered in Determining Undue hardship
9. Acting on Reasonable Accomodation Requests
Appendix 1  Sample Request Form for Reasonable Accomodation
Appendix 2  Reasonable Accommodation for Qualified Disabled Persons


1. POLICY. In accordance with Section 501 of the Rehabilitation Act of 1973 and Equal Employment Opportunity Commission (EEOC) Directives 712 and 713 (Comprehensive Affirmative Action Program Plans for Hiring, Placement and Advancement of Individuals with Disabilities), and Regulations at 29 CFR 1614, the U.S. Fish and Wildlife Service will make reasonable accommodations for the known physical or mental limitations of a qualified disabled employee or applicant unless the accommodation would impose an undue hardship on the operation of the program. The Service is not required to implement an accommodation which would amount to substantial, extensive or fundamental alterations of its operations.

2. PURPOSE. This document provides a description of the Service's policy on making reasonable accommodations for persons with disabilities by establishing requirements and providing instructions for acting on requests from employees or applicants.

3. APPLICABILITY. This Policy applies only to employees and applicants who have a disability as defined in 4a below.


a. DISABLED PERSON is one who has a physical or mental impairment that substantially limits one or more major life activities; has a record of such an impairment; or is regarded as having such an impairment.

b. PHYSICAL OR MENTAL IMPAIRMENT is any physiological disorder or condition cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems: neurological; musculoskeletal; special sense organs; cardiovascular; reproductive; digestive; gento-urinary; hemic and lymphatic; skin; and endocrine; or any mental or psychological disorder, such as mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities.

c. MAJOR LIFE ACTIVITIES are functions such as caring for one's self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning and working.

d. HAS A RECORD OF SUCH AN IMPAIRMENT is defined as having a history of, or has been classified (or misclassified) as having a mental or physical disability that substantially limits one or more major life activities.

e. IS REGARDED AS HAVING SUCH AN IMPAIRMENT is defined as having a physical or mental impairment that does not substantially limit major life activities, but is treated by an employer as constituting such a limitation; has a physical or impairment that substantially limits major life activities only as a result of the attitude of an employer toward such an impairment; or has none of the impairments defined above but is treated by an employer as having such a limitation.

f. A QUALIFIED DISABLED PERSON is one who, with or without a reasonable accommodation in an employment setting, can perform the essential functions of the position in question without endangering the health or safety of the individual and others; and who, depending on the appointing authority being used, meets the experience and/or education requirements of the position in question (which may include passing a written test), or meets the criteria for appointment under one of the special appointing authorities for disabled persons.


a. THE SERVICE DIRECTOR is responsible for implementing the Service's Policy on reasonable accommodation (that is, ensuring that reasonable accommodations are made for qualified disabled employees or applicants in-accordance with applicable laws, regulations and this Policy and applicable bargaining unit agreements).

b. THE CHIEF, OFFICE OF HUMAN RESOURCES AND ASSISTANT REGIONAL DIRECTORS, HUMAN RESOURCES are responsible for providing guidance and assistance to the Service in the effort to make reasonable accommodations to qualified disabled employees or applicants; and reviewing decisions, prior to issuance, made by Service Offices when those decisions are unfavorable to the qualified disabled employees and applicants. The individuals or designated staff may provide technical assistance and guidance on taking or recommending the appropriate action on work accommodations, assignments, and other activities which would benefit both the Service and the disabled employee or applicant. This responsibility does not include any accommodations that would create an undue hardship on the Service.

c. THE CHIEF, BRANCH OF HEADQUARTERS PERSONNEL OPERATIONS AND REGIONAL PERSONNEL OFFICES or designated staff serve as the Service's Employment Officers and are responsible for conducting Job analysis on Service vacancies to ensure that knowledge, skills and abilities are related to the essential functions of the job, and that artificial barriers are removed from the hiring process; accepting requests from employees or applicants and making in conjunction with the supervisor an initial determination whether an accommodation is made.

d. SERVICE MANAGERS are responsible, for ensuring that selections of qualified disabled persons are made in a non-discriminatory manner, and that reasonable accommodations for persons with disabilities are implemented.
e. EMPLOYEES AND APPLICANTS are responsible for providing specific information on the nature of their abilities and disabilities with regard to the requirements of the job, so that an assessment can be made of possible means for reasonable accommodation. (Examples of means of reasonable accommodation are provided in Section 7).


a. Overview.

Reasonable accommodation is a logical change or adjustment to a job or worksite that makes it possible for otherwise qualified employees with disabilities to perform the essential functions of the positions in question. Accommodations are determined on a case-by-case basis, taking into consideration the needs of the applicant or employee, his/her specific disability, the essential duties for the position in question, the work environment, and the reasonableness of the proposed accommodation.

In all cases, the employee or selectee must be consulted before an accommodation is made. Most accommodations involve minimal cost. Many persons with disabilities do not need reasonable accommodation because they have made adjustments to their disability so that no accommodation is needed or desired. An accommodation must be work-related and not personal needs or use such as providing eye glasses, hearing aids or transportation to work. The responsibility to provide reasonable accommodation does not end when the person with a disability is placed in a position. It is also considered in training, promotion, reassignment and developmental assignments.

b. Reasonable Accommodation Assessment.

The Service is required to make reasonable accommodation for a qualified person with a disability unless it can demonstrate that the accommodation would impose an undue hardship on the operation of the Service's program. These determinations must be made on an individual basis. Most accommodations are not costly, nor do they adversely affect the operation of a program. All alternatives will be explored to determine if the reasonable accommodation is the most effective one for both the employee and the Service.

The first step in determining an appropriate accommodation is to consult with the employees with a disability and ask for suggestions as to what accommodations would enable him/her to perform the job, When providing auxiliary aids, the Service manager should give preference to the request of the person with the disability, unless the request would constitute an undue hardship. Accommodations need to be made to the known physical or mental limitations. The Service is not obligated to make an accommodation for a job interview, or for an existing job, until the applicant or employee has communicated his/her needs.

The value and nature of a particular accommodation may be clarified by considering questions such as the following:


Examples of the kinds of actions which may constitute reasonable accommodations are listed at 29 CFR 1614.203(c). Reasonable accommodation may include, but shall not be limited to the following:


The following are some factors that should be considered in determining whether an employee's or an applicant's accommodation would impose undue hardship on the operation of the Service.

The Service, in identifying resources for providing reasonable accommodations, must exhaust all Service and Departmental sources of funding before rendering any determination that an accommodation presents an undue hardship.


a. When an employee or applicant makes a request for reasonable accommodation, the following requirements apply:

b. The Service's Decision on the Request


Formal Request For a Reasonable Accommodation

Please describe the disability and the need for a reasonable accommodation.

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I hereby request an accommodation for the stated disability, as follows:

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Signature                                                                     Date

Medical Documentation to Support Requests for Reasonable Accommodation

Medical documentation provided or obtained in connection with a medical determination related to employability should include the following information, or the parts identified by the Service as necessary or relevant:

1. The history of the specific medical condition(s) including references to findings from previous examinations, treatments, and responses to treatments.

2. Clinical findings from the most recent medical evaluation, including any of the following which have been obtained: findings of physical examination, results of laboratory tests, X-rays, EKG, and other special evaluations - or diagnostic procedures and, in the case of psychiatric evaluation or psychological assessment, the findings of a mental status examination and the results of psychological tests:

3. Assessment of the current clinical status and plans for future treatment;

4. Diagnosis;

5. An estimate of the expected date of full or partial recovery;

6. An explanation of the impact of the medical condition on life activities both on and off the job;

7. Narrative explanation of the medical basis for any conclusion that the medical condition has or has not become static or well stabilized;

8. Narrative explanation of the medical basis for any conclusion which indicates the likelihood that the individual is, or is not, expected to experience sudden or subtle incapacitation as a result of the medical condition.

Standard for Review of Medical Documentation

Review of medical documentation is an assessment by, or in coordination with, a physician to ensure that the following criteria are met:

1. All diagnoses and clinical impressions are justified in accordance with established diagnostic criteria; and

2. The conclusions and recommendations are consistent with generally accepted medical principles and practice.

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