The Department of Energy (DOE) is required to provide reasonable accommodation to qualified individuals with disabilities who are employees or applicants for employment, except when such accommodation would cause an undue hardship. Reasonable accommodation is also provided for an employee or applicant to practice or observe their religious beliefs. An accommodation is any change in the work environment, or in the way things are customarily done, that enables an individual to enjoy equal employment opportunities. “Disability” is defined broadly under the Americans with Disabilities Act (ADA) and its amendments. Not all disabilities require accommodations, only those that impact the essential functions of the position need to be accommodated, and then, only if the accommodation does not remove the essential functions of the position.

Employees who request an accommodation, require an individual analysis of their request and circumstances. Designated Management Officials (DMOs), who are usually the employee’s first line supervisor, should obtain the advice and assistance of their servicing Local Reasonable Accommodation Coordinator (LRAC), and follow the procedures in Policy Memorandum (PM) #100 Reasonable Accommodation:

Procedures for Requesting Reasonable Accommodation (RA):

  1. Employees submit a request (preferably in writing), to their first line Supervisor (the Designated Management Official (DMO)) or to their servicing LRAC. NOTE: To protect their privacy, employees should only provide medical documentation to the LRAC. LRACs are trained in the RA process, which includes handling medical information, determining if the medical documentation is sufficient, and determining if the underlying condition meets the definition of a disability for purposes of the ADA. The LRAC only communicates the impact of the underlying condition, not the diagnosis, to the DMO.
  2. Employees provide the LRAC, the necessary medical documentation. Documentation is not required if the condition is open and obvious, or if the employee has previously provided the medical documentation. NOTE: Whenever there is an unavoidable delay in obtaining sufficient medical documentation, DMOs should consider interim (temporary) accommodations if appropriate. LRACs will provide guidance.
  3. Employees, LRACs, and DMOs engage in discussions, referred to as the interactive process, on the impacts and needs of any potential accommodations. DMOs make the determination on which duties are essential duties. LRACs provide guidance and tools to document the analysis.
  4. When more than one reasonable and effective accommodation is identified, DMOs have discretion to choose among the accommodations and make a written determination, with the LRAC’s assistance.
  5. If a DMO intends to deny the requested accommodation, or some part of the accommodation, the local Office of General Counsel and the LRAC must be consulted.
  6. If a DMO issues a denial, the employee will be informed, in writing, of their reconsideration and appeal rights.