What Constitutes a Reasonable Accommodation?

A reasonable accommodation is an adjustment that allows an employee with a physical disability to perform the essential functions of their job. These accommodations might include an ergonomic keyboard for wrist issues, a different office location for employees with epilepsy who are sensitive to fluorescent lights, or even modified parking arrangements. Employees must request accommodations through their supervisor or Equal Employment Opportunity (EEO) department, outlining the necessary physical modifications to their work environment.

Common Workplace Modifications for Physical Disabilities

Federal employees may seek accommodations for a variety of physical disabilities, including mobility impairments due to age, injuries, or chronic conditions. Common modifications include:

  • Parking closer to the building
  • Working on the first floor or in an accessible office
  • Telework options for those with mobility challenges
  • Standing desks and ergonomic equipment
  • Assistive technology such as sign language interpreters for deaf employees

The Process of Requesting Workplace Modifications

The process for requesting physical workplace modifications is similar to other accommodation requests but may be more straightforward when the disability is visible. For example, an employee using a wheelchair should not need to provide excessive medical documentation to justify an accessible parking space. The Rehabilitation Act, which serves as the Americans with Disabilities Act (ADA) equivalent for federal employees, explicitly states that open and obvious disabilities do not require extensive documentation.

Steps for Requesting an Accommodation

Many employees may feel hesitant to request accommodations, but it is important to recognize that there is no stigma in doing so. More than 10–15% of the workforce is disabled, and there are clear legal protections in place. Steps for requesting an accommodation include:

  1. Submitting a formal request in writing (email or official agency forms)
  2. Describing how the accommodation will enable the employee to perform essential job functions
  3. Providing supporting medical documentation, if necessary
  4. Engaging in the interactive process with the agency to find a suitable solution

The Role of Medical Documentation

While some physical disabilities require little to no documentation, in other cases, agencies may ask for a doctor’s statement. This documentation should include:

  • The nature of the disability
  • Why the requested accommodation is necessary
  • How the accommodation will enable the employee to perform their job duties

Employees are not required to use an agency-provided form; a simple doctor’s letter explaining the need for an accommodation is sufficient.

How to Strengthen an Accommodation Request

To increase the chances of approval, employees should:

  • Reference their official position description
  • Identify specific job functions affected by their disability
  • Clearly connect the requested accommodation to their ability to perform job duties

For example, an employee in a wheelchair requesting closer parking should explain that they cannot safely traverse a large parking lot without experiencing exhaustion, which impacts their ability to begin work effectively.

Challenges in Obtaining Accommodations

Agencies and supervisors vary in their willingness to grant accommodations. Employees may encounter resistance, particularly when requesting telework, which has become more scrutinized due to the January 2025 return-to-work order. When supervisors are unsupportive, the process can become more difficult, often requiring legal assistance.

One of the strengths of disability accommodation law is that agencies must accommodate employees unless they can prove an undue hardship, which is difficult for a federal employer to claim given its resources. In some cases, agencies have even been required to construct special offices with modified lighting for employees with epilepsy. The larger the employer, the harder it is to argue that an accommodation is an undue hardship.

Successful Workplace Accommodations

Some common and successful accommodations include:

  • Telework options
  • Ergonomic workstations
  • Modified lighting to accommodate epilepsy
  • Reserved parking for employees with mobility impairments
  • Assistive technologies, such as sign language interpreters

A valuable resource for identifying possible accommodations is the Job Accommodation Network (askjan.org), which provides a searchable database of reasonable accommodations tailored to various disabilities.

If an accommodation request is denied, employees should first attempt to engage in the interactive process with their employer. If issues persist, legal assistance may be necessary. Eric L. Pines and his team provide support in filing accommodation requests, discrimination claims for failure to accommodate, and even assisting with disability retirement when an employee can no longer perform their job duties. Because the federal government has fee-shifting statutes, many employees who successfully challenge an accommodation denial may have their attorney’s fees reimbursed.

Conclusion

Understanding and asserting the right to workplace modifications can make a significant difference in the work life of federal employees with physical disabilities. If you or someone you know is struggling with an accommodation request, consider seeking legal guidance to ensure your rights are upheld.