SECTION I: OVERVIEW OF AGENCY POLICY AND PROCEDURES FOR IMPLEMENTING REASONABLE ACCOMMODATION IN NEW YORK STATE AGENCIES


1. Policy Statement

Each agency and facility should establish a written plan that includes a policy statement reflecting the agency's commitment to provide reasonable accommodation to employees and applicants with disabilities. Reference should be made to the State's Reasonable Accommodation Policy, which was restated in the April 11, 1996, memorandum issued by the Executive Chamber (Appendix A) and applicable State and federal laws. An additional statement should be included which describes the benefits the agency derives by providing reasonable accommodation.
 
2. Confidentiality

This section emphasizes the agency's responsibility to protect and maintain the confidentiality of information provided by employees requesting reasonable accommodation. The plan should identify steps that the agency undertakes to enhance confidentiality at all levels of the reasonable accommodation process.
 
3. Medical Documentation

This section should clearly state when, and the circumstances for requesting medical documentation.
 
4. Definitions

This section defines those terms that supervisors, managers, employees and other agency personnel should understand when considering whether to provide reasonable accommodation. While agencies may want to add to the list, it is important that the following terms be defined. (Section II includes definitions.)
  • person with a disability
  • physical, mental or medical impairment
  • reasonable performance
  • essential job functions
  • qualified person with a disability
  • reasonable accommodation
  • undue hardship
     
5. Who May Request an Accommodation?

This section broadly defines those individuals who may apply for reasonable accommodation. Included are applicants with disabilities and employees with disabilities currently working for the State, regardless of their title, grade, length of service or employment status.
 
6. Employee Access to Information on Reasonable Accommodation

This section specifies the steps which the agency must take to ensure that employees have access to information regarding their right to reasonable accommodation and the agency's policy and procedures for requesting reasonable accommodation. If an accommodation is denied at the agency level, employees must be given information on other options available, such as the external review process conducted by the Compliance Review Board through the Department of Civil Service. In addition, employees should also be informed of their right to file a complaint under the agency's internal discrimination complaint procedure, the New York State Human Rights Law, Sections 503/504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act (ADA) and/or that they may have a private right of action to challenge an alleged discriminatory practice. (Section 503 covers any entity with contracts or subcontracts with the federal government in the amount of $10,000 a year or more. Section 504 covers any entity receiving any federal money, either directly or indirectly.)
 
7. Maintenance of Records and Data Collection

This section describes the records that must be maintained by the agency with reference to reasonable accommodation. It also describes the specific data which must be collected by the agency for reporting purposes and identifies the division or office responsible for data collection.
 
8. Procedures for Requesting Reasonable Accommodation and Reviewing Requests
This section describes the agency's internal procedures for handling requests for reasonable accommodation. A procedure must be available for applicants and employees with disabilities who work for state government.

Statements regarding the various levels of review, including the external review process by the Compliance Review Board, are included in this section.Also, the role of the agency's designated responsible person for reasonable accommodation, is described. The agency's designated responsible person for reasonable accommodation is the individual identified by the agency head to coordinate agency compliance obligations arising from the New York State Human Rights Law, Sections 503/504 of the Rehabilitation Act of 1973 and/or the Americans With Disabilities Act. This section identifies the options that are available to employees when an accommodation has been denied. This section also includes the time frame for the review process and explains how the employee is informed of decisions at various points throughout the process.
 
9. External Review Process--Process for Requesting a Review by the Compliance Review Board
This section includes more detailed information about the Compliance Review Board. It also details the information which needs to be sent to the Department of Civil Service when an accommodation has been denied and the employee requests a review by the Compliance Review Board.

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