Reasonable Work Accommodation FAQs
What is a reasonable work accommodation?
A reasonable accommodation is the modification of an application process, position, or work environment that allows employees with disabilities, who are otherwise qualified for the position, to perform the essential functions of their positions.
Who is covered by the reasonable work accommodation policy?
All Northwestern faculty and staff are covered. Moreover, job applicants are covered during the application process.
When can a reasonable work accommodation be requested?
A reasonable work accommodation may be requested:
- during the job application process;
- after the job offer is made; or
- any time during the course of employment with the University
In accordance with the Americans With Disabilities Act (ADA), Northwestern University will not ask job candidates during the interview process about the presence of a disability. However, job candidates can be asked if they can perform specific job responsibilities and how they would go about accomplishing those tasks, with or without an accommodation.
What is considered a disability?
A disability is a physical or mental impairment which substantially limits one or more major life activities such as walking, seeing, hearing, breathing, bending, lifting, or sitting.
What are essential job functions?
Essential job functions are the fundamental and critical responsibilities performed in a position. Factors to consider in determining if a function is essential include but are not limited to whether:
- The function requires specialized skills;
- A significant amount of time is spent performing the function;
- There are a limited amount of people who can perform the function;
- There is a significant consequence if the function is not performed; or
- The reason the job exists is to perform that function. For example, an essential function of a shuttle driver is to drive a bus.
Must I request an accommodation if I have a disability?
No, requesting an accommodation is not required if the employee feels that an accommodation is not needed. It is the employee’s decision whether or not to request an accommodation.
My supervisor is already accommodating me. Why do I need to fill out the paperwork?
Northwestern University has a process in place to ensure fair treatment for all employees requesting reasonable accommodations. Following the process also enables the University to ensure that it is fully compliant with its obligations under the ADA.
What do reasonable accommodations look like?
Requests for a “reasonable accommodation” will be analyzed on a case-by-case basis, after consultation with the employee, the employee’s health care provider(s), and the supervisor. Examples of reasonable accommodations may include, but are not limited to, the purchase of special equipment, changing the physical layout of the workplace, restructuring job responsibilities and duties, and modifying the work schedule.
If a requested accommodation would result in an undue hardship, the University does not have to provide the accommodation. The EEOC defines “undue hardship” as an accommodation that “would be unduly costly, extensive, substantial or disruptive, or would fundamentally alter the nature or operation of the business.” If a requested accommodation presents an undue hardship, the Office of Civil Rights and Title IX Compliance (OCR) will work with the employee and the department to determine whether alternative accommodations are available. (You can find more information about undue hardship on the EEOC’s website.)
What happens after an employee requests a reasonable accommodation?
Employees will be asked to complete an Accommodation Request Form as well as an Authorization to Release Medical Information Form. Employees also have the option of submitting a letter from their health care provider. The ADA Coordinator will contact the employee’s health care provider to verify the medical condition and the need for accommodation – if the disability is not obvious.
The employee’s supervisor will be informed of the accommodation request and will be engaged in an interactive process to discuss effective work accommodations, the essential functions of the position, and the department’s operational needs. Although the employee provides input concerning the accommodation process, OCR will determine what constitutes a reasonable accommodation on a case-by-case basis. While OCR will take the employee’s preferred accommodation into account when possible, OCR may opt to approve a different accommodation that would also meet the employee’s needs.
- When an accommodation is granted the employee will receive an approval notice. OCR will work with the department and other personnel, if applicable, to implement the accommodation.
- In limited instances, a requested accommodation may pose an "undue hardship" on the department which would prevent the accommodation from being offered. If an accommodation is not granted, both the employee and the employee’s department are provided with an explanation for the denial. OCR will work with the employee and the department to determine whether alternative accommodations are available.
What does a signed Authorization for Release of Medical Information let OCR do?
Signing the form gives OCR permission to speak with an individual’s health care provider. OCR will seek only medical information relevant to the request for accommodation; additional medical information or history is not required.
Will my medical information remain confidential?
Yes. OCR will not share the employee’s medical records or details of an employee’s medical condition with a supervisor or the department. General, limited information about about a medical condition’s impact may need to be shared with supervisors and certain University staff (such as individuals in Facilities or Risk Management) when there is a “need to know” in order to effectively conduct the interactive process and/or implement accommodations.
What is an “obvious disability”?
In certain cases, documentation of a medical condition is unnecessary because the condition’s existence is clear. An example of an “obvious disability” is when an individual uses a wheelchair. In such a case, medical documentation would not be required when the accommodation request is clearly related to the individual’s obvious disability.
However, OCR can always request medical documentation in order to better understand the nature of the disability and the need for the requested accommodation.
Who qualifies as a “health care provider”?
The appropriate health care provider will depend on the specific disability and its functional impact in a given situation. Some examples of appropriate health care providers include but are not limited to: doctors, psychiatrists, psychologists, nurses, licensed mental health professionals, physical therapists, speech therapists, and vocational rehabilitation specialists.
If I want to submit a letter from my health care provider to support my accommodation request, what should the letter say?
A letter from your health care provider should contain the following information:
- A description of your medical condition, including its nature, severity, and expected duration;
- The activity or activities that the condition limits, and its impact on the activity; and
- What accommodation(s) are considered medically necessary as a result of the condition.
OCR asks only for medical documentation related to the accommodation request. Additonal medical information or history unrelated to the accommodation request does not need to be provided.
My department has been asked to purchase equipment for an accommodation. Can we get reimbursed?
Yes, if the cumulative cost of accommodations for the employee surpasses $500. Departments are responsible for the first $500, and then they can seek reimbursement from the Central Accommodation Fund for amounts over $500. Questions about the Central Accommodation Fund should be addressed to Laura Conway, ADA Coordinator (firstname.lastname@example.org).
How do I extend/change/add new accommodations to an existing accommodation agreement?
You should follow the instructions in your accommodation agreement for requesting extensions of, or changes or additions to existing accommodations. Updated medical documentation will likely be necessary to confirm a continuing need for an existing accommodation, or a need for a new accommodation.
If you have an existing accommodation and want to request new or changed accommodations, you may also be asked to fill out another Accommodation Request Form in addition to submitting updated medical information.
After receiving a request to extend/change/add accommodations, the Office of Civil Rights and Title IX Compliance will consult with the health care provider and with the department.
Who can employees and job applicants contact to request an accommodation or ask for additional information about accommodations?
Please email Laura Conway, the ADA Coordinator. Email tends to be the best way to reach Laura, since she is hard of hearing. University faculty and staff can also call Laura at 847-491-3745 if email is not a good option.