Procedures for Processing Reasonable Accommodations

Step 1: Request

Requests can be made orally, in writing or through the U.S. National Science Foundation e-file system and can be submitted by an applicant, employee, representative, supervisor or any NSF personnel. Submit requests to the supervisor, the Disability Program Manager (DPM) or the human resources specialist.

NSF provides written confirmation via the e-file system. Confirmation includes the date the request was received and the required next steps in the interactive process.

Step 2: Documentation

Role of the Disability Program Manager (DPM)

The DPM is the central expert who evaluates and adjudicates all requests for medical and complex cases. The DPM manages requests ranging from workspace reconfigurations and assistive technology to specialized support services like sign language interpreters.

The DPM advises the deciding official (your immediate supervisor) on legal requirements and alternative effective options.

Both the supervisor and the DPM are required to have designated backups so that the process can proceed if they become unavailable.

Required documentation

Substantiating the need: If your disability or the need for accommodation is not obvious, the DPM may require medical documentation to establish the existence of a disability and identify specific functional limitations.
Nexus determination: The DPM reviews your medical data alongside your position description to determine the nexus or link between your medical condition and the essential functions of your job.
Interim agreement: To ensure you are supported while gathering medical paperwork, the DPM has the exclusive authority to issue temporary interim agreements.

Confidentiality and record keeping

Medical review: When necessary, as deemed by the DPM, supporting medical documentation will be reviewed by medical professionals (contracted physician or qualified health care provider) to provide expert recommendations.
Privacy protections: Supervisors are only informed of functional limitations, not the specific diagnosis. All Reasonable Accommodation records are kept in a secure electronic system entirely separate from your Official Personnel Folder. This is a critical item checked during audits by the U.S. Equal Employment Opportunity Commission (EEOC).

Timelines

The agency must process and implement accommodation requests as expeditiously as possible. The Rehabilitation Act does not mandate rigid deadlines.

Standard timelines (from receipt of all documentation):

Standard cases: 15-30 business days of active processing.
Complex cases or extenuating circumstances: 45-60 business days.
Medical documentation: The DPM will provide up to 30 days for the requester to obtain additional documentation.
Cases are closed if no documentation (medical or other) is received on day 60, with an opportunity to reopen a case and resubmit once an employee has gathered all required documentation.

Step 3: Interactive process

The interactive process is a collaborative, good-faith dialogue between the DPM, the supervisor and the employee or applicant. In alignment with the EEOC guidance and the "Americans with Disabilities Act," this process is a core requirement and an ongoing obligation. The agency remains committed to this dialogue throughout an employee's tenure, reengaging whenever there are changes in job duties, supervision or workplace structure to ensure accommodations remain effective.

Collaborative consultation: The DPM facilitates a good-faith dialogue between the employee and the supervisor to identify effective solutions. While the employee’s preference is considered, the Agency may choose any effective alternative that removes the workplace barrier.
Core evaluation factors: The DPM ensures compliance by verifying "qualified individual" status, assessing the impact of the medical condition on essential job functions, and evaluating the technical viability of requested solutions.
Internal technical support: To address complex cases, the DPM may consult with legal (NSF Office of the General Counsel), IT (NSF Office of the Chief Information Officer) or facilities (NSF Office of Administrative Services) to vet specific technical requirements without disrupting the employee's workflow.
Accommodation continuity: Approved accommodations are not automatically rescinded due to personnel changes. A change in supervision triggers a continuity review to ensure the new supervisor understands the legal requirements and integration into the team.
Strategic re-engagement: The agency will re-initiate the interactive process if there are significant shifts in work schedules, office designations or core mission tasks to ensure the accommodation remains viable and effective.
Periodic recertification: The DPM may request updated medical documentation at reasonable intervals or when a disability is degenerative to verify that the workplace support being provided is still effective.

Step 4: Decision

Following the interactive process, the agency issues a formal written decision for one of the following outcomes:

Approval: The agency will communicate the decision, as well as how the accommodation will be implemented and maintained.
Alternative accommodation: The agency will communicate the decision and the reasoning behind it, as well as how the alternative accommodation will be implemented and maintained.
Denial of accommodation: The agency will communicate the decision, the reasoning behind it and the steps to appeal it.
Reassignment: Reassignment is the "accommodation of last resort," available only to employees who can no longer perform their essential job functions with other accommodations. Reassignment is not available to applicants.

Step 5: Implementation

Once a decision is reached, the agency moves to implement it. This stage involves the physical delivery of equipment, the modification or realignment of work schedules, the provision of specialized services and more. The DPM coordinates the ordering and installation of necessary tools, software, or specialized services (American Sign Language, equipment, etc.) and notifies relevant stakeholders of required actions. A clear, effective date is set, and if a solution is delayed, an interim solution will be provided whenever possible.

Step 6: Reconsideration and appeals

First-level supervisor

If the immediate supervisor denies the request, the employee may submit a written request for reconsideration to their second-line manager within 10 business days of receiving a decision. The second-line manager will provide a written response within 10 business days of receiving the request for reconsideration.

Second-level supervisor

If the second-line manager upholds the denial, the employee has 10 business days to present a reconsideration request to the head of the Office of Civil Rights.

Office Head of Civil Rights

The office head has 10 business days to respond with a final decision. Their written response serves as the agency's final decision, concluding the internal reconsideration process.

Equal Employment Opportunity (EEO) Complaints

Individuals have the right to pursue an EEO complaint under 29 CFR Part 1614.
An EEO counselor must be contacted within 45 calendar days of the date of the decision or action being challenged.
Participation in internal reconsideration, administrative grievances or negotiated grievance procedures does not extend the 45-day deadline for initiating an EEO claim.