Agency Accommodation Program

303.1 Purpose and background

1. The National Archives and Records Administration (NARA) is committed to ensuring qualified individuals that require accommodations, whether due to a disability, pregnancy and related conditions, or religious beliefs, are afforded equal opportunity to perform the essential functions of their position and enjoy equal access to the benefits and privileges of employment by providing reasonable accommodations.

2. This policy provides a detailed description of reasonable accommodations, defines roles and responsibilities throughout the accommodation process, and establishes expectations for processing accommodation requests.

303.2 Scope and applicability

1. This policy applies to all qualified employees of NARA, including permanent, probationary, and temporary employees, as well as applicants for employment, unless providing the accommodations would impose an undue hardship on the Agency.

2. This policy applies to reasonable accommodation requests related to religion and religious beliefs; pregnancy, childbirth, and related medical conditions; disabilities; medical conditions ; and requests for Personal Assistance Services (PAS). With respect to disabilities, it applies to requests involving both temporary and permanent impairments, episodic conditions, and conditions in remission, where such conditions substantially limit one or more major life activities when active.

3. This policy applies to requests in all employment-related contexts, including recruitment, hiring, onboarding, work assignments, training, travel, and access to facilities and systems.

4. This policy does not apply to requests based solely on personal, family, or lifestyle preferences, including childcare, eldercare, pet care, commuting preferences, or general scheduling convenience.

303.3 Policy

1. NARA will engage in a timely, good-faith interactive process once a request for reasonable accommodations is received. NARA strictly prohibits retaliation, interference, coercion, or adverse treatment against any applicant or employee based on their need for, request for, use of, or participation in the reasonable accommodations process.

2. In accordance with Title VII of the Civil Rights Act of 1964, NARA must provide reasonable accommodations for sincerely held religious beliefs, practices, and observances of applicants and employees, unless doing so would impose an undue hardship on the conduct of Agency operations.

3. In accordance with the Pregnant Workers Fairness Act (PWFA), NARA must provide reasonable accommodations for qualified employees and applicants with known limitations related to pregnancy, childbirth, or related medical conditions, unless doing so imposes an undue hardship on Agency operations.

4. In accordance with the Rehabilitation Act of 1973 and the Americans with Disabilities Act, NARA must provide reasonable accommodations to employees and applicants with disabilities unless it would impose an undue hardship on the conduct of Agency operations. NARA also is required to provide Personal Assistance Services (PAS) to qualified individuals with targeted disabilities who need assistance with performing basic activities of daily living, such as eating, removing and putting on clothing, and using the restroom, during work hours, including at the worksite, an approved alternative duty station, or while teleworking. NARA does not provide accommodations that would impose undue hardship on the Agency.

5. All religious, medical, pregnancy-related, disability-related, and accommodation-related information obtained in connection with a reasonable accommodations request shall be treated as confidential.

303.4 Responsibilities

In addition to the authorities delegated in NARA 101, NARA Organization and Delegation of Authority, the following responsibilities are assigned to effectively implement this policy.

1. Agency Accommodations Program (AAP) is responsible for administering and coordinating NARA's Reasonable Accommodations Program and providing technical expertise to employees, applicants, supervisors, and managers.

2. Agency Accommodations Program Manager (AAPM) serves as the primary coordinator and subject matter expert.

3. Deciding Official (DO) makes decisions for interim and final determinations on reasonable accommodations requests based on the information gathered during the interactive process. This is the Chief Human Capital Officer or designee.

4. Deputy Chief of Management and Administration (DCMA) provides oversight of NARA's Reasonable Accommodations Programs and ensures Agency-wide compliance with statutory, regulatory, and policy requirements related to accommodations and accessibility.

5. Office of General Counsel (NGC) provides legal advice and review related to reasonable accommodations matters.

6. Office of Human Capital (H) collaborates with the AAPM and the Reasonable Accommodation Team (REACT), as appropriate, to ensure alignment between accommodations decisions and personnel policies, workforce planning, and staffing requirements.

7. RESOLVE Program provides neutral mediation and facilitation services to assist in resolving disputes or concerns arising during the reasonable accommodations process.

8. Reasonable Accommodation Team (REACT) Panel provides multi-disciplinary expertise to support the evaluation of complex, high-risk, or novel accommodations requests.

9. Reconsideration Official reconsiders final determinations on reasonable accommodations requests. This is the Chief of Management and Administration.

10. Supervisors and managers play a critical operational role in the reasonable accommodations process, but are not the final deciding officials.

11. Applicants and employees are responsible for communicating accommodation needs in a timely manner and participating in the interactive process in good faith.

303.5 Glossary

Disability.
A physical or mental impairment that substantially limits one or more major life activities; a record of such an impairment; or being regarded as having such an impairment.

Essential functions. The essential functions of a job are those job duties that are so fundamental to the position that the individual cannot do the job without being able to perform them. A function can be "essential" if, among other things, the position exists specifically to perform that function, there are a limited number of other employees who could perform the function if it were assigned to them, or the function is specialized and the incumbent is hired based on his/her ability to perform it.

Interactive process. An individualized, timely, and collaborative exchange between the Agency and an individual who has requested reasonable accommodations, or whose need for accommodations is otherwise known.

Qualified individual. An individual who meets the requisite skill, experience, education, certification, and other job-related requirements of a position and who, with or without reasonable accommodations, can perform the essential functions of the position held or sought, or can participate in the application and selection process.

Reasonable accommodation. A modification or adjustment to a job, the work environment, the manner or circumstances under which a position is customarily performed, or to the application and selection process, which enables a qualified individual with a disability, a pregnant woman, and/or an individual requiring a religious accommodation to perform the essential functions of a position; or enjoy equal access to the benefits and privileges of employment.

Undue hardship. An accommodation that would require significant difficulty or expense when evaluated in relation to the overall resources of the organization, the nature and cost of the accommodations, the impact on operations and mission requirements, and the effect on workplace safety and security.

303.6 Authorities, records management, and releasability

See PDF.

Supplements

Supplement 1, Reasonable Accommodations Procedures

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