222 Step One: Determine Whether an Individual Has a Disability and Meets Minimum Qualification Standards

The Postal Service is entitled to know that an employee or applicant has a covered disability that requires a reasonable accommodation. Supervisors, managers, RACs and others involved in the process must not ask for documentation to support the existence of a disability when an applicant’s or employee’s disability is obvious (such as blindness). If the supervisor or manager is unsure whether the employee or applicant has a disability or believes he or she does not have a disability, the supervisor or manager must contact the RAC. Questions to consider:

• Does the individual have a physical or mental impairment?
• Does the impairment substantially limit the performance of a major life activity as compared to the performance of that activity by most people in the general population?
• Does the impairment substantially limit the operation of a major bodily function or organ?

In general, medical documentation must substantiate the following:

• The severity of the impairment (how it impacts the employee at work and outside of work).
• Any restrictions or limitations related to the impairment and their duration.
• If a specific accommodation is being requested, an explanation as to why it is needed.

Next, the supervisor or manager must consider whether the individual can meet the minimum qualifications for the job at issue. Minimum-qualification standards must be related to and necessary to perform the job. If the supervisor or manager questions whether a qualification standard is necessary to perform the job, he or she must contact the RAC for guidance.

Being minimally qualified includes the following:

• Meeting the requisite license, required examination(s), skills, experience, education requirements, and other job-related requirements for the position.
• Being able to perform the essential functions of the position, with or without reasonable accommodations, without posing a direct threat.

The existence of a direct threat is a high standard, so supervisors and managers must refer any questions concerning safety to the RAC for guidance and assistance.

Note: An individual with a disability may require reasonable accommodation in exams and/or training needed to meet job prerequisites (see Chapter 3).

If you (the supervisor, manager, or RAC) determine that the individual has a covered disability and is minimally qualified, proceed with steps 2 through 6 to determine whether the individual is able to perform the essential functions of the position, with or without accommodation, and what accommodation, if any, is appropriate.

The Postal Service encourages informal dialogue with the individual to obtain relevant information throughout the process, and considers it necessary to make an informed decision.

If you (the supervisor or manager) believe the individual does not have a covered disability, notify the individual in writing that you are referring the individual’s request to the RAC for further review or assessment.

Contact the manager, Field Human Resources, or the manager, Disability Programs, at Headquarters if you need help making this determination. The RAC can help with this step or the entire decision-making process.