65 The RAC’s Decision-Making Process

651 Meeting With an Employee or Applicant: The Interactive Process

The RAC must meet with the employee or applicant in person, if possible. If not, the RAC must contact the individual by telephone to discuss the accommodation request. In addition, the RAC must invite the affected manager or supervisor as he or she may find it helpful to attend this meeting. The RAC will conduct the interactive meeting within 30 days from the chair’s receipt of the request.

Before the meeting, the RAC will need to obtain medical documentation regarding the nature and extent of the impairment and its limitations from any of the following:

• The employee or applicant may use Medical Information & Restriction Assessment, Part B, along with Reasonable Accommodation Request, RAC Part A, to provide additional clarifying information.
  (See Exhibit 651a, Request for Information).
• PS Form 2485-A, Medical Assessment – Focused Examination Report.
• The appropriate Occupational Health Services office for preemployment medical assessments where the appropriate medical professional identifies the physical limitations or restrictions.

However, keep in mind that the determination whether an impairment substantially limits a major life activity should be construed broadly in favor of expansive coverage. Consequently, in many instances, this determination should not demand an extensive analysis.

Next, the RAC meets with the individual to do the following:

• Review medical information, when necessary.
• Discuss and evaluate limitations to major life activities.
• Discuss essential functions of the position in question and explore whether and how the individual can perform those functions without posing a direct threat.
• Elicit input regarding potential accommodations, including alternatives such as reassignment (where necessary, available and appropriate).

In addition, the RAC must advise the employee or applicant of the following:

• The anticipated time frames for processing the particular request for accommodation.
• The confidential treatment of the medical information relayed.

The RAC must maintain ongoing communication with the individual throughout its proceedings, and advise that additional information may be sought later, if the need arises.

The RAC chair or designee must document in the RAC file the meeting with an employee or applicant. Documentation includes the following:

• Recording the efforts to schedule meetings.
• Whether meetings were rescheduled and why.
• The dates the RAC chair or designee held the meetings.
• The name and position of everyone in attendance at each meeting.
• The accommodation(s) requested by or for the employee or applicant.
• Documentation provided in support of accommodation.
• A synopsis of the meeting.

Exhibit 651a

Request for Information

Exhibit 651b

Reasonable Accommodation Request (page 1)

Exhibit 651b

Reasonable Accommodation Request (page 2)

Exhibit 651c

Medical Information and Restriction Assessment (page 1)

Exhibit 651c

Medical Information and Restriction Assessment (page 2)