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, or else via phone or a virtual platform, such as Zoom or Microsoft Teams.

In addition, the RAC must invite the affected manager or supervisor as he or she may find it helpful to attend this meeting, and the RAC will benefit from input on the nature of the job in question. The RAC will conduct the interactive meeting within 30 days from receipt of the request.

Before the meeting, the RAC will obtain, from any of the following, medical documentation regarding the nature and extent of the impairment and its limitations (unless both are obvious or known):

• The employee or applicant. 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 651(a), “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, the RAC must 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 does not demand an extensive analysis.

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

• Review medical information and restrictions, 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.
• Notice of any delays in processing, the reasons for delay, and anticipated revised time frame.
• 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 chairperson or designee must document in the RAC file the interactive process with the employee or applicant. Documentation includes the following:

• Recording the efforts to schedule meetings.
• Whether meetings were rescheduled and why.
• The dates the RAC chairperson or designee held the meetings.
• The name and position of everyone who attended each meeting.
• The accommodation(s) requested by or for the employee or applicant.
• Documentation provided that supports accommodation.
• A meeting synopsis.

Exhibit 651(a)

Request for Information

Exhibit 651(b)

Reasonable Accommodation Request (page 1)

Exhibit 651(b)

Reasonable Accommodation Request (page 2)

Exhibit 651(b)

Reasonable Accommodation Request (page 3)

Exhibit 651(c)

Medical Information and Restriction Assessment (page 1)

Exhibit 651(c)

Medical Information and Restriction Assessment (page 2)

Exhibit 651(c)

Medical Information and Restriction Assessment (page 3)

Exhibit 651(c)

Medical Information and Restriction Assessment (page 4)