652 The RAC’s Findings

Once the RAC has completed the interactive process and made all necessary consultations, the RAC must determine whether the employee or applicant has a disability as defined under the Rehabilitation Act. In making this determination, the RAC must do the following:

If a disability exists, determine the following:

  1. Whether the individual can perform the essential functions of the position held or desired, with or without reasonable accommodation. In making the essential functions determination, the RAC must obtain information on the essential functions of the position in question from the appropriate affected office or site and consider the input of the employee or applicant. At times, a site visit to evaluate the job functions may be necessary.
  2. Whether the affected office or site can provide accommodation, including reassignment (for an employee, not an applicant), without undue hardship.

Note: Reassignment is an accommodation of last resort and the RAC should consider it only if no accommodation is possible within the employee’s current position. First, the RAC should consider reassignments to vacant, funded, equivalent positions, then reassignments to a lower level position. Reassignment to a higher level position is not a reasonable accommodation. Where consideration of reassignment as an accommodation is called for, the RAC must determine whether the employee is willing to relocate (at his or her own expense) and to where. This information will guide the geographic scope of the search for appropriate positions.

With regard to findings 1 and 2, consultation with the management of the affected office or operation is essential.

The RAC chair or designee must document the findings for the RAC file. Documentation includes the following:

If the Postal Service cannot provide an accommodation without undue hardship, the RAC chair or designee must consult with the Postal Service law office before it makes a final decision.