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:

• Identify the impairment at issue; and
• Determine whether the impairment substantially limits the performance of a major life activity as compared to the performance of that activity by most people in the general population (see 14).

If a disability exists, the RAC must determine the following:

• 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.
• Whether the affected office or site can provide accommodation, including reassignment (for an employee, not an applicant), without undue hardship.

In making the above determinations, consulting the management of the affected office or operation is essential.

Note: Reassignment is an accommodation of last resort; the RAC may consider it only if no accommodation is possible within the employee’s current position. The RAC must first consider reassignments to vacant, funded, equivalent positions, and then reassignments to a lower-level position. Reassignment to a higher-level position is not a reasonable accommodation. If considering reassignment as an accommodation is necessary, the RAC must determine whether and to where the employee is willing to relocate (at his or her own expense).

Note: This information will guide the geographic scope of the search for appropriate positions. (See Exhibit 543, “Reassignment Questionnaire.”)

The RAC chairperson or designee must document the findings for the RAC file using the Reasonable Accommodation Decision Guide (Exhibit 213(b). Documentation includes the following:

• The date(s) of all RAC member meetings to discuss the request.
• The identity of all RAC members present in each meeting.
• The date and identity of any person consulted who contributed to the RAC findings, and the substance of his or her contribution.
• Whether the RAC determined that the individual is disabled.
• Who was involved in the determination, and the rationale for the determination.
• Whether the RAC determined that the individual could perform the essential functions of the position, with or without reasonable accommodation.
• Whether the RAC obtained information on the essential functions of the position.
• Whether the RAC conducted a site visit (the date and who participated) to evaluate the job functions.
• Whether the Postal Service can provide an accommodation without undue hardship.

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