IDEAA ensures that the University is not only in compliance with the American with Disabilities Act “ADA” of 1990, as amended, and the Rehabilitation Act of 1973, as amended, but such University policies as the Equal Opportunity and Non-Discrimination in Employment Policy have not been violated.
The ADA prohibits discrimination on the basis of a disability. It is a part of the University’s Equal Employment Opportunity and Non-Discrimination in Employment policy to comply with the ADA. Under the ADA, a qualified individual with a disability who can perform the essential functions of the job with or without a reasonable accommodation is protected from discrimination due to his or her disability.
The following person has been designated to coordinate Georgetown University’s compliance with Section 504 of the Rehabilitation Act of 1973:
Vice President for Institutional Diversity and Equity
M-36 Darnall Hall
37th & O Streets NW
Washington, DC 20057
Phone: (202) 687-4798
Fax: (202) 687-7778
Procedures for Applicant and Employees:
Applicants and Employees who believe they will need a reasonable accommodation to apply for or have an interview for a position at the University or to perform their essential job functions should contact IDEAA. The University will also accept a request from a legally authorized family member, health care provider, or other representative who is legally authorized to make such requests on behalf of an individual with a disability.
Applicants or Employees should complete the Disability Accommodation Request Form for Applicants or Disability Accommodation Request for Employees form and submit it to IDEAA. The form asks for information on the medical condition, the requested accommodation, how the accommodation will assist the individual in performing the essential functions of the job, and the anticipated duration of the requested accommodation. Verbal requests for accommodation are also acceptable. If a supervisor, academic representative or HR representative receives a verbal or written request for accommodation, he or she must contact IDEAA.
IDEAA may require an applicant or an employee to submit medical documentation from an employee’s doctor or health care provider in support of the request. The Accommodation Request Form also includes a release which, if signed, authorizes IDEAA to contact the health care provider directly and obtain necessary medical information related to the request. If an employee does not sign the release, then it is the responsibility of the employee to obtain the necessary information from the health care provider.
Once an applicant or employee has requested an accommodation, the University will engage the employee in a dialogue known as “the interactive process” to determine what accommodation, if any, is appropriate. No specific form of accommodation is guaranteed for all individuals with a particular disability. Rather, an accommodation must be tailored to match the needs of the individual with the disability with the needs of the job’s essential functions.
In some situations, the University may request the applicant or employee undergo an Independent Medical Evaluation (“IME”) at the University’s expense, if the employee and health care provider are unable to provide sufficient medical information in support of the accommodation request. The IME will be limited to determining the existence of a disability and/or the functional limitations that require a reasonable accommodation. When an IME is warranted and the employee fails to participate, it could result in a denial of a reasonable accommodation.
As part of the interactive process, IDEAA may contact the appropriate departmental official for the purposes of discussing possible accommodations. No medical information is shared or released to the department. Medical information is confidentially housed within IDEAA and is not to be included in employment/departmental files. Limited information may be shared with managers if necessary in order to arrange for necessary accommodations, but only with the knowledge and agreement of the individual requesting the accommodation.
In making this determination, IDEAA, in conjunction with the appropriate departmental supervisor or official, may consider a number of relevant factors, including:
- The nature and duration of the requested accommodation.
- The impact of the requested accommodation on the performance of the employee’s essential functions or core work-related duties.
- The financial impact of the requested accommodation.
- The impact of the requested accommodation on other employees, students, or university operations. Note that this may include consideration of seniority within the same unit or department.
- Any alternative accommodations.
Once an accommodation has been deemed appropriate and reasonable, both the employee and the departmental representative are notified and an accommodation work plan is implemented for the duration specified. The work plan is monitored by IDEAA and reviewed on occasion to ensure the accommodation enables the employee to complete the necessary work tasks and to ensure effectiveness.
If an accommodation is deemed appropriate and reasonable for an employee, then the department bears the responsibility for funding the accommodation.
Modifications to the work plan can be made if the health conditions change and/or the nature of the work performance/duties changes.
IDEAA must be contacted to re-engage the interactive process.
If no reasonable accommodation can be made, the employee is notified in writing.