The Accommodation Playbook
Navigating the Interactive Process
"A request for accommodation is not a burden - it's a leadership test."
As a federal supervisor, you will encounter employees who request changes to how, when, or where they work due to medical limitations. It's not a matter of if - it's a matter of when. And how you respond will either protect your team, your agency, and your career - or expose them all to unnecessary risk.
This module isn't about theory. It's about real-world execution - the kind of playbook that keeps you out of hot water and helps your team succeed.
From a servant leadership perspective, reasonable accommodations aren't burdens to avoid - they're opportunities to help good people continue serving the mission effectively.
What Is a Reasonable Accommodation?
A Reasonable Accommodation (RA) is any change to the work environment or the way things are customarily done that enables an individual with a disability to apply for a job, perform the essential duties of a job, or enjoy equal benefits and privileges of employment.
Under the Rehabilitation Act of 1973 (which applies to federal agencies), all federal supervisors and agencies are required by law to provide reasonable accommodations to qualified employees with disabilities - unless doing so would cause an undue hardship.
This Is Not Optional
This is not a discretionary practice. It is a legal obligation - and one of the most litigated areas of federal personnel law.
You don't have to like it. You don't have to agree with it. You just have to do it right.
Common Accommodation Examples
Schedule Modifications
Modifying work schedules to allow for medical appointments or pain management during certain times of day.
Equipment and Technology
Providing specialized ergonomic equipment such as chairs, keyboards, or assistive technology devices.
Telework Arrangements
Allowing telework as a form of accommodation when it doesn't interfere with essential job functions.
Duty Modifications
Modifying non-essential duties or temporarily reassigning tasks that conflict with limitations.
Workplace Changes
Physical modifications to workspace, lighting, or environmental factors that affect performance.
Reassignment
Reassignment to a vacant position if the employee can no longer perform their current job with accommodation.
The List Is Not Exhaustive
Every case is unique - and your job as a supervisor is not to pre-judge or dismiss the request, but to initiate a structured, fair, and legal process.
The Interactive Process: Step by Step
The Request
The employee does not need to use any special legal terminology. They don't have to say "reasonable accommodation" or cite the Rehabilitation Act.
Any statement that implies a need for help due to a medical condition or disability triggers your duty to act.
For example:
- "My back injury makes it hard to sit for long periods."
- "I need time off for chemotherapy treatments."
- "My medication makes me drowsy in the mornings."
As soon as you hear something like this, you must treat it as a potential request for reasonable accommodation.
Acknowledge and Alert
Your immediate obligation is to acknowledge the request professionally and notify the right people. Do not delay, ignore, or minimize the situation.
Start the conversation by asking: "How can I help? What is it about the work environment or the way your duties are performed that is causing difficulty?"
You should immediately contact your agency's HR or EEO office - they are trained to guide you through the process and protect both the employee and the agency.
Gather Documentation (If Needed)
If the disability or the need for accommodation is not obvious, your agency may ask the employee for medical documentation from a licensed provider.
This documentation should:
- Confirm that the employee has a medical condition that substantially limits a major life activity
- Explain how the condition affects their ability to perform essential job functions
- Suggest accommodations (if appropriate)
As a supervisor, you are not allowed to review or store the medical documentation. It must be kept confidential and handled by HR or EEO.
Important: Don't wait for paperwork to start the interactive process. Begin the conversation immediately while the documentation is being gathered.
The Interactive Dialogue
This is a critical step. The "interactive process" is not just a form - it's a conversation.
You must engage with the employee to:
- Understand their limitations
- Explore possible accommodations
- Clarify what is reasonable based on the job
This is not a one-way demand. You are allowed to discuss alternatives. The employee doesn't get to dictate the exact accommodation - but you can't just deny it without offering something meaningful in return.
Make a Determination
You will work with HR, EEO, and possibly your legal counsel to determine:
- Whether the accommodation is reasonable
- Whether it would create an undue hardship
- Whether there are alternative options
Undue hardship can include significant cost, disruption of agency operations, or direct threat to health/safety - but it must be clearly documented, not just assumed or speculated.
Critical: You must consult with HR/EEO before denying any request. All proposed denials require legal review.
Implement Promptly
Once approved, the accommodation must be implemented as quickly as possible. The standard timeline is 30 business days from when the request is received.
If implementation will take longer than 30 days, provide a provisional accommodation in the meantime.
Dragging your feet, second-guessing the decision, or placing unnecessary conditions can be viewed as retaliation or obstruction.
Follow Up and Monitor
After the accommodation is in place, continue to communicate with the employee. Is it working? Are adjustments needed?
If the medical condition evolves or the job duties change, the accommodation can be reassessed - but it must be done fairly and transparently.
What Gets Supervisors in Trouble
Here are some of the most common mistakes federal supervisors make with RA requests - and why they lead to grievances, EEO complaints, or worse:
Taking it personally
It's not about you. RA requests are not a judgment on your management or team structure. They're legal rights.
Reacting emotionally
Rolling your eyes, groaning, or making dismissive comments can be used against you later.
Assuming it's "unfair" to others
RA is not about equal treatment - it's about equal opportunity.
Blocking requests over budget fears
Many supervisors wrongly assume that RA costs must come from their operating budget. Most agencies have separate RA funds or special accounting codes.
Failing to notify the proper offices
If you try to handle it alone and mess it up, you're liable.
Delaying the process
Time is a factor. If you drag your feet, it can be construed as denial.
Oversharing or gossiping
You cannot share details about the request or the medical issue with anyone who doesn't have a need to know. If other employees ask, simply say "It is a personal matter" or "It is the agency's policy to respect employee privacy."
Documenting poorly
Every RA case must have clear records of when the request was made, how you responded, and the outcome. If an employee refuses to put their request in writing, you must document it yourself.
Mixing performance with accommodation
Keep conduct and performance issues completely separate from reasonable accommodation matters. You cannot deny an accommodation because of performance problems, and all employees must meet the same standards.
Real-World Example: The $900 Chair
The Situation
One of the most illustrative cases we've seen involved a supervisor who became enraged when an employee with a documented back condition requested an ergonomic chair that cost $900.
Instead of initiating the RA process, he tried to block the purchase - citing cost, optics, and "not being fair to others."
What he didn't know was:
- The chair cost would have been covered by centralized RA funds
- His agency had already approved similar chairs for other employees
- His emotional reaction and blocking behavior created exposure for a grievance and a potential EEO complaint
The Solution Was Simple
This entire situation could have been avoided by simply saying:
"Let's get the right people involved and make sure we handle this correctly."
Servant Leadership in Action
A reasonable accommodation is not a "favor" or a "concession." It's a right under federal law. But beyond compliance, this is a chance to model the best kind of leadership - servant leadership.
Servant Leaders Don't Look for Ways to Say "No"
They look for ways to say "Let's figure it out."
- How can I help this person do their best work?
- How can I ensure my team has what they need to thrive?
- How can I fulfill my legal duties with empathy and professionalism?
You're not here to build walls. You're here to build capability - and sometimes that means adapting the structure so good people can continue to serve.
The Servant Leadership Perspective
From a servant leadership standpoint, reasonable accommodations align perfectly with the core principle of helping people grow and succeed. When you help someone with a disability continue contributing their talents and expertise, you're serving:
- The individual by enabling their continued service and career growth
- Your team by retaining valuable knowledge and experience
- The mission by keeping qualified people in productive roles
- The taxpayers by maximizing the return on training and development investments
This isn't about special treatment. It's about removing barriers so everyone can contribute their best work.
Lead with Law and Logic
Supervisors are not expected to be legal experts - but they are expected to follow the law and apply policy fairly.
The Litigation Reality
Reasonable accommodation is one of the most litigation-prone areas of federal employment. But ironically, it is also one of the easiest to navigate if you simply follow the process.
Know Your Resources
- HR Office
- EEO Office
- Labor Relations
- Legal Counsel
Follow the Process
- Acknowledge requests promptly
- Involve the right people immediately
- Document everything
- Communicate professionally
Focus on Solutions
- Interactive dialogue
- Explore alternatives
- Consider the whole person
- Implement promptly
Maintain Perspective
- It's not about you
- Legal compliance protects everyone
- Good people want to contribute
- Barriers can be removed
The Servant Leader's Approach
When you do this right, you protect your team, your agency, and yourself - and you model the kind of leadership that makes the federal workforce stronger.
The process works when you work the process. Trust it, follow it, and let the experts guide you through the complexities.
Your job isn't to be the accommodation expert. Your job is to be the leader who ensures everyone gets the support they need to serve effectively.
Final Thought
Every accommodation request is an opportunity to demonstrate that your organization values people over processes, outcomes over obstacles, and service over convenience.
That's servant leadership in action.
Ready to handle accommodation requests with confidence? Remember: A request for accommodation is not a burden - it's a leadership test.
© 2025 Jerin Falcon. All rights reserved. No part of this publication may be reproduced, distributed, or transmitted in any form or by any means without the prior written permission of the author.
Your job isn't to be the accommodation expert. Your job is to be the leader who ensures everyone gets the support they need to serve effectively.