Disability & Accommodations: 3 Easy Steps to Establishing & Implementing a Reasonable Accommodation Policy

I've worked with a large number of One-Stop or workforce development agencies across the State of California. As part of the technical assistance and training we provide, I often engage staff in a conversation around the agency's Reasonable Accommodation Policy. I'm often surprised at the number of staff that are either unaware of whether they actually have a policy (all should) or what exactly the policy says. I say that all should because it is a requirement under Workforce Investment Act (WIA) Section 188 as well as other disability-related laws that apply to federally funded programs. If you're unsure if you need a policy, a good question to answer is whether or not your agency or business is required to provide reasonable accommodations under the American's with Disabilities Act or the Fair Employment Housing Act (CA Only). If you are, then you should have a policy, and this applies to you.

Now, we all know if you haven't had to use certain information, what often happens is that you hear it once, you store the information away somewhere, and you move on to issues that are more pressing. If you don't use it, you lose it. Right?

As a good rule of thumb, I'd like to suggest the following 3 strategies around establishing and implementing a reasonable accommodation policy…and I'm saying this from the perspective of a consultant who has seen what can happen when you don't do these things.

First, locate your policy. As I mentioned before, most of you will find that you do have one. If the policy is more than two years old, review it for accuracy and make sure that the contact information and instructions still make sense. With staff turnover or restructure, you may need to update your policy to reflect those important changes.

Next, get your staff together and share and discuss the policy with everyone. Interestingly, I've found that for some reason, the person who answers the phones or sits at the front desk isn't included in the everyone. In a Secret Shopper survey we conducted of a local workforce investment area, excluding administrative staff in this discussion led to a significant amount of misinformation going to the public. These are your gatekeepers! If anyone needs to be trained on your policies and procedures, it's the person or persons who interact most with your customers or the public. Include them in the review, and ensure they know how to respond to questions as they arise.

Lastly, be sure to put a 20 minute placeholder for policy review on your staff meeting agenda every quarter. With the hiring of new staff and the many other things that fill your days, a review of the information will make sure that everyone is on the same page. This will lead to less misinformation going to your customers, and ultimately help you to avoid any potential misunderstandings with the people you serve.

If you'd like more detailed information about the enforcement and reasonable accommodation process according to the American's with Disabilities Act, visit: http://snipurl.com/3ffs5. For more information about the Fair Employment Housing Act, please visit: http://snipurl.com/3ffrt.

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