Reasonable Accommodation Procedures

Procedures for Employees and Qualified Candidates

Responsible Office: Human Resources
Date Established: August 2024

Employee accessibility and accommodation matters are administered by the Employee and Labor Relations team within the Office of Human Resources. Human Resources serves as the central point of contact for employees and qualified candidates seeking reasonable accommodations through an interactive process. This process is initiated by employees making a request for employment-related or workplace accommodation to either their supervisor or to Human Resources directly. Employees can initiate these procedures via email by contacting employee-relations@mtholyoke.edu, by phone, or in-person to request an intake meeting.

Employees can also initiate the accommodation process by submitting a Reasonable Accommodation Request Form, where employees can securely submit relevant medical documentation along with their initial communication. The online form can be found at the following link:
https://cm.maxient.com/reportingform.php?MountHolyoke&layout_id=27

This form is reviewed by a member of the Human Resources team and a member of the team will be in touch with the employee as soon as possible, usually by the next business day.

While not all requests require an intake meeting, for example requests for proximity parking for medical/temporary disability or injury or pregnancy-related conditions, when medical documentation is provided; requesting ergonomic equipment - unless specialized equipment is needed purchasing assistive technologies (ex. Dragon speech software, screen readers); interpretation or translation services for meetings (ASL interpretation services, braille); or migraine accommodations (ex. removal of fluorescent lighting from work area) employees will still engage in an interactive process coordinated by Human Resources.

Please note that language translation services or requests are not managed by this process. If you are in need of language interpreters or translation services please contact Human Resources at: human-resources@mtholyoke.edu.

Employee Reasonable Accommodation Process

The step-by-step process for requesting accommodations is detailed below:

1. The employee informs their direct supervisor or Human Resources about the need for a job accommodation. Please note that if the employee communicates with their direct supervisor, they do not have to disclose information related to any medical/mental health condition that relates to the need for an accommodation to their supervisor. The supervisor should refer the employee to the Office of Human Resources for the ADA accommodation process.

   Alternatively, the supervisor may be aware of an actual or potential need for an accommodation based on visual observation: assistive device in use, overhears employee complain about condition, or employee discloses challenge to supervisor related to access without making a request for an accommodation. The supervisor should let the employee know about the ADA accommodation process within Human Resources. Human Resources encourages supervisors to contact HR when this situation presents itself.

2. Employees and supervisors can have a discussion of the type of accommodation(s) that may be needed. This is perfectly acceptable where the requested accommodation is de minimis, i.e. a request for a lamp rather than have fluorescent lights or access to a chair or stool throughout a shift if it does not impact the employee’s work. If able, the supervisor can put the accommodation in place. The supervisor should also encourage the employee to register their disability and need for accommodation with Human Resources.
3. Requesting employees should complete the Reasonable Accommodation Request Form or make an appointment with Human Resources for help completing this form. We ask the requesting employee to fully complete the form and specify their accommodation request. (Note accommodations may not be fully approved if there are alternatives that can accommodate the employee’s needs).
4. Once the accommodation request is received, Human Resources emails the employee an acknowledgment and instruction email which will include information on employee rights, appeals, external filings, and other resources.
5. From here, the Assistant Vice President for Employee & Labor Relations, or designee, will begin the interactive process. This may involve speaking/emailing with the employee to ensure there is no missing information or to ensure what is being requested is accurate.

6. Medical documentation may be requested to identify an appropriate reasonable accommodation. When requested, documentation should be from an appropriate health care or rehabilitation professional. The provider does not have to be a medical doctor (MD) per se, but should be from the relevant care provider responsible for the care of the employee. Examples may include doctors (including psychiatrists), psychologists, nurses, physical therapists, occupational therapists, speech therapists, vocational rehabilitation specialists, and licensed mental health professionals, among others.

   For short-term parking accommodations, employees may be asked to have their care provider complete a specific form to best allow Human Resources, in partnership with Public Safety and Service, to ensure compliance with the Massachusetts Registry of Motor Vehicle, as may be necessary.

7. The Assistant Vice President for Employee and Labor Relations or assigned Human Resources staff will reach out to the employee and their supervisor about the requested accommodation, whether it can be granted, if this is reasonable and/or appropriate, whether granting can or will cause unreasonable disruption to the workplace, and determine if there are other options for a reasonable accommodation. Human Resources will follow up with the employee with suggested alternatives if necessary.

8. The Assistant Vice President for Employee and Labor Relations or designee reviews the request and feedback from the employee, supervisors, and will issue a determination in writing.

   The Assistant Vice President for Employee and Labor Relations or designee will be responsible for communicating directly with the employee’s supervisor about the implementation of the reasonable accommodation and/or appropriate workforce planning considerations if there is an impact to the work, role, or department.

   If a request is denied, in whole or in part, the Assistant Vice President for Employee and Labor Relations or designee will provide rationale for their decision and/or offerings of appropriate alternatives. Reasons for denial include but are not limited to: accommodation imposes an undue hardship on the College; the accommodation modifies essential functions of the job as listed in the job description or relative to the job duties; or the employee has not provided sufficient medical documentation as requested by the College. Employees making requests for reasonable accommodations should be aware that a request, even when documentation is provided by a care provider, may not be appropriate if otherwise deemed inappropriate, unreasonable, or an undue hardship.

   If denied in whole or in part, the employee will be provided notice of their right to appeal the denial to the College’s ADA/504 Coordinator who will determine if the denial should stand, be modified or reversed. The grievance procedures can be found within the College’s Nondiscrimination and Anti-Harassment Procedures which can be located here: 
   https://www.mtholyoke.edu/student-handbook/discrimination-and-harassment-policies

   If an accommodation is denied, the employee may continue to engage in the interactive process to identify and request an alternative accommodation.

Medical Documentation

Sufficient medical documentation may be needed to assist Human Resources in helping the employee with their accommodation request. When medical documentation is requested the appropriate Human Resources staff will work with the employee to help them understand what medical documentation (letter from doctor, doctor's notes, etc.) is needed. Generally, sufficient medical documentation outlines how their condition affects day-to-day functioning. It is important for the medical documentation to reflect the need for the requested accommodation. Human Resources will review the employee's job duties, medical information, and other relevant information to suggest a reasonable and appropriate accommodation.

What is considered “sufficient” medical documentation? Sufficient medical documentation:

• Describes the nature, severity, and duration of your disability, the activity(s) that the disability limits, and the extent to which the disability limits your ability to perform the activity(s);
• Substantiates why the requested reasonable accommodation is needed;
• Is provided by a healthcare provider qualified to diagnose in the appropriate area of specialization;
• Is on letterhead, typed, dated, signed, and otherwise legible; and
• Is based on a current evaluation (unless the condition is chronic and there is no change to the employee’s condition).

Please note that all medical documentation will remain confidential within Human Resources and be stored in accordance with the College’s policies regarding sensitive material. No medical documentation will be shared with the employee’s supervisor. Additionally, Human Resources will not share any specific diagnosis. However, Human Resources may share information pertaining to the employee’s accommodation request so that the supervisor can be an active participant in the accommodation process. For example, Human Resources staff may tell a supervisor that an employee has a medical condition which limits their ability to remain seated for more than an hour at a time but may not disclose the medical condition.

Transitioning Back to Work from a Medical Leave of Absence

Employees seeking employment-related accommodations upon returning to work from a leave of absence from work including medical leaves, protected leaves, use of sick time, or otherwise in which the paperwork states long-term restrictions greater than six (6) months should follow the process noted above for a reasonable accommodation.