1. Policy Statement
Family Promise of Puget Sound (FPOPS) is committed to providing equal employment opportunities and a welcoming work environment for all qualified individuals, including those with disabilities. In accordance with the Americans with Disabilities Act (ADA), as amended, and the Washington Law Against Discrimination (WLAD), FPOPS will provide reasonable accommodations to qualified individuals with disabilities, unless doing so would cause undue hardship to the organization. This policy outlines what constitutes a reasonable accommodation and establishes the process for requesting, reviewing, and implementing such accommodations for employees and job applicants.
2. Purpose
The purpose of this policy is to:
* Affirm FPOPS’s commitment to compliance with the ADA and WLAD.
* Define “reasonable accommodation” and “qualified individual with a disability.”
* Establish a clear, accessible, and consistent process for employees and applicants to request reasonable accommodations.
* Ensure that requests for accommodation are promptly and fairly reviewed.
* Facilitate the effective performance of essential job functions by individuals with disabilities.
* Promote an inclusive workplace culture.
3. Scope
This policy applies to all paid employees, unpaid staff, and job applicants of Family Promise of Puget Sound. It covers all aspects of employment, including the application process, hiring, training, promotion, compensation, benefits, and all terms and conditions of employment.
4. Guiding Principles
* Legal Compliance: Strict adherence to the Americans with Disabilities Act (ADA), as amended, and the Washington Law Against Discrimination (WLAD), RCW 49.60.
* Equal Opportunity: Ensure that individuals with disabilities have equal opportunities in employment, volunteering or receiving services.
* Individualized Approach: Recognize that reasonable accommodations are determined on a case-by-case basis, considering the specific disability, job requirements, and the individual’s needs.
* Interactive Process: Engage in a good-faith, interactive process with the individual requesting accommodation to identify effective solutions.
* Confidentiality: Maintain the confidentiality of medical information and accommodation requests.
* Non-Retaliation: Prohibit any form of retaliation against individuals who request accommodations or participate in the accommodation process.
* Inclusivity: Foster a workplace where individuals with disabilities feel supported and valued.
5. Definitions
* Disability: As defined by the ADA and WLAD, a physical or mental impairment that substantially limits one or more major life activities; a record of such an impairment; or being regarded as having such an impairment.
* Qualified Individual with a Disability: An individual with a disability who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires.
* Essential Functions: The fundamental job duties of a position that an individual must be able to perform. These do not include marginal functions of the position.
* Reasonable Accommodation: Any modification or adjustment to a job, an employment practice, or the work environment that makes it possible for a qualified individual with a disability to enjoy an equal employment opportunity. Examples include, but are not limited to:
* Making existing facilities readily accessible to and usable by individuals with disabilities.
* Job restructuring, part-time or modified work schedules.
* Reassignment to a vacant position.
* Acquiring or modifying equipment or devices.
* Adjusting or modifying examinations, training materials, or policies.
* Providing qualified readers or interpreters.
* Undue Hardship: An action requiring significant difficulty or expense when considered in light of factors such as the nature and cost of the accommodation, the overall financial resources of FPOPS, the number of employees, and the impact of the accommodation on the operation of the business.
6. Requesting a Reasonable Accommodation
6.1. How to Make a Request
* An employee or job applicant who requires a reasonable accommodation should initiate a request to their immediate supervisor or the CEO.
* Requests can be made verbally or in writing. While a written request is preferred for documentation purposes, FPOPS will respond to all requests regardless of format.
* The request should ideally include:
* A statement that an accommodation is being requested due to a disability.
* A description of the specific accommodation being sought.
* An explanation of how the accommodation would enable the individual to perform the essential functions of the job or participate in the application process.
6.2. Medical Documentation (If Required)
* FPOPS may request reasonable medical documentation to confirm the existence of a disability and the need for accommodation.
* The documentation should describe the nature, severity, and duration of the impairment, the activity or activities limited, and the extent to which the impairment limits the individual’s ability to perform the job’s essential functions.
* FPOPS reserves the right to have a medical professional of its choosing review the documentation to ensure the information is sufficient to determine the need for accommodation.
* All medical information will be kept confidential and separate from the employee’s personnel file.
7. Review and Interactive Process
Upon receiving a request for accommodation, FPOPS will engage in a prompt, good-faith, and interactive process with the individual:
1. Acknowledge Receipt: FPOPS will acknowledge receipt of the request.
2. Information Gathering: The supervisor/CEO will meet with the individual to discuss the request, the essential functions of the job, and the individual’s limitations.
3. Explore Options: FPOPS and the individual will explore potential reasonable accommodations. This may involve researching various options, consulting with disability experts, or considering the individual’s suggestions.
4. Evaluate Effectiveness: FPOPS will evaluate whether a proposed accommodation would be effective in enabling the individual to perform the essential functions of the job.
5. Undue Hardship Assessment: If an accommodation is identified, FPOPS will assess whether it would pose an undue hardship to the organization.
6. Decision and Communication: FPOPS will make a decision regarding the accommodation request and communicate the decision to the individual in a timely manner. If a request is denied, the reason for the denial will be provided.
8. Implementation and Monitoring
* Once a reasonable accommodation is approved, FPOPS will implement it promptly.
* FPOPS will monitor the effectiveness of the accommodation and may periodically review the arrangement to ensure it continues to meet the needs of both the employee and the organization.
* Either the employee or FPOPS may request a re-evaluation of the accommodation if circumstances change.
9. Confidentiality
All medical information and details related to accommodation requests will be treated as confidential and maintained in separate, secure files, accessible only to those with a legitimate need-to-know, in accordance with FPOPS’s Confidentiality Policy and applicable laws.
10. Non-Retaliation
Family Promise of Puget Sound strictly prohibits any form of retaliation against an individual for:
* Requesting a reasonable accommodation.
* Exercising their rights under the ADA or WLAD.
* Participating in the accommodation process.
* Opposing any practice made unlawful by the ADA or WLAD.
Any employee or volunteer found to have engaged in retaliation will be subject to disciplinary action, up to and including termination of employment or service.
11. Relationship to Anti-Discrimination Policy
This policy complements and is to be read in conjunction with FPOPS’s Non-Discrimination and Equal Opportunity Policy (FPPS-ND-001), which affirms FPOPS’s broader commitment to preventing discrimination based on disability and other protected characteristics.
12. Responsibilities
* Employees/Applicants: Responsible for initiating accommodation requests, providing necessary information, and cooperating in the interactive process.
* Supervisors: Responsible for receiving requests, engaging in the interactive process, consulting with the CEO, and assisting in the implementation of approved accommodations.
* CEO: Responsible for overseeing the accommodation process, making final decisions on complex requests, ensuring compliance with ADA/WLAD, and maintaining confidentiality.
* Board of Directors: Provides oversight to ensure the organization’s compliance with disability rights laws.
13. Policy Review and Revision
This policy will be reviewed annually by the CEO and Board of Directors, or more frequently as needed, to ensure its continued effectiveness and alignment with organizational needs, best practices, and federal and Washington State laws, particularly the ADA and the Washington Law Against Discrimination (WLAD), RCW 49.60. Any revisions will be communicated to all relevant personnel.