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DRC Handbook Chapter 4: Reasonable Accommodations

4.1 Reasonable Accommodations Overview
4.2 Interactive Process
4.3 Assistive Technology
4.4  Reasonable Accommodation Maintenance and Replacement Policy
4.5 Contract Services
4.6 Sign Language Interpreting Services
4.7  Communication Access Realtime Translation (CART) Services
4.8 Personal Assistance Services in the Workplace
4.9 Reader Services
4.10  Interim Accommodations
4.11 When a Decision Maker disagrees with the DRC

Overview

Reasonable accommodations can be defined as any change in the work environment or in the way things are usually done that results in equal employment opportunity for an individual with a disability. At DOT, reasonable accommodations can be provided to job applicants, to employees to enable them to perform essential job functions, or to employees when a modification is required to ensure equal access to benefits and privileges of employment.

As partners in the reasonable accommodation process, the supervisor/decision maker, the employee, and the DRC must be aware of and fulfill their responsibilities as described in the DOT Order. 

Reasonable accommodations accountability rests with the supervisor/decision maker who must process and analyze accommodation requests made by his or her employees as required by the Order.   Determinations on reasonable accommodation requests should ensure that requested accommodations are:

  • being provided to an employee who has a disability;
  • related to the impairment that is the basis for the disability determination;
  • necessary for the performance of essential job functions; and
  • reasonable in light of other possible alternatives.

Confidentiality of information 2, information technology management, and fulfilling reporting requirements are paramount to those involved in the process. The DRC is only able to fund accommodations that meet all applicable legal, regulatory, and organizational requirements and, therefore, must concur with the outcome of the accommodation process when DRC funding is sought. 3 These requirements can include applicable reasonable accommodations requirements, procurement regulations, and IT policies for the Common Operating Environment.

4.2 Interactive Process

The reasonable accommodation process is a cooperative interactive process which must take place between the supervisor/decision maker and the individual requesting the accommodation. When the DRC’s assistance is sought, the parties should consult with DRC as early as possible in the process. Decisions are made on a case-by-case basis to meet specific individual needs.

When the DRC receives a request for an accommodation, an intake interview is conducted to determine if the supervisor can be contacted as required to begin the interactive process. If the employee does not give DRC permission to contact the supervisor, the request is “Closed Without Action.” If permission to contact the supervisor is granted, the following process occurs.

4.2.1 Disability Determination by Supervisor/Decision Maker

The supervisor/decision maker is contacted by a DRC Analyst and asked whether he or she has made a disability determination.  A determination of disability is needed in situations where the condition for which the individual is seeking the accommodation is not obvious, or when the requested accommodation does not relate to the condition that is obvious.  It is necessary to have record of such determination because DRC is funded to provide accommodations only to employees whose impairments meet the legal definition of disability.

4.2.2 Needs Analysis

Once a disability determination is made, the DRC Analyst works with both the employee and supervisor/decision maker to perform a needs analysis.  This analysis addresses key factors in determining reasonable, appropriate, and effective accommodations.  The steps are:

  • Identify essential job functions. The DRC Analyst reviews the position description with the employee and the supervisor/decision maker.  In situations where the position description does not address duties that reflect the nature of the actual job, the Analyst may request that the manager and requester provide written information that addresses specific functions. 
     
  • Determine essential functions requiring accommodation, or the benefits and privileges of employment for which equal access is required The DRC will ask the employee what aspects of the essential functions of the job need to be accommodated, and will work with the employee and manager to identify solutions that will fulfill those needs. If the employee is seeking assistive technology, the Analyst will investigate which technologies will address the identified needs, and which are compatible with the employee’s existing software and hardware.  The Analyst will also ensure compatibility of selected technologies with the security requirements and other aspects of the Department’s IT Common Operating Environment.
     
  • Evaluate accommodation options.  If an employee and/or his or her supervisor/decision maker is unfamiliar with the product/service solutions being proposed or if several different products/services appear to meet the need in a similar way, the Analyst can arrange a demonstration of various products/services so that the right product for the job can be identified. If the solution involves a service (sign language interpreting, reader services, personal assistance services, for example), the Analyst will work with the employee and supervisor/decision maker to determine parameters for such services, such as frequency, nature of the service, etc.
     
  • Provide documentation, if needed. In some circumstances, the employee might not be able to adequately describe the functional limitations of a disability (for example, a late-deafened adult who does not know their degree of hearing loss, or a person with low vision who cannot quite describe the severity of the vision loss).  When such clarity is required to help create an effective solution, the DRC might ask for documentation that only addresses the specific functional limitations.

4.2.3  Develop a Consensus on Accommodation(s)

The Analyst will work with the employee and decision maker to ensure that everyone agrees with the proposed accommodation(s). If such agreement cannot be reached, the Analyst might recommend a facilitator or will seek advice from the OA Civil Rights Office and/or the Departmental Office of Civil Rights (DOCR), as needed.  For information on specific items and services that are out of the scope of DRC services, please see Chapter 11 of this document, “Services Out of the Scope of the DRC.”

4.2.4  Assistance and Referral with Out of Scope Accommodation Requests

In some situations, the employee and supervisor/decision maker might desire an accommodation that the DRC cannot provide because that accommodation is beyond the scope of the services or equipment DRC offers. In those instances, the DRC will provide information and resources on how the accommodation could be obtained outside of DRC should the decision maker and employee wish to pursue the accommodation.

4.2.5  Written Agreement of Accommodation(s) Provided

When the needs analysis is complete, the Analyst will prepare a written report (Action Plan) outlining the product/service to be provided by DRC, including property requirements, such as inventory, repair and maintenance.  If the accommodation being requested relates to a previous accommodation (for example, a new tool or service that will augment previous items/services provided) the Analyst will prepare an Action Plan Addendum that describes the new product(s)/services being provided.  The Action Plan or Action Plan Addendum is signed by the employee, the supervisor and the DRC. 

4.2.6  Acquisition of Items/Services

The next step is the procurement and delivery of the product/service that has been identified and agreed upon in the Action Plan.

4.2.7  Accommodation Request Closure Notification

When the accommodation items or services have been received and are functioning well to accommodate the employee, the DRC will close the request. The DRC notifies the employee and supervisor/decision maker via e-mail that the request has been successfully fulfilled and is being closed. 

4.2.8  Accommodation Request Follow-up

The DRC staff conducts follow-up to ensure the product/service is meeting the needs of the employee. The DRC will contact the employee and supervisor/decision maker within 45 days after the accommodation request is closed to ensure the accommodation is meeting the needs of the employee as intended.   The DRC will also follow-up by sending a voluntary customer feedback survey to the employee and the supervisor/decision maker after the action has been closed.

4.3 Assistive Technology

Assistive technology products can enable an employee with a disability to perform the essential functions of his or her job.  These items can include, but are not limited to:

  • screen readers for auditory output of information displayed on the computer screen, as well as data being entered into the computer;
  • screen enlargement software for enlarging text and graphics displayed on the computer screen;
  • videophone equipment;
  • adaptive input devices for alternative control of the computer and keyboards;
  • desktop magnification devices, including CCTVs and portable digital magnifiers;
  • assistive listening devices;
  • Braille displays, or
  • voice recognition software.

Prior to purchasing any assistive technology item as an accommodation, the DRC performs an analysis that compares all possible solutions and determines whether the item: 

  • is an effective accommodation that will allow the employee to perform his or her identified essential job functions;
  • addresses the specific needs of the individual employee;
  • is compatible within DOT’s Common Operating Environment, and
  • does not cause conflicts with existing office software or other assistive technology.

Through the analysis process described in Section 4.2.2, the DRC will work with the employee and the decision maker to determine what item or items will best meet the needs of the employee and will function well within the DOT environment.  If the employee has a suggestion of what products are preferred, or what has worked well in the past, the suggestion will be considered. However, it is possible that the preferred item will not function properly within existing systems, or that the DRC may recommend a different product with similar features

4.3.1 Assistive Technology Training

To ensure the employee’s success in using the identified product, training can also be provided.  This training is usually provided by an outside vendor.  The employee will be provided with the vendor’s contact information and is expected to schedule the training directly with the vendor.  To ensure that all procurement requirements are met and to document that the request is fulfilled, the employee must keep the DRC informed of when trainings are scheduled and actual training occurs

Assistive technology training is not limited to the time of initial purchase of the technology.  If at a later time the employee finds that he or she needs to learn some other feature or aspect of the product that addresses an essential job function, the employee can submit a new request for a reasonable accommodation to the DRC.  Once a specific product and/or training is identified that meets the employee’s needs, a new Action Plan/Action Plan Addendum would be prepared.

4.3.1.1 Security Escorts for Assistive Technology Trainers

While security policies vary somewhat from one building to another, in general DOT security policy requires that visitors be escorted by the person they are visiting at all times.  The person who “signs for” the visitor at the guard desk is responsible for that visitor at all times until the visitor leaves.

DRC does not provide the escort for trainers who are here to provide service to DOT employees.  Escorting the trainer is the responsibility of the person who requests the service. If the person requesting the service is unable to escort the vendor or arrange for an escort, the employee cannot receive the accommodation he or she needs from the agency.

Because there are frequent occasions when the contact person provided does not answer the telephone when the guard desk calls, the DRC requires two alternate contacts for each service request.  Please ensure that the contacts you provided to the DRC when making the request will be available to answer the phone and can escort the provider to the location of the event when the interpreter arrives. It is not possible for DRC to provide an escort for your trainers. You also should not assume that the trainers will have a contractor badge.

4.3.2 Assistive Technologies Purchased Through CAP

DRC is able to procure a variety of assistive technology products through its MOU with CAP.  As established in the MOU, all requests submitted to CAP must be completed and submitted by the DRC; therefore, DOT Department Offices, OAs, or employees should not contact CAP directly.  This ensures that the MOU and the accommodation process have been followed.  After receiving a request from the DRC, CAP will perform its own analysis of the reasonable accommodation request according to its own operating guidelines.  To support CAP’s analysis, DRC provides them with information gathered during DRC’s analysis with the employee and supervisor/decision maker.  The type of information that CAP requests includes, but is not limited to:

  • documentation regarding functional limitations,
  • details about the job task(s) to be accommodated by the requested item(s),
  • details about the employee’s limitations in performing the job task(s),
  • details about the physical environment, general technology and infrastructure, and
  • a signed authorization that Information Technology (IT) agrees to allow the product to be connected to the infrastructure.

In some cases, the employee might be contacted directly by the CAP analyst.  If this occurs, the employee should contact the DRC analyst, keeping him or her informed. 

If CAP approves the item, the product will be purchased by CAP at no cost to the employee’s OA.  The DRC will work with CAP and the employee to arrange delivery of the product and/or training.

Occasionally CAP does not approve requests that have been submitted by the DRC.  Reasons for disapproving a request include the following examples:

  • CAP’s new fiscal year budget has not been approved,
  • CAP’s fiscal year funding has been exhausted,
  • the requested items or services are not on CAP’s approved list,
  • documentation has not been submitted by CAP’s due date,
  • products are not currently available for purchase (e.g. backordered items), or
  • CAP has determined the item requested is not an effective accommodation or it is out of the scope of the types of equipment CAP is authorized to provide (e.g., keyboards, mice, monitors, etc.)

When using CAP services the DRC must comply with CAP’s requests for information.  Failure to comply will result in the request being disapproved by CAP.

If CAP does not approve the item, representatives of the CAP organization might suggest an alternative item from their approved list.  If the item meets the needs of the employee with similar features and functions, the DRC, in consultation with the employee and the decision maker, can consider accepting the alternative product.

The DRC will work with the employee’s supervisor/decision maker in these cases to determine the best course of action in meeting the requirements of the DOT Order.  In the event that CAP is not able to fulfill the request, the DRC can make the purchase using DRC funds.  DRC funds are used to purchase products and services when:

  • CAP disapproves the item and provides no alternative,
  • CAP disapproves the item and the alternative recommended by CAP is deemed by DRC not appropriate,
  • CAP has exhausted its budget, or its budget has not yet been approved; or
  • the product is not part of CAP’s approved list.

When DRC funds are used to purchase an accommodation, all DOT  WCF procurement regulations and procedures must be followed.  These include, but are not limited to:

  • ensuring a legitimate Government need for the item(s) or service(s),
  • ensuring competition requirements are followed,
  • adhering to spending limits on credit cards,
  • utilizing approved vendors, and
  • adhering to scope and funding limits of existing contracts.

For more specific information on specific purchasing regulations, consult the Transportation Acquisition Regulations and the Transportation Acquisition Manual.

4.3.3 Property Agreements

A Property Agreement is prepared by the DRC and will include the following information.

  • Date prepared
  • Employee’s name
  • Employee’s office phone number
  • Employee’s location 
  • Employee’s Operating Administration 
  • Employee’s Supervisor’s name 
  • Product information, including serial numbers, if available
  • Terms to be agreed to by the employee and the supervisor

The DRC will provide the employee and supervisor/decision maker with the Property Agreement prior to delivery of the product.  The Property Agreement requires the signature of both the employee receiving the product as an accommodation, and the supervisor/decision maker.  In some OAs the property custodian will be required to sign the form.  The DRC delivers the product after the property agreement has been signed.

By signing the Property Agreement form, all parties are agreeing to the following terms required by DOT procurement and asset management regulations.  The terms are:

  • Upon delivery, all equipment becomes property of the employee’s OA.  The employee’s office accepts the item(s) into its inventory, and is responsible for following all OA inventory procedures and policies in place.  If an individual wishes to familiarize himself or herself with policies regarding property, he or she should contact the OA property custodian for more information.
  • The OA will be responsible for maintaining the item in good working order.  This includes peripherals (i.e., batteries, paper, bulbs, accessory items, etc.), on-going service fees, (i.e., line charges, service agreements, etc.) routine maintenance and repairs.
  • In the event the employee leaves the OA or Department for another Federal position, the OA is free to transfer the equipment to the new agency if mutually agreed.  The DRC does not receive property back into inventory; however, we may be able to assist the OA with finding another appropriate recipient.  If the employee separates from Federal service, the equipment will remain in the inventory of the OA The supervisor/decision maker should contact the OA property custodian regarding transferring of equipment, if necessary, within the Department. 

By signing the Property Agreement form the supervisor/decision maker and employee are acknowledging that they have received and accept responsibility for the item(s) as government property. As employees of the government to whom public property has been entrusted, they are acknowledging that they understand:

  • they are responsible for the proper custody, care, and safeguarding of this property;
  • they are authorized to use the property only for the purposes set forth in the agreement;
  • if the property is lost, damaged or destroyed, they may be held financially liable and/or subject to discipline if the loss, damage or destruction resulted from their negligence, misuse, dishonesty or willful destruction, and
  • as appropriate, they agree to inform property officials within their OA of this commitment.

4.4  Reasonable Accommodation Maintenance and Replacement Policy

The DRC does not perform general maintenance of reasonable accommodation items.  It is the responsibility of the individual’s office or OA to ensure that any necessary maintenance is performed to keep the item in good working order.

Occasionally, an item will need to be updated or replaced.  Whether or not the DRC covers the update or replacement is decided on a case-by-case basis.  The following factors are considered.

  • Typical life span for the item in question.
  • Normal wear and tear.
  • A product has become obsolete and is no longer supported for maintenance purposes.
  • A different product can be justified because its features meet the employee’s specific needs.
  • An update to the Common Operating Environment for our IT services causes a compatibility problem with existing technologies.

OA’s will be responsible for replacing items within its inventory under the following conditions 

  • misuse or accidental breakage,
  • the item becomes lost or stolen,
  • a newer version of the item has been released and the customer desires the latest version (unless it can be demonstrated that the newer version contains a significant change that addresses an employee’s essential job function).

Items such as batteries, paper, light bulbs, or other expendable items for assistive technology devices are considered office supplies and should be ordered locally by whatever procedure the employee’s office uses to obtain other office supplies.

4.5 Contract Services

Contract services are sometimes needed to fulfill an accommodation.  These services generally include, but are not limited to:

  • sign language interpreting for employees who are Deaf/hard of hearing,
  • Communication Access Realtime Translation (CART) services for employees who are Deaf/hard of hearing,
  • reader services for employees who are visually impaired,
  • personal assistant services in the workplace for employees who have disabilities, and
  • personal assistant services when on travel for employees who have disabilities requiring assistance with personal care.

These services may be ongoing, regularly scheduled or on an as needed basis for a specific task or event that is part of the employee’s essential job functions.  These services can also occur as a one-time service for training or other event outside of the employee’s regular routine, but related to their essential job functions. 

If an employee requires contract services from the DRC as a reasonable accommodation, the first step is to request an accommodation from the DRC.   The interactive process outlined in this document and the DOT Order will be followed. As described earlier, a disability determination might need to take place if the condition that triggers the request is not obvious, or if the request does not appear to relate to the obvious disability.  The DRC will conduct an analysis of the employee’s needs and the essential job functions to be accommodated.  The identified service and its terms are detailed in the Action Plan/Action Plan Addendum written by the DRC.  Modifications to the Action Plan/Action Plan Addendum are made if the employee’s needs change.   Examples include:

  • when sign language interpreting services are approved, but some factor has changed and CART services are now requested;
  • 3 hours per week of reader services are approved, but some factor has changed, and now 6 hours per week for the next 3 weeks is requested;
  • personal assistant services are approved for a specific set of tasks, but a factor has changed and access to new tasks is requested;
  • personal assistant services is approved in the workplace, but work related travel is required and a personal attendant (PA) for travel is requested.

Individuals using service providers obtained through the DRC cannot have the contract staff provide tasks/services beyond the scope of the contractual agreement.  Any changes in scope must be discussed with DRC.

4.6 Sign Language Interpreting Services

Contact Information

For information on requesting a sign language interpreter, contact the DOT Disability Resource Center (DRC):

4.6.1  Overview of Sign Language Services

DRC provides sign language interpreting services for the DC headquarters for DOT, for various DC FAA offices and for various DOT offices located throughout the country. The specific procedures for requesting services vary depending on the location and the type of activity that requires the service.

When an employee with a disability makes a request for interpreting services as an accommodation in the workplace, the interactive process will take place.  An analysis will be completed to determine the type of interpreting needed and the range of situations where interpreting would be required.  An Action Plan will be developed that reflects the scope of the employee’s interpreting needs.  Once the employee and supervisor have agreed on the interpreting requirements, a reasonable accommodation does not need to be requested each time an interpreter is needed as long as the request is consistent with the action plan. Once approved, interpreting services can be arranged through the DRC interpreting coordinator or the procedures established with the service provider at the employee’s location. 

DRC provides interpreters on a scheduled basis.  Interpreters are assigned to specific employees for specific events.  DRC does not provide services on an as-needed basis (i.e., in response to whatever comes up on a given day.)

A request for interpreting services is a reasonable accommodation request and will initiate that process. The reasonable accommodation process that DRC uses for interpreting is the same as for any other service. The result is an action plan that specifies the scope of services. Subsequent requests that are outside of the services described in the action plan are referred to the supervisor. The process as related to interpreting is described in section 4.6.4.

The meeting sponsor is ultimately responsible for ensuring their event/meeting is accessible.  If no interpreters are located, the event sponsor should reschedule the event/meeting or locate alternative sources.

4.6.2 Information needed for all interpreting requests

Specific procedures for obtaining interpreting services vary depending on the location and the company that provides services. Procedures for DC DOT and FAA offices are described in section 4.6.5 while procedures for field offices are described in 4.6.10.

Information needed for all interpreting request includes:

  • Date
  • Start time
  • End time
  • Location
  • Description of event
  • OA and person requesting service
  • On-site contact name and phone number
  • Alternate on-site contact name and phone number
  • Type of interpreting service required (we usually know the type required if the employee name is provided)
  • Special circumstances

A separate interpreting request is required for each meeting or event, even if one occurs immediately after the other. This ensures that appropriate interpreters are available for all events.

Ensure sufficient time is allowed in advance of the event start time to allow for security processing and escort. The amount of time varies from one building to another and at different times during the day. Interpreting services allow some time for security processing, however including the additional time in the request ensures that the particular building/event circumstances are considered.

The number of interpreters needed for a particular request can depend on the number of participants and break-out sessions, nature of the events such as for a conference, trainings or Departmental programs. Therefore, requests for interpreters should be made as soon as the date and time of the event have been determined, with a minimum of five business days' notice in advance of the event or meeting.

Meeting and training material that will be distributed during the event should be provided to the interpreters at least one business day in advance. In some instances, especially when highly specialized terms will be used, a list of vocabulary or frequently used terms would be helpful. This is so the interpreters can familiarize themselves with the material in advance to better facilitate communication.

When interpreting requests are filled by service providers who are not under a DRC contract or not core interpreters, customers may be requested to sign a, “receipt of service” document to validate services rendered.  This receipt is used to document proof of service and allows DRC to pay the contractor’s invoice.

Certain kinds of meetings and events require specialized interpreting services or advance arrangements with individual interpreters.  For example, an interpreter’s permission must be secured before they are assigned to videotaped events or in highly controlled events. When the Secret Service is involved, an interpreter may be required to provide personal identifiable information in advance of the event to the Security Office.  The requestor is responsible for making the request at the earliest possible moment and providing all known information.  DRC may not be able to fill late requests for interpreting for these specialized events.

Videotaping or transmitting an interpreter in an on-screen "bubble" or "picture in picture" format is not an effective accommodation and is not supported by the DRC.

Meetings concerning legal or medical matters such as depositions, hearings, accommodations, adverse actions, retirement counseling, alternative dispute resolution meetings, Equal Employment Opportunity, security and criminal matters usually require certified interpreters. This requires advance planning and incurs additional cost.  If the activity is occurring at the request of another Federal agency or private sector organization, the DRC recommends asking the sponsoring organization if interpreting services are available to meet the individual needs. In DOT, the provider of Employee Assistance Program (EAP) services provides sign language interpreting. Indicate if the service is required when making an appointment.

Activities involving performances such as singing (including the National Anthem), skits, plays, videos and/or other multimedia require specialized skills to be effectively interpreted.  If the person requesting services does not provide the information about these special circumstances, and the interpreter does not feel he or she is qualified to interpret under the circumstances, ethically, he or she is not required to complete the assignment.  The interpreter will notify the on-site contact of the issue and suggest that the event be rescheduled.  Providing ineffective interpreting that does not meet an individual’s need is something the DRC strives to prevent.

4.6.3  Event Planning

As stated in the DOT Memorandum, “Accessible Workplace Programs and Activities for Individuals with Disabilities," planners should ask all participants in advance if accommodations are needed. This can be incorporated into a registration process. An accessibility statement is required on all event invitations, notices, posters, and emails, providing adequate time for people to identify their accommodation needs and for DRC to obtain interpreters. An example of an accessibility statement is as follows:

“The US Department of Transportation (or name of Operating Administration or office) is committed to providing equal access to this meeting (or event) for all participants. If you need alternative formats or services because of a disability, please contact (name of person) at (telephone number) or via e-mail (e-mail address) with your request by close of business (deadline.)”

The number of interpreters needed for a particular request can depend on the number of participants and break-out sessions, nature of the events such as for a conference, trainings or Departmental programs. Therefore, requests for interpreters should be made as soon as the date and time of the event have been determined, with a minimum of five business days' notice in advance of the event or meeting.

4.6.4  Reasonable Accommodation Process for Interpreting Services

DOT managers, event sponsors, meeting planners, training coordinators and schedulers for speaking engagements are responsible for arranging and providing accommodations for all participants.  The DOT Policy for accessible meetings provides more information on these responsibilities.  If reasonable accommodations cannot be made for a person attending the event, it should be rescheduled for a day and time when accommodations are available. In some instances it might be possible for the event planner to work collaboratively with the attendee and the DRC to identify other methods of communication; however, effectiveness of any alternatives should always be evaluated before they are deemed acceptable.

With the initial request for interpreting services as an accommodation in the workplace, DRC begins the reasonable accommodation process.  An analysis will be completed to determine the type of interpreting needed and the range of situations where interpreting would be required.  An Action Plan will be developed that reflects the scope of the employee’s interpreting needs.  If an Action Plan exists for interpreting services but the employee needs to make a change to that service, then a new analysis will be conducted and an Action Plan Addendum will be developed.  Both the employee and his or her supervisor sign the Action Plan/Action Plan Addendum and return it to the DRC prior to the start of interpreting services. Once the employee and supervisor have agreed on the interpreting requirements, a reasonable accommodation does not need to be requested each time an interpreter is needed as long as the request is consistent with the Action Plan. Once approved, interpreting services can be arranged through the DRC interpreting coordinator or the procedures established with the service provider at the employee’s location. 

The DRC will provide interpreters for work-related or DOT sponsored one-on-one or small group meetings in which a Deaf employee or applicant participates.  It will also provide interpreters for DOT sponsored internal ceremonies and events (such as all hands meetings and award ceremonies) that will be attended by Deaf employees.  Additionally, the DRC will provide interpreters for training courses attended by a Deaf employee if the training vendor does not provide the needed accommodation (Private sector trainers are required to provide interpreters under the ADA and interpreting should be required as part of the purchase order or contract). 

If an employee requires regular, unscheduled, ad-hoc interpreting, he or she should discuss the need with the supervisor.  It may be necessary for the employee’s Departmental Officer or OA to explore alternatives such as a part-time or full-time contract or Schedule A position to fill the employee’s communication needs. 

If an employee requests interpreter services to attend an event outside of DOT while on official duty, the following factors will be considered:

  • Did the employee receive management approval to attend the outside event?
  • Does the sponsoring outside organization provide interpreter services, and if not, should it? The outside entity might have contractual or legal obligations to ensure that accommodations are provided.
  • Is the activity sponsored by DOT?

Certain activities are not considered DOT sponsored (such as union meetings) or may not be an approved work-related activity (such as employee or professional associations).

4.6.5  Things to Know About DRC’s Sign Language Interpreting Services

Late requests sometimes occur because meetings or events are scheduled with short notice.  DRC makes every effort to locate interpreters in these cases, but cannot guarantee that resources will be available. Requests with less than 1 business day’s notice are unlikely to be filled, unless another request is cancelled at the last minute.

When the DRC receives late requests and cancellations, additional costs are charged by the service provider which the DRC must pay.  For example, a change in the date, time or location in many cases will be considered by the interpreting contractor as a cancellation and a new request.  If the modification occurs with less than 3 full business days notice, both late cancellation and late request fees may apply.  Therefore, it is important and highly encouraged to ensure accurate information is provided and changes are provided with more than 3 full business days notice.

The DRC tracks the numbers of late requests and cancellations as part of our contracting oversight process. If a particular user of interpreting services appears to have an unusually high number of cancellations or late requests, the DRC might schedule a meeting with the employee and the supervisor to discuss interpreting scheduling issues.  The DRC might suggest ways of planning meetings or events in a manner that will minimize the additional expense incurred with late requests and late cancellations. The DRC must ensure that its resources are used efficiently and effectively, and our customers play a critical role in that endeavor.

DRC provides interpreters for limited DOT events, typically Secretarial functions, public meetings and special emphasis programs. An individual does not need to request an interpreter in these cases. Interpreters are not required to perform if no one is being accommodated with the service.  Since meeting sponsors may not be aware of procedures for ensuring accessible meetings, it is always good practice to notify the event sponsor when interpreters will be needed for an employee unless the announcement states that interpreters will be provided.

If interpreters are being provided for an individual, they are not required to interpret for any other individuals or to provide a different kind of service other than what has been requested for the employee.  If the person receiving the service leaves the event or meeting, normally the interpreters will also leave. They may be required for the next activity. Do not assume that interpreters are being provided for all attendees at a meeting or event, with the exception of the limited events listed above.

Interpreters are provided for the sole purpose of facilitating effective communication for people who are Deaf or hard of hearing.  They are not available to do other tasks such as file, provide a security escort for DOT visitors, retrieve any item, open and close doors or operate office equipment.

Sign language interpretation is the translation of one language into another language and requires mental concentration.  Interpreters are not able to translate more than one conversation at a time.  Additionally, interpreting requires significant repetitive physical effort.  Therefore, interpreters require breaks at least every 2 hours and more frequently depending on the intensity and how much the Deaf employee is participating.  

When an employee is making a presentation, serving as part of a panel discussion, or otherwise making significant contributions to a meeting, two interpreters are required.  This allows one person to speak for the employee and another to translate for the employee.  Highly interactive events might require more interpreters. 

Since different people require different types of sign language interpreting, if more than one deaf employee attends an event, multiple interpreters may be required simultaneously.

4.6.6  Requests for DOT Headquarters and FAA DC locations

The DRC Interpreting Office is located at W56-449 in the DOT Headquarters West Building. Scheduling requests are accepted Monday through Friday from 8:30 a.m. to 4:30 p.m. Requests after 4:30 p.m., will be received the following business day.
Interpreters may be reserved in advance for times other than those listed above on an as-needed basis. Every effort will be made to accommodate each request, subject to the constraints noted below. Interpreting requests are accepted via email and the exact procedure will vary depending on the location.

Because of the large volume of interpreting requests in Washington, DC, DRC has both staff interpreters and contract interpreters assigned to the South East Federal Center (SEFC). These interpreters are scheduled by the DRC interpreting coordinator. All requests for sign language interpreters at the DOT Washington Headquarters will be filled on a first-come, first served basis. At least 5 business days advance should be provided.    This notice enables the DRC to seek and pay for the services of another vendor, if the current service provider is unable to meet the need.  However, if multiple requests for the same time slot cannot be accommodated, the first-come, first-served rule will apply.  

DRC headquarters interpreters may be available on a same-day basis because the schedule is not full or because requests for that day have been cancelled.  If DRC headquarters interpreters are available, they may be used for same-day requests.

4.6.7 Format for Headquarters Sign Language Interpreting Requests

The DRC manages all interpreting requests via e-mail. The DRC uses an e-mail template that makes it easy for requestors to fill out an interpreting request. A separate e-mail for each assignment is required.  For on-going requests, follow those procedures when the same request repeats frequently.  The information below is to be included in ALL requests for headquarters interpreting should include the following information:

Subject line:   New Request: (mm/dd/yy); (start time to end time), Bldg/Room number.

  • Operating Administration requesting interpreting service
  • Deaf Consumer's name
  • Description of the event
  • Requestor’s Name and Phone Number
  • Location of event (address, building and room number)
  • Contact information for 3 different points of contact so that the security desk can use to call for escort when the interpreter arrives at the facility or for the DRC’s use

Without the above information, DRC interpreters and interpreting agencies are not able to assign a person to the specific job.

To ensure that requests for interpreting services are handled appropriately, all pertinent information shall be provided to DRC prior to the interpreting assignment in order to locate and respond to these requests as efficiently as possible.  The DRC asks all requestors to follow a consistent format for making requests to ensure requests are easy to sort and identify, and that the information is transcribed accurately to our interpreter calendar and provided to the vendor in a clear and concise format.

To ensure maximum availability of service, the requestor is responsible for providing notification of a cancellation as soon as it is known that the service will not be required.  The requesting office should notify the DRC of cancellations at least three full business days prior to the interpreting event or meeting.  This will help the DRC reassign interpreting services to other individuals or events and avoid costs for services that are not used.

If DRC interpreters are not available, the DRC staff will attempt to procure services through another vendor.  There is no assurance that services requested on short notice can be filled.  In the event that the DRC is unable to provide interpreters with the purchasing vehicles we have available, the DRC will provide the requestor with a list of interpreting companies from which they can attempt to locate and pay for the service directly.  Alternatively, the meeting sponsor can reschedule the event/meeting.

4.6.8  Late Requests

Untimely requests are those made less than five business days prior to the date interpreter services are needed. Whenever possible, late requests should be avoided as they might result in additional fees charged to the DRC by our contracted interpreting vendors.  Late requests are also much less likely to get filled as interpreter demand in Washington, DC is very high. 

4.6.9  Modifications to Requests

Please follow the following format and procedure when making a modification to a previously submitted request:

Subject line:  Mod Request: (original request information) (mm/dd/yy); (start time to end time), Bldg/Room number.

Example of a Modification Request:
Subject: Mod Request:  07/15/06; 01:00-02:00, , DOT HQ, W56-403

In the Body of the email: (Modified Information)
Example:  Time changed from 01:00-02:00 to 02:00 to 03:00 room number 6214

Note: Modified requests that make changes to the date and time and that are made with less than five working days notice, are considered late requests and may incur additional costs.

4.6.10  Cancellations

The requestor is responsible for notifying the DRC of cancellations at least three business days prior to the interpreted meeting, event or training. This will help the DRC reassign interpreting services to other individuals or events and avoid unnecessary costs.

To ensure maximum availability of service, the requesting office is responsible for providing notification of a cancellation as soon as it is known that the service will not be required.  Please follow this format for canceling a request:

Subject line:  Cancel Request: (mm/dd/yy); (start time to end time), Room number.

Example:

Cancel Request: 07/15/06; 01:00-02:00, DOT HQ, W56-403

4.6.11  On-Going/Recurring Requests

For meetings that are repetitive in nature, it is not necessary to submit an individual request for each meeting.   However, it is necessary to list each date of the meeting on the initial request.  Please remember to cancel at least three days in advance if the meeting will not be held.  Repetitive meetings (i.e., weekly staff meetings) may be scheduled through the fiscal quarter and must be reviewed/renewed each quarter.  The DRC cannot confirm requests past the end of the fiscal year or the term of a contract.  The DRC cannot approve requests for new fiscal year funds until funds have been approved nor can a contractor confirm services past their contract service dates.

For requests that are on-going, be sure to include intervals, for example: (1st Monday, 4th Thursday, every other…). Include information on the upcoming meeting dates, for example, next three meeting dates:  07/01, 07/14, 08/01.
 
Example of an On-Going Request:
 
Subject line:  On-going request: (start date-end date): (start-end time); Location/Room:

4.6.12  Request Confirmations

Due to a high volume of interpreting requests, please allow at least two business days for a confirmation.  However, if this is a last minute request we will inform you as soon as possible.  You should receive a confirmation for each assignment requested.   If you do not receive a confirmation, please contact DRC.Interpreters@dot.gov via e-mail with the date of your assignment and the time and date your request was submitted.

4.6.13  Sign Language Services for Field Offices and the Greater United States

To ensure that the DRC has adequate time to secure interpreters, especially in areas/cities where an existing procurement vehicle is not in place, please give as much notice as possible. Send an email with the following information below:  Emails may be sent to drc@dot.gov or directly to an accommodation analyst you may have worked with previously. Please send a separate email for each assignment.

Your email should contain the information as outlined below:

Subject line: New Request: (mm/dd/yy); (start time to end time), Bldg/Room number.

  • Date
  • Start time
  • End time
  • Location
  • Description of event
  • OA and person requesting service
  • On-site contact name and phone number
  • Alternate on-site contact name and phone number
  • Type of interpreting service required (we usually know the type required if the employee name is provided)
  • Special circumstances
  • Number of Interpreters (if known)

Logistics and procedures for requesting interpreting services in locations outside of the Washington, DC area are arranged on an individual basis taking into consideration frequency, types of services needed, planning capabilities and security considerations. The DRC funds interpreting services for DOT employees throughout the country on either a one-time basis or to fill a continuing need. Organizations with a recurring need for services may request the DRC's support in establishing on-call agreements with local interpreting services. The interpreting service guidelines outlined in this document also apply to DOT locations throughout the United States. Because interpreting services may be difficult to obtain in some areas, as much additional notice as possible is requested.

Logistics and procedures for requesting services in locations outside of DC are arranged on an individual basis taking into consideration frequency, types of services needed, planning capabilities and security considerations.

If an employee is traveling out of town for a meeting, the DRC will need additional time to locate interpreters and procure the services.  If the DRC is not able to do both, the OA may elect to order and pay for services, or the meeting may need to be rescheduled. The OA or the DRC will also give consideration to making a direct request to those holding the meeting to provide the appropriate interpreting services. 

4.6.14  Security Escort for Sign Language Interpreting Service Providers

While security policies vary somewhat from one building to another, in general DOT security policy requires that visitors be escorted by the person they are visiting at all times.  The person who “signs for” the visitor at the guard desk is responsible for that visitor at all times until the visitor leaves.

DRC does not provide the escort for interpreters who are here to provide service to DOT employees.  Escorting the interpreter is the responsibility of the person who requests the service. If the person requesting the service is unable to escort the vendor or arrange for an escort, the employee cannot receive the accommodation he or she needs from the agency.

Because there are frequent occasions when the contact person provided does not answer the telephone when the guard desk calls, the DRC requires two alternate contacts for each service request.  Please ensure that the contacts you provided to the DRC when making the request will be available to answer the phone and can escort the provider to the location of the event when the interpreter arrives. It is not possible for DRC to provide an escort for your interpreters. You also should not assume that the interpreters will have a contractor badge. After 20 minutes of waiting (and this includes waiting in the lobby to be escorted to their assignment when no one shows up to escort them), interpreters will be released from the assignment.

4.7  Communication Access Realtime Translation (CART) Services

CART service provides instantaneous translation of what is being said into visual print display so that it can be read (instead of heard or interpreted).  CART service can be provided in situations such as lectures, presentations, and panel discussions.  In situations where multiple requests for CART have been made for the same event, the captioned text can be displayed on a large screen for all to view.   When necessary, a transcript of the captioned text can be provided to the requester if deemed appropriate during the interactive accommodation process.

When an employee with a disability makes a first time request for CART services as an accommodation in the workplace, the interactive accommodation process will be initiated.  If required, a disability determination must be made, then an analysis completed, and an Action Plan developed.  If an Action Plan exists for a different type of communication service (such as sign language interpreting), then after the analysis has been completed, an Action Plan Addendum will be developed.

The Action Plan/Action Plan Addendum will include frequency, duration and other details of the event and the services needed to be performed by the vendor, as well as the responsibilities of the employee and their supervisor.  Both the employee and their supervisor must sign the Action Plan/Action Plan Addendum and return it to the DRC prior to the securing of the CART services. 

The DRC will order the CART services and provide the employee and supervisor with information instructing them on scheduling and canceling services as needed.  The vendor will be provided with:

  • employee’s name and contact information,
  • location where service needed – full address, including room number
  • start and end time
  • information about the type of event
  • description of tasks to be provided, as agreed upon in the Action Plan/Action Plan Addendum
  • start and end date of event, if applicable

If there is any change in the requested service, the employee or their supervisor must notify the DRC immediately. Last minute cancellations may result in paying for services that are not provided and should be avoided.

To ensure that services can be arranged and a last minute request fee is not charged to the DRC, requests should be made at least 10 days prior to the date of service needed.  When the DRC does receive a last minute request for CART service, every effort will be made to secure the service, but actual service will be determined by vendor availability.

4.7.1  Security Escorts for CART Service Providers

While security policies vary somewhat from one building to another, in general DOT security policy requires that visitors be escorted by the person they are visiting at all times.  The person who “signs for” the visitor at the guard desk is responsible for that visitor at all times until the visitor leaves.

The DRC does not provide the escort for the CART service providers who are here to provide service to our employees. Escorting the service provider is the responsibility of the person who requests the service. If the person requesting the service is unable to escort the vendor or arrange for an escort, the employee cannot receive the accommodation he or she needs from the agency.

Because there are frequent occasions when the contact person provided does not answer the telephone when the guard desk calls, the DRC requires two alternate contacts for each service request. Please ensure that the contacts you are providing will be available to answer the phone when the service provider arrives and can escort the provider to the location of the event.  It is not possible for DRC to provide an escort for your service providers.  You also should not assume that the service provider will have a contractor badge.

4.8 Personal Assistance Services in the Workplace

Personal Assistance Services (PAS) can be defined as people or services that assist a person with a physical, sensory, mental, or cognitive disability with tasks that the person would perform for him or herself if he or she did not have a disability.  In general, these may include assistance with eating, toileting and cognitive tasks such as facilitating communication access with a reader.

In the workplace, PAS is provided as a reasonable accommodation to enable an employee to perform the essential functions of a job.  The employer's responsibility for providing reasonable accommodations begins when the employee reaches the job site and concludes when the work day ends.  Workplace-related PAS might include, but are not limited to:

  • filing,
  • retrieving work materials that are out of reach,
  • providing travel assistance for an employee with a mobility impairment, or
  • reading handwritten mail to an employee with a visual impairment.

Each person with a disability has different needs and may require a unique combination of PAS.

Skilled medical care, which involves personal use items/services, is not required to be furnished by an employer in the workplace per the Rehabilitation Act for Federal employees and the Americans with Disabilities Act (ADA) for non-Federal workers.  At DOT, PAS involving skilled care is provided on a case-by-case basis through the DRC to qualified employees who would otherwise be prevented from performing the essential functions of their position. The DRC recognizes the sensitive nature of these personal services and will discuss any requests for personal care in a private consultation.

The individual who provides PAS is referred to as a Personal Attendant (PA).  Anyone can serve as a PA as long as he or she has been determined by the employee’s manager to be capable of meeting the pre-determined needs of the employee without posing a potential liability to the Department.  A PA is not permitted to act as an official representative on behalf of DOT, its employees, or its contractors.  Under no circumstance is the PA to perform any of the employee’s essential or non-essential duties.  The PA is only able to provide access to otherwise inaccessible aspects of the job or personal care.

If an individual volunteers to provide PAS for his or her co-worker, the manager should seek advice from legal counsel before agreeing to such an arrangement.  Otherwise, DOT could be subject to potential liability (Equal Employment Opportunity Commission (EEOC) ADA Policy Division Guidance October 2002/JAN).  The EEOC recommends that DOT managers take a case-by-case approach and only consider allowing co-workers to voluntarily assist employees with disabilities when DOT does not face potential liability for any injuries that may result and the assistance does not substantially disrupt the workplace.  Assistance with taking off and putting on a coat, as well as carrying items, are examples of services that could be provided by a co-worker.  Before allowing a co-worker to assist with tasks such as chair transfers or administering medications, DOT should ensure that proper training is provided.

Neither the DRC nor a DOT manager is permitted to compensate a family member for the services that are provided in the workplace. {See Section 4.8.2 for a discussion on special circumstances related to invitational travel.)

When an employee with a disability makes a request for PAS as an accommodation in the workplace, the interactive accommodation process is initiated.  If required, a disability determination must be made, an analysis completed, and an Action Plan developed.  If an Action Plan exists for a different type of PA service then what is being asked for or there is a need to make a change to the existing service being provided, then after the analysis has been completed, an Action Plan Addendum will be developed.

The Action Plan/Action Plan Addendum will include frequency, duration and type of tasks to be performed by the PA.  Both the employee and his or her supervisor/decision maker must sign the Action Plan/Action Plan Addendum and return it to the DRC prior to the start of PAS. 

The DRC will order the PAS and provide the employee and supervisor/decision maker with information instructing them on scheduling and canceling services as needed.  The vendor will be provided with:

  • employee’s name and contact information,
  • work site location - name and address,
  • start date,
  • end date if applicable,
  • general schedule of services, and
  • description of tasks to be provided, as agreed upon in the Action Plan/Action Plan Addendum.

In the event that the PAS provider feels that what is being asked by the employee with a disability falls outside of the DOT written contract/agreement or the employee with a disability feels that they are not receiving appropriate services, both parties must immediately contact the DRC.  The DRC will work with the employee, and vendor to resolve the situation.  The supervisor/decision maker may need to be involved in some situations to assist with resolution.

The employee must notify the DRC immediately if there are any changes needed to the services currently in place.  The DRC will work with the employee and his or her supervisor/decision maker to address these changes.  Changes in the type, manner, or frequency of service cannot be made without consultation with and approval of the DRC.

The employee will be asked to acknowledge receipt of the PAS by signing paperwork provided by the vendor describing services provided.  The schedule for this could be daily, weekly, monthly, etc. as established in the contract between DOT and the PAS vendor.  If the employee feels that there is a discrepancy between what is listed on the paperwork and actual services received, they are to notify the DRC immediately.

4.8.1  PAS on Travel (Service Provided Through DRC Contract)

An employee who travels for work and requires the services of a PA is not personally responsible for covering the additional costs incurred as a direct result of the travel.  The DRC will work with the employee and manager to determine whether a PA will be provided enroute with the employee, or whether the service will be provided at the destination only.  The DRC can explore both of these options even if the employee indicates a preference.

The DRC may request justification to determine if the request is reasonable. The EEOC suggests that DOT managers recognize the delicate and intimate work of a PA and not automatically assume that any particular set-up will suffice.

When an employee with a disability makes a new request for PAS as an accommodation while on travel, the interactive process is initiated.  If needed, a disability determination must be made, an analysis completed, and an Action Plan developed.  If an Action Plan exists for a different type of PA service then what is being asked for, then after the analysis has been completed, an Action Plan Addendum will be developed.  Subsequent requests by the same employee will be reviewed for any changes, and if there are any changes, the Action Plan Addendum will be revised accordingly.

The employee must provide the DRC with his or her travel itinerary including:

  • departure date and time,
  • departure city/airport,
  • departure & arrival transportation details (flight number, times train number, etc.).,
  • return date and time,
  • return city/airport,
  • return departure & arrival transportation details (flight number, train number, etc.),
  • hotel name and contact information,
  • numbers of days/nights while on official business travel,
  • description of reason for travel, i.e. conference or meeting name, and
  • general description of needed PA services.

The DRC will order PAS for this specific trip from the contracted vendor.  The vendor will be provided with:

  • employee’s name and contact information,
  • hotel and/or work site name and address,
  • start and end dates,
  • general schedule of services, and
  • services to be performed.

Putting PAS in place for an employee on official government travel requires sufficient lead time prior to the date of travel.  Once the analysis and interactive process has taken place and the services are agreed upon, our current vendor contract allows for five business days to put the services in place.

Once the vendor has confirmed that services are scheduled, the DRC will provide the employee with the vendor’s contact information.  The vendor will contact the employee to discuss the details of the needed services.  The employee is responsible for informing the PAS provider with the details of how and when services are to be performed. 

In the event that the PAS provider feels that what is being asked falls outside of the DOT written contract/agreement or the employee feels that they are not receiving appropriate services, both parties must immediately contact the DRC.  The DRC will work with the employee and vendor to resolve the situation.  The supervisor/decision maker may need to be involved in some situations to assist with resolution.

The employee must notify the DRC immediately if there are any changes to the travel itinerary or the services requested.  The DRC will work with the employee and service provider to address these changes.

The employee will be asked to acknowledge receipt of the services by signing paperwork provided by the vendor describing services provided.  If the employee feels that there is a discrepancy between what is listed on the paperwork and actual services received, they are to notify the DRC immediately.

In some instances, an employee’s own personal PA or a family member who typically assists the employee when at home can be used by an employee as his or her PA for official travel.  See Section 4.8.2  for a discussion of invitational travel.

4.8.2  Invitational Travel for PAS

An employee who travels for work and requires the services of his/her own personal PA is not individually responsible for covering the additional costs incurred as a direct result of the travel.  For example, if the employee typically pays the PA’s salary, DOT is not obligated to do so; however, DOT could be responsible for covering the cost of the PA’s airfare and per diem, which might be reimbursable.

Each trip taken by an employee is considered a unique event and must be carefully considered as to how best to provide the accommodation. For example, one trip might involve a single overnight stay, while another might involve being on travel for several weeks. DRC has the option of exploring whether the appropriate reasonable accommodation is to send the employee’s PA and pay for the travel-related expenses or to arrange for on-site PAS at the travel destination via a pre-established government contract.  A DOT supervisor/decision maker always has the option of exploring with the employee the alternative of arranging for PAS at the destination site, rather than paying for the employee's PA to travel with him/her.  The DRC can explore this option even if the employee's PA is prepared to travel with the employee.  If an employee insists on taking his/her PA on work-related travel, The DRC may request justification to determine if the request is reasonable. The EEOC suggests that DOT supervisors/decision makers recognize the delicate and intimate work of a PA and not automatically assume that any person will suffice.  Therefore the employee with a disability’s choice should be highly considered in making these determinations.

When an employee with a disability makes an initial request for PAS via invitational travel, as an accommodation while on travel, the interactive accommodation process is initiated.  If needed, a disability determination must be made, an analysis completed, and an Action Plan developed.  If an Action Plan exists for a different type of PA service then what is being asked for, then after the analysis has been completed, an Action Plan Addendum will be developed.  Subsequent requests by the same employee will be reviewed for any changes, and if there are any changes, the Action Plan will be revised accordingly.

In some situations it might be determined that PAS would best be provided by a non-contract provider selected by the employee.  An analysis will be conducted by the DRC which examines all options including contract and non-contract services that address the specific task required to be performed for the employee by the PA.

The employee must provide the DRC with their travel itinerary including:

  • departure date and time,
  • departure city/airport,
  • departure & arrival transportation details (flight number, train number, etc.),
  • return date and time,
  • return city/airport,
  • return departure & arrival transportation details (flight number, train number, etc.).
  • hotel name and contact information,
  • numbers of days/nights while on official business travel,
  • description of reason for travel, i.e. conference or meeting name.
  • name and contact information for PA traveling under invitational travel.

When it is determined that the best solution is to have the PAS provided by an individual selected by the employee via the DRC, that PA will only be able to travel with the employee under the OA’s policies, procedures and terms for invitational travel through the DRC.  If the PA incurs any personal, local travel or expenses during the trip (for example, if the PA is given a few hours of free time in the evening), those expenses are not considered reimbursable. GSA travel regulations will also apply. Setting up a person for invitational travel requires 5-10 business days in addition to the 5 business days necessary for making the travel arrangements. 

The PA traveling under invitational travel will be provided with a form requiring them to provide all of the following information:

  • full name of invitational traveler,
  • email address,
  • home address and telephone number,
  • social security number,
  • banking institution routing and account information, and
  • emergency contact information.

The PA must return the completed form to the DRC so that the DRC can work with E-Travel to establish the invitational traveler’s profile in the computerized travel system, GovTrip.  The above information will be used to arrange airfare when needed, pre-approve reimbursable expenses, as well as set up direct deposit of reimbursed funds for previously approved expenses incurred while on travel as a PA for the DOT employee. If the PA identified by the DOT employee is not a U.S. Citizen, the DOT employee is responsible for ensuring that the PA has all documentation of his or her status in order and all required security measures have been taken prior to the DRC processing the invitational travel authorization for the PA.

If the person identified by the employee to provide PAS is a DOT employee and has an existing E-Travel profile, the DRC will work with that employee’s OA and E-Travel to create a new profile under the DRC for the purpose of this trip while he or she is acting as a PA for an employee with a disability.  This is necessary so that DRC can cover the approved travel expenses via the WCF.  This process can take a minimum of 10 business days to complete.  The DOT employee who will act as a PA will be instructed that he/she will have to adhere to the policies and restrictions of the DRC/OST travel guidelines.

Once the PA’s profile has been created under the E-Travel system or existing profile has been moved to the DRC’s account, the DRC will be notified by the E-Travel system.  The DRC will now be able to initiate the travel authorization process.  This involves making airfare arrangements if necessary, estimating the cost of per diem, and any other expense deemed necessary during the analysis process.  At this point, the PA’s invitation travel authorization must be approved by the four levels of approving agents as determined by the process for utilizing WCFs.  Five business days must be allowed for this part of the process.

Once the approval process has been completed, the DRC will forward all travel itineraries to both the employee and the PA.  If any changes are made to the travel plans, the employee must notify the DRC immediately.

Upon completion of the travel, the DRC must be informed of the trip’s conclusion and receipts must be provided for pre-approved expenses, as approved prior to the trip.  The DRC will prepare for the PA the travel voucher for reimbursement of all pre-approved expenses.  If any expenses are required that have not been pre-approved, the DRC must be notified immediately to obtain pre-approval or arrange for an alternative solution.  In emergency situations or when the DRC cannot be reached, an explanation and receipts must be provided to the DRC along with any pre-approved expenses. This allows the DRC to follow up with the appropriate action in accordance with procurement, travel policy and procedures, and secured reimbursement if appropriate. 

A copy of the completed voucher will be provided to the PA for his or her review and to obtain the required signature.  This is to confirm/acknowledge that the voucher does not contain any errors.  Any noted errors or problems with the voucher must be brought to the attention of the DRC immediately.  The signed voucher must be returned to the DRC so that approval can be given to reimburse the PA via direct deposit to the PA’s listed financial institution.

4.8.3  Security Escorts for Personal Assistance Service Providers

While security policies vary somewhat from one building to another, in general DOT security policy requires that visitors be escorted by the person they are visiting at all times. The person who “signs for” the visitor at the guard desk is responsible for that visitor at all times until the visitor leaves.

The DRC does not provide the escort for Personal Attendants who are here to provide service to DOT employees. Escorting the service provider is the responsibility of the person who requests the service. If the person requesting the service is unable to escort the vendor or arrange for an escort, the employee cannot receive the accommodation he or she needs from the agency.

Because there are frequent occasions when the contact person provided does not answer the telephone when the guard desk calls, the DRC requires two alternate contacts for each service request. Please ensure that the contacts you are providing will be available to answer the phone when the service provider arrives and can escort the provider to the location of the event. It is not possible for the DRC to provide an escort for your service providers. You also should not assume that the service provider will have a contractor badge.

4.9 Reader Services

The DRC will provide readers for Blind, Low Vision, and learning-disabled (LD) employees and applicants for access to hardcopy materials that are not available electronically or can be otherwise scanned and are not available in any other accessible format with or without the use of assistive technology.  The DRC will provide readers for day-to-day responsibilities as well as special projects and events.  However, Blind, Low Vision, and LD employees are encouraged to request electronic/alternative format media when registering for special projects, programs and/or trainings.  The DRC will provide readers for training courses attended by DOT employees if the training vendor does not provide the needed accommodation or alternative media.

The DRC provides readers as a reasonable accommodation to DOT employees and job applicants with visual and LD.  There is no additional charge to OAs for this service.

Due to the limitations of our current contract with the Reading Services vendor, the primary responsibility of a Reader is to read material that is otherwise inaccessible.  If requesting DOT employees need additional assistance or have needs beyond basic reading, they should contact the DRC for further assistance.  Requests for additional services will be handled on a case-by-case basis.

4.9.1 Scope of Reader Services

A reader can be billed for a minimum of two hours per session, with a maximum of three hours per day and six hours per week. Exceptions to time limits must be requested and pre-approved by the DRC in writing, as part of the interactive process.  All requests for readers from the DRC will be provided on a first-come, first-served basis.  Five business days notice is requested whenever possible.  This notice enables the DRC to seek and pay for the services of another vendor if the current DRC reading service provider is unable to meet the need.  If a reader is not available, the DRC staff will attempt to procure services through another vendor if the request is made in a timely manner.  However, if multiple requests for the same time slot cannot be accommodated, the first-come, first-served rule will apply. 

4.9.2 Requesting Reader Services as a Reasonable Accommodation

When an employee with a disability is in need of Reader services as an accommodation, the interactive accommodation process must be engaged.  If needed, a disability determination must be made, an analysis completed, and an Action Plan developed.  If an Action Plan exists for a different type of service then what is being asked for or there is a need to make a change to the existing service being provided, then after the analysis has been completed, an Action Plan Addendum will be developed.

The Action Plan/Action Plan Addendum will include frequency, duration and type of tasks to be performed by the Reader.  Both the employee and their supervisor must sign the Action Plan/Action Plan Addendum and return it to the DRC prior to the start of Reader Services. 

To assist the DRC in providing the most appropriate reader for the assignment, the DRC must be provided with:

  • name of the Blind, Low Vision, or LD employee,
  • describe the nature of the job, project, or event,
  • duration -- include start and end times,
  • location -- include appropriate OA contact for security clearance/escort,
  • description and subject of material(s) to be read.

The DRC will order the Reader services and provide the employee and supervisor/decision maker with information instructing them on scheduling and canceling services as needed.  The vendor will be provided with:

  • employee’s name and contact information,
  • work site name and address,
  • start dates,
  • end date if applicable,
  • general schedule of services, and
  • description of tasks to be provided, as agreed upon in the Action Plan/Action Plan Addendum.

The employee must notify the DRC immediately if there are any changes needed to the services currently in place.  The DRC will work with the employee and their supervisor/decision maker to address these changes.  In no case is the employee, supervisor or DRC staff permitted to commit Federal funds without prior written authorization.

The employee will be asked to acknowledge receipt of the Reader services by signing paperwork provided by the vendor describing services provided.  The schedule for this could be daily, weekly, monthly, etc. as established in the contract between DOT and the Reader service provider.  If the employee feels that there is a discrepancy between what is listed on the paperwork and actual services received, they are to notify the DRC immediately.

Untimely requests are considered to be those made less than five business days prior to the date services are needed.  There is no guarantee that services requested on short notice can be fulfilled.  In the event that DRC readers are unavailable to fulfill the request, the requestor can provided an alternate request date/time. 

The requesting office is responsible for notifying the DRC/Vendor of cancellations at least two business days prior to the scheduled arrival of the reader.  This will allow the DRC to reassign readers to other employees, applicants or events.

In order to assure maximum availability of service, the requesting office is responsible for providing notification of the cancellation as soon as it is known that the service will not be required.

The DRC funds reading services for DOT employees throughout the country on either a one-time basis or to fill a continuing need.  Organizations with a recurring need for services may request the DRC's support in establishing agreements with local reading services.  The Reading Services guidelines outlined in this document also apply to DOT locations throughout the United States.  Because reading services may be difficult to obtain in some areas, we would appreciate as much additional notice as possible.

4.9.3 Limitations of Reader Services

In the event that the Reader service provider feels that what is being asked falls outside of the DOT written contract or the employee feels that they are not receiving appropriate services, both parties must immediately contact the DRC.  The DRC will work with the employee, and vendor to resolve the situation.  The supervisor/decision maker may need to be involved in some situations to assist with resolution.

If an employee requires regular, unscheduled, ad-hoc reader services, he or she should discuss the need with the supervisor/decision maker.  It may be necessary for the employee’s Departmental Office or OA to explore alternatives such as a part-time or full-time contract or Schedule A position to fill the employee’s needs. DRC does not provide staff positions as a reasonable accommodation. See Section 11.7 for more information.

4.9.4  Security Escorts for Reader Services Providers

While security policies vary somewhat from one building to another, in general DOT security policy requires that visitors be escorted by the person they are visiting at all times. The person who “signs for” the visitor at the guard desk is responsible for that visitor at all times until the visitor leaves.

The DRC does not provide the escort for Readers who are here to provide service to DOT employees. Escorting the service provider is the responsibility of the person who requests the service. If the person requesting the service is unable to escort the vendor or arrange for an escort, the employee cannot receive the accommodation he or she needs from the agency.

Because there are frequent occasions when the contact person provided does not answer the telephone when the guard desk calls, DRC requires two alternate contacts for each service request. Please ensure that the contacts you are providing will be available to answer the phone when the service provider arrives and can escort the provider to the location of the event. It is not possible for DRC to provide an escort for your service providers. You also should not assume that the service provider will have a contractor badge.

4.10  Interim Accommodations

When an employee requests a reasonable accommodation that cannot be put in place immediately, an interim accommodation must be established as a temporary measure until the actual accommodation is available.   Some factors that can cause this type of a situation can include but are not limited to availability of the product, procurement and installation process timelines.  An interim accommodation can also be used as a method for an employee to try/evaluate a potential accommodation. 

When a situation requires an interim accommodation, all regulations, policies and procedures that govern a reasonable accommodation must be followed.  The major difference is that the Action Plan documents the terms of the interim accommodation such as the extent and duration of the terms of the interim accommodation.

The employee, his or her supervisor and the DRC will work together to identify a temporary solution that will allow the employee to be successful at completing his/her primary job functions.  The terms and duration of the interim accommodation will be clearly stated in the Action Plan or Action Plan Addendum prepared by the DRC, and the time for which the temporary accommodation is needed will be as short as possible. 

Sometimes the identified interim accommodation might fall outside the scope of what the DRC can provide and it therefore remains the sole responsibility of the employee’s Operating Administration to put in place.  Examples of interim accommodations typically out of DRC’s scope can include but are not limited to:

  • Temporary reassignment of job duties.
  • Change in job or task expectations.
  • Establishing a partnership between the employee needing the accommodation and a co-worker to accomplish the task jointly.

Since these types of accommodations are outside of the authority of the DRC, the supervisor/decision maker will need to decide the feasibility of putting such changes in place and is advised to consult their Departmental Office’s or Operating Administration’s Human Resources and/or Civil Rights Office. 

In the event that the employee and/or the supervisor/decision maker find that the interim accommodation is not working, then the interactive process is re-engaged to find a new solution.  It is important to remember that interim accommodations are governed by the same regulations, policies, and procedures as reasonable accommodations.  Interim accommodations are not provided in lieu of decisions and determinations required by the DOT Order.

4.11 When a Decision Maker disagrees with the DRC

When a supervisor/decision maker disagrees with the DRC’s recommendation, the supervisor/decision maker can elect to purchase the desired items with funds from his/her OSTs/OAs budget.  The  DRC can provide information to the supervisor/decision maker on the pros and cons of making this choice.


Footnotes

For information on confidentiality as it pertains to the reasonable accommodation process, see DOT Order 1011.1, “U.S. Department of Transportation Procedures for Processing Reasonable Accommodation Requests by Employees and Applicants with Disabilities,” Section 6-4.

See DOT Order 1011.1, “U.S. Department of Transportation Procedures for Processing Reasonable Accommodation Requests by Employees and Applicants with Disabilities,” Section 4-4.

A person with a disability is generally defined as an individual who (1) has a physical or mental impairment that substantially limits one or more "major life activities," (2) has a record of such an impairment, or (3) is regarded as having such an impairment. Rehabilitation Act of 1973, as amended; 29 U.S.C. 791 et seq., Americans with Disabilities Act of 1990, 42 U.S.C. 12101 et seq, Americans with Disabilities Act Amendments Act of 2008, 42 U.S.C. §12102 et seq.

See DOT Order 1011.1, “U.S. Department of Transportation Procedures for Processing Reasonable Accommodation Requests by Employees and Applicants with Disabilities,” Section 6-1.

Transferred equipment is the responsibility of the receiving Operating Administration and should be managed in accordance with the OA’s property management policies.

9 Additional fees may be incurred when the CART is displayed on a large screen, as per industry standard charges.

Updated: Monday, July 9, 2012