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April 25, 2008
Disability & Reasonable Accommodations: 3 Easy Steps to Establishing &
Implementing a Reasonable Accommodation Policy
I’ve
worked with a large number of One-Stop or workforce development agencies across
the State of California. As part of the technical assistance and training we
provide, I often engage staff in a conversation around the agency’s Reasonable
Accommodation Policy. I’m often surprised at the number of staff that are
either unaware of whether they actually have a policy (all should) or what
exactly the policy says.
I say that all should because it is a requirement under Workforce Investment Act
(WIA) Section 188 as well as other disability-related laws that apply to
federally funded programs.
If you’re unsure if you need a policy, a good
question to answer is whether or not your agency or business is required to
provide reasonable accommodations under the American’s with Disabilities Act or
the Fair Employment Housing Act (CA Only). If you are, then you should have a
policy, and this applies to you.
Now, we
all know if you haven’t had to use certain information, what often happens is
that you hear it once, you store the information away somewhere, and you move on
to issues that are more pressing. If you don’t use it, you lose it. Right?
As a good
rule of thumb, I’d like to suggest the following 3 strategies around
establishing and implementing a reasonable accommodation policy…and I’m
saying this from the perspective of a consultant who has seen what can happen
when you don’t do these things.
First,
locate your policy. As I mentioned before, most of you will find that you
do have one. If the policy is more than two years old, review it for accuracy
and make sure that the contact information and instructions still make sense.
With staff turnover or restructure, you may need to update your policy to
reflect those important changes.
Next, get
your staff together and share and discuss the policy with everyone.
Interestingly, I’ve found that for some reason, the person who answers the
phones or sits at the front desk isn’t included in the everyone. In a
Secret Shopper survey we conducted of a local workforce investment area,
excluding administrative staff in this discussion led to a significant amount of
misinformation going to the public. These are your gatekeepers! If anyone
needs to be trained on your policies and procedures, it’s the person or persons
who interact most with your customers or the public. Include them in the
review, and ensure they know how to respond to questions as they arise.
Lastly, be
sure to put a 20 minute placeholder for policy review on your staff
meeting agenda every quarter. With the hiring of new staff and the many other
things that fill your days, a review of the information will make sure that
everyone is on the same page. This will lead to less misinformation going to
your customers, and ultimately help you to avoid any potential misunderstandings
with the people you serve.
Would you like to reprint this article?
You may as long as you include this blurb in its entirety:
Lisa Jordan
is a disability and workforce development expert. Lisa uses her keen ability to
identify challenges and develop solutions so
that workforce development professionals can increase their comfort level,
productivity and effectiveness when working with a diverse clientele. Download
Lisa’s White Paper on 5 Easy Disability Tips to Immediately Increase Agency
Accessibility by visiting
www.human-solutions.net.
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