Best Practices

Reasonable Accommodation Policy

Rain Khoo, Jan 2024

A Reasonable Accommodation (RA) policy enhances inclusivity by ensuring employees with disabilities have equal opportunities. The median one-time cost of accommodations is modest at US$300 (US data, 2019-2022), but employer attitudes are often the main barrier. Employers with experience in hiring individuals with disabilities generally have more positive views towards disability hiring and providing RA.

Implementing a RA policy is key to reducing discrimination risks and promoting a fair work environment. Additionally, it supports legal compliance in countries such as in Japan and South Korea, where considering RA requests is a legal requirement.

Our recommended practices align with the principles set forth by the United Nations Department of Economic and Social Affairs (2011), emphasising the need for the inclusion of Persons with Disabilities (PwDs) in all aspects of our Policy.

• Accountability: The policy should be held accountable to PwDs. It should involve your employees with disabilities actively in policy formation and incorporate mechanisms for feedback. Additionally, we collaborate with leaders from the disability community in our RA policy consultancy, to ensure best practices.

• Overcome Stigma: Stereotypes and stigmatisation significantly hinder disability inclusion. Executive support and awareness training for HR and managers are essential to foster positive attitudes toward disability. Creating an inclusive culture with high psychological safety is critical, enabling employees to disclose their disabilities without fear of discrimination. The RA Policy should be integrated into the company’s comprehensive framework for facilitating disability employment.

• Capability Location: Implementing a centralised accommodation system is considered a best practice. Some companies empower the disability Employee Resource Group as their centralised system. This approach streamlines the process, making it more efficient and ensuring the team or coordinator has the necessary expertise and oversight over funds for RAs. The roles and responsibilities of RA coordinators should be clearly defined. Separate SOPs are required for processing, record keeping and reporting. Coordinators may need to be further supported by external experts and internal staff.environment benefits not only the individuals but the organization as a whole.
• Communication: Information on RA should be available in multiple locations and easily accessible. Contacts of RA coordinators should be included.
• Confidentiality: The policy stresses the importance of maintaining the confidentiality of medical information provided by employees. There are self-identification reassurances and different avenues for employees to contact the RA Coordinator.

RA processes should include the following:

• Multimodal Accessibility: Employees can request accommodations either verbally or in writing. Online request forms should be designed to be screen-reader friendly and simple, catering to various cognitive abilities. The language used in these forms should be easily understandable, and they should include helpful reminders about supporting employees with these arrangements.
• Timeframe: The timeline for approvals and fulfilment of the RA should be stated.
• Verification of Disability: States when documentation or further supporting documentation is needed, and when it is inappropriate.
• Range of accommodation: Provides examples of RAs, and what is out of scope.
• Appropriateness: The processes for RA should be replicable to all markets. Clear criteria for what constitutes a reasonable accommodation related to essential job functions.
• Handling Denials: Provides guidance on how to handle situations where accommodation requests are denied.
• Exception handling: Considers reassignment as a last resort when no other accommodation is possible. Provides a process for employees to appeal decisions.
• Interactive Process: Policy emphasises the importance of ongoing communication between the employee, people manager, and RA coordinator for effective accommodation.

Governance

• Outline the composition of the Council or Committee that is responsible for the policy; how senior management, leaders of business units or independent consultants are involved;
• Define the roles and responsibility of the RA Coordinator, HR, people managers and all employees; 
• State commitment to compliance with all relevant anti-discrimination laws and RA regulations;
• Process for changes to policy;
• Include standard details such as applicability, last review dates, effective date, policy owner, policy approver, policy version (if relevant).

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^[i] Job Accommodation Network, https://askjan.org/topics/costs.cfm

^[ii] Kim L. MacDonald-Wilson, Ellen S. Fabian and Shengli Dong, 2008. “Best Practices in Developing Reasonable Accommodations in the Workplace: Findings Based on the Research Literature”, in The Rehabilitation Professional 16 (4) pp. 221-232.

^[iii] Office of Federal Contract Compliance Programs, US Department of Labor “Best Practices,Creating an Inclusive Workforce”.

Dignitea works on embedding D&I into the organisation through integrating D&I into every aspect of the employee lifecycle, from hiring to development and retention, and in every single touchpoint from processes to policies.