Reasonable Accommodation Policy for Employees and Job Applicants

Overview

In compliance with the Americans with Disabilities Act Amendments Acts (ADAAA) of 2008, the Americans with Disabilities Act of 1990 (“ADA”), Sections 504 of the Federal Rehabilitation Act of 1973 (“Rehabilitation Act”), and New York State Executive Law §296, Purchase College provides qualified individuals with disabilities the opportunity to participate in programs, activities, or employment.

Purchase College will not discriminate against any employee or applicant for employment because of physical or mental disability. Additionally, Purchase College agrees to take affirmative action to employ, advance in employment and treat qualified individuals with disabilities without discrimination based upon their physical or mental disability in all employment practices including but not limited to: Advertising, recruitment, employment, upgrading, demotion, transfer, layoff or termination, rates of pay or other forms of compensation, and professional development.

Employees and Applicants

Employees and applicants are protected from coercion, intimidation, retaliation, interference or discrimination for filing a complaint or assisting in an investigation under appropriate federal and state law.

Purchase College’s Americans with Disabilities Act (ADA) Designee for Reasonable Accommodations (DRA) is responsible for ensuring compliance with this policy and data collecting and for record keeping of all employee requests for accommodations.

Students

Students with disabilities who wish to request accommodations should contact Alyssa McCarthy, Director, Office of Disability Resources (914) 251-6035. The Office of Disability Resources is responsible for data collection and record keeping of all student requests for accommodations.

Procedures for Requesting Reasonable Accommodations

Employees or prospective employees/applicants with disabilities (as defined in the ADAAA 2008) may request reasonable accommodation in the workplace, if necessary, to enable them to have access to employment opportunities or to perform duties essential to their job. Such requests may be made regardless of title, salary, salary grade, bargaining unit, or employment status (permanent, temporary, provisional).

Current Employees

• Employees in need of an accommodation (as defined under ADAAA of 2008) should first submit a completed Request for Reasonable Accommodation Form (Section A & B) to their immediate supervisor or the Designee for Reasonable Accommodations (DRA), Ricardo Espinales in the Department of Human Resources. Please contact Ricardo Espinales at (914) 251-6086 or via email at Ricardo.espinales@purchase.edu to obtain copies of the forms.
• If the request is first submitted to the DRA, the DRA will contact the employee’s immediate supervisor for their review and/or approval. If the request is made to the immediate supervisor, the supervisor will either approve the employee’s request or refer the application to the DRA for their assistance in resolving the employee’s request. Regardless of the supervisor’s decision, the supervisor should indicate their decision and sign Section B.
• Requests for reasonable accommodation that are minor in nature can be resolved at the supervisory level. If a determination cannot be made due to the type or complexity of the accommodation or the expenditure involved in providing the accommodation, please speak to your department head or contact the DRA to discuss the issue.
• The employee, the employee’s supervisor and the DRA should engage in an interactive process to determine whether and what type of accommodation would be effective.
• As part of this interactive process, it is important that an employee in confidence advise the supervisor and the DRA precisely how limitations from a disability affect the ability to perform the duties of the position. If the employee knows what type of reasonable accommodation would be helpful, they should advise the supervisor and the DRA.
• The DRA can suggest alternative accommodations and the individual should consider whether they would be effective. The ADA Coordinator does not have to provide the specific accommodation requested, but rather must offer an effective reasonable alternative, unless to do so would create an undue hardship for the institution.
• The DRA will conduct a comprehensive review of the request for accommodation, which may include:
• • Requesting and assessing of medical documentation. If the DRA requires additional documentation, the DRA will ask the applicant to inform their doctor to provide medical documentation to the DRA that identifies the limits of the applicant’s disability and how they would affect the employee’s job performance
  • Meeting with the employee and their immediate supervisor
  • Arranging for a job analysis

Job Applicants

Applicants requesting a Reasonable Accommodation should submit a request to the Department of Human Resources.

Review of Accommodation Decision

Should an employee not agree with the accommodation being provided or if the request for accommodation is denied, and the employee believes the basis of the denial is due, in part, to discrimination the employee may contact the Office of Affirmative Action in accordance with Purchase College’s discrimination complaint procedures.

Recordkeeping

The DRA is responsible for collecting the information on all accommodation requests including the number made and type of accommodation provided to employees. The Affirmative Action Office is responsible for collecting the information on all accommodation requests including the number made and type of accommodation provided to students. All original Requests for Reasonable Accommodation are kept in a separate file within Human Resources.

Confidentiality

Medical records are confidential. Medical documentation submitted or obtained may only be used to evaluate the request for accommodation. Employee medical records shall be secured in a separate and confidential file in the Department of Human Resources. Student medical records shall be secured in a separate and confidential file and maintained in the Office of Student Affairs.