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Suggestions When Submitting Reasonable Accommodation Requests

posted July 23, 2020

The form management has made available for requesting Reasonable Accommodations, if you believe you are at heightened risk of negative health outcomes from COVID-19 exposure, is somewhat limited in the possible risks and circumstances it lists.

For example, DoDEA's form does not list age as a risk factor, despite guidance from the CDC stating that the risk from COVID does increase with age (you'll find that CDC guidance at this page).

FEA recommends members address age issues when filling out their RA requests and include reference to the CDC info in the above link.

Another example of the shortcomings in DoDEA's form is the lack of reference to health of household members as a potential risk factor, despite guidance from OPM telling agencies that "to the extent possible, employers are encouraged to consider telework options for employees with vulnerable household members, until their state or region has entered Phase 3 in accordance with the Guidelines for Opening Up America Again (see item #2 in this link, OPM's FAQs).

In addition, that same OPM link above, in question number 4, states: "For localities where schools are closed, should telework flexibilities continue to be utilized for employees with school-aged children? Yes. Agencies are encouraged to review the full spectrum of available workplace flexibilities, including telework and FWS, to support employees with children and other dependent care obligations."

Factors such as the health of household members and your children's local schools being closed are additional risks/conditions not listed on DoDEA's form that you may consider adding to your application. The narrative statement section of the application form appears to be the best place to do so.

We present these ideas not as legal guidance but as suggestions for additional factors you may wish to include with your request for Reasonable Accommodation. We cannot promise, however, that the inclusion of any of these factors will increase your odds of receiving a Reasonable Accommodation.

DoDEA's RA request form can be found at this page.