Requiring Federal Agencies To Establish Procedures To Facilitate the Provision of Reasonable Accommodation

This executive order requires all federal agencies to establish written procedures for processing reasonable accommodation requests from employees and applicants with disabilities, with specific requirements for timelines, medical information handling, and dispute resolution. The EEOC must issue implementation guidance within 90 days, and agencies must submit their procedures to the EEOC within one year.

Federal Register Open PDF 65 FR 46565

Impact dates

Jul 26, 2001
Agencies submit reasonable accommodation procedures to EEOC
Oct 24, 2000
EEOC issues implementation guidance

Key directives

Each federal agency shall establish effective written procedures for processing reasonable accommodation requests
Procedures must include 10 specified elements covering initiation, processing, timelines, medical information, reassignment, written denials, recordkeeping, and dispute resolution
EEOC shall issue implementation guidance within 90 days
Each agency shall submit its procedures to EEOC within 1 year
Agencies must submit modifications to EEOC when adopted
Agencies must honor collective bargaining obligations when adopting procedures

Who is ordered

EEOC Chair · EEOC

Timeline

Immediate

EO takes effect; agencies must begin developing written procedures

Near term (90d)

EEOC must issue implementation guidance by October 24, 2000

Long term

Agencies must submit procedures to EEOC by July 26, 2001; ongoing compliance and recordkeeping obligations

Risks & tensions

No enforcement mechanism for non-compliant agencies beyond EEOC oversight
Section 5(b) explicitly disclaims creating enforceable rights, limiting judicial recourse
'As short as reasonably possible' timeline requirement (Sec. 1(b)(3)) is vague and agency-discretionary
Potential tension between agency medical review rights and employee privacy protections