Federal Employee Reasonable Accommodation: Process and Denials

If you work for the federal government and a disability is making some part of your job harder than it should be, you have the right to ask for a reasonable accommodation under Section 501 of the Rehabilitation Act of 1973.¹ A reasonable accommodation for a federal employee is any change to the job, the work environment, or the way things are normally done that lets you perform your work despite a disability. You can ask verbally, you don’t need a specific form, and the request itself starts a process your agency is legally required to engage in.

Who Qualifies

Two things have to be true. First, you must have a disability: a physical or mental condition that substantially limits a major life activity such as walking, breathing, concentrating, or working.² The ADA Amendments Act of 2008 broadened this definition considerably, so conditions that once fell in a gray area often qualify today. A record of a past disability, such as cancer in remission, also counts.³

Second, you must be qualified for your job. You have the skills, education, and experience the position requires, and you can perform its essential functions with or without accommodation. Essential functions are the core duties the position exists to accomplish, not every peripheral task listed in a position description.

What Counts as an Accommodation

Federal regulations list several recognized categories, and agencies should treat them as a floor rather than a ceiling.³ Common options include:

Modified work schedules, such as adjusted start and end times, compressed workweeks, or additional break time for medical needs.
Physical workspace changes, including accessible desks, ergonomic furniture, or relocation to a more accessible office.
Equipment and technology like screen readers, voice recognition software, amplified phones, or other assistive devices.
Policy adjustments, including modified attendance policies, permission to bring a service animal, or changes to how training or testing is administered.
Job restructuring that redistributes non-essential tasks to other employees so you can focus on core functions.
Telework when your disability makes commuting or being in the office difficult.
Reassignment to a vacant position you’re qualified for when no other accommodation will work in your current role.

Any modification that removes the barrier between your disability and your ability to do your job can qualify, as long as it doesn’t create an undue hardship for the agency.

How to Make the Request

You can ask at any time and you can do it verbally. You don’t have to submit a written request, fill out a specific form, or even use the phrase “reasonable accommodation.” All you need to do is tell your employer that you need a change at work because of a medical condition.⁴ You also don’t have to know what accommodation you want before you ask.⁵

Putting the request in writing is still smart. It establishes the date and what you said, which matters if a dispute develops later. Direct it to your supervisor, the agency’s Disability Program Manager, a Reasonable Accommodation Coordinator, or whoever your agency has designated to handle these requests. Many agencies also run online intake portals; check your Human Resources or Equal Employment Opportunity page for specifics.

Executive Order 13164 requires every agency to have written procedures for processing requests, including a designated timeframe for granting or denying them.⁶ The EEOC doesn’t set a single government-wide deadline, but it directs agencies to keep processing “as short as reasonably possible.”⁷ Ask your accommodation coordinator what the internal timeline is so you know what to expect.

Medical Documentation and Privacy

Your agency can ask for medical documentation, but only when neither the disability nor the need for accommodation is obvious. If you use a wheelchair and request an accessible parking space, no doctor’s note is required; both facts speak for themselves. When documentation is warranted, the agency can ask only for information tied to the specific disability and the specific accommodation you’ve requested, not your complete medical history.⁴

A vague note confirming a diagnosis usually won’t be enough. Useful medical evidence connects the dots: it identifies your condition, explains what it limits, and describes how the requested change would help you perform your job. If the initial documentation is unclear, the agency can request more detail or arrange a review by a doctor of its choosing at agency expense.⁶

Whatever the agency collects has to be stored separately from your official personnel records and treated as confidential. Only a narrow group can access it: your supervisor may be told about necessary work restrictions and accommodations, first aid personnel may be informed when your condition could require emergency treatment, and officials investigating compliance may review it.⁸ Coworkers have no right to this information.

The Interactive Process

Once you ask, federal regulations require the agency to engage in an informal, interactive process to figure out what will actually work.³ In practice, that’s a back-and-forth conversation about your limitations, the barriers in your workplace, and the accommodations that could remove them. Both sides share responsibility for keeping it moving.

Before the conversation, think through the essential functions of your job and identify which ones your disability makes difficult. Review your position description, but don’t rely on it alone; the day-to-day reality of the role usually matters more than a document drafted years ago. When you can name the specific barrier, you can propose targeted solutions, which tends to speed things up.

The agency isn’t required to give you the exact accommodation you asked for. If it can offer an alternative that’s equally effective, it can choose that alternative.⁹ Stay engaged. If you refuse to participate, stop responding, or won’t provide information the agency reasonably needs, the agency may deny the request.

Telework as an Accommodation

Telework is one of the most commonly requested accommodations and one of the most contested as agencies push employees back to the office. In 2026, the EEOC and OPM issued joint guidance reminding agencies that return-to-office directives do not override their obligations under the Rehabilitation Act.¹⁰ Each telework request still gets an individualized assessment, not a blanket denial.

Telework is not automatic, though. Like any accommodation, it has to serve a recognized purpose: enabling you to participate in the application process, to perform essential job functions, or to enjoy equal access to workplace benefits. If the agency can show that an in-office alternative would be equally effective, it can choose that alternative. And if the telework you want would primarily serve personal convenience rather than address a specific limitation caused by your disability, the agency can deny it.⁹ What the agency cannot do is skip the interactive process by pointing to a general return-to-office policy.

Reassignment When Nothing Else Works

When no accommodation will let you perform the essential functions of your current job, the agency has to consider transferring you to a vacant position you’re qualified for. Reassignment is a recognized form of reasonable accommodation, but it’s the option of last resort; other possibilities in your current role should be exhausted first.⁴

The agency doesn’t have to create a new position or remove another employee to open one. The position must already be vacant or expected to be within a reasonable timeframe. If you meet the qualifications, though, the agency must give it to you; you don’t compete against other applicants. The agency also isn’t required to promote you through reassignment. The new position can be equivalent to or lower than your current grade.

Section 501 regulations require federal agencies to spell out in their reasonable accommodation procedures how supervisors search for available vacancies.⁵ If nobody has told you what’s available, ask. Identifying possible positions is a shared responsibility.

When the Agency Can Say No

An agency can deny a request if granting it would cause undue hardship, meaning significant difficulty or expense. The analysis looks at the cost of the accommodation and any outside funding or tax credits that could offset it, the financial resources of the specific facility involved, the size and resources of the overall agency, and the impact on operations, including whether the accommodation would interfere with other employees’ work or the agency’s mission.¹¹

For a federal agency this is a high bar. The entire federal government’s resources can come into the analysis, so cost alone rarely justifies a denial. Minor expense or slight inconvenience is not enough; the agency has to show genuinely significant difficulty.¹² When an agency does deny a request, Executive Order 13164 requires the denial to be in writing with the reasons explained.⁶

One boundary catches people off guard. If the accommodation you need conflicts with an established seniority system, such as a shift assignment that would bump a more senior employee, the Supreme Court has ruled that the conflict ordinarily makes the accommodation unreasonable as a matter of law. You can overcome that presumption by showing special circumstances, but the burden falls on you.¹³

If Your Request Is Denied

A denial is not the end. Agencies are encouraged to offer informal dispute resolution so you can get a quick second look without filing a formal complaint.⁶ Check your agency’s reasonable accommodation procedures; many include a built-in reconsideration process.

If that doesn’t resolve things, you can file a formal EEO complaint, and the deadlines are strict. You must contact an EEO Counselor at your agency within 45 days of the denial. The counselor will offer you a choice between informal counseling and alternative dispute resolution such as mediation. If neither resolves it, you can file a formal discrimination complaint with your agency’s EEO office within 15 days of receiving notice from your counselor about how to proceed.¹⁴

The 45-day clock is the one that trips people up. It starts the day the discrimination occurred, meaning the day your accommodation was denied, and missing it can forfeit your right to file. Mark the date the moment you get a written denial. Don’t wait to see whether the situation sorts itself out.

Retaliation Is Prohibited

Federal law bars your agency from punishing you for requesting a reasonable accommodation or participating in the accommodation process. Retaliation can look like a poor performance review timed suspiciously close to your request, reassignment to undesirable duties, exclusion from projects, or outright discipline. If you experience an adverse action that appears connected to your request, you can file a retaliation complaint through the same EEO process, subject to the same 45-day deadline for contacting a counselor.¹⁴ The protection exists so the request itself is safe, whether or not the accommodation is ultimately granted.

1
U.S. Equal Employment Opportunity Commission. Employment Protections Under the Rehabilitation Act of 1973
2
Congress.gov. Public Law 110-325 – ADA Amendments Act of 2008
3
eCFR. 29 CFR 1630.2 – Definitions
4
U.S. Equal Employment Opportunity Commission. Enforcement Guidance on Reasonable Accommodation and Undue Hardship under the ADA
5
eCFR. 29 CFR 1614.203 – Rehabilitation Act
6
U.S. Equal Employment Opportunity Commission. Policy Guidance on Executive Order 13164 – Establishing Procedures to Facilitate the Provision of Reasonable Accommodation
7
U.S. Equal Employment Opportunity Commission. Questions and Answers – Policy Guidance on Executive Order 13164
8
eCFR. 29 CFR 1630.14 – Medical Examinations and Inquiries Specifically Permitted
9
U.S. Equal Employment Opportunity Commission. Frequently Asked Questions from the Federal Sector about Telework Accommodations for Disabilities
10
U.S. Equal Employment Opportunity Commission. EEOC and OPM Issue FAQs on Federal Sector Telework to Accommodate Disabilities
11
Office of the Law Revision Counsel. 42 USC 12111 – Definitions
12
eCFR. 29 CFR Part 1630 – Regulations to Implement the Equal Employment Provisions of the Americans with Disabilities Act
13
Justia. US Airways Inc v Barnett – 535 US 391 (2002)
14
U.S. Equal Employment Opportunity Commission. Overview of Federal Sector EEO Complaint Process