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The Digital Accessibility Maturity Model: DAMM-HR Dimension #2 – Reasonable Accommodations

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In the last post in the Digital Accessibility Maturity Model (DAMM) Series I discussed Dimension #1 of DAMM-HR – Recruiting and Job Application.  In this post I’ll cover the second dimension of DAMM-HR – Reasonable Accommodations – which measures the extent to which the organization has a defined process in place for implementing accommodations in the workplace and job application process, and other changes need to address internal systems that are inaccessible.

Aspects

  • Reasonable Accommodations Analysis Process – The level of maturity associated with analyzing reasonable accommodations requests.
  • Reasonable Accommodations Issue Resolution – Organizational maturity regarding the handling of reasonable accommodations issues. This includes ensuring accessibility issues are identified and escalated on an appropriate basis. This aspect requires a defined process for job applications to contact the organization about accessibility bugs and those issues to be addressed and resolved in a timely fashion.
  • Accessible Documentation – Organizational maturity in providing accessible documentation to job applicants and employees. Includes both native provisioning of accessible electronic documentation, and the ability to provide alternative formats of that documentation as needed on request.

 Artifacts

  • Reasonable Accommodations Catalog – an internal catalog of standard hardware and software regularly provided to job applicants and employees as reasonable accommodations
  • 503(b) filings – regulatory filings required to comply with Rehabilitation Act Section 503(b) which discusses goals pertaining to hiring persons with disabilities.
  • VEVRAA filings – regulatory filings required to comply with the Vietnam Era Veterans Readjustment Act which discusses goals pertaining to hiring Vietnam era veterans with disabilities.

Maturity Levels

 Level 1 – Initial

  • Minimal processes in place for performing reasonable accommodation analysis or providing reasonable accommodations.
  • Approach to analyzing reasonable accommodation requests is reactive to the situation.
  • Reasonable accommodations that are provided are individually treated as a one-offs with no repeatable underlying process or standards.
  • Reasonable accommodations are not offered to job applicants.
  • HR owns reasonable accommodation requests in their entirety. There is no interaction with other groups, such as the Accessibility Program Office, legal, or other departments which could provide integrated reasonable accommodation request input.
  • There is no centralized budget for reasonable accommodations.
  • There is poor organizational understanding of reasonable accommodation legal requirements.

Level 2 – Managed

  • The reasonable accommodations process is documented, and covers initial requester assessment through to delivery of accommodations.
  • If a reasonable accommodations request is denied, the reason is documented. The requester is offered an appeals process, and may be offered an alternative reasonable accommodation.
  • Reasonable accommodation requests and the outcomes are tracked.
  • A support process is defined for ongoing needs of reasonable accommodation recipients.
  • A list of standard reasonable accommodations exists, is updated on a regular basis, and is made available to employees and job applicants. However, reasonable accommodation requests are not limited to the contents of the catalog.
  • A procurement and implementation process is in place for reasonable accommodations, once approved.

Level 3 – Defined

  • An integrated reasonable accommodations process is defined, documented, and is in regular use in the organization.
  • All staff have been trained on and actively use the reasonable accommodations process. Managers and HR staff receive a more intensive level of training because of their additional responsibilities.
  • A Service Level Agreement (SLA) between the reasonable accommodation recipient and the support organization has been defined and is in effect.
  • There is a well-defined financial model for reasonable accommodations:
    • Requests below a specified financial threshold can be automatically processed at a lower approval level;
    • A centralized budget for reasonable accommodations is in place, and is tied to prospective staffing and job applications; and
    • A process is in place to fund reasonable accommodation requests if the centralized budget is exceeded.
  • The employee on-boarding process includes a consideration of reasonable accommodation needs.
  • Reasonable accommodations stay with the employee/job applicant. This includes movement within the organization, restructuring activities, repeated job applications, etc.
  • Reports on reasonable accommodation requests and their outcomes can be generated.
  • Merits of tools or assistive technology (AT) are evaluated to resolve ICT challenges for employees
  • User satisfaction survey conducted and acted upon.

 Level 4 – Quantitatively Managed

  • Performance data, metrics, and trending data for reasonable accommodations are reviewed on a regular basis.
  • Monitoring of “planned vs. actual” of the reasonable accommodations SLA occurs, and cases not conforming to the agreement are escalated.
  • Confidential reasonable accommodation user satisfaction survey data are collected and used as the basis for program efficacy analysis.
  • Periodic monitoring of reasonable accommodations are made to evaluate long term effectiveness.
  • Deployed Reasonable Accommodations and issues reported are actively reviewed to see if systemic solutions are needed and improvements can be made.
  • Tools / AT evaluation is coordinated with other departments using AT (development, IT).
  • Reasonable Accommodations feedback is provided to the Accessibility Program Office, financial and budgeting groups, legal, etc.

Level 5 – Optimizing

  • New reasonable accommodation approaches are developed and shared across the industry.
  • Examples of new accommodation approaches can be demonstrated and have been shared.
  • Staff and potential job applicants are actively consulted on and engaged in process improvement plans.

Coming Up

In my next post I’ll discuss the third dimension of DAMM-HR – Staff Evaluations – which measures the extent to which the organization has a defined process in place for evaluating staff competencies with respect to accessibility.

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