Saint Paul College Policies & Procedures

01.05.00.1 - Reasonable Accommodations in Employment Procedure

​Existing Staff:

  1. The Americans with Disabilities Act (ADA) Coordinator for Saint Paul College employees is Rachelle Schmidt, Chief Human Resources Officer, (651) 846-1348. The TTY number for the College is 651-846-1371.
  2. An employee shall inform his/her manager or supervisor of the need for an accommodation.
  3. Documentation of a disability is required as part of the reasonable accommodation process unless the nature and extent of the disability is already known to the employer, or as a practical matter, the requested accommodation is minimal and the employer makes modifications for its convenience, regardless of whether the employee or applicant meets the requirements for a reasonable accommodation under this procedure. 

    Any medical documentation will be collected and maintained on separate forms and in separate files. Supervisors and managers may be told about necessary restrictions on the work or duties of the employee and about necessary accommodations. Supervisors and managers will not be told or have access to medical information unless the disability might require emergency treatment.
  4. When a qualified disabled person has requested an accommodation, the employer shall, in consultation with the individual:
    1. Discuss the purpose and essential functions of the particular job involved (completion of a step-by-step job analysis may be necessary);
    2. Determine the precise job-related limitation;
    3. Identify the potential accommodations and assess the effectiveness each would have in allowing the individual to perform the essential functions of the job; and
    4. Select and implement the accommodation that is the most appropriate for both the individual and the employer. While an individual’s preference will be given consideration, the College is free to choose among equally effective accommodations and may choose the one that is less expensive or easier to provide.
  5. The College’s ADA Coordinator will work with the supervisor and employee to obtain technical assistance, as needed.
  6. If the Manager/Supervisor is unable to make a definitive decision, for whatever reason, about providing the accommodation, the Manager/Supervisor will forward a written request for accommodation, along with his/her recommendations, to the College ADA Coordinator within five (5) working days following the receipt of the employee’s request.
  7. If the ADA Coordinator is unable to make a definitive decision about providing the accommodation, the ADA Coordinator will forward a written request; along with his/her recommendations to the President within ten (10) working days from the date the request was received from the Manager/Supervisor.
  8. The President of the College will provide a decision in writing to the ADA Coordinator and employee within ten (10) working days.
  9. If an accommodation cannot overcome the existing barriers or if the accommodation would cause an undue hardship on the operation of the business, the employee and the ADA Coordinator shall work together to determine whether reassignment may be an appropriate accommodation.

    The ADA Coordinator shall first look for a vacant position in the College equivalent to the one presently held by the employee in terms of pay and other job status. If the disabled person is not qualified, with or without reasonable accommodation, for a vacant position (or a position the College knows will become vacant within a reasonable period of time) the College may reassign the individual as a reasonable accommodation to a lower graded vacant position for which the employee is qualified. If this occurs, the College is not required to maintain the individual’s salary at the previous level. The College will look at transfer opportunities, mobility opportunities, appointment opportunities, noncompetitive and competitive opportunities (M.S. 43A). The College is not required to create a new job or to bump another employee from a job in order to provide a reassignment as a reasonable accommodation.
  10. If a request for accommodation is not approved, the College President, or designee, shall inform the employee of the reason(s) for non-approval, in writing, within three (3) working days of the decision.

Procedure - Job Application

  1. The College shall notify all applicants of this accommodation policy using accessible formats.
  2. When a request for accommodation is received from an applicant, the supervisor/Human Resource Office will discuss the needed accommodation and discuss possible alternatives with the applicant.
  3. The supervisor/Human Resource Office will make a decision regarding the request for accommodation and, if approved, take the necessary steps to see that the accommodation is provided.
  4. If the supervisor/Human Resource Office is unable to make a definitive decision, for whatever reason, about providing the accommodation, the supervisor/Human Resource Officer will forward a written request for accommodation, along with his/her recommendations to the ADA Coordinator within three (3) working days following the applicant’s request, except in cases where the supervisor/Human Resource Officer is also the ADA Coordinator.
  5. If approved, the ADA Coordinator shall take the necessary steps to see that the accommodation is provided. If the accommodation is not approved, the ADA Coordinator will inform the applicant the reason for non-approval, in writing, within three (3) working days of the decision.

Policy for Funding Accommodations

Funding must be provided by Saint Paul College for accommodations, which do not cause an undue hardship (M.S. 43A.191(c)).

An undue hardship is an action that is unduly costly, extensive, substantial, or disruptive, or that would fundamentally alter the nature or operation of the College.

The ADA Coordinator, in consultation with the Minnesota State System Office, will determine undue hardship by considering the nature and cost of the accommodation in relation to the size, the financial resources, the nature and structure of the College’s operation, and the impact of the accommodation on the nature or operation of the particular College.

If the ADA Coordinator considers the accommodation will impose an undue hardship, the ADA Coordinator will forward an undue hardship analysis and recommendation to the President of the College within ten (10) working days following the employee request or within three (3) working days following the applicant request.

The President of the College will provide a decision in writing to the ADA Coordinator, supervisor, and employee within ten (10) working days or applicant within three (3) working days.


Reference

Review Date

-

Policy Status

Approved

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