Requesting Reasonable Accommodation at the CFPB

Do you have certain health issues, underlying medical conditions, and/or disabilities that put you at a higher risk of serious illness or death from catching Covid? Are you immunocompromised? Are you also 50+? You may want to consider requesting a Reasonable Accommodation to protect yourself from exposure to Covid in the CFPB workplace – to include exposure during any commute to and from the office via public transportation, or during official travel.

Not everyone may be eligible for a Reasonable Accommodation (RA). Please refer to the CFPB Reasonable Accommodations Policy.

Step One: Prepare Yourself

• Prepare yourself by reviewing CFPB’s Reasonable Accommodation Forms and creating a list of your concerns and issues before making an appointment with your healthcare provider. You and your medical provider will need to show a compelling proof of conditions and/or disabilities to support your case for an RA.
• Think about what reasonable accommodations you would want to request.
• Here are some medical conditions to consider:
  • https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/people-with-medical-conditions.html
  • https://www.cdc.gov/coronavirus/2019-ncov/hcp/clinical-care/underlyingconditions.html
• Have you already recovered from Covid once? Are you experiencing Long Covid side effects?
• You may also be at a higher level of risk due to your age (50+) and a combination of your health and medical conditions, and/or the fact that you have already recovered from a previous case of Covid. 
• Remember, a reasonable accommodation is not always exactly what you have asked for, but what is considered “reasonable”. Accommodations are considered “reasonable” if they do not create an undue hardship to the Bureau. For more information, please refer to https://www.eeoc.gov/laws/guidance/enforcement-guidance-reasonable-accommodation-and-undue-hardship-under-ada
• Still have questions about reasonable accommodations and your particular core duties and support needs? Ask JAN - The Job Accommodation Network (JAN) is a great resource for all employees. JAN is run under a grant from the Office of Disability Employment Policy (ODEP) under the Department of Labor. JAN is available as a resource to all employees in America, not just Federal Employees. https://askjan.org/
• Make an appointment with your medical provider. Let your medical provider know that your appointment is to discuss a workplace reasonable accommodation due to your medical conditions and your workplace Covid exposure concerns. Bring your notes and the CFPB RA Forms with you to your appointment.

Step Two: Talk to your Healthcare Provider

• Discuss your medical conditions and concerns with your health care provider at your appointment, and have them highlight with you any condition or combination of conditions that put you at a higher risk of complications or death if you should be exposed to Covid in the workplace.
• With your healthcare provider, fill the forms out, and have them provide a statement regarding your health conditions (with all diagnoses) and your high risk due to these conditions should you contract Covid. If you are 50 and older, or are immunocompromised, ensure that these facts are part of the statement. Include the suggested reasonable accommodation (s) – max telework, parking at HQ so you do not need to take public transport, unscheduled telework, flexible work schedules, limited to no work travel, etc. 
• Have your medical provider print this statement on their letterhead, date, and sign.
• Have your medical provider fill out the forms for you, date, and sign.

Step Three: Contact the CFPB Reasonable Accommodations (RA) Team 

• As of March 2022, the Reasonable Accommodations office (RA) at CFPB is seated under OMWI/Director’s Office.
• Email [email protected] and initiate a request for a Reasonable Accommodation. Simply state that you are looking to request a Reasonable Accommodation and would like to start the process. They will return your email with instructions on how to submit your request.
• You have already met with your medical provider and completed the CFPB RA request forms and all necessary medical documentation - email these as attachments back to the CFPB RA Office.
• The CFPB RA Office can answer any additional questions you may have about the CFPB RA process. 

Step Four: 

• Participate in ongoing communication with the CFPB RA Office and other applicable parties regarding your request. The CFPB RA Office has 30 days to take action on your request once you have contacted them and initiated the process.
• You do not have to share any of this information with your Supervisor or Managers. Only the CFPB RA Office have access to your detailed medical documentation. 

Denied? 

If your request is denied, you should receive feedback from the CFPB RA Office to include a Denial of a Reasonable Accommodation Request Form. You can bring this information back to your medical providers for consult and review/adjust your information if possible and resubmit your RA request. You should also contact your Union steward ASAP and copy them on the denial and your resubmission, to request a grievance, which must be filed within 20 working days of the denial. You can resubmit your request as many times as you need after any denial.

Remember, not everyone is eligible for a reasonable accommodation. However, a large majority of Americans do fall under the umbrella of underlying conditions that make contracting Covid a higher risk.

For more information and resources on the Coronavirus global pandemic, vaccines, testing and more, go to Covid.gov