The objective of our inspection was to review the U.S. Department of Education’s (Department) administration of its reasonable accommodation program. This included determining whether reasonable accommodation requests were processed timely and in accordance with applicable policies and procedures. We found that improvements are needed in the Department’s processing of reasonable accommodation requests. Specifically, we found that the Department did not always process employee reasonable accommodation requests in accordance with relevant policies and procedures or maintain adequate documentation to allow for a determination of whether it complied with these policies and procedures, including those related to processing timeframes. In addition, we found that the Department did not adequately process applicant reasonable accommodation requests to ensure that accommodations were only provided to applicants with a qualifying disability. We also found that the Department does not have adequate processes to track and report on reasonable accommodation requests. The processes used by the Department do not ensure that all requests are captured, that data specific to the requests is adequately tracked, and that data is properly reported. We also noted issues with the quality of the data included in spreadsheets used by the Department to track and report on reasonable accommodation requests.
Open Recommendations
| Recommendation Number | Significant Recommendation | Recommended Questioned Costs | Recommended Funds for Better Use | Additional Details | |
|---|---|---|---|---|---|
| 1.1 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary update policies and procedures to provide additional clarification to help supervisors and employees work through each step in the reasonable accommodation process, such as clarifying supervisors’ responsibilities when a request is first received, when a medical review officer assessment is requested, when an interim accommodation is provided, when extenuating circumstances or delays exist, and when a decision is made. | |||||
| 1.2 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary require OEEOS management to research reasonable accommodation policies and procedures of other Federal agencies to identify and adopt best practices to improve the clarity, transparency, and efficiency of the Department’s reasonable accommodation policies and procedures. | |||||
| 1.3 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary ensure that reasonable accommodation materials and guidance, including training materials, are readily available and are consistent with Department policies and do not establish additional requirements beyond what is in Department policy. | |||||
| 1.4 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary require OEEOS to hold or offer periodic refreshers or trainings on the reasonable accommodation program in addition to mandatory, online trainings, to encourage the proper handling and processing of reasonable accommodation requests. | |||||
| 1.5 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary establish a formal process for the Department and FSA to coordinate the administration of their respective reasonable accommodation programs, to include ensuring that FSA is aware of Department policy and that any additional program guidance developed by FSA is consistent with Department policy. | |||||
| 1.6 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary ensure Department policy is followed regarding reasonable accommodation requests from applicants, to include determining whether requests are associated with a qualifying disability, and that the Program Manager is not in a decision-making role. | |||||
| 1.7 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary develop an appropriate system for documenting all reasonable accommodation requests in a manner where the documentation is complete, organized, and readily available for examination. | |||||
| 2.1 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary assess whether OEEOS has allocated sufficient resources and assistance to the reasonable accommodation program and make changes as appropriate. | |||||
| 2.2 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary direct the Program Manager to develop and implement a tracking system that includes appropriate data validation checks and captures all of the information the Department is legally required to track and report. | |||||
| 2.3 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary ensure the Program Manager is populating the tracking system with dates that comply with definitions established in policy (e.g., request dates; provision dates). | |||||
| 2.4 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary develop and implement the use of a form that supervisors are required to complete and submit to the Program Manager within a specified timeframe after a reasonable accommodation request is received to assist with ensuring the Program Manager is notified of all requests and captures needed data for tracking and reporting purposes. | |||||
| 2.5 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary coordinate with the Office of the Chief Information Officer to determine whether a process can be established that would allow reasonable accommodation requests for assistive technology submitted through the ServiceNow portal to be designated as such and notifications of such requests to be automatically sent to the Program Manager for tracking and reporting purposes. | |||||
| 2.6 | No | $0 | $0 | ||
| We recommend that the Deputy Secretary ensure the Department’s Program Manager coordinates with the FSA Program Manager to obtain needed data for compiling the annual MD-715 report. | |||||
