Policy Owner: Chief Human Resources Officer
Effective Date: March 8, 2023
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Accommodation Plans
According to the Accessibility for Ontarians with Disabilities Act (AODA), accommodation plans are written documents that list all accommodations workers with disabilities need to make their jobs accessible. For the purpose of this procedure, the individualized accommodation plan will be referred to as the accommodation plan.
It is important to have an individualized accommodation plan to ensure that expectations are understood and accepted by the employee, HR and the manager. The discussion and documentation of accommodation also gives the parties an opportunity to identify any non-medical issues that could affect the success of accommodations and therefore require additional follow-up by HR and/or the manager.
Generally, accommodation plans outline and assign responsibilities and identify next steps.
The Accommodation Plan includes the following information:
- The employee’s name, employee ID, position title and department.
- The limitation or limitations due to the illness, injury and/or disability. The employee’s diagnosis will not be noted in the plan.
- The essential job requirements of the employee’s position.
- The job tasks and activities that will be affected by the limitation or limitations.
- The identified accommodations that will be provided, i.e., The agreed to assistance strategies and resources to meet the essential job requirements, tasks and activities will be listed.
- If requested, information regarding accessible formats and communications supports will be provided.
- If required, individualized workplace emergency response information.
- The person or persons assigned to implement any accommodations and the expected date or dates of implementation.
- The start and end date of the accommodation plan. If the duration is indefinite, the accommodation plan will be reviewed every six months or as circumstances change and prompt a review*.
- Revision date.
- The employee and manager signatures.
- Date of signatures.
- *Note: If there is a change in circumstances, a new/updated Individual Accommodation Plan is required.
- Appendices, for example: Accommodation Request Form, individualized workplace emergency response plan, Return to Work (RTW) plan and Consent form.
All accommodation plans are available in accessible formats.
Confidentiality
The College is committed to protecting the confidentiality of employee medical and personal information collected during the accommodation process. Records of personal medical information and/or claim files are kept confidential in accordance to the Personal Health Information Protection Act.
Employee health information is gathered through a process of informed, written consent from the employee. Information collected will remain separate from the employee’s file. The only College employees with access to the information are the Disability Management Specialist (DMS) and the Director, Employee Health, Safety & Wellness. All information is stored on a secure, password protected platform. The third-party Disability Management Provider (DMP) will only have access to an employee’s personal and medical information if the employee provides written consent.
Roles and Responsibilities
As it relates to medical or disability leave of absences, the process is as follows:
Employees who are ill, injured or have a disability and are therefore unable to perform their essential job duties can request an accommodation at any time. Employees complete the Accommodation Request Form and submit it to the Disability Management Specialist (DMS) who is a member of the Human Resources, Health, Safety and Wellness department. They will be asked to sign a consent form enabling the DMS to share their information with the DMP provider.
Depending on the circumstances, the employee may be asked to provide documentation from their healthcare provider or providers. This documentation typically describes an employee's functional abilities and indicates if their restrictions are temporary or permanent.
Depending on the circumstances, an independent medical assessment may be required. This assessment provides further information regarding the employee’s functional abilities and need for accommodations.
The employee participates in the developing the accommodation plan with the manager and the DMS. If the employee wants their union representative present, they may also be present during the discussion. If the employee is not represented by a union, they may request to have a workplace support person present during the discussion. A support person is someone who may provide the employee with moral support or communication, mobility and/or accessibility assistance if needed. Lawyers are not usually present unless there is a recognized need.
Once an accommodation plan is agreed to and implemented, the employee will contact the manager and DMS if their needs change so that the plan will be revised accordingly.
If an employee cannot be accommodated in their current role, alternative work positions will be considered.
The Disability Management Specialist (DMS) receives the Accommodation Request Form and the consent form from the employee. The DMS then makes a referral to the DMP provider.
The DMS, on the College’s behalf, can request an independent medical examination or other expert evaluation, if necessary, at the college’s expense. This evaluation can help determine whether and/or how the accommodation can be provided.
After receiving the request, DMP provider informs the DMS of the limitations that require accommodation to ensure the employee is able to work safely.
If the DMP provider denies the accommodation request, the HRSP has a conversation with the employee. The HRSP would explain the reasons why the accommodation was denied and discuss alternative options that may be considered.
If the accommodation is approved, the DMS provides the manager with the non-confidential information related to the accommodation request.
The DMS will provide instructions to the manager regarding the purpose and process of the Accommodation Plan Procedure.
The DMS develops the accommodation plan with the manager and the employee. If the employee asks for other people to attend these discussions, such as a union representative, they will also attend the meetings.
The DMS, manager and employee will develop an individualized workplace emergency safety plans as needed.
All plan documents will be signed by the employee and the manager.
The Manager, DMS and employee meet to discuss, develop and agree to an accommodation plan. Once developed, the accommodation plan will be reviewed every six months from its effective date.
If the employee changes their position or work location, their accommodation plan will also be adjusted as needed.
The DMS, employee and manager will meet to discuss the accommodation plan when it is time for revision. At that time, any changes to the plan and outstanding actions for the implementation of the plan will be discussed.
As it relates to medical accommodation requests that are not related to extended leave of absences the process is as follows:
Employees who are ill, injured or have a disability and are therefore unable to perform their essential job duties can request an accommodation at any time. Employees complete the Accommodation Request Form and submit it to the Human Resources Strategic Partner (HRSP).
The HRSP receives the Accommodation Request Form and the consent form from the employee.
The HRSP develops the accommodation plan with the manager and the employee. If the employee asks for other people to attend these discussions, such as a union representative, they will also attend the meetings.
The Manager, HRSP and employee meet to discuss, develop and agree to an accommodation plan. Once developed, the accommodation plan will be reviewed every six months from its effective date.
If the employee changes their position or work location, their accommodation plan will also be adjusted as needed.
Any medical accommodations that do not require a leave of absence will be addressed by the DMS. Please see section 4.
Training:
Training on policies and procedures will be provided to all college managers on a semi-annual basis.