Inclusive Employer Handbook Learner's Guide Table of Contents

Inclusive Employer Handbook

Learner’s Guide

Table of Contents

Overview Page 2

Inclusive Workplace Pages 2-14

Recruiting, Hiring and Supporting Employees Pages 14-22

Workplace Accommodations Pages 22-29

Workplace Accessibility Pages 29-39

Conclusion Page 40

Resources Pages 40-43

Presented by:

Name Dustin Schwab Julie Zeigler Wood, OTR/L, ADAC

Title Career Development Specialist Worksite Accessibility Specialist

Occupational Therapist Registered/Licensed

ADA Coordinator

Office: 614-813-4649 Office: 614-205-5898

Email: [email protected]o.gov Email: [email protected]

Website: www.ood.ohio.gov Website: www.ood.ohio.gov

Overview

Opportunities for Ohioans with Disabilities (OOD) supports employers in creating workplaces that are

diverse and inclusive of employees with disabilities. One way OOD does this is through providing

consultations and training on Title I of the Americans with Disabilities Act (ADA), worksite accessibility,

reasonable accommodations, and disability inclusion. This learner’s guide is a reference companion for

the five-part webinar series, “Inclusive Employer Handbook.”

The inspiration for this series comes from the criteria used in the Governor’s Inclusive Employer Award.

Moments after taking the oath of office, Ohio Governor Mike DeWine signed Executive Order 2019-03D,

which established Ohio as a Disability Inclusion State and a Model Employer of Individuals with

Disabilities. To reinforce his commitment to Ohioans with disabilities, H.B. (House Bill) 110 included

presenting an award during October’s National Disability Employment Awareness Month (NDEAM) to

employers who meet the criteria for having a workplace inclusive of individuals with disabilities. OOD

determined the criteria for the award in alignment with its Inclusive Employer Toolkit: Inclusive

Workplace; Recruiting, Hiring, and Supporting Employees; Workplace Accommodations; and Workplace

Accessibility.

The “Inclusive Employer Handbook” is an educational series focused on supporting employers in

creating and sustaining workplace cultures that are diverse, equitable, and inclusive of individuals with

disabilities. According to the Centers for Disease Control and Prevention, 61 million adults in the United

States (US) live with a disability, which equals one in four adults. Simply put, disability impacts us all.

With these statistics, a person either has a disability themselves, or has a friend, family member, or

coworker with a disability.

There are benefits for employers who embrace hiring and supporting individuals with disabilities and

fostering disability-inclusive workplace cultures. These can include increased morale, improved

productivity, and greater profit margins. This series of webinars can serve as a guide for employers to

begin or continue their journey in creating a disability-inclusive workplace

The information included is for educational purposes, is not an exhaustive list, and is not intended as

legal advice.

Inclusive Workplace

An inclusive workplace is one where employers recognize the value of diversity and the unique skills and

perspectives each employee brings to the organization. By valuing diversity, employers may foster a

culture where all employees feel they can “fully represent themselves in the workplace”. This means

individuals feel comfortable being themselves at work and valued for their contributions. In an inclusive

workplace, employees can feel confident that their employer will promptly address bias, discrimination,

and harassment effectively if it occurs. Creating an inclusive workplace often goes beyond an employer’s

responsibilities under Title I of the ADA and results in a workplace where all employees feel they belong

and are a part of the culture.

In this first session of the handbook, these topics that promote disability inclusion will be addressed:

• Building the business case,

• Formalized commitment,

• Engagement with external organizations,

• Internal resources to support inclusion, and

• Disability awareness training.

Building the Business Case

Fostering a disability-inclusive culture can send a positive message to prospective candidates,

employees, and customers with disabilities that an employer values inclusion in the workplace.

According to the Northeast ADA Center’s “The Small Business at Work Toolkit,” individuals want to work

for employers who care about the needs of employees with and without disabilities, and most

customers prefer to spend their money with businesses that hire and support individuals with

disabilities.

Investing in an inclusive workforce gives employers a competitive edge. According to the Employer

Assistance and Resource Network on Disability Inclusion (EARN), employees with disabilities have

skillsets as diverse as employees without disabilities and strengthen the workplace by offering a variety

of perspectives for problem-solving, innovative thinking, and performing work.

A report released by Accenture in 2018 indicated that employers who implement best practices for

hiring and supporting employees with disabilities “consistently outperform their peers, including having,

on average, 28 percent higher revenue, double the net income, and 30 percent higher economic

profits.” One reason may be attributed to employees with disabilities remaining on the job longer which

reduces turnover costs. In addition, studies show employing individuals with disabilities leads to

improved productivity, increased morale, and greater diversity in the workplace. The report

was based

on a research study conducted by Accenture in partnership with Disability:IN and the American

Association of People with Disabilities (AAPD).

Creating a disability-inclusive culture in the workplace can also positively impact an employer’s

customer base. According to EARN, individuals with disabilities make up the “third largest market

segment” in the US. When employers embrace disability-inclusive workplace practices they may gain a

better awareness of the needs of individuals with disabilities. This awareness may extend to the

products and services they offer, helping employers to attract this valuable market segment.

To tap into increased innovation, improved productivity, a better work environment, and increased

market share, employers are encouraged to embrace best practices for creating a disability-inclusive

workplace. Part of this includes formalizing a commitment to hire individuals with disabilities which is

discussed in the next section.

Formalized Commitment

Employers who are successful in fostering inclusive cultures often have a formalized commitment to

disability inclusion in the workplace. This customarily includes a commitment to hiring and supporting

OOD Resource:

For information on the services OOD offers to help employers recruit, hire, and retain this valuable

workforce, visit the “Building the Business Case” section of the Inclusive Employer Toolkit on the

employer’s page of the OOD

website.

individuals with disabilities. There are many ways this commitment can be made, both internally and

externally, to create this culture and achieve workplace goals for diversity, equity, inclusion, and

accessibility.

In its resource titled “Expressing a Commitment to Disability Inclusion”, EARN provides strategies

employers can use to express their commitment. Here are some examples:

• Communicate formal statements of commitment to disability-inclusion,

• Include disability in diversity policies and activities,

• Post equal employment opportunity (EEO) statements,

• Post reasonable accommodation (RA) statements,

• Distribute employee newsletters including disability-related topics,

• Include images of individuals with disabilities in marketing materials, and

• Share the business case for employing individuals with disabilities.

Statement of Commitment

When top-level executives formally express a commitment to disability-inclusion in the workplace it can

send a message to applicants, employees, and customers that diversity is valued. This commitment

often becomes an organization’s vision for disability-inclusion, informing business objectives, hiring

goals, and policies. This can also result in the facilitation of inclusive practices in the workplace such as

empowering managers and supervisors to incorporate inclusion in their daily operations.

A formal commitment can be in the form of a policy, a strategic plan, or another communication

method. Here are examples:

• From the Oracle website

: “We’re committed to creating a workplace where all kinds of people

can succeed without barriers. We know that in order to tackle the world’s most important

problems, our workforce needs to reflect the diversity of the billions of people who use our

technology.”

o Oracle indicates “Our inclusion journey is ongoing” and includes hiring people with

disabilities, supporting talent, uplifting each other, and championing equality.

• From the Wells Fargo website

: “We value and promote diversity and inclusion in every aspect of

our business and at every level of our organization.”

o Wells Fargo indicates “Meeting the increasingly diverse needs of Wells Fargo’s global

customer base is critical for our company’s long-term growth and success. We’re

committed to advancing diversity and inclusion by helping ensure that all people across

our workforce, our communities, and our supply chain feel valued and respected and

have equal access to resources, services, products, and opportunities to succeed.”

o Wells Fargo indicates “We define diversity as the unique combination of various

dimensions that makes each of us different from and similar to others. Those

dimensions can include — but are not be limited to — age, gender, ethnic heritage,

race, physical or mental abilities, sexual orientation, values, religion/spiritual practice,

income, family status, education, and geographic location.”

• From the Disability:IN website

regarding Comcast NBCUniversal’s strategic plan: “Vision:

Comcast NBCUniversal is a recognized leader with an inclusive workplace where individuals of all

abilities can thrive in support of business innovation. Goal: Attract, hire, engage, retain and

empower people with disabilities across the enterprise to fully enrich their workforce and

position Comcast NBCUniversal as the destination for the right talent and the employer of

choice for everyone.” Strategies:

o “Build a workforce that fully mirrors the customers and communities we serve and is

reflective of current and growing demographics of the disability community,”

o “Cultivate a disability sensitive work environment by building awareness and increasing

competency for a more inclusive workplace,” and

o “Empower and engage People with Disabilities by providing equal access to tools,

information, support and systems.”

Diversity Policies and Activities

Many employers create diversity, equity, and inclusion (DEI) policies and implement DEI-related

activities at work. To be inclusive, these should acknowledge disability as part of the employer’s diverse

population. According to EARN, this means including terms like “disability” and “people with

disabilities” in descriptions of DEI policies. It also means DEI events and activities should include topics

related to disability, disability-focused organizations, and people with disabilities. A DEI policy provides

an opportunity for an employer to communicate why committing to diversity, including employees with

disabilities, is important to the organization. Policies can help support an organization’s DEI goals by

including initiatives and ways to achieve goals. They also ensure there is a process in place to address

bias, discrimination, and harassment should it occur in the workplace.

Here are some examples of policies and activities:

• According to responses received for the Governor’s Inclusive Employer Award application, one

employer reports having a workforce diversity and inclusion policy that is available to employees

through the organization’s intranet and is incorporated into new employee orientation through

online learning modules. The module which addresses diversity and inclusion includes

information on Title I of the Americans with Disabilities Act and reasonable accommodations.

Another respondent reports having a non-discrimination policy which includes disability that is

supported by a DEI department and a steering committee.

• According to the Disability:IN website

, “The United Services Automobile Association (USAA)

holds three employee speaker series events each year focused on employees to share their

personal diversity and inclusion stories, often related to disability. Suggested themes include be

yourself, embrace uniqueness, inspire belonging, create healthy challenge, pursue progress over

perfection, drive accountability, resiliency, inclusion, and advocacy. Three employees are

selected to speak at each event. Employees share their stories in front of live and virtual

audiences. Their stories are recorded for replay. Each speaker is then featured on an enterprise-

wide news article published on their internal intranet site throughout the year.”

• Also from the Disability:IN website, “TD Bank recognized National Disability Employment

Awareness Month to raise awareness about disability employment issues and celebrate the

many and varied contributions of workers with disabilities. TD posted weekly videos about

colleagues on the AccessAbility Connections and TeamWow! the most frequently used

communication mediums by employees. TD also hosted weekly online coffee chats regarding

recruitment, accessibility and disability inclusion shared across the enterprise. And throughout

the month TD posted Blogs on personal colleague journeys and “Moments of Truth” videos

featuring TD colleagues with disabilities ranging from rheumatoid arthritis to blindness to a

Veteran with Parkinson’s disease. The key messages of the blogs and videos focused on how

employees self-identified, self-disclosed at work, positive outcomes and the inclusive culture at

TD.”

The Society for Human Resource Management (SHRM) has a resource on its website

titled “How to

Develop a Diversity, Equity and Inclusion Initiative” which describes four phases and associated action

steps to help employers create these initiatives. These phases address data collection and analysis,

strategies that coincide with business objectives, implementation, and evaluation and monitoring.

EEO Statements

An equal employment opportunity (EEO) statement declares an employer does not discriminate in

employment based on protected classes, such as disability, and can send the message that an employer

values diversity.

The U. S. Equal Employment Opportunity Commission (EEOC) guidance states “the law requires an

employer to post a notice describing the Federal laws prohibiting job discrimination based on race,

color, sex, national origin, religion, age, equal pay, disability, or genetic information.” This notice should

be included in easy to find locations in the workplace and on internal websites where other notices are

customarily posted for applicants and employees. These notices should be accessible for individuals with

disabilities which includes placing postings in physically accessible locations and providing notices in

accessible formats, such as an audio file, electronic format compatible by a screen reader, and read to

individuals with limitations with seeing or reading. The EEOC website

offers additional information

about this requirement and the “EEO is the Law” poster that employers can access at no cost.

The SHRM website offers a detailed resource on what to include in an EEO policy, such as the scope of

protected categories covered, who is responsible for disseminating and implementing the policy, what

procedures to follow, a description of harassment and prohibitions, and remedies for violations.

According to the Job Accommodation Network (JAN)

website, EEO statements are advised to be

included in job postings, employee handbooks, and workplace policies. Here are examples of

statements:

• Fr

om SHRM: “[Company Name] is an equal opportunity employer. In accordance with anti-

discrimination law, it is the purpose of this policy to effectuate these principles and mandates.

[Company Name] prohibits discrimination and harassment of any type and affords equal

employment opportunities to employees and applicants without regard to race, color, religion,

sex, sexual orientation, gender identity or expression, pregnancy, age, national origin, disability

status, genetic information, protected veteran status, or any other characteristic protected by

law. [Company Name] conforms to the spirit as well as to the letter of all applicable laws and

regulations.”

• From JAN: “[Employer] is an affirmative action and equal opportunity employer. All qualified

applicants will receive consideration for employment without regard to race, color, religion, sex,

disability, age, sexual orientation, gender identity, national origin, veteran status, or genetic

information.”

RA Statements

Invite individuals with disabilities to communicate accessibility barriers in the hiring process and in the

workplace by posting a reasonable accommodation statement in key areas. This statement informs

individuals with disabilities of their right to request a reasonable accommodation and how to do so. This

is one way employers can communicate to applicants and employees their commitment to being a

workplace that is disability-inclusive. This statement is often included in job descriptions, job postings,

application forms (both online and in-person), reasonable accommodation policies, employee

handbooks, company intranets, and in invitations to interviews, onboarding, meetings, trainings, and

conferences.

Combining the reasonable accommodation statement with an EEO statement sends the message to

applicants and employees that the employer cares about what individuals with disabilities may need to

access the hiring process, perform the job, and enjoy the benefits of employment. This can result in

employers attracting more qualified candidates, including candidates with disabilities for their open

positions. Here is an example of a combined reasonable accommodation and EEO statement:

• From JAN: “[Employer] is an affirmative action and equal opportunity employer. All qualified

applicants will receive consideration for employment without regard to race, color, religion, sex,

disability, age, sexual orientation, gender identity, national origin, veteran status, or genetic

information. [Employer] is committed to providing access, equal opportunity, and reasonable

accommodation for individuals with disabilities in employment, its services, programs, and activities.

To request reasonable accommodation, contact [include name and/or department, telephone, and

e-mail address].”

Employee Newsletters and Publications

Employers can reinforce their commitment to a diverse workplace that values individuals with

disabilities by including articles related to disability in their employee newsletters and publications.

According to an article on the Partnership on Employment and Accessible Technology (PEAT) website

employers can use these platforms to educate employees on disability-related issues, like accessibility.

Here are some examples:

• “Oracle Corporation, for example, publishes a staff newsletter called, Dimensions of Diversity,

which has featured articles on ‘The Challenges of PDF Accessibility,’ ‘Creating Accessible

Multimedia,’ and other helpful topics.”

• “Ernst & Young produces a series of ‘AccessAbilities Minutes.’ These 60-second videos share

strategies for fostering an inclusive workplace, including the use of accessible technology.”

Images in Marketing Materials

Another way employers can create disability-inclusive workplaces is to include images of individuals with

disabilities in advertising and marketing materials. Doing so can demonstrate equality by showing

individuals with and without disabilities participating in work-related activities. Disability:IN offers

disability-inclusive stock photography available to the public on its website

Share the Business Case

The business case for hiring and retaining individuals with disabilities was discussed in the previous

section. Communicating these benefits to leadership, supervisors, and stakeholders in an organization

can further facilitate creating a workplace culture that is inclusive of individuals with disabilities.

A formalized commitment to disability inclusion is best supported with action. There are ways

employers can put their commitment into motion through participation with external organizations

focused on disability and through implementing internal resources to support inclusion. These topics are

discussed in the next two sections.

Engagement with External Organizations

Employers can gain valuable insights on disability inclusion by recognizing the best practices

implemented by other businesses and through participation in activities provided by organizations

focused on disability. These external resources can inform the efforts employers make to hire and retain

individuals with disabilities and create disability-inclusive cultures in the workplace.

There are a variety of ways employers can gain information from external resources. Here are some

examples:

• Benchmark disability efforts against peers,

• Participate in events and community activities focused on disability, and

• Partner with Opportunities for Ohioans with Disabilities.

Benchmark Disability Efforts

Webster defines benchmark as “something serving as a standard by which related items may be

judged.” Employers who strive to foster disability-inclusive workplaces often benchmark their practices

against what other organizations are doing to continually improve their efforts. One way an employer

can benchmark against other organizations is through membership and/or participation in professional

organizations focused on disability. These organizations often offer opportunities to network with peers

and participate in educational sessions on disability-related topics in the workplace. Another way

employers can benchmark their efforts is through participation in benchmarking assessments.

Here are examples of professional organizations:

• Disability:IN

o According to the website

: “Disability:IN is the leading nonprofit resource for business

disability inclusion worldwide. Our network of over 400 corporations expands

opportunities for people with disabilities across enterprises. Our central office and 25

Affiliates serve as the collective voice to effect change for people with disabilities in

business.”

o Resources available:

OOD Resource:

For information on reasonable accommodation statements view OOD’s on-demand webinar “Top

10 Accessibility Resolutions” on the employer’s page of the website.

 Resource library of best practices on a variety of disability-related topics,

 Information on news, press releases, awards, and media kits,

 Annual conference and inclusion awards, and

 Disability Equality Index benchmarking tool.

• Ohio Diversity Council

o According to the website

: “The Ohio Diversity Council (OHDC) is committed to fostering

a learning environment for organizations to grow and leverage their knowledge of

diversity. Through a variety of events and programs, the OHDC serves as the premier

resource for diversity best practices and leadership development in the state of Ohio. It

is currently comprised of 5 advisory boards: Cincinnati, Cleveland, Columbus, Dayton,

Toledo.”

o Resources available:

 Strategic consulting for diversity and inclusion topics,

 Certification program for diversity and inclusion strategies,

 Diversity toolkit with resources for employee awareness and diversity efforts

within an organization, and

 Workshops on a variety of topics.

• Ohio Industry Liaison Group

o According to the website

: “The National Industry Liaison Group (ILG) is the premier

employer association on affirmative action and equal employment opportunity in the

United States, supporting approximately 200 ILGs. The NILG is proud of the voluntary

and unique partnership of public and private sector cooperation, it has been able to

foster as an effective approach in dealing with important legal and regulatory issues

regarding affirmative action and equal opportunity. No other employer association has a

broader base of constituents focused on EEO/AA matters.”

o Resources available:

 News, tips, and meetings

 Networking with members to exchange information

• Ohio Society for Human Resource Management (SHRM) State Council

o According to the website

: “The Ohio SHRM State Council is a non-profit organization and

an affiliate of The Society for Human Resource Management (SHRM), the world's largest

HR Professional society with over 300,000 members in more than 165 countries. For

nearly seven decades, the Society has been the leading provider of resources serving the

needs of HR professionals and advancing the practice of human resource management.”

o Resources available:

 Conferences and events,

 Chapters throughout Ohio listed on this webpage

 Human resource (HR) advocacy center, and

 Newsletter with HR-related topics.

Here are examples of assessments:

• Disability:IN offers a comprehensive benchmarking tool employers can use to “build a roadmap

of measurable, tangible actions that they can take to achieve disability inclusion and equality.”

This tool is called the Disability Equality Index (DEI). Employers who participate in the DEI and

receive a score of 80% or higher are recognized as “Best Places to Work for Disability Inclusion.”

According to the website

, “for top-scoring companies, the DEI score builds brand recognition

among potential and current employees, investors, and customers – including those with

disabilities and their friends and families.”

o Here are the criteria employers are measured on in the DEI:

 Culture and leadership,

 Enterprise-wide access,

 Employment practices,

 Community engagement,

 Supplier diversity, and

 Non-US operations.

• The National Organization on Disability (NOD) offers a no-cost Employment Tracker employers

can use to “benchmark your organization’s disability employment policies and practices against

the 200+ companies in the pool.” Employers may qualify for the NOD Leading Disability

Employer Seal. The Employment Tracker results enable employers to create plans and prioritize

practices to further their efforts with inclusion policies and practices.

o Here are the disability inclusion focus areas in the Employment Tracker:

 Strategy,

 Talent outcome metrics,

 Climate and culture,

 Talent sourcing,

 People practices, and

 Workplace tools and accessibility.

Disability-Focused Events and Activities

Employers may participate in community events and activities focused on disability. These may not have

a direct tie to employment or the workplace but can serve to increase an employer’s awareness and

understanding of disabilities. For example, employers may choose to participate in their local

community’s Special Olympics events or join in an Autism Speaks Walk or attend a conference with a

focus on disability. Members of leadership may volunteer to serve on a board or committee for a

disability organization in their community. Examples may include a community center for the deaf, a

sight center, a center for independent living, or a disability services provider.

According to the Disability:IN website

, Bank of America has employees known as Cause Champions who

focus on disability-related non-profit organizations and then incorporate activities into the workplace,

such as hosting a training session on a particular disability, sharing a personal connection to the non-

profit, inviting subject matter experts to speak on a disability-related topic, or lead volunteer activities

related to the disability group.

Employer Partnership with Opportunities for Ohioans with Disabilities

Employers can enhance their efforts to hire and retain individuals with disabilities and create disability-

inclusive cultures in the workplace by becoming an Employer Partner with OOD. OOD’s Division of

Employer and Innovation Services (EIS) has a team of Business Relations Specialists (BRSs) who work to

build employer partnerships to support job placement and retention of individuals with disabilities

throughout Ohio. The BRS team is dedicated to working with employers to provide services to support

their hiring needs and to build an inclusive workplace. These services include candidate sourcing, hiring

events, and customized training. To find your local BRS, go to pages 17-18 of this learner’s guide for a list

with contact information and a service map of counties in Ohio.

Ideas on how employers can utilize internal resources to support disability inclusion are discussed in the

next section.

Internal Resources to Support Inclusion

As referenced earlier in the Business Case, “individuals want to work for employers that care about the

needs of employees with and without disabilities.” Inclusive workplaces don’t just happen, they require

planning and ongoing effort to create and maintain a culture where employees feel comfortable to be

themselves, offer their unique contribution, and ask for what they need.

There are many ways employers can dedicate internal resources to build and promote a disability-

inclusive culture unique to their workplace. Here are some examples:

• Dedicate a staff position, role, or team to manage disability-inclusion efforts,

• Create an employee resource group focused on disability, and

• Form a diversity committee for or in support of employees with disabilities.

Dedicated Position, Role, or Team

Creating an internal source with responsibility for supporting the needs of employees with disabilities

can be a great way to ensure disability is a part of an inclusive workplace. This can be achieved by adding

responsibilities to a staff member’s position or through creating a dedicated role or team to support

disability in the workplace. One example of this is to assign the responsibility of overseeing requests for

reasonable accommodations and facilitating the reasonable accommodation process. The Job

Accommodation Network (JAN) offers examples of job descriptions on their website

which detail the

duties, skills, and qualifications for the role of an employee responsible for the reasonable

accommodation process. These examples could serve as a guide for an employer to determine what

duties to assign to a position, role, or team within their organization.

Employee Resource Group

An employee resource group (ERG) is an internal group of employees from various levels of an

organization who have a shared interest in the needs of a diverse group in the workplace. An ERG offers

the opportunity to network with other employees, address the needs and concerns of this diverse

OOD Resource:

For information on becoming an OOD Employer Partner, contact the Business Relations Specialist in

your region, listed by county on the employer’s page of the OOD website.

For more information on how OOD can assist with meeting your workforce needs, visit the

“Candidate Sourcing” page on the OOD website

For information on how OOC can assist with providing education and training, visit the “Disability

Education Resources” page on the OOD website

group, find support from those with similar experiences, and effect change related to this diverse group

regarding work-related activities and needs.

An ERG should include employees from all levels, including leadership. Representation from all levels

enables the ERG to effectively capture the work-related needs of the diversity group. Leadership

presence provides the ERG with decision-making ability to support the group’s goals. According to EARN,

here are examples of best practices when creating and maintaining a successful ERG:

• Ensure a commitment from leadership,

• Create a clear mission and goals, and

• Establish a clear line of communication with leadership.

These practices help to legitimize the efforts of the ERG and ensures decisions are made to improve and

benefit the organization.

Here is an example of an outcome from Northwestern Mutual’s “disAbility Alliance Employee Resource

Group” as shared on the Disability:IN website

• A “group discussion facilitated by the ERG focused on accessibility accommodations, sharing the

story of a deaf employee’s experience. In an ERG-led effort to better accommodate [hard of

hearing] employees, closed captioning was successfully funded and implemented through the

Enterprise Venture Fund, a company innovation campaign that invites employees to submit

ideas that challenge the way business is done. The deaf employee described how elated she was

to fully participate when closed captioning became available at Town Hall meetings and on

AudioVideo HQ, an app that houses company videos and podcasts. This discussion also included

a video and handouts on disability etiquette.”

Here is an example of how Dell utilizes its ERG, “True Ability” as shared on the Disability:IN website

• “Dell’s True Ability ERG provides support and advocacy for those with disabilities, ensuring all

team members can innovate in their own unique ways. True Ability consults with the Dell

Benefits team to support employee needs and provide employees assistance in understanding

and optimizing available benefits. True Ability also partnered with the Dell Talent Acquisition

organization to develop the Dell Autism Hiring Program, which tailors the hiring process for

candidates with autism spectrum disorder. Additionally, True Ability provides education training

on disability hiring and disability etiquette to Dell recruiters and hiring managers.”

Here are resources for employers with best practices for disability-related ERGs in the workplace:

• Disability:IN offers an ERG/BRG Resources toolkit on their website

which addresses:

o Disability inclusion across the entire employment life cycle,

o Strategies to enable employees to bring their whole selves to work, and

o Tools and websites with additional information.

• EARN offers an Employee Resource Groups (ERGs) resource on their website

which provides:

o An ERG toolkit via PDF that shares how to create and implement an ERG,

o A PDF that describes ERGs and how to approach creating a disability-related ERG, and

o A fact sheet via PDF of how to plan accessible ERG events.

Diversity Committee

Similar to an ERG, some employers create a diversity committee consisting of executives, members of

leadership, and employees to implement the goals developed in an organization’s DEI policy and

promote diversity in the workplace. The inclusion of leadership in this committee is vital for support in

making decisions and taking action. To be successful, the committee should have a mission, a budget,

and methods to measure performance. Diversity committees often work to increase awareness through

events and education, engage with coworkers on topics related to DEI, and contribute to policies that

promote DEI in the workplace. In the absence of a committee, some employers designate these

responsibilities to management or hire a DEI professional.

To be inclusive, diversity committees should acknowledge disability as part of the employer’s diverse

population and include terms like “disability” and “people with disabilities” in descriptions of the

committee’s purpose and activities.

According to responses to the Governor’s Inclusive Employer Award, one employer reports having a DEI

steering committee that has a “three-tiered approach” which includes creating a safe work

environment, providing education and awareness, and partnering with internal business units to

facilitate inclusive practices.

Another important strategy employers can facilitate internally to foster a disability-inclusive culture is to

provide disability awareness education for all employees which is discussed in the final section.

Disability Awareness Training

Participating in disability awareness training in the workplace can help all employees feel more

confident and comfortable when communicating and interacting with individuals with disabilities. This

training can help hiring professionals and supervisors to become aware of any personal biases they have

towards individuals with disabilities, help them feel more comfortable when conducting an interview or

managing employees, and help them to understand that behaviors such as lack of eye contact or a flat

affect (lack of emotional expression) can be a characteristic of certain types of disabilities. OOD offers

disability awareness and disability etiquette training for employer partners at no-cost.

Disability Awareness

OOD’s team of Business Relations Specialists (BRSs) provide a variety of disability awareness training

offerings which can be customized to support employers in creating workplace cultures that are diverse

and inclusive of individuals with disabilities. Here are examples of topics offered:

• Disability Awareness - a training designed for employers to examine personal attitudes and

biases toward individuals with disabilities.

• Invisible Disabilities – an engaging session focused on the fears, myths and barriers often

associated with disabilities that are not apparent, such as traumatic brain injury, mental health

disabilities, and intellectual disabilities.

OOD Resource:

For information on services available to support your internal efforts, view OOD’s Worksite

Accessibility Services on the employer’s page of the website.

• Hiring and Onboarding - an interactive session focused on identifying and removing barriers in

the hiring and on-boarding process to make it more accessible and inclusive for people with

disabilities.

Disability Etiquette

OOD’s BRS team delivers disability etiquette training which defines disability, includes practical

examples of respectful interactions with people with disabilities, and addresses proper language usage.

This training can be customized as an in-person or virtual presentation, and an on-demand version is

available on the employers’ page of the OOD website.

Recruiting, Hiring, and Supporting Employees

Investing in an inclusive workplace gives employers a competitive edge. Recruitment efforts that are

inclusive of people with disabilities give employers access to a greater pool of talent, skills, and

innovative thinking in its candidates. Reports show that employers who hire and support employees

with disabilities experience higher revenues and greater profit margins. In this second session of the

handbook, these topics about recruiting, hiring, and supporting employees will be addressed:

• Goals for Employing Individuals with Disabilities,

• Inclusive Recruitment Process,

• Right to Reasonable Accommodation,

• Inclusive Essential Functions, and

• Accessible Hiring Process.

Goals for Employing Individuals with Disabilities

The 2017 Kessler Foundation National Employment and Disability Survey revealed that of the employers

who responded, 57 percent have goals for hiring qualified diverse individuals, but only 28 percent have

goals for hiring qualified individuals with disabilities.

Studies show hiring and retaining individuals with disabilities strengthens the workplace through

increased innovation and productivity in its workforce and positively impacts the bottom line. However,

the unemployment rate for individuals with disabilities is more than double that for individuals without

disabilities. Employers who are intentional about recruiting, hiring, and supporting individuals with

disabilities are more likely to attract more qualified candidates, including candidates with disabilities and

increase their chances of hiring the best individuals for their open positions.

Employers who establish disability employment goals, establish ways to track these goals, and embrace

disability inclusive practices may benefit from the advantages that come with a diverse workforce that

includes employees with disabilities.

OOD Resource:

For information on Disability Etiquette and Disability Awareness training, view OOD’s on-demand

webinar “Disability Etiquette Training” on the employer’s page of the website.

For information on OOD’s no-cost Disability Etiquette and Disability Awareness training for

employers, view OOD’s “Disability Education Resources” on the employer’s page of the website

Inclusive Recruitment Process

One way employers can be intentional about hiring qualified candidates with disabilities is to establish

inclusive recruitment processes or strategies. These efforts can include being proactive to source

qualified candidates with disabilities, sharing openings with colleges and universities, and participating

in disability-focused hiring events.

Sourcing Qualified Candidates with Disabilities

An inclusive recruitment process requires being intentional about partnering with sources that include

qualified candidates with disabilities. These sources may offer ways to support recruiting efforts and

provide qualified candidates with disabilities for employers to consider. An example of this type of

recruitment source are state vocational rehabilitation agencies. These agencies offer services to

individuals with disabilities related to their employment goals.

Ohio’s state vocational rehabilitation agency is Opportunities for Ohioans with Disabilities (OOD). OOD

empowers Ohioans with disabilities through employment, disability determinations, and independence.

The agency partners with business, education, and non-profits to facilitate individualized employment

plans for Ohioans with disabilities. OOD's trained and professional staff help Ohio employers recruit and

retain employees with disabilities.

Employers can enhance their recruiting efforts by becoming an Employer Partner with OOD. OOD’s

Division of Employer and Innovation Services has a team of Business Relations Specialists (BRSs) who

work to build employer partnerships to support job placement and retention of individuals with

disabilities throughout Ohio. The BRS team is dedicated to working with employers to provide services

to support their hiring needs and to build an inclusive workplace. These services include candidate

sourcing, hiring events, employer spotlights, and disability etiquette and awareness training. To find

your local BRS, go to pages 12-13 of this learner’s guide for a list with contact information and a service

map. A link to information on candidate sourcing through OOD is provided in the OOD Resource box at

the end of this section.

Disabilities Services Offices at Colleges and Universities

Employers who offer internships, apprenticeships, and entry-level professional jobs may consider

partnering with offices at colleges and universities. The Disability Services Office, Career Services Office,

and offices for specific academic departments can be a great resource for connecting with qualified

students and graduates with disabilities for employers’ open positions. The Ohio College2Careers (C2C)

program is another source employers can consider for finding qualified talent for their open positions.

The Ohio C2C program includes partnerships with 17 colleges and universities throughout Ohio to

ensure students with disabilities have the support they need to complete their education, earn higher

wages, and meet the demands of the labor market. A map of these colleges and universities can be

found on page 14 of this guide. For more information on how to attract qualified talent from the Ohio

OOD Resource:

For more information on the business case for hiring qualified individuals with disabilities, view

session one’s webinar “Inclusive Workplace” on the Inclusive Employer Handbook page of the OOD

website.

C2C program, employers can contact their OOD BRS. OOD also has Career Development Specialists

(CDSs) who work closely with the BRSs to connect students and graduates with disabilities with

internships and careers with employers.

CDSs can also help employers develop inclusive internships in their workplaces. Several OOD Employer

Partners work with their BRS and CDS to get information about the majors of students being served

through Ohio C2C. The employers use that information to determine what areas of their workplaces will

host interns. When the employers are ready to hire for the internships, they reach out to OOD and local

universities for candidates. By partnering with OOD to structure these internships, the employers have a

source to assist with the recruitment of qualified candidates who attend any college or university in

Ohio.

Disability-Focused Hiring Events

Attending disability-focused hiring events is great way for employers to reach more qualified candidates

for their open jobs and meet their goals to hire individuals with disabilities. OOD offers a variety of

options for employers to participate in hiring events. Several of our Employer Partners have worked with

OOD to host virtual hiring events for their organizations. One of these employers who applied for the

Governor’s Inclusive Employer Award noted that they hired nearly 50 candidates per event.

Right to Reasonable Accommodation

Employers can support candidates and employees with disabilities by making sure to communicate the

right to reasonable accommodation (RA) under Title I of the ADA. Employers may establish a process or

strategy to ensure this is achieved. One strategy includes the development and communication of an RA

statement. This statement informs applicants and employees of the right to RA and how to request one.

Here is one example of an RA statement from the Job Accommodation Network (JAN) website

• “[Employer] is committed to the full inclusion of all qualified individuals. As part of this

commitment, [Employer] will ensure that persons with disabilities are provided reasonable

accommodations. If reasonable accommodation is needed to participate in the job application

or interview process, to perform essential job functions, and/or to receive other benefits and

privileges of employment, please contact [include name and/or department, telephone, and e-

mail address].”

An RA statement should be included in key locations such as job descriptions, job postings, application

forms (both online and in-person), RA policies, employee handbooks, company intranets, and in

invitations to events such as interviews, onboarding, meetings, trainings, and conferences. Including an

RA statement in these locations can send the message to candidates and employees that an employer

cares about what individuals with disabilities need in the workplace.

OOD Resource:

For more information on how OOD can assist with recruitment of qualified candidates with

disabilities visit the “Candidate Sourcing” page of the OOD website.

For more information on the Ohio C2C program and creating an inclusive internship visit the

“Recruiting, Hiring, and Supporting Employees” section of OOD’s Inclusive Employer Toolkit

In addition, it’s a best practice to provide training for all employees on the right to RA. This type of

training is a customary part of most employers’ onboarding process and is recommended to be provided

on an ongoing basis for all employees.

Inclusive Essential Functions

The Equal Employment Opportunity Commission (EEOC) defines essential functions as “the basic job

duties” an applicant or employee with a disability “must be able to perform, with or without reasonable

accommodation.” In other words, essential functions are the critical job duties that must be completed

to meet the job’s expectations and removal of these duties would “fundamentally change jobs.”

Essential functions are a valuable tool in an inclusive workplace. They have a role in the hiring process

and during employment. Many applicants rely on essential functions to decide whether they’re qualified

for the job. Essential functions can also inform the questions asked in an interview, be useful when

evaluating job performance, and help determine appropriate reasonable accommodations during the

interactive process. How essential functions are described can increase the possibility of jobs being

performed in more than one way. This can lead to employers attracting more candidates for open jobs

and retaining talented and qualified employees. For these reasons, it is important to have a process or

strategy for identifying a job’s essential functions, describing them inclusively, and posting essential

functions in key locations.

Identifying Essential Functions

The EEOC regulates and enforces Title I of the ADA and in its guidance offers employers factors and

evidence that can be useful when determining a job’s essential functions. These are included on JAN’s

website in the “Technical Assistance Manual for Title I of the ADA” with examples. JAN’s website

also

offers a resource called “Job Description Topics” which includes information on creating job descriptions

and how to use a job analysis to determine a job’s essential functions.

Writing Essential Functions

Essential functions are most effective when written based on the outcome of the job task and in an

inclusive way. The focus of an essential function should be on the purpose of the task and the desired

outcome, rather than the customary way the job is performed. This is because there is often more than

one way to perform a task. An individual with a disability may have a limitation with performing a task in

the customary way it has always been done but can perform the task just as effectively another way,

possibly through using a reasonable accommodation. Describing essential functions using inclusive

language is another way to support the possibility of a job task being performed effectively in more than

one way. HR Guide offers guidance on their website

with examples of how to write outcome-based

essential functions. PACE University has a chart on their website which describes physical demands

using inclusive language.

OOD Resource:

For information on the employer’s responsibility to provide reasonable accommodations, view

OOD’s on-demand webinar “The Employers’ ADA Handbook: Reasonable Accommodations and

Undue Hardship” on the employer’s page of the OOD

website.

Posting Essential Functions

The EEOC guidance states employers should examine their jobs to determine the essential functions

before making recruitment efforts, conducting the hiring process, or making employment decisions.

Including essential functions in job postings and on applications can result in expanding the pool of

qualified candidates for employers to consider for their open positions.

Although employers are not required under the ADA to create job descriptions, employers often do, and

it is a best practice to include the job’s essential functions in these. Job descriptions prepared with

essential functions can be used by applicants to determine whether they qualified for the job, by hiring

professionals to create interview questions, by supervisors to measure work performance, and by

human resources professionals during the interactive process to determine reasonable

accommodations.

In addition, when onboarding new employees, providing a job description which includes the essential

functions can help a new employee with a disability know whether they need a reasonable

accommodation to perform the job. Remembering to include the reasonable accommodation statement

informs them of how to make a request.

Accessible Hiring Process

Attracting qualified talent for open positions is key to employers finding the right candidates for their

jobs. An accessible hiring process ensures qualified candidates with disabilities can access job postings

for open positions, complete the application, and participate in interviews and onboarding.

Job Postings

How employers recruit for jobs in their advertisements, notices and postings will impact how many

qualified candidates can access this information for consideration. Because candidates rely on the job’s

essential functions to determine whether they’re qualified, it’s important to include these in the job

posting. Including equal employment opportunity and RA statements in your job postings help to

communicate you are an inclusive employer and care about what candidates with disabilities may need

to access the hiring process. In addition, creating advertisements and postings that are accessible

ensures all candidates can access the information to decide whether to apply for the job. Here are some

examples of ways to make these accessible:

• Post job information in locations that are physically accessible,

• Establish accessible telecommunications, such as a telephone relay service, and

• Provide written information in alternative formats, such as large print or audio upon request.

According to responses received for the Governor’s Inclusive Employer Award application, one employer

reports they offer a dedicated support line for candidates to call for assistance with completing an

online job application if needed.

OOD Resource:

For more information on creating and using essential functions, view OOD’s on-demand webinar

“Essential Functions in the Workplace” on the employer’s page of the OOD website.

Applications

Employers may have applicants apply for jobs through an online application system or in-person. It is a

best practice to be intentional about making these processes accessible for candidates with disabilities.

Here are some examples of how to make an online application accessible:

• Ensure the application site is accessible for a screen reader,

• Design hyperlinks with large graphics to provide additional space to activate the link,

• Create organized and uncluttered pages to support increased focus and concentration,

• Provide accurate captions for sounds and video,

• Design for keyboard navigation, and

• Allow sound, visual content, and time limits to be controlled by the applicant.

Some employers use online applicant tracking systems to automatically manage incoming applications

and screen out applicants based on certain criteria. Employers are encouraged to permit hiring staff to

override the system and select candidates who may have been automatically screened out when

otherwise qualified.

It is a best practice to include an RA statement on the online application. Despite efforts to provide an

accessible application process, there may be times an applicant needs to make a request for an

accommodation. Providing an RA statement that is easy to find and directs applicants on how to make a

request may increase the likelihood of qualified applicants applying for open positions. An RA statement

may also convey to the applicant that diversity and inclusion are important to the employer.

When an applicant reports a barrier with an online application it can be helpful for employers to be

prepared to handle a request for a reasonable accommodation. What reasonable accommodation an

applicant will need is determined on a case-by-case basis through a collaborative interactive process.

Here are some examples of reasonable accommodations:

• Allow an applicant to provide required information via e-mail, fax, telephone, or mail.

• Have print versions available that an applicant may pick up onsite in an accessible location.

• Provide written information in various formats, including large print, braille, or audio recording.

• If a telephone number is provided to call for information, establish an accessible option for deaf

and hard of hearing applicants, such as a telephone relay service.

Interviews

Once a qualified applicant is identified, the preemployment phase begins. Title I of the ADA requires

employers to base the pre-offer phase of preemployment on the applicant’s ability to meet qualification

standards and perform the job. Disability-related questions and medical examinations must wait until a

conditional job offer is made and the post-offer phase of preemployment begins. These questions and

exams must apply to all candidates who receive a job offer in the same job category. This difference

between the pre-offer and post-offer phases is designed to prevent hiring professionals from screening

out candidates due to a disability prior to evaluating their ability to perform the job. To adhere to these

guidelines, here are some best practices for an accessible and inclusive interview process:

• Provide training for hiring professionals on:

o Requirements of Title I of the ADA,

o Disability etiquette and awareness,

o Disability disclosure and confidentiality, and

o How to address a request for a reasonable accommodation.

• Create protocols for hiring professionals to use during interviews:

o Pre-written questions that focus on performing the job’s essential functions and are not

disability related, and

o Instruction on when an interviewer may and may not ask a candidate to describe or

demonstrate an essential function.

• Include an RA statement in the invitation for the interview:

o Provide detailed information on the interview environment, whether onsite or virtual,

o Be prepared to receive and facilitate reasonable accommodation requests, and

o Create a list of vendors to contact if you receive a request for accommodations like sign

language interpretation so these requests can be facilitated promptly.

• Plan for accessibility barriers that occur with virtual hiring platforms:

o Determine if the hiring platform is accessible by a screen reader used by a candidate

who is blind or has low vision,

o Know that captions generated by artificial intelligence can cause errors that create an

accessibility barrier; instead, consider real-time captioning by a trained stenographer for

an interview or a sign language interpreter, and

o Be aware that time limited, pre-recorded videos can sometimes present challenges due

to certain disability-related issues; consider offering an extension of time for an

individual with a disability to complete the pre-recorded video.

Onboarding

The purpose of the onboarding process is to smoothly integrate newly hired employees into their

positions and the culture of the company. To ensure this process is smooth for employees with

disabilities, reasonable accommodations may be needed. Employers are encouraged to review their

onboarding process and consider these best practices:

• Assign an employee to oversee requests for reasonable accommodation to ensure the request is

facilitated efficiently and that reasonable accommodations are in place for the first day of work.

• Educate the employees who facilitate reasonable accommodations for parking and facilities,

information technology, security, and the workstation. Include education on confidentiality and

how to respond to questions asked by coworkers.

• Include an RA statement in communications delivered to all newly hired employees regarding

the activities included in orientation, the components of the work environment, and information

about the job and workstation. This enables a newly hired employee with a disability to

determine if a reasonable accommodation is needed. It also ensures the employee has the

information needed to make the accommodation request.

• Become familiar with common solutions for RA requests:

o Ensure electronic forms and intranets are accessible and be prepared to provide

alternative ways to access the information,

o Conduct onboarding in locations that are accessible,

o Provide a qualified reader to read written materials,

o Provide a qualified scribe to assist with completing forms or taking notes,

o Use plain language that is clear, avoiding jargon and unnecessary information,

o Provide a sign language interpreter,

o Ensure training videos are captioned,

o Permit the use of service animals,

o Conduct in a quiet space free of distractions, and

o Allow a job coach to be present.

Onboarding customarily includes communication about the policies and benefits that apply to all

employees as a result of employment. Including training about policies and procedures pertaining to the

right to reasonable accommodation and how to request an accommodation helps an employer to

support new employees with disabilities. Being mindful to repeat this training periodically for all

employees ensures employers are supporting employees with disabilities as well as employees without

disabilities who may acquire a disability in the future.

Employers also provide information during onboarding about the benefits they offer all employees,

including retirement and savings plans. To support disability inclusive benefits, employers may consider

providing information on financial savings plans known as STABLE accounts that apply to employees

with specific disabilities or employees with family members living with a specific disability. STABLE

accounts are a powerful tool for people with disabilities to increase financial security and experience

greater independence. STABLE accounts permit eligible individuals with disabilities to save a portion of

their earnings which grow tax-free. This investment is not subject to federal income tax when monies

are spent on Qualified Disability Expenses, which include items such as education, housing,

transportation, healthcare, assistive technology, basic living expenses, and many other items. Employers

can play a role in this important benefit for eligible employees with disabilities by helping employees to

contribute to these accounts through payroll deductions. For more information, visit the STABLE

Account website

. In addition to enabling access to STABLE accounts for employees with disabilities and

employees with family members living with a disability, employers can further support this benefit by

making an employer sponsored contribution to these plans.

To support employers in creating a hiring process and workplace culture that are diverse, inclusive of

individuals with disabilities, and accessible, OOD’s team of Business Relations Specialists (BRSs) provide

a variety of disability awareness training offerings which can be customized. Here are examples of topics

offered:

• Disability Awareness - a training designed for employers to examine personal attitudes and

biases toward individuals with disabilities.

• Invisible Disabilities – an engaging session focused on the fears, myths and barriers often

associated with disabilities that are not apparent, such as traumatic brain injury, mental health

disabilities, and intellectual disabilities.

• Hiring and Onboarding - an interactive session focused on identifying and removing barriers in

the hiring and on-boarding process to make it more accessible and inclusive for people with

disabilities.

To find your local BRS, go to pages 12-13 of this learner’s guide for a list with contact information and a

service map of counties in Ohio.

Workplace Accommodations

Title I of the Americans with Disabilities Act (ADA) requires covered employers to provide reasonable

accommodations to qualified applicants and employees with disabilities (when needed) to access equal

employment opportunities and participate in work-related activities. Employing qualified individuals

with disabilities can strengthen the workplace through innovative thinking, creative problem solving,

increased productivity, decreased turnover, and improved morale. Studies show these benefits can

positively impact an employer’s bottom line.

Many employers have embraced these benefits and feel empowered to go beyond meeting their

responsibilities under Title I of the ADA when employing individuals with disabilities and creating

inclusive work cultures. OOD is here to support employers by addressing best practices and providing

resources. In this third session of the handbook, these topics about workplace accommodations will be

addressed:

• Reasonable Accommodation (RA),

• Interactive RA Process,

• Funding,

• Confidentiality, and

• Training.

Reasonable Accommodation (RA)

A reasonable accommodation is a change in the hiring process or workplace that removes a barrier and

enables an individual with a disability to access equal employment opportunities and participate in

work-related activities.

Covered employers are required to provide RAs in three categories of employment which enable

qualified applicants and employees to:

• Access the hiring process,

• Perform the job’s essential functions, and

• Enjoy the privileges of employment.

Thus, an RA is effective in enabling an applicant or employee with a disability to compete for a job,

perform the job’s essential functions, and enjoy the benefits of employment as equally as employees

without disabilities. Title I of the ADA is regulated and enforced by the Equal Employment Opportunity

Commission (EEOC). The EEOC has organized RAs into the following types:

• Making the work environment accessible,

• Restructuring a job,

• Permitting a flexible schedule,

• Altering or providing equipment or services,

OOD Resource:

For more information on creating an accessible hiring process, view OOD’s on-demand webinar

“Inclusive Hiring: Applicants with Disabilities” on the employer’s page of the OOD website.

• Modifying policies, and

• Providing reassignment.

Not all modifications and items are considered a form of RA. For example, employers are not required

to:

• Eliminate essential functions,

• Lower quality or production standards, or

• Provide personal use items or services.

Covered employers are not required to provide accommodations that cause a direct threat to health or

safety or that cause an undue hardship. An undue hardship is an accommodation that is too costly or

difficult to implement.

Interactive RA Process

When providing accommodations, the ADA requires employers to engage in an informal process, known

as the interactive process, with the applicant or employee making the accommodation request. The

interactive process helps both parties to better understand what is needed and how to identify an

effective solution. Employers are not required under the ADA to create a formal process for providing

RAs, but it is a best practice. To support receiving and facilitating requests for accommodations,

employers may consider establishing a formal process, assigning responsibility for facilitating the

process, and creating forms to document the process. It can also be helpful for employers to be aware

of external resources available for identifying effective RA solutions.

RA Process

One of the best ways to provide effective RAs in the workplace is to establish a process. This helps to

ensure requests are identified quickly, the interactive process is started promptly, and accommodations

are implemented effectively.

The RA process, known as the interactive process, begins when an applicant or employee with a

disability makes a request for a change in the hiring process or at work related to a medical condition or

a disability.

When a request for RA is received, employers are expected to begin the interactive process promptly.

This includes collaborating with the individual making the request to verify the disability exists,

determine whether documentation is needed, identify the limitation related to the disability that is

impacting participating in a work-related activity, identify possible effective solutions, and then

implement and monitor the selected RA.

The EEOC provides guidance and criteria for what constitutes a request for an RA, when documentation

can be obtained, and how to determine whether an accommodation causes an undue hardship.

OOD Resource:

For information on the employer’s responsibility to provide RAs, view OOD’s on-demand webinar

“The Employers’ ADA Handbook: Reasonable Accommodations and Undue Hardship” on the

employer’s page of the

website.

Incorporating the EEOC guidance into an RA policy will help an employer to navigate their

responsibilities under the law and execute an effective process of providing individuals with disabilities

what they need in the workplace.

Here are resources for guidance on the interactive process:

• From the EEOC website: Enforcement Guidance on Reasonable Accommodation and Undue

Hardship

• From the Job Accommodation Network (JAN) website: Technical Assistance Manual for Title I of

the ADA

• From the JAN website: Interactive Process

According to responses received for the Governor’s Inclusive Employer Award application, one employer

reported they have a formal procedure to address requests for RAs that includes a detailed description

of the interactive process, identifies roles and responsibilities, describes who reviews medical

documentation provided, and how information is shared with leadership and human resources to

facilitate the process.

Responsibility for the RA Process

To ensure requests for RA are recognized, and the interactive process is facilitated promptly, employers

should assign the responsibility of managing the RA process. Employers can do this by adding

responsibilities to a staff member’s position or through creating a dedicated role or team to support

disability in the workplace.

The Job Accommodation Network (JAN) offers examples of job descriptions on their website

which

detail the duties, skills, and qualifications for the role of an employee responsible for the RA process.

These examples could serve as a guide for an employer to determine what duties to assign to a position,

role, or team within their organization.

According to responses received for the Governor’s Inclusive Employer Award application, one employer

reported they assign the responsibility for the RA process to a third party to administer and others

reported having teams of people to implement the process.

Documentation

An RA policy is often accompanied by forms designed to assist with receiving requests and then

facilitating and tracking the process. Creating a policy and these supporting forms can help an employer

to ensure employees with disabilities have what they need in the workplace while fulfilling their

responsibilities under Title I of the ADA.

JAN offers examples of policies, processes, forms and training on their website

employers can review to

enhance their existing policies and procedures or to create new ones. Here are examples of the sample

resources JAN offers:

• Accommodation policies,

• Accommodation processes and flowcharts,

• Training for managers and for effective communications,

• Accommodation request forms,

• Medical request forms,

• Accommodation approval forms,

• Monitoring forms, and

• Fitness for duty forms.

Documentation can further assist employers in tracking the success of their RA process and serve as a

demonstration of the good faith effort they make in providing employees with disabilities what they

need to participate in the workplace.

According to responses received for the Governor’s Inclusive Employer Award application, several

employers reported having a tracking form to ensure the steps of the RA process are followed.

Resources to Support the Process

Often during the interactive process, the employer and employee are able to determine what

reasonable accommodation is needed in the workplace. However, there may be times when the two

parties know an RA is needed but are unable to determine the solution. When this is the case, it can be

beneficial for the employer to be familiar with the external resources available to both parties to assist

during the process. Here are some examples:

• An employer may consider asking the employee to consult their medical provider for

recommendations for accommodations or to comment on a specific accommodation being

considered. It can be helpful to provide the employee with a standard document to give their

provider that addresses the work-related concerns.

• The Job Accommodation Network (JAN) is a federally-funded source of guidance on workplace

accommodations and disability employment issues which offers a variety of services for

employers and individuals with disabilities on their website: https://askjan.org/

. Employers may

consult this website for examples of types of RAs.

• The ADA National Network provides guidance and training on how to implement the Americans

with Disabilities Act (ADA). The network has ten regional ADA centers and Ohio is in the Great

Lakes Region. Resources on RAs and additional information related to Title I of the ADA can be

found on these websites:

o The ADA National Network website: https://adata.org/national-network

o The Great Lakes Region website: http://www.adagreatlakes.org/

• An employer may inform the employee during the interactive process of the vocational

rehabilitation (VR) services offered through Opportunities for Ohioans with Disabilities (OOD).

OOD is a state agency that provides Ohioans with disabilities the services and support they need

to attain and maintain employment. VR services are customized for each employee through

assessments and one-on-one meetings with professional VR counselors. These services may be

helpful in identifying effective RAs. Interested Ohioans with disabilities may visit

www.oodworks.com

to learn about VR services, take a self-assessment, create a profile, and

apply.

• An employer may contact their local Business Relations Specialist (BRS) to discuss the services

OOD offers to employers at no cost, such as a worksite accessibility consultation. This

consultation is a combined meeting with the employer, the BRS, and OOD’s Worksite

Accessibility Specialist to discuss the employer’s questions and concerns pertaining to the

interactive process and RAs. The intention is to address the questions the employer has in

navigating their responsibilities under Title I by providing resources, information, and ideas to

support the employer in making their decisions about next steps and helping to identify possible

accommodation solutions. The consultation is not an assessment of the work environment, job,

or individual performing the job. The consultation can occur over the phone, through a virtual

call, or in-person when needed.

Funding

A report released by Accenture in 2018 indicated that some employers have not embraced employing

individuals with disabilities due to the myth that providing RAs is costly. Many employees with

disabilities do not need accommodations at work. When an accommodation is needed, a survey

from

JAN revealed 56% of accommodations were free. Of those that required a one-time cost, the typical

expenditure was $500. Based on these studies, accommodations are often reasonable.

However, there are times accommodations may cost more and having a plan in place to address these

costs can support employers in providing employees with disabilities what they need to perform the job

and access the workplace.

One way employers can plan for the cost of RAs is to track accommodations and create a budget. This

could be a department budget or an organization-wide budget. To decide how much to allocate, an

employer could review what they’ve previously spent on accommodations through the years and

average these costs. Tracking accommodations will help employers to address trends, understand

commonalities amongst accommodations, and be better prepared to provide accommodations in the

future.

Another way employers can plan for the cost of providing RAs is through creating a centralized

accommodation fund (CAF). A CAF is an “enterprise-wide” fund for purchasing RA products and services.

This streamlined approach for purchasing accommodations can eliminate the concern hiring managers

and supervisors have that the cost of an accommodation will come from their department’s operating

budget. It can also help to make the process of procuring and providing accommodations more

consistent across an organization.

Creating and using a CAF is unique to each employer. However, understanding how other employers

have implemented a CAF can be beneficial. Disability:IN offers a resource titled “Centralized

Accommodations Funds” on their website

and JAN offers a resource titled “Best Practices in Establishing

a Centralized Accommodation Fund” on their website. Both these resources include best practices and

testimonials from employers who have implemented a CAF.

According to responses received for the Governor’s Inclusive Employer Award application, one employer

reported they have departmental budget lines reserved for accommodations.

OOD Resource:

For information on best practices for the interactive process, view OOD’s on-demand webinar

“Navigating the Reasonable Accommodation Process” on the employer’s page of the website.

Confidentiality

During the interactive process, all personal and medical information obtained must be kept confidential.

This includes information received through accommodation requests, discussions, disability-related

inquiries, medical examinations, and documentation. It is helpful for employers to know the criteria for

protecting this confidential information and have a policy or procedure to ensure this protection is

provided.

The EEOC criteria for confidentiality are provided on its website

in the guidance titled “The ADA: A

Primer for Small Business.” This guidance indicates that medical information that is obtained and

recorded should be kept in separate medical files apart from general personnel files, whether stored in

physical filing cabinets or in electronic databases. Including this guidance in the policy or procedure

helps an employer to ensure this information can only be accessed by designated parties when

appropriate. Here are examples of when certain information may be shared:

• Necessary information may be shared with employees responsible for facilitating RAs when

handling safety and emergency situations,

• Information specific to the proper implementation and use of an RA may be shared with

designated supervisors, and

• Information requested for a compliance investigation or to assess an insurance claim, such as a

workers’ compensation claim, may be shared with designated parties.

Confidentiality must be considered during communications in the workplace. At times, coworkers may

ask their supervisors about the RAs they notice a colleague receiving. Because the ADA prohibits

employers from disclosing an employee’s disability, the supervisor is not permitted to tell the coworker

the colleague has a disability or is receiving an RA. Instead, what the employer may consider is providing

training for supervisors on confidentiality guidelines and how to respond to these types of questions.

According to the EEOC guidance on its website

titled “Enforcement Guidance on Reasonable

Accommodation and Undue Hardship under the ADA”, here are examples of how the employer or

supervisor may respond:

• Emphasize the employer’s policy of assisting any employee who encounters difficulty at work,

• Explain that these types of situations are personal, and it is the employer’s policy to follow

confidentiality guidelines, and

• Reassure the coworker that his or her privacy would be respected in a similar situation.

OOD Resource:

For more information on creating a budget for reasonable accommodations, view OOD’s on-

demand webinar “Top 10 Accessibility Resolutions” on the employer’s page of the website.

For more information on resources available to support employers in navigating their

responsibilities under Title I, view OOD’s on-demand webinar “The Employers’ ADA Handbook –

Resources and Funding” on the employer’s page of the website

According to responses received for the Governor’s Inclusive Employer Award application, several

employers reported they keep confidential information related to RAs stored in an internal system that

is kept separate from other documentation and can only be accessed by designated parties.

Training

Employers can support their efforts to foster an inclusive workplace and adhere to their responsibilities

under Title I of the ADA by providing training for all employees and supervisors. These efforts can be

further supported through policies or procedures that describe the group(s) to receive training, the

information to be addressed, and the specific times to deliver training, such as during onboarding, and

on a regular basis.

Training for All Employees

A best practice is to be proactive and provide training for all employees on the laws the employer is

required to follow, including the right to RA for qualified employees with disabilities. This training is

recommended to initially be offered to new employees during onboarding and then on an ongoing basis

to all employees. Here are examples of important topics to address in this training:

• How to request an RA and who to contact,

• The employer’s RA policy and process, and

• Confidentiality rules regarding personal and medical information.

Training can be supported with information included in employee handbooks, company intranets, and

company newsletters. In addition, communications for jobs and invitations to interviews, trainings,

events, and meetings should always include an RA statement that is easy to find. This statement to

informs applicants and employees of the right to RA and how to make a request when needed. Here is

an example of an RA statement:

• [Employer] is committed to providing access and reasonable accommodation in its services,

activities, programs, and employment opportunities in accordance with the Americans with

Disabilities Act and other applicable laws. To request an accommodation based on a disability,

please contact (insert contact name or title with contact information such as phone number and

email address) by Month, Day, Year.

Training for Supervisors

It is important to also provide training for supervisors and managers on RAs. Research shows that

employees are more likely to request an accommodation from their supervisor than someone in human

resources. Supervisors can contribute in an important way to the employer’s process for identifying,

implementing, and monitoring RAs. Here are examples of important topics to address in this training:

• How to recognize a request for an RA,

OOD Resource:

For more information on employers’ responsibilities under Title I of the ADA and confidentiality,

view OOD’s on-demand webinar “The Employers’ ADA Handbook: Title I Overview” on the

employer’s page of the OOD

website.

• What steps to take when a request is received,

• The supervisor’s role in the interactive process,

• Confidentiality guidelines, and

• How to respond to questions from coworkers about RAs.

Training supervisors and managers about the RA process can make them feel confident to fulfill their

responsibilities correctly.

It is also important to train staff who assist with implementing RAs, such as IT professionals or facilities

staff, of the confidentiality rules related to RAs and how to respond to questions when they receive

them.

According to responses received for the Governor’s Inclusive Employer Award application, one employer

reported creating and administering a training focused on the ADA for its leadership that addresses how

to recognize a request for RA and who to contact to begin the interactive process. This employer

indicated this training must be completed successfully upon promotion to a leadership role and then

repeated annually.

Workplace Accessibility

Creating a workplace that is accessible for as many people as possible can help employers attract

qualified candidates, increase productivity on the job, retain and advance experienced employees,

ensure important information is conveyed, and expand their customer base. Employers who are

intentional about creating an accessible hiring process and workplace can foster an inclusive workplace

culture. In this fourth session of the handbook, these topics about workplace accessibility will be

addressed:

• Define Accessibility,

• Know the Accessibility Guidelines,

• Assess the Work Environment,

• Remain Current with Accessibility,

• Utilize a Reasonable Accommodation Statement,

• Offer Accommodations for All,

• Provide Training, and

• Consider a Centralized Fund.

Define Accessibility

According to the Centers for Disease Control and Prevention, one in four adults in the United States (US)

has a disability. Based on these numbers, employers likely have employees with disabilities in the hiring

process and the workplace, whether they know it or not. These statistics underpin the importance of

OOD Resource:

For more information for supervisors and the reasonable accommodation process, view OOD’s on-

demand webinar “Supervisors and Title I of the ADA” on the employer’s page of the OOD website.

creating policies and procedures to ensure accessibility of all aspects of the hiring process and the

workplace.

Employers who successfully foster cultures that are inclusive of disability integrate accessibility into their

diversity, equity, and inclusion (DEI) goals. According to www.dictionary.com

accessibility is:

• “the quality of being easy to approach, reach, enter, speak with, use, or understand”

• “the quality of being usable, reachable, obtainable, etc.”

• “the quality of being suitable or adaptable for use by people with disabilities.”

The Federal government's strategic plan to advance “Diversity, Equity, Inclusion, and Accessibility”

(DEIA) in the Federal workforce defines accessibility as:

• “The design, construction, development, and maintenance of facilities, information and

communication technology, programs, and services so that all people, including people with

disabilities, can fully and independently use them. Accessibility includes the provision of

accommodations and modifications to ensure equal access to employment and participation in

activities for people with disabilities, the reduction or elimination of physical and attitudinal

barriers to equitable opportunities, a commitment to ensuring that people with disabilities can

independently access every outward-facing and internal activity or electronic space, and the

pursuit of best practices such as universal design.”

Accessibility is comprehensive of the entire workplace and includes the built environment, the digital

environment, and communications. It is an ongoing proactive journey that addresses all business

operations, including additions, changes, and maintenance of the built and digital environments and

communications. Accessibility often benefits everyone, including people with disabilities, helping to

make everyone feel more comfortable and included in the workplace.

Fostering an accessible workplace includes creating policies and/or procedures that address knowing the

accessibility guidelines, assessing the work environment, remaining current, utilizing a reasonable

accommodation (RA) statement, offering accommodations for all, providing training, and considering a

centralized fund. Each of these is discussed in detail in their own section of this learner’s guide.

Know the Accessibility Guidelines

An accessible environment can lead to equity for qualified individuals with disabilities competing for

open positions, exceling in job performance, and advancing in their careers. Creating and maintaining an

accessible workplace begins with knowing the current accessibility guidelines and best practices.

Addressing these in policies and procedures can serve as a starting point for making the workplace

accessible for as many people as possible. The aspects of the workplace addressed in this learner’s guide

include the built environment, the digital environment, and communications.

OOD Resource:

For more information on how OOD can support employers at no cost visit the “Workplace

Accessibility” page of the Inclusive Employer Toolkit on the Employers’ page of OOD’s website.

Built Environment

Employers utilize the physical built environment for the hiring process, performing work, and accessing

information. This environment includes components like parking, entrances and exits, accessible routes,

common areas, work areas and surfaces, signs, and emergency systems. Accessibility standards for the

built environment are provided by entities like the Department of Justice (DOJ) and the US Access

Board.

The Department of Justice (DOJ) provides accessibility standards for Titles II and III of the ADA called the

“2010 ADA Standards for Accessible Design”, also known as the “Standards.” The Standards include

minimum requirements for new construction and major alterations that apply to “State and local

government facilities, public accommodations, and commercial facilities.” The Standards are regulated

and enforced with the intention that these facilities and accommodations “be readily accessible to and

usable by individuals with disabilities.” Employers can review the Standards for questions related to

their responsibilities under Titles II or III of the ADA.

From an employment perspective, the Standards are a good place to start when addressing the

accessibility of the built environment. The US Access Board has a “Guide to the ADA Accessibility

Standards” with illustrations that describe some of the common technical guidelines from the

Standards. The Standards and the guide from the Access Board are helpful resources for employers who

are reviewing their workplaces for accessibility:

• “2010 ADA Standards for Accessible Design” on the DOJ website

• “Guide to the ADA Accessibility Standards” on the US Access Board website.

Here is an example of an illustration from the US Access Board for accessibility of a door:

According to responses received for the Governor’s Inclusive Employer Award application, one employer

reported they design new facilities with accessibility in mind.

Digital Environment

Employers utilize the digital environment for the hiring process, performing work, and accessing

information. This environment includes components like websites and intranets, virtual platforms and

multimedia, and online forms and documents. Accessibility standards for the digital environment are

provided by entities like the World Wide Web Consortium’s (W3C) Web Accessibility Initiative (WAI), the

Partnership on Employment and Accessible Technology (PEAT), Disability:IN, Minnesota IT Services,

Microsoft, the Employer Assistance and Resource Network on Disability Inclusion (EARN), DOJ, and the

U.S. General Services Administration’s (GSA) Digital.gov website.

When creating digital accessibility for web content, the Web Content Accessibility Guidelines (WCAG)

provide a “single shared standard for web content accessibility that meets the needs of individuals,

organizations, and governments internationally.” WCAG is developed through W3C’s WAI. W3C’s

website offers a comprehensive overview of WCAG along with a free online course, tips, and tutorials.

When reviewing the accessibility of a virtual platform and how to conduct workplace activities in an

accessible way, PEAT offers ways to research various platforms and a checklist of how to conduct

accessible meetings and presentations virtually. Disability:IN offers resources for accessible conferencing

technologies and how to make virtual meetings inclusive. These resources include information on

providing live captioning and sign language interpretation in the virtual environment.

When reviewing the accessibility of multimedia, online forms, and documents, a variety of resources are

helpful. PEAT has a resource for creating accessible documents, virtual presentations, events, social

media, emails, and videos. The State of Minnesota’s IT Services has a resource which provides training

and best practices for making documents, meetings, webinars, videos, social media, and websites

accessible. Disability:IN has a resource which provides resources for conferences and meetings, social

media and email, and new technologies and services. Microsoft has an Accessibility Checker built into its

Microsoft 365 applications that identifies accessibility problems and provides remedies with instructions

to resolve these barriers.

The DOJ provides guidance on web accessibility related to the ADA for state and local governments and

businesses open to the public. This guidance addresses why accessibility matters, and shares examples

of barriers, when web content is required to be accessible under the ADA, how to make websites

accessible, and helpful resources. Employers can review the guidance for questions related to their

responsibilities under Titles II or III of the ADA.

The guidance is helpful for employers who are reviewing their workplace for digital accessibility.

Additional resources provide a comprehensive overview of the importance of accessibility in the digital

environment and the many ways this impacts the workplace. EARN provides a resource which addresses

the accessibility of technology used when recruiting, hiring, retaining, and advancing employees with

disabilities. GSA’s Digital.gov website provides a resource which addresses federal laws pertaining to

digital accessibility, inclusive design, disability awareness, and links to additional guidance.

Here are the resources discussed for digital accessibility guidelines and best practices:

• “W3C Accessibility Standards Overview” on the W3C WAI website

• “How to Pick an Accessible Virtual Meeting Platform” on the PEAT website

• “Checklist for an Accessible Virtual Meeting & Presentation” on the PEAT website

• “COVID-19 Response: Digital Accessibility and Other Best Practices for Remote Work” on the

Disability:IN website

• “Digital Accessibility Basics” on the PEAT website.

• “The Office of Accessibility” on the Minnesota IT Services website.

• “Accessibility Video Training – Making Your Content Accessible” on the Microsoft support

website

• “Make Your Content Accessible to Everyone with the Accessibility Checker” on the Microsoft

support website

• “Technological Accessibility” on the EARN website.

• “Guidance on Web Accessibility and the ADA” on the DOJ website.

• “An Introduction to Accessibility” on GSA’s Digital.gov website.

According to responses received for the Governor’s Inclusive Employer Award application, one employer

reported they have a checklist for publishing digital content that includes alternative text (alt text).

Communications

Employers utilize communications during the hiring process, with performing work, and to share

information. Communications can be direct and indirect and include items like job postings, websites

and intranets, emails, social media, training, policies, forms, and documents. Some ways to create

inclusive and accessible communications are addressed in the accessibility guidelines and best practices

in the built environment and digital environment sections of this learner’s guide. In addition, best

practices are available from entities like the DOJ, National Deaf Center (NDC), Job Accommodation

Network (JAN), Missouri School for the Blind, Communication Disabilities Access Canada (CDAC), and

OOD.

The DOJ provides regulations under Titles II and III of the ADA for effective communications with people

with communication disabilities. These regulations address an overview of a covered entity’s

responsibilities, auxiliary aids and services, and effective communication provisions. In addition,

employers can review the Standards for questions related to their responsibilities under Titles II or III of

the ADA related to accessibility of communications in the built environment. Communications guidelines

addressed in the Standards include fire alarm systems, signs, telephones, detectable warnings, and

assistive listening systems. This guidance is helpful for employers who are reviewing their workplace

communications in the built environment.

When communicating with individuals who have various disabilities, being informed of best practices

helps to ensure successful communications.

Deaf or Hard of Hearing: NDC offers a tip sheet which addresses the variety of ways individuals with

hearing disabilities communicate, how the environment impacts communication, tips for

communicating, and effective communications in large groups. JAN offers a resource with tips for

communicating by phone.

Blind or Low Vision: the Missouri School for the Blind offers a resource on how to interact with a person

who has a visual disability which addresses direct communications.

Intellectual Disabilities: JAN offers a resource with communication tips for communicating with

individuals with intellectual disabilities.

Speech-Language Disabilities: CDAC offers communications tips for interacting with individuals with

speech-language disabilities that includes direct communications, tips for when a picture board or

communication device is being used, tips for when either party has difficulty understanding the other,

and when a communication assistant is present.

Here are the resources discussed for communications accessibility guidelines and best practices:

• “Effective Communication” on the ADA website

• “Communicating with Deaf Individuals” on the NDC website.

• “Communication Tips for Working with Individuals with Intellectual Disabilities” on the JAN

website

• “How to Interact with a Person Who is Visually Impaired” on the Missouri School for the Blind’s

website

• “Communication Tips” on the CDAC website.

• “Accessible Communications in the Workplace” on the OOD website.

According to responses received for the Governor’s Inclusive Employer Award application, one employer

reported they have a telecommunications device for the deaf available to their employees in case an

interpreter is not available.

From an overall accessibility standpoint, JAN offers an accessibility resource on their website

which

addresses guidance for virtual and in-person events, facilities, general, products and devices, recruiting

and hiring, telework and websites.

NOTE: Employers with responsibilities under Title I of the ADA to provide reasonable accommodations

likely also have responsibilities under Titles II or III. Titles II and III address the public accessing such

things as goods, services, and programs. Creating an accessible environment under Titles II or III does

not negate providing a reasonable accommodation under Title I when needed.

Assess the Work Environment

Employers can progress with creating accessible workplaces by assessing the status of their current

environment. This helps employers identify where they are and prioritize next steps. One way to ensure

progress with accessibility remains a priority is to include a requirement for assessing accessibility in

policies and procedures. Resources for assessments are available for the built and digital environments

from entities like the New England ADA Center, PEAT, Web Accessibility In Mind (WebAIM), and W3C’s

WAI.

Built Environment

The New England ADA Center has created a checklist based on the Standards for the built environment

mentioned in the previous section. The checklist addresses responsibilities under Titles II and III of the

OOD Resource:

For more information on employers’ responsibilities to provide reasonable accommodations, view

OOD’s on-demand webinar “The Employers’ ADA Handbook Session 2: Reasonable

Accommodations and Undue Hardship” on the employer’s page of the OOD

website.

ADA and includes these priority areas: approach and entrance, access to goods and services, toilet

rooms, and additional access for drinking fountains, public telephones, and fire alarms. This checklist

provides employers with a starting point to assess the built environment. For employers with

responsibilities under Title I of the ADA to provide reasonable accommodations, it is important to know

that what an applicant or employee with a disability needs for accessibility of the built environment may

at times be greater than the minimum requirements in the Standards. When an employer receives a

request from an applicant or employee with a disability regarding accessibility of the built environment,

the employer should begin the interactive process promptly to collaborate with the individual and

identify an effective solution.

Here are the resources discussed for assessments of the built environment:

• “ADA Checklist for Existing Facilities” on the New England ADA Center’s website

Digital Environment

PEAT offers employers digital accessibility toolkits to assess and create accessible digital environments,

such as TalentWorks, which is a no-cost tool for employers to ensure their online job applications and

eRecruiting technologies are accessible, and TechCheck, which is a short assessment that gives

employers a “snapshot” of their accessibility practices, the goals they wish to achieve, and steps to take

to achieve them.

WebAIM has several resources for employers to assess the digital environment, including a reference list

for testing web content for accessibility through software, checklists, a screen reader, and scans; ways

to assess for screen reader technologies; a contrast and font checker; and a Web Accessibility Evaluation

(WAVE) tool.

W3C’s WAI offers a resource for completing a first review of website accessibility through their tool

called Easy Checks.

Here are the resources discussed for assessments of the digital environment:

• “Digital Accessibility Toolkits” on PEAT’s website

• “TalentWorks” on PEAT’s website.

• “Welcome to TechCheck” on PEAT’s website.

• “Articles” on WebAIM’s website.

• “Contrast Checker” on WebAIM’s website.

• “Quick Reference” on WebAIM’s website.

• “Typefaces and Fonts” on WebAIM’s website.

• “WAVE Web Accessibility Evaluation Tool” on WebAIM’s website.

• “Easy Checks – A First Review of Web Accessibility” on W3C’s WAI website.

OOD Resource:

For more information on best practices for the digital and virtual environment, view OOD’s on-

demand webinar “Digital Accessibility and Accommodations” on the employer’s page of the OOD

website.

Remain Current with Accessibility

Fostering an inclusive and accessible workplace requires ongoing effort. Beyond knowing the

accessibility guidelines and assessing work environments, inclusive employers are intentional about

remaining current with accessibility. Employers can prioritize this by creating a policy and/or procedures

to take action to identify the most recent guidelines and best practices. To remain current, employers

can periodically review available guidance, participate in external training, and consult with subject

matter experts. Several organizations offer newsletters, webinars, informational resources, conferences,

networking opportunities, and consults related to workplace accessibility and inclusion. Here are

resources to consider:

• Great Lakes ADA Center is a part of the ADA National Network and serves the Ohio region. This

center offers “information, materials, technical assistance and training on the Americans with

Disabilities Act of 1990 (ADA).” Employers may view additional information, register for

webinars, and sign up for their newsletter on their website

• The DOJ’s ADA website offers “information and technical assistance on the Americans with

Disabilities Act.” Their website includes the Standards, a guide to the Standards, and the option

to sign up for email updates.

• The W3C WAI website offers information on the current and upcoming WCAG standards for

accessible websites, training resources, and an option to receive news via email.

• PEAT’s website offers employer toolkits for assessing the work environment, a resource library,

and a newsletter.

• EARN’s website offers a framework for building a disability-inclusive organization which includes

accessible information and communication technology, training courses and webinars, a

resource library, and an option to subscribe for news and updates.

• Disability:IN’s website offers a resource library, webinars, the Disability Equality Index (DEI)

benchmarking assessment tool, and the option to subscribe for email updates. In addition, this

organization hosts an annual conference for employers to come together to participate in

educational sessions, sharing best practices, and networking.

• JAN’s website offers extensive resources for employers on navigating their responsibilities under

Title I of the ADA, templates for policies and documentation, educational webinars,

consultations with subject matter experts, and a newsletter.

• An employer may contact their local OOD Business Relations Specialist (BRS) to discuss the

services OOD offers to employers at no cost, such as a worksite accessibility consultation. This

consultation is a combined meeting with the employer, the BRS, and OOD’s Worksite

Accessibility Specialist to discuss the employer’s questions and concerns pertaining to

accessibility in the workplace. The intention is to address the employer’s goal by providing

resources, information, and ideas to support the employer in making decisions about next steps

with making the workplace more accessible. The consultation can occur over the phone,

through a virtual call, or in-person when needed.

• OOD’s website

offers an Employers page with access to an Inclusive Employer Toolkit, an on-

demand library of webinars on a variety of topics related to inclusion and accessibility, fact

sheets, and worksite accessibility services.

Utilize a Reasonable Accommodation Statement

Creating an accessible work environment may result in a workplace culture where everyone can

participate, and everyone feels included. However, barriers may remain in the hiring process, in

performing work, and in accessing the benefits of employment. Because of this, a reasonable

accommodation statement should be included in key areas.

A reasonable accommodation statement invites an individual with a disability to request an

accommodation, when needed, and provides contact information that informs the individual how to

make the request. Employers are permitted under Title I of the ADA to create their own reasonable

accommodation statement. Some employers may choose to combine this statement with their equal

opportunity (EO) statement to communicate both being a disability-inclusive employer and a

commitment to providing reasonable accommodations.

Offer Accommodations for All

To further support an inclusive workplace that meets the needs of all employees, employers may

consider creating a policy and/or procedures to provide certain accommodations for all employees

when requested. This allows employers to create a list of items that can be provided quickly without

requiring an individual to disclose a disability and participate in the formal reasonable accommodation

process. A preapproved list of items may include things like ergonomic keyboards and mice, ergonomic

chairs, sit/stand workstations, live captioning for large meetings and presentations, noise cancelling

earbuds, and flexible schedules.

When employers provide accommodations for all, it’s a best practice to inform all employees so they

know these items are available for them if needed.

According to responses received for the Governor’s Inclusive Employer Award application, one employer

reported they have standing desks available for any employee who requests one and another employer

indicated that when they distribute books for training purposes, employees can choose if they would

like a physical copy, audio book, or digital copy.

OOD Resource:

For more information on how OOD can support your efforts to remain current with accessibility in

the workplace, review OOD’s “Worksite Accessibility Services” on the employer’s page of the OOD

website.

OOD Resource:

For more information on best practices for reasonable accommodation statements, view session

one of OOD’s Inclusive Employer Handbook webinar series “Inclusive Workplace” on the

employer’s page of the OOD

website.

Provide Training

One important way to ensure an accessible workplace is to make accessibility a priority for all

employees when planning events, creating communications and invitations, designing physical and

digital workspaces, and starting projects. This ensures accessibility is addressed from the onset and is

not an afterthought. Here are some examples:

• Consider accessibility when planning events in onsite and offsite locations and facilities,

• Check the accessibility of documents before publishing and distributing,

• Include a reasonable accommodation statement in emails to interviews and onboarding, and

• Make sure to consider accessibility in the beginning stages of new projects.

To support all employees in successfully implementing accessibility, provide training on the importance

of inclusion in the workplace, disability basics and common workplace barriers, ways to make the built

environment accessible, how to conduct accessible virtual meetings, and how to create accessible

documents. Resources for best practices related to training are available for employers to consider from

entities like PEAT, Minnesota IT Services, Microsoft, and OOD.

PEAT offers staff training resources on its website

with ideas for training in disability inclusion, creating

accessible documents, and staff training for various roles.

Minnesota IT services offers training on its website for making Microsoft Word documents accessible

and includes resources for training, documents, maps, meetings, multimedia, social media, web and

apps on their “Why Accessibility Matters”

webpage.

Microsoft offers an accessibility fundamentals course on their documentation webpage which provides

an introduction to disability and accessibility, instruction on Microsoft’s accessibility features and tools,

ways to create accessible content with Microsoft 365, and how to create digital accessibility. Microsoft

offers information about its free, built-in Accessibility Checker on its support

webpage which addresses

a set of rules that identify accessibility issues, how and why to fix accessibility issues, and the limitations

of this tool.

OOD’s team of Business Relations Specialists (BRSs) provide a variety of disability awareness training

offerings which can be customized to support employers in creating workplace cultures that are diverse

and inclusive of individuals with disabilities. For example, OOD offers Disability Awareness training that

is designed for employers and employees to examine personal attitudes and biases toward individuals

with disabilities. OOD also offers Disability Etiquette training which defines disability, includes practical

examples of respectful interactions with people with disabilities, and addresses proper language usage.

Employers can find additional information about Disability Education Resources on OOD’s website

OOD Resource:

For more information on best practices for accommodations, view OOD’s Inclusive Employer Toolkit

section “Workplace Accommodations” on the employer’s page of the OOD website.

Consider a Centralized Fund

The Federal government’s strategic plan to advance DEIA in the Federal workforce includes an

accessibility roadmap which suggests Federal employers evaluate the need for a centralized fund to

both improve accessibility and provide accommodations. In the third session of the Inclusive Employer

Handbook: Workplace Accommodations, creating a centralized accommodation fund was discussed for

purchasing reasonable accommodations.

Funding a budget for workplace accessibility will be unique for each employer. Employers who hire

people with disabilities and/or remove barriers to improve the physical accessibility of their work

environments may be eligible for tax credits and deductions, such as the Disabled Access Credit, the

Barrier Removal Tax Deduction, and the Work Opportunity Tax Credit. Resources with more information

on these tax benefits are included in the OOD Resource box at the end of this section.

Employers often have budgets for purchasing technology to support their organization’s operations. A

best practice is to ensure the procurement process addresses accessibility from the start. This could

include creating a policy and/or procedures that requires employees who are responsible for making

these purchases to include accessibility as a core component of the decision-making process. Resources

for best practices related to procuring accessible technology are available for employers to consider

from entities like Disability:IN and PEAT.

The Disability:IN organization offers a toolkit on their website

for procuring accessible technology. This

toolkit addresses why digital accessibility matters, policies, inventory, culture, requirements, evaluating

bids, training, and more. In addition, Disability:IN offers a resource on their

website which addresses

purchasing virtual platforms that are accessible for everyone. This resource addresses questions to ask

vendors, sample contract language, capabilities for captioning and sign language interpretation,

accessibility and usability testing, and more.

PEAT offers a guide for purchasing accessible technology on their website. Their eight-step process

addresses setting priorities, preparing to buy, issuing solicitation, evaluating proposals, negotiating

contracts, testing and validation, and reviewing.

According to responses received for the Governor’s Inclusive Employer Award application, one employer

reported their Information Technology department utilizes an accessibility checklist when reviewing

new products. The checklist evaluates programs for screen reader compatibility, keyboard compatibility,

closed captioning, and other elements.

OOD Resource:

For more information to support training, view OOD’s “Accessible Communications in the

Workplace” fact sheets on the employer’s page of the OOD website.

OOD Resource:

For more information on tax benefits, view session four of OOD’s “The Employers’ ADA Handbook:

Resources and Funding” on the employer’s page of the OOD website or visit OOD’s Inclusive

Employer Toolkit’s webpage on Employer Tax Incentives.

Conclusion

OOD appreciates your interest in identifying solutions and resources to support a workplace that is

diverse and inclusive of employees with disabilities. Each employee with a disability, each employer, and

each workplace is unique and because of this, the effective strategy to create a work environment that

is accessible and inclusive will be unique. We hope the information shared in this learner’s guide and

webinar are helpful in supporting your efforts.

Resources

Opportunities for Ohioans with Disabilities

About Us

Accessible Communications in the Workplace

Business Relations Team

Candidate Sourcing

Digital Accessibility and Accommodations

Disability Education Resources

Disability Etiquette Training

Employer Tax Incentives

Essential Functions in the Workplace

Inclusive Employer Toolkit

Inclusive Employer Handbook

Inclusive Hiring: Applicants with Disabilities Training

Information for Employers

Navigating the Reasonable Accommodation Process

Recruiting, Hiring, and Supporting Employees

Supervisors and Title I of the ADA

The Employers’ ADA Handbook

Top 10 Accessibility Resolutions

Welcome to OODWorks

Workplace Accessibility

Worksite Accessibility Services

Disability:IN

About

Accessible Technology Procurement Toolkit

Bank of America’s Disability Advocacy Network

Centralized Reasonable Accommodations Fund

Comcast NBCUniversal’s Deep Commitment to Disability Inclusion

COVID-19 Response: Digital Accessibility and Other Best Practices for Remote Work

DEI Best Practices Collection

Dell’s Disability-Focused ERG, True Ability, Informs the Organization’s Disability Inclusion Strategies

Disability Equality Index

Disability Inclusive Stock Photography

ERG/BRG Resources

Homepage

Innovative Events and Actions from Northwestern Mutual’s disAbility Alliance Employee Resource Group

Purchasing and Licensing Accessible Video Conferencing Platforms that Work for Everyone

TD Bank’s Comprehensive NDEAM Awareness Campaign Showcases Inclusive Culture

The United Services Automobile Association Employee Speaker Series Highlights Disability Inclusion

Employer Assistance and Resource Network on Disability Inclusion (EARN)

Employee Resource Groups (ERGs)

Technological Accessibility

Looking to recruit, hire, retain and advance qualified people with disabilities?

Job Accommodation Network

Accessibility

Best Practices in Establishing a Centralized Accommodation Fund

Communicate

Cost and Benefits of Accommodation

Homepage

Interactive Process

Job Description Topics

Making a Statement – About Reasonable Accommodation and Equal Opportunity

Sample and Partner Example Accommodation Policies, Processes, Forms, and Training

Technical Assistance Manual for Title I of the ADA

Partnership on Employment and Accessible Technology (PEAT)

Checklist for an Accessible Virtual Meeting & Presentation

Communicating your Commitment to Accessibility: Tips for Employers

Digital Accessibility Basics

Digital Accessibility Toolkits

Homepage

How to Pick an Accessible Virtual Meeting Platform

Spark Inclusion in Your Organization

Staff Training Resources

TalentWorks

Welcome to TechCheck

Microsoft

Accessibility Fundamentals

Accessibility Video Training – Making Your Content Accessible

Make Your Content Accessible to Everyone with the Accessibility Checker

Rules for the Accessibility Checker

Society for Human Resource Management

How to Develop a Diversity, Equity and Inclusion Initiative

U.S. Equal Employment Opportunity Commission

Enforcement Guidance on Reasonable Accommodation and Undue Hardship under the ADA

Know Your Rights: Workplace Discrimination is Illegal Poster

The ADA: A Primer for Small Business

W3C Web Accessibility Initiative

Easy Checks – A First Review of Web Accessibility

Making the Web Accessible

W3C Accessibility Standards Overview

Web Accessibility In Mind

Articles

Contrast Checker

Quick Reference

Typefaces and Fonts

WAVE Web Accessibility Evaluation Tool

Other

Accenture. Getting to Equal: The Disability Inclusion Advantage

ADA National Network. Learn About the National Network

ADA. Effective Communication

Communication Disabilities Access Cananda (CDAC). Communication Tips

Department of Justice. 2010 ADA Standards for Accessible Design

Department of Justice. Guidance on Web Accessibility and the ADA

Department of Justice. Information and Technical Assistance on the Americans with Disabilities Act

Department of Justice. The Americans with Disability Act

Dictionary.com. www.dictionary.com

Great Lakes ADA Center. Homepage

HR Guide. Job Analysis: Job Descriptions

Minnesota IT Services. Accessible Word Document Training

Minnesota IT Services. The Office of Accessibility

Missouri School for the Blind. How to Interact with A Person Who is Visually Impaired

National Deaf Center. Communicating with Deaf Individuals

New England ADA Center. ADA Checklist for Existing Facilities

Ohio Diversity Council. About Us

Ohio Industry Liaison Group. Welcome Members and Guests

Ohio SHRM State Council. Affiliate of The Society for Human Resource Management

Ohio SHRM State Council. Chapter Finder

Oracle. Embracing Diverse Abilities

PACE University. Americans with Disabilities Act Compliant Words for Job Descriptions

Stable Account. Stable Account

US General Services Administration’s Digital.gov. An Introduction to Accessibility

Wells Fargo. Diversity, Equity and Inclusion

Inclusive Workplace

Recruiting, Hiring, and Supporting Employees

Workplace Accommodations

Workplace Accessibility

Employers who value an inclusive workplace tap an underutilized talent pool. Studies

show employing individuals with disabilities boosts morale, productivity, and

profitability. This guide offers ways to foster an inclusive workplace; recruit, hire, and

support employees with disabilities; provide workplace accommodations; and create

workplace accessibility.

Strategies included within this guide:

An inclusive workplace is one where employers recognize the value of the diversity

each employee brings to the organization. Employees feel comfortable fully expressing

their unique perspectives at work. A workplace inclusive of individuals with disabilities

offers benefits like innovation, improved productivity, and a better work environment.

Strategies to strengthen your workplace’s inclusion of individuals with disabilities:

Formalized Commitment to Disability Inclusion

□ Communicate a statement of commitment from top-level executives

□ Create diversity policies and host activities

□ Post an equal employment opportunity statement in key areas

□ Post a reasonable accommodation statement in key areas

□ Feature disability-related topics in employee newsletters

□ Include images of people with disabilities in marketing materials

□ Share the business case with stakeholders

Engagement with External Organizations

□ Partner with Opportunities for Ohioans with Disabilities

□ Benchmark disability efforts against peers

□ Participate in disability-focused events and activities

Internal Resources to Support Inclusion

□ Dedicate a role to managing disability inclusion

□ Create an Employee Resource Group (ERG) focused on disability

□ Form a diversity committee that includes disability

Disability Education Training

□ Disability Etiquette

□ Disability Awareness

□ Invisible Disabilities in the Workplace

□ Accessible Hiring Process and Onboarding

Inclusive Workplace

Recruiting, Hiring, and Supporting Employees

Being intentional about recruiting, hiring, and supporting employees with disabilities

can help employers attract and retain qualified talent. Inclusive recruitment strategies,

an accessible hiring process, and communicating the right to reasonable

accommodation to all employees are keys to an inclusive employer’s success.

Strategies for recruiting, hiring, and supporting employees with disabilities:

Goals for Employing Individuals with Disabilities

□ Create goals to hire qualified individuals with disabilities

□ Establish a way to track progress on hiring goals

Inclusive Recruitment Process

□ Engage with sources that include qualified candidates with disabilities

□ Partner with Opportunities for Ohioans with Disabilities

□ Collaborate with university disability and career services offices

□ Participate in disability-focused hiring events

Right to Reasonable Accommodation (RA)

□ Include RA statement in key locations

□ Regularly train employees on the right to RAs

Inclusive Essential Functions

□ Identify each job’s critical duties

□ Focus on the purpose and outcome of the job

□ Use inclusive language to describe essential functions

□ Include in job postings, applications, and job descriptions

Accessible Hiring Process

□ Ensure job postings and application forms are accessible

□ Train hiring professionals on disability awareness

□ Focus interview questions on the job’s essential functions

□ Be familiar with common RAs for interviews and onboarding

Workplace Accommodations

Inclusive employers often go beyond their legal responsibilities to provide

reasonable accommodations (RAs) in all aspects of employment. RAs cost less

than is commonly believed and provide many benefits in the hiring process and

the workplace.

Strategies for providing workplace accommodations:

Interactive Reasonable Accommodation Process

□ Establish a formal RA policy

□ Assign responsibility for facilitating the process to a role or team

□ Create forms to track the process

□ Be familiar with external resources for determining RA solutions

Funding Reasonable Accommodations

□ Utilize a department budget

□ Create a centralized accommodation fund

Confidentiality Guidelines

□ Establish formal confidentiality procedures

□ Identify protocols for storing confidential information

□ Address who has access to what information

Supervisor Training on Reasonable Accommodations

□ Identify when training should be provided or repeated

□ Address how to recognize a request and what steps to take next

□ Explain how to respond to questions from coworkers

Employee Training on Reasonable Accommodations

□ Review RA policy and process

□ Identify how to request an RA and who to contact

□ Address confidentiality rules

Workplace Accessibility

Inclusive employers remove barriers and create work environments that are

accessible for everyone. This can attract qualified candidates, increase

productivity, help convey important information, and retain qualified employees

– all of which contribute to fostering a disability-inclusive workplace.

Strategies for developing an accessible workplace:

Know the Guidelines and Assess

□ Recognize the standards and evaluate the built/physical environment

□ Recognize the standards and evaluate the digital/virtual environment

□ Review and utilize best practices for accessible communications

Remain Current with Accessibility

□ Periodically review accessibility guidelines

□ Participate in external training and review industry newsletters

□ Consult with subject matter experts

Provide Accommodations

□ Include a reasonable accommodation statement in key areas

□ Provide some accommodations without requiring disability disclosure

Train all Employees on Accessibility

□ Address the importance of inclusion and accessibility

□ Instruct on the basics of disability and common workplace barriers

□ Inform of the priority to include accessibility in planning

□ Educate on best practices for an accessible workplace

□ Include disability awareness and etiquette training.

Provide Training on Accessibility Practices

□ Develop a centralized fund for accessibility

□ Create an accessible procurement process for all purchases

Know the

Guidelines and

Ways to Assess

• 2010 ADA Standards for Accessible

Design on the DOJ website

• Guide to the ADA Accessibility Standards

on the US Access Board website

• ADA Checklist for Existing Facilities on the

New England ADA Center’s website

• Accessibility on JAN’s website

Consider All

Workplace Areas

• Parking lots and accessible spaces

• Entrances and exits

• Pathways, stairs, and elevators

• Common areas like meeting rooms,

restrooms, and break areas

• Employee work area, equipment, and tools

• Emergency systems and exits

Remember

Workplace Events!

• Accessible Meetings, Events, and

Conferences Guide on the ADA Hospitality

website

• Planning Accessible ERG Events on EARN’s

website

For more information, contact Julie Wood, OTR/L, ADAC –Worksite Accessibility Specialist –Julie.W[email protected]

Know the

Guidelines

• W3C Accessibility Standards Overview on the

W3C WAI website

• Digital Accessibility Basics on the PEAT

website

• The Office of Accessibility on the Minnesota

IT Services website

• Guidance on Web Accessibility and the ADA

on the DOJ website

Assess Your

Workplace

• Digital Accessibility Toolkit” on PEAT’s

website

• TalentWorks on PEAT’s website

• Welcome to TechCheck on PEAT’s website

• Articles on WebAIM’s website

• Quick Reference on WebAIM’s website

• WAVE (Web Accessibility Evaluation Tool on

WebAIM’s website

• Easy Checks – A First Review of Web

Accessibility on W3C’s WAI website

For more information, contact Julie Wood, OTR/L, ADAC –Worksite Accessibility Specialist –Julie.W[email protected]

Make

Documents

Accessible

• Accessibility Video Training – Making Your

Content Accessible on the Microsoft support

website

• Make Your Content Accessible to Everyone

with the Accessibility Checker” on the

Microsoft support website

• Contrast Checker on WebAIM’s website

• Typefaces and Fonts on WebAIM’s website

Remember

Virtual Events

• How to Pick an Accessible Virtual Meeting

Platform on the PEAT website

• Checklist for an Accessible Virtual Meeting &

Presentation on the PEAT website

Procure

Accessibility

• Accessible Technology Procurement Toolkit

on the Disability:IN website

• Purchasing and Licensing Accessible Video

Conferencing Platforms that Work for

Everyone on the Disability:IN website

• Buy It! Your Guide for Purchasing Accessible

Technology on the PEAT website

For more information, contact Julie Wood, OTR/L, ADAC –Worksite Accessibility Specialist –Julie.W[email protected]ov