ENews: Volume 9, Issue 2, Second Quarter, 2011
The JAN E-News is a quarterly online newsletter of the Job Accommodation Network. Its purpose is to keep subscribers informed about low-cost and innovative accommodation approaches; the latest trends in assistive technologies; announcements of upcoming JAN presentations, media events, trainings, and Webcasts; and legislative and policy updates promoting the employment success of people with disabilities.
An e-mail announcement is sent to an opt-in list when a new issue is available. Please use the links at the end of this document to subscribe or unsubscribe.
ADAAA Regulations, Finally!
The Interactive Process: Hurdles, Pitfalls, and Getting Out of Your Own Way
May is Hepatitis Awareness Month
Material Lifting Devices, Part 2 of a Continuing Series
Spring Cleaning the Workplace
Campaign for Disability Employment "I Can" PSA Honored at National Awards Ceremony
JAN Releases New Resources
- JAN Exhibit and Training Schedule
- Subscribe to JAN Newsletter
- ADAAA Regulations, Finally!
- The Interactive Process: Hurdles, Pitfalls, and Getting Out of Your Own Way
- May is Hepatitis Awareness Month
- Material Lifting Devices, Part 2 of a Continuing Series
- Spring Cleaning the Workplace
- Campaign for Disability Employment "I Can" PSA Honored at National Awards Ceremony
- JAN Releases New Resources
- JAN Exhibit and Training Schedule
- Subscribe to JAN Newsletter
More than two years after the ADA Amendments Act (ADAAA) went into effect, the Equal Employment Opportunity Commission (EEOC) has issued final regulations to help us understand just how broad the definition of disability now is. The overarching message of the regulations is that determining who has a disability should not be a drawn-out, complicated assessment, but for those of you who are not convinced, the regulations provide a lot of information to help convince you. Let's take a look at some of the highlights.
As you may know, the definition of disability is the same as it always was – an impairment that substantially limits one or more major life activities, a record of such an impairment, or being regarded as having an impairment. What changed was the meaning and application of the terms "substantially limits" and "major life activities." In the ADAAA itself, the term "major life activity" was clearly defined – the regulations added a few things, but did not make any major changes. However, the term "substantially limits" was not defined in the Act and although the regulations still do not define the term, they do provide nine rules of construction to help us understand how to determine whether a person is substantially limited. And in the accompanying appendix, the EEOC provides additional information and examples. For many people, these examples are the most useful part.
Virtually Always Covered Impairments:
Taking the nine rules of construction that apply to the term substantially limits, the EEOC provides examples of impairments that will virtually always meet the definition of disability. These impairments are: deafness, blindness, intellectual disability (formerly termed mental retardation), partially or completely missing limbs or mobility impairments requiring the use of a wheelchair, autism, cancer, cerebral palsy, diabetes, epilepsy, Human Immunodeficiency Virus (HIV) infection, multiple sclerosis, muscular dystrophy, major depressive disorder, bipolar disorder, post-traumatic stress disorder, obsessive compulsive disorder, and schizophrenia.
The regulations emphasize that the determination of disability is still done on a case by case basis, but the inherent nature of these impairments will in virtually all cases give rise to a substantial limitation of a major life activity.
Condition, Manner, and Duration:
For other impairments a bit more analysis may be needed. The regulations suggest that for people with these types of impairments, when determining whether the person is substantially limited, it may sometimes be useful to consider (as compared to most people in the general population) the condition under which the person performs the major life activity; the manner in which the person performs the major life activity; and/or the duration of time it takes the person to perform the major life activity, or for which the person can perform the major life activity.
- Linda Carter Batiste, J.D., Principal Consultant
What causes the accommodation process to break down without an effective solution? JAN research findings addressing the costs and benefits of job accommodations for people with disabilities also garner data about why the interactive process sometimes is not successful. Results consistently show that there are three major hurdles that impede an effective job accommodation solution:
Hurdle #1. Lack of information on what medical documentation an employer can request. For example, a lot of employees do not understand that employers can request certain medical documentation in response to an accommodation request, and if they fail to provide it, they may not be entitled to the needed reasonable accommodation.
To determine whether a particular employee has a disability, an employer may request medical documentation that shows whether the employee has an impairment and whether that impairment substantially limits one or more major life activities.
An employer may require that the documentation about the disability and limitations come from an appropriate health care or rehabilitation professional. Appropriate professionals include, but are not limited to, doctors (including psychiatrists), psychologists, nurses, physical therapists, occupational therapists, speech therapists, vocational rehabilitation specialists, and licensed mental health professionals.
For more information on medical exams and inquiries, including forms for employers, individuals, and medical professionals, visit: http://AskJAN.org/topics/medexinq.htm
Hurdle #2. Lack of clarification on how to determine the essential functions of a position. For example, employees may request the removal of an essential function without realizing that this is not required as a reasonable accommodation.
An employer can require that an individual with a disability meet the skill, experience, education, and other job-related requirements of a position, including the performance of the essential functions of a job with or without an accommodation. To determine whether a job function is essential, the first consideration is whether employees in the position actually are required to perform the function. According to the Equal Employment Opportunity Commission, there are several other reasons why a job function could be considered essential, including that there are a limited number of other employees available to perform the function or among whom the function can be distributed, a function is highly specialized, and that the person in the position is hired for special expertise or ability to perform the function. Evidence to be considered when determining whether a function is essential includes:
- The employer's judgment,
- A written job description prepared before advertising or interviewing applicants for a job,
- The amount of time spent performing the function,
- The consequences of not requiring a person in this job to perform a function, and
- Work experience of people who have performed a job in the past and work experience of people who currently perform similar jobs.
While employers are not required to eliminate an essential function, lower a production standard, or provide personal use items, they can do so if they wish. For information on identifying the essential functions of a job, including other relevant factors and examples, visit: http://AskJAN.org/links/ADAtam1.html#II
Hurdle #3. Lack of agreement on effective reasonable accommodations, including the role of temporary accommodations, leave time, and reassignment. For example, employees may reject an offer of reassignment not realizing that reassignment to a vacant position is a form of reasonable accommodation when there are not any available in the current position.
In most situations, employers should first consult with the employee who requested the accommodation to clarify what the individual needs and identify the appropriate reasonable accommodation. Often the employee will be the best resource for information about accommodation needs. By talking with the employee who requested the accommodation and obtaining medical information if needed, the employer should be able to identify what the problem is, which is the first step in determining effective accommodation solutions.
Once the employee's limitations and abilities are identified, the next step is to determine how they impact the employee's ability to perform the job. To make this determination, the employer needs to consider what specific job tasks, work environments, equipment, or policies are creating barriers to successful job performance. Sometimes it may be necessary to go beyond a traditional job description and consider other factors, such as what equipment is used to perform a task, where the work is performed, and why certain policies are being followed.
After the employer identifies the employee's limitations and abilities and determines how they impact job performance, the employer is ready to consider accommodation options. These options can include temporary accommodations, leave time, and reassignment, which can be all or part of an effective solution to a specific situation.
For more information on the determining accommodations, see: JAN's Five Practical Tips For Providing And Maintaining Effective Job Accommodations at http://AskJAN.org/media/FivePracticalTips.doc
These hurdles are sometimes pitfalls that could be avoided if the parties involved engaged in additional discussion prior to conflict. Obtaining information on your rights and responsibilities can expedite the accommodation process. To discuss your case in detail, contact JAN directly for one-on-one consultation.
- Beth Loy, Ph.D., Principal Consultant
In addition to the blooming flowers and warmer weather, May is recognized as National Hepatitis Awareness Month. JAN would like to take this opportunity to provide a basic overview of the most common types of hepatitis as well as accommodation solutions that can benefit employees with hepatitis.
While there are multiple types of hepatitis, types A, B, and C are the most common. According to the CDC there are an estimated 4.4 million Americans living with chronic hepatitis and most are not aware that they are infected. Treatment options and side effects of hepatitis viral infections differ among types. What this means for employees with hepatitis and employers is that accommodations need to be evaluated on an individual basis, just as in any other situation.
Each type of hepatitis has varying identifying characteristics. So what are they? Well, hepatitis A is caused by the hepatitis A virus (HAV) and does not result in chronic infection or chronic liver disease. Symptoms can include but are not limited to nausea, loss of appetite, fever, fatigue, or abdominal pain. Once individuals are infected with HAV they build antibodies, which prevent them from ever becoming infected again. The average incubation period for hepatitis A is 28 days (CDC, 2011) and the best way to prevent HAV infection, aside from good hygiene, is to get the hepatitis A vaccine.
Hepatitis B is caused by the hepatitis B virus (HBV) and can be acute or chronic. Symptoms of acute HBV are similar to those present with HAV (nausea, fatigue, fever, etc.) and begin around 90 days after exposure. Acute HBV symptoms can last for several weeks or persist for up to 6 months and the majority of adults infected (95%) will recover completely and not become chronically infected (CDC, 2011). There is no cure for HBV, but the rates of new HBV infections have declined since routine vaccinations of children have been recommended.
Hepatitis C, caused by the hepatitis C virus (HCV), is the most common chronic bloodborne infection in the United States (CDC, 2011). HCV is largely transmitted through exposure to infected blood and individuals who are newly infected can be asymptomatic or have mild symptoms including fever, fatigue, loss of appetite, headaches, abdominal pain, and nausea. Those with chronic HCV infection can have chronic liver disease, which in severe cases can include cirrhosis and liver cancer. Treatment therapy and duration of treatment for HCV is dependent on the HCV genotype and individuals may rely on medical professionals from a variety of specialties in their treatment regimen.
With all of the various types of hepatitis and range of symptoms it might seem like finding the right accommodation solution would be a confusing task, but it does not have to be! An employer should work with employees needing accommodations to determine what limitations they are experiencing and how these limitations are impacting their ability to perform their job. Employees may have suggestions that could be helpful for the employer and its okay for them to be part of the discussion, especially since the employee will be the one using the accommodation and will want it to work. Once the appropriate accommodations have been put into place, it's important to make sure that they are working effectively and to see if any additional accommodations are needed. Common options to think about when an employee with hepatitis has asked for accommodations include:
- Allowing flexible leave for doctor's appointments or when symptoms exacerbate
- Adjusting arrival or departure times
- Allowing rest breaks throughout the day
- Providing a part-time work schedule
- Considering a work from home arrangement, which can be full time, part-time or on an as-needed basis
- Reassignment if the employee cannot perform the essential functions of the current job, either with or without accommodations
For more information about accommodating employees with hepatitis, visit http://AskJAN.org/media/hepa.htm
Resources: Center for Disease Control and Prevention. (2011). Viral hepatitis. Retrieved April 21, 2011, from http://www.cdc.gov/hepatitis/index.htm
- Elisabeth Simpson, M.S., Consultant, Motor / Sensory Team
As stated in Part 1 of this series, many material lifting devices are designed for use with large, heavy objects. Repetitive lifting/handling of heavy loads are major causes of work related injuries. Vacuum lift systems are ergonomic devices designed to make material lifting easier and safer. These systems are excellent preventative products and use a vacuum to grip and lift heavy loads. These products can be used in a variety of work environments and can be used to handle boxes and cartons, sacks and bags, drums and barrels, rolls and reels, pallets, electronics, and many other items. Because these lifts are overhead, items can be safely lifted, allowed to dwell at a workable height, and rotated 360 degrees for inspection purposes. Two recent examples of JAN calls illustrate these points.
- A warehouse worker with a pre-existing back injury needed to have a material lifting device for picking up/moving cartons to an area close by to avoid a re-injury and to ease the pain of repetitive lifting. An overhead vacuum lifting system was recommended to improve the worker's performance and to lessen any possible risk of a re-injury.
- Due to a recent shoulder injury, a package handler for a private mailing service was having trouble lifting/moving parcels quickly enough to keep up with the volume of packages. A small vacuum lift device was suggested because the operation can be performed with one hand.
An operator can use these material handling devices for small but heavy loads as well. The Microlex from Vacutrade USA lifts up to 75 lbs and is usually powered by an electric non-lubricated rotary vane pump or a compressed air pump. Typical use would include lifting doors, batteries, computers, paint containers, cartons, and other light loads. Operators can use one hand to manipulate the item. Manually operated suction hand cups are used for even smaller, lighter needs. These small hand-held cups use lever action or pump action. They will hold on to most smooth, dry, nonporous surfaces such as glass, metal, fiberglass, linoleum, or polished stone. Ideal for preventing cuts to the hands, strains, and aches, these products are reliable and inexpensive. Below are product links to vacuum lift systems:
- http://www.palamatic.com/ (Vacuum Tube Lifters and Vacuum Lifting)
- http://www.vacutrade.com/ (Vaculex Product Line)
- http://www.anver.com/ (Vacuum Lifters)
The Job Accommodation Network does not sell lifting devices, but we do make information available as to manufacturers and distributors of lifting devices. For more information regarding product information, prices, specifications, and vendors, visit JAN's SOAR at:
- http://AskJAN.org/soar/motor/4_lifting.html (Moving, Carrying, or Lifting Materials or People)
- Eddie Whidden, M.A., Senior Consultant, Motor Team
After the long, dark, and cold winter it seems spring has finally come. We look forward to the flowers, the birdsong, and getting outside to get fresh air. We also look forward to the opportunity to spring clean our homes, workspaces, and classrooms. What better time to get rid of clutter and lighten up? It would be a much easier task if it were one we kept up on throughout the year, but most of us find that difficult to do. Many people do have organizational difficulties brought on by attention deficit or attention deficit hyperactivity disorders. For others who might be having cognitive and/or fatigue issues due to cancer treatments, fibromyalgia, brain injury, multiple sclerosis, or other impairments, organization can be very difficult.
For those of you who work from home, you may find it even more difficult to keep up with the clutter in your workspace. Maybe the fact that you do not have co-workers who can see your mess makes it easier to let it go and let it grow! There is a chance at home that the things not belonging in our offices have an easier time of showing up there.
Regardless of whether you work in a classroom, an office, a cubicle, or a home office, reducing the disarray in your workspace may very well increase your sense of professionalism and increase your productivity. Look to the following tips to help organize your workspace and reduce your clutter to a more manageable level.
- Don't become overwhelmed when you look at the area about to be cleaned. Take heart! Be brave!
- Start from one side of the room, area, or desk and move in a path to the opposite side.
- Remove tools, gadgets, and gizmos that you rarely use. Place them in a storage area that is convenient for when you do need them.
- Do you have books that you rarely use? Remove those to storage as well. If you haven't used a book within the last 60-90 days, it is probably not something you need to have at your fingertips.
- If you are a collector of whatnots and trinkets, consider limiting the number you display on your desk at a time. Put the others into storage and plan to rotate them in and out for a fresh new look.
- If you have extra furniture in your space that is not needed, consider removing it; having extra furniture just allows you to collect even more clutter.
- Consider hanging photos of your family, sports teams, etc., on the walls instead of having them take up desk space.
- Make sure that your desk drawers contain what you need to have handy. If you have items in your desk that you don't use on a regular basis, put those into storage as well.
- If you have a mountain of paperwork, go through it with only three things in mind: things that need you to take action, things to file away, or things to toss.
- Use color-coded files to help identify them with ease.
- Invest in stackable bins or trays for papers. Label them.
- Use a bulletin or magnetic board to keep often-used items, schedules, or policies / procedures within eyesight. If you are a person who likes to collect photos, cards, or whatever, consider having one board for work use and one for personal use.
- Have a trash can handy while opening mail. Toss absolutely everything that does not need to be responded to or remembered.
- If your office recycles paper, have a tray handy for that. Take to the larger recycling area at least weekly.
- Arrange the items on your desk and in your office according to how you use them. Your desk and surrounding office / cubicle space may look different if you are left-handed, for example.
Having an efficient usable workspace isn't about it looking good, it's more about the space being functional for you and your needs in your particular job.
Try to reserve 10 minutes at the end of each day to put things away, clear off your workspace, and prepare for the next day. You can control the clutter by not allowing it to accumulate. Then when next spring rolls around, you may be able to spend more time enjoying the flowers, the birds, and the fresh air.
- Melanie Whetzel, M.A., Consultant, Cognitive / Neurological Team
The Campaign for Disability Employment (CDE) received Honorable Mention in the category of Best Use of Audio/Video for the "I Can" video public service announcement (PSA) at the 2010 PRWeek Awards held in New York City, March 10, 2011. Each year, PRWeek awards corporate, nonprofit, agency, and educational institutions in recognition of excellence in public relations activities. The Best Use of Audio/Video award recognizes the combination of creativity, cost effectiveness, and overall impact of the PSA and Campaign initiative. One PRWeek judge said the "I Can" PSA Campaign is a "Thought-provoking concept that shined through with the video element."
Responding to the accolade, Kathleen Martinez, Assistant Secretary for the U.S. Department of Labor's Office of Disability Employment Policy (ODEP), noted that, "It is an honor for the CDE to be recognized for creatively promoting employment of people with disabilities in a meaningful and impactful way." "I Can" features seven people with disabilities sharing what they "can do" on the job when given the opportunity. The PSA participants represent different ages, genders, ethnic backgrounds and disabilities – some of which are apparent and some not. Ms. Martinez added, "I Can" reflects the diversity of skills people with disabilities have to offer and demonstrates their capacity to work for businesses of all sizes and industries." The PSA challenges common misconceptions about disability and employment and reminds viewers that at work, it's what people CAN do that matters.
To view "I Can," order free outreach tools, and learn more about the CDE's "What can YOU do?" initiative, please visit whatcanyoudocampaign.org. Become a supporter of the CDE's mission to promote positive employment outcomes for people with disabilities by hiring, retaining and advancing skilled, qualified workers with disabilities and sharing the important message that, "At work, it's what people CAN do that matters." The CDE is funded by the U.S. Department of Labor's Office of Disability Employment Policy (ODEP).
- Read more about the Campaign for Disability Employment.
- By Tracie DeFreitas Saab, M.S., Program Manager, Campaign for Disability Employment
- JAN Releases Updated Accommodation and Compliance Series and Fact Sheet Series Publications on Accommodations for AIDS/HIV. More than 50 experts and advocates joined Secretary Solis, Assistant Secretary of the Office of Disability Employment Policy Kathy Martinez, and Jeff Crowley, director of the White House's National AIDS Policy and Senior Advisor on Disability Policy, at the Labor Department's HIV/AIDS Employment Roundtable. >> Read the technical assistance information JAN provided (also in Spanish).
- JAN Releases Archived Webcast and Updated Accommodation and Compliance Series and Fact Sheet Series Publications on Accommodations for Fibromyalgia. Tune in and receive some first-rate information on fibromyalgia and accommodations for individuals with this type of disability. View our archived Webcast presentation for information on possible accommodations, including technology solutions and certain non-product options. JAN consultants provided practical tips for handling job accommodation issues involving the myriad number of limitations fibromyalgia presents and gave listeners solutions to perplexing and sometimes difficult situations. Also download updated technical assistance and accommodation ideas on fibromyalgia, a complex, chronic condition that causes widespread pain and fatigue as well as a variety of other symptoms. >> View Webcast and Read the technical assistance information JAN provides.
- JAN Provides Guidance on Making Online Applications Accessible. SNAP Your Website into Shape! Millions of individuals connect to the Internet for quick access to vast amounts of information. Some Website designers still overlook accessibility, but with more focus from enforcing agencies on making electronic materials accessible, especially multimedia applications, it is time for employers, organizations, government agencies, and others to review their Websites for accessibility. Recently, the U.S. Department of Justice announced settlement agreements involving the accessibility of the Law School Admission Council's (LSAC) online application service. Because of these agreements, LSAC's online application service, and the online application process of the nation's law schools, will be accessible. The ADA prohibits discrimination on the basis of disability, including discrimination by law schools and other post-graduate institutions. Use JAN's updated publication from its Technical Series on Tips for Designing Accessible Websites as a guide. And, if you need a self-assessment tool to assist with making online application systems accessible, follow JAN's SNAP Tool! >> Learn more.
- JAN Distributes Consultants' Corner. JAN distributes issue on "Epilepsy, Driving, and Employment" to address one of the most common questions consultants at JAN answer in regards to employees with epilepsy driving. >> Read the Consultants' Corner.
- JAN Provides Access to Federal Employer Winter Webcast Series. Find practical solutions with JAN's 2011 archived Federal Employer Winter Webcast Series. JAN provided three free 1.5 hour Webcast sessions beginning in January 2011. The three part series covered the hiring and employment of people with disabilities in the Federal government and the reasonable accommodation process. JAN welcomed guest speakers from the Equal Employment Opportunity Commission, the Office of Personnel Management, Department of Defense's Computer/Electronic Accommodations Program, and the U.S. Environmental Protection Agency. >> View the entire Federal Winter Webcast Series archive.
- JAN Research Highlighted. Read more about JAN research in an the EEOC's Regulations to Implement the Equal Employment Provisions of the ADA, as amended. >> Read more.
- JAN Highlighted in California AT Project Blog. JAN's SOAR ranked fourth, and JAN's Employers' Practical Guide to Reasonable Accommodation ranked fifth on the California Forum on Assistive Technology (AT Project) list of top eight online employment resources. >> Read more on the AT Blog.
- JAN Releases Archived Webcasts. Tune in to Current Events in Accommodation and get up-to-date on current events in job accommodation, including tough accommodation situations, tricky ADA issues, and technology challenges. Review Employing and Accommodating an Aging Workforce to get an overview of how to accommodate an aging workforce, including steps to an inclusive process, available assistive technologies, and accommodation examples. >> Access archives.
- National Disability Employment Awareness Month Theme Announced. The U.S. Department of Labor's Office of Disability Employment Policy has announced the official theme for October's National Disability Employment Awareness Month: Profit by Investing in Workers with Disabilities. The theme honors the contributions of workers with disabilities, and serves to inform the public that they represent a highly skilled talent pool that can help employers compete in today's global economy. >> Read press release.
- New Alliance, ODEP and PPS. A new alliance between the Office of Disability Employment Policy and the Partnership for Public Service will help federal agencies fulfill President Obama's executive order to increase federal hiring of people with disabilities. >> Read press release.
- US Labor Department Launches National Outreach Campaign to Protect Workers from Heat-Related Illnesses. Secretary of Labor Hilda L. Solis announced a national outreach initiative by the U.S. Department of Labor's Occupational Safety and Health Administration to educate workers and their employers about the hazards of working outdoors in the heat and steps needed to prevent heat-related illnesses. >> Get more information.
- US Labor Department Proposes Rule to Improve Employment of Veterans. The U.S. Department of Labor has proposed a new rule to strengthen affirmative action requirements of federal contractors and subcontractors for Veterans protected under the Vietnam Era Veterans' Readjustment Assistance Act of 1974 (VEVRAA). >> Get more information.
- "What can YOU do?" The Campaign for Disability Employment in Massachusetts. A part of a public awareness campaign was launched on April 1st by the University of Massachusetts Medical School, in partnership with the national "What Can YOU Do?" Campaign for Disability Employment and the U.S. Department of Labor's Office of Disability Employment Policy (ODEP). Massachusetts is the first state to customize this award-winning campaign, using outreach tools such as billboards, radio placements, and television public service announcements (PSAs). >> Learn more.
- Telework Guidance Updated. The Office of Personnel Management issued a telework guide to help agencies implement the Telework Enhancement Act, which was signed into law in December, and to serve as a resource on the law for the Federal government. >> Download Guide to Telework in the Federal Government.
- Ticket to Work Technical Assistance Center Website Launched. The Website is full of great information including work from home job openings available, resources and links, how to qualify for the program, and more. >> Get more details.
- Top 10 Companies for People with Disabilities. DiversityInc ranks the Top 50 companies for people with disabilties. >> Get more details about the top 10.
- Federal Dispute Resolution Conference To Be Held August 8-11, 2011, in Palm Desert, CA. Now in its 26th year, the Federal Dispute Resolution Conference has been the leading training event for Federal civil service law practitioners and professionals to gain expert insights into hot-button issues and emerging trends. >> Register now.
- 2011 USBLN® Annual Conference & Expo - "Aligning Disability with the Bottom Line: Talent, Market Share, and Supplier Diversity" To Be Held in October 16-19, 2011, in Louisville, KY. Be sure to mark your calendar for Louisville, Kentucky on October 16-19, 2011, for the US Business Leadership Network's 14th Annual Conference at the Louisville Marriott Downtown hotel. The 2011 USBLN® Annual Conference & Expo is the preeminent national employer-to-employer event that taps into the vast economic potential of people with disabilities. This conference brings corporate, government, disability-owned businesses and BLN affiliates together to create workplaces, marketplaces, and supply chains where people with disabilities are fully included as professionals, customers, and entrepreneurs. >> Register now.
Events of particular interest: Get the most up-to-date and comprehensive training on employing people with disabilities. To view the complete JAN travel schedule go here: http://AskJAN.org/training/On-the-Road.htm
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This document was developed by the Job Accommodation Network, funded by a cooperative agreement from the U.S. Department of Labor, Office of Disability Employment Policy (DOL079RP20426). The opinions expressed herein do not necessarily reflect the position or policy of the U.S. Department of Labor. Nor does mention of tradenames, commercial products, or organizations imply endorsement by the U.S. Department of Labor.