From the desk of Louis E. Orslene, MPIA, MSW, JAN Co-Director
One of the best practices in hiring and retaining employees with disabilities touted over the past years has been a centralized accommodation fund (CAF). Providing an enterprise-wide general fund to pay for applicant and employee accommodations is one strategy towards increasing employment for people with disabilities. The strategy works by reducing the fear of hiring managers and supervisors that their individual unit or departmental budget will be charged for the cost of the accommodation. Such a charge would effectively reduce their operating budget.
Much of this fear stems from the belief that accommodations are costly. While we know from many studies conducted over the past few decades that the cost of accommodation is not to be feared, many still stubbornly hold on to this myth. In an ongoing study conducted with JAN customers, employers report that a high percentage (57%) of accommodations cost absolutely nothing to make and that the rest typically cost only $500 (Job Accommodation Network, 2014).
While there are a number of articles addressing the challenge of getting hiring manager and supervisor buy-in to pay for the cost of an accommodation, there is scant information about how to actually implement a CAF. This article seeks to provide this information by interviewing and reporting the experience of two companies that have established or are in the process of developing a CAF. The companies interviewed are large enterprises with more than 20,000 employees.
Both companies interviewed suggested multiple internal and external drivers for developing a CAF. One company framed the development of a CAF as an investment in the future of employees, managers, and the enterprise as a whole. Primary to these external drivers was the new Section 503 regulations and the fierce competition for talent in the future. One of the interviewees reported “a fierce competition for a limited pool of talent" so the effort must be made to attract the best workers including from the pool of people with disabilities. As expected, reducing the fear of supervisors in providing accommodations from their department funds was one of the primary drivers for developing a CAF.
However, as important with these two companies was bringing consistency to the overall existing accommodation process. This consistency promised to make the whole process more understandable to all employees but particularly hiring managers and supervisors. One of the company representatives interviewed referred to the process of refreshing the existing accommodation process while instituting a CAF as harmonizing their accommodation policies and practices. Previously, every department within the company processed requests and with so many functional areas there was inconsistency. The new harmonized system insures “no one feels threatened and everyone understands.” While not using the word “harmonizing,” the other company representative explained the fund resulted from a need to streamline current processes including clearly identifying personnel roles and responsibilities.
In each of the companies interviewed, the effort to develop and implement a CAF resulted from the CEO and VP suites understanding the business case. One of the company representatives reported two business cases being developed, one developed during a pilot of the fund in 2005 and the other in 2010 as the CAF processes were refreshed. The 2010 business case included a financial analysis regarding what would be provided by the fund and at what cost. A questionnaire was also developed to globally benchmark others within the industry. The second company representative reported no formal development of a business case. In this company, the CEO understood the global business case and provided leadership to insure VPs made the CAF a priority.
One of the companies has a long standing accommodation process, but starting in 2009, their best practices team looked at the process in order to develop a more consistent, formalized process across business sectors. The group worked closely with the information and communication technology department. One recommendation was for an accessibility officer to be hired in order to insure that the company intranet, website, and applicant tracking system be accessible. In 2011, an effort began to harmonize the accommodation process. Once legitimized by senior vice presidents, this harmonization resulted in the funding of the CAF. The fund was launched before all of the processes were harmonized. The company representative reported “Taking budget out of their hands (hiring managers and supervisors) turned out to be best first step.”
Both company representatives reported buy-in by VPs and managers as essential to the success of the CAF. In one company, Human Resources (HR) spearheaded both the development as well as the communications for the CAF. More specifically, the Senior Vice President of HR approved the centralized fund in consultation with all of the departments touched by accommodations. This consultation enabled the other stakeholders, i.e., benefits, safety, and fleet, to be vested in the fund implementation. One lesson learned included earlier involvement of stakeholders. The second company reported a similar effort although the responsibility for the program resided in the Vice President of Global Corporate Responsibility in partnership with HR. Two other major stakeholders included Vice President of employee self-service and IT services. One stakeholder not yet brought in the CAF implementation in this particular company was Workers Compensation.
The responsibility of communicating information about the development and implementation for the CAF was primarily the responsibility of the leadership in HR or Global Corporate Responsibility. However, once the VP level were vested then they too shared this responsibility. In one of the companies, the CAF was promoted through regular factoids being sent and disability etiquette training provided to 80+ VPs. In this same company, when it was realized that employees were not requesting accommodation, a workplace enablement program was launched to make employees aware of the CAF. Numerous communication efforts were designed to increase knowledge including Enews sent to all employees. Global Corporate Responsibility and HR worked closely with stakeholders to communicate messages about the program.
The biggest challenge reported by this particular company was that of cultural change. The CAF implementation team had a dedicated change management team who met frequently with the employee resource groups (ERG), human resource business partners, and hiring and functional managers. Every step of the way, communication flowed to the 80 VPs, the CEO, the Global Diversity and this communication was through various channels. The ERG also had the responsibility to carry the message. Reportedly, communication insured the big cultural shift that was necessary for CAF implementation.
Important to establishing this fund is setting a budget for the CAF. One of the CAFs was budgeted at $300,000 for the company of 22,000 employees. This budget was established after a pilot project with employees in a specific geographic area. The other company – a federal contractor with more than 65,000 employees - reported their budget being based upon 6% of the employees of that particular sector coming forward to request an accommodation. The company representative suggested developing the budget for the fund was much easier than first thought. Once it was developed then it was submitted to the federal government for approval. This approval was granted.
Central to establishing a CAF is the determination of accommodations to be covered. In one company, their initial fund in 2004 covered communication support, technology, and interpreters. The CAF expanded in 2010 now covers ergonomics, adjustments required of the company’s fleet of cars, and facility modifications. The second company interviewed provided all types of accommodation even considering a workplace personal assistance (WPAS), which is a form of accommodation not often offered by most employers. WPAS is most often offered in the case of external training. The employer would pay for the WPAS as well as any travel related costs such as hotels and meals.
After speaking about the fundamentals of establishing a CAF, I asked the company representatives about the process of accessing the CAF. Both companies used some form of reasonable accommodation tracking technology to manage the CAF. One company used SharePoint to track the accommodation but found that tool wasn’t robust enough because it did not allow for assigning roles. Now they use a segregated mailbox. The other company recently launched an employee accommodations portal for processing requests. This employee accommodations portal uses a customized version of the Simplicity software.
In talking further about the process for requesting an accommodation, both companies reported that requests came from various stakeholders of the organization. The request may come directly from the person with a disability, or from a hiring manager, supervisor, safety department, benefits, physical plant or even a disability vendor. Both companies respond to the request by asking for medical documentation to support the request if appropriate. In one company, requests would be followed up by asking the employee to sign a HIPAA form and then the person who needs the accommodation would be engaged in a conversation about what is needed and why. Once the accommodation request is clear then it is costed out. The request is then forwarded to the department responsible for implementing the accommodation. The final decision is then communicated to the employee with an estimated time frame for implementation. At this point, the employer representative communicates what is going to happen, why it needs to happen, and when it will happen. The accommodation is then charged against the centralized budget.
At the second company, the process for accessing the centralized fund starts with the employee making a request of their manager, service center, medical, or a request may be made directly to the Director of Diversity and Inclusion. In January of 2015, employees will also be able to go to a self-service accommodations portal. The system, says the employer representative, “takes a major headache off of the manager who does not have the expertise in this area.” The portal allows employees to answer a series of questions including if the person is a current employee, where they are located, and what kind of accommodation is being requested – a medical or a mobility accommodation. No diagnosis is required. The company only asks for limitations. The self-service portal contains an array of tools to be requested. This includes services. For instance, an ergonomic assessment is requested then a request for such a service is sent to the Diversity & Inclusion employer representative who will approve the request and then refer the person to a telephonic ergonomic firm that has been contracted to provide an assessment. Depending upon whether an employee discloses a medical or mobility accommodation, the company may or may not engage the employee in a formal reasonable accommodation meeting.
It was interesting to me that neither company reported a challenge related to the purchase of the accommodation. I have heard often that companies were challenged to buy accommodations through their regular procurement system. Delays tended to be the largest challenge. But neither of the companies interviewed reported this problem. One company had an I-buy procurement system, which expedited the purchasing process. The I-buy system eliminates the need for invoicing. The only issue reported was that of purchasing Apps and other software posing a security risk. The company resolved this issue by developing a list of vetted Apps and software programs. The other company representative reported that they capitalize on relationships and partnerships with their technology, facilities, and equipment departments. And, all of these department have direct access to the centralized fund.
In conclusion, let me offer a few best practices in establishing a centralized accommodation fund valid for businesses of all sizes:
- Commitment from C-Suite or VP level is essential to legitimizing the CAF;
- Develop a team of change agents to manage the process of developing and implementing the CAF;
- Communicate to everyone involved the business case for what is being asked of them – it can be formal or informal – but everyone must know why a CAF is being instituted – communicate, communicate, communicate;
- Ask other industry leaders about their benchmarks; this will help in developing your CAF budget;
- Know what accommodation tools and services will be covered by the CAF;
- Harmonize your accommodations process with your CAF process this can bring consistency to your entire process;
- Use technology to track your accommodation requests even if it is as simple as an Excel spreadsheet;
- Consider an expedited procurement system, which again may be a dedicated credit card for accommodation purchases;
- And, bring all the stakeholders into the process from the beginning. Understanding everyone’s concerns and addressing these promptly vests them in the process.