The Accommodation and Reassignment Standard
One of the eligibility requirements for FERS disability retirement is that your agency must be unable to accommodate your medical condition in your current position or reassign you to a vacant position at the same grade or pay level for which you are qualified.
What Counts as Accommodation
Reasonable accommodation can include modified work schedules, telework arrangements, assistive technology, modified duties, or physical workspace changes. If your agency can make accommodations that allow you to perform the essential functions of your position, your disability retirement application may be denied.
The Reassignment Search
The disability-retirement reassignment inquiry concerns qualifying vacant positions in the same agency, at the same grade or pay level and tenure, in the same commuting area, for which you are qualified. The agency documents its accommodation and reassignment certification on SF 3112D; SF 3112B is the supervisor's statement. Do not confuse this inquiry with the full range of separate reasonable-accommodation obligations.
Common Agency Issues
Some federal employees encounter resistance from their agencies during this process:
- Agencies that delay processing paperwork
- Supervisors who refuse to complete the SF 3112B accurately
- HR offices unfamiliar with the disability retirement process
- Agencies that offer inadequate accommodations and claim the issue is resolved
Documenting Agency Failures
Keep detailed records of every accommodation request, every response (or lack thereof), and every interaction with your agency regarding your condition. If your agency fails to engage in the interactive process or provides inadequate accommodations, this documentation supports your claim.
Your Rights
Remember that you have the right to file for disability retirement regardless of your agency's cooperation. Current OPM instructions direct current employees to start ORA through HR and former employees to apply directly through ORA. Required agency documents remain important after separation. If agency delay threatens a filing deadline, contact OPM promptly and seek qualified assistance; do not assume an unfinished request protects the deadline.