Across the federal workforce in 2026, one collision keeps surfacing: return-to-office mandates running into employees' medical accommodations. If you have a condition that made telework or a modified schedule workable, and that arrangement is now in question, it is worth understanding how this moment intersects with FERS Disability Retirement — and, just as importantly, where the two are not the same thing.
Return-to-office and accommodation
Return-to-office policy does not eliminate the Rehabilitation Act’s reasonable-accommodation requirements. OPM and EEOC issued joint guidance on February 11, 2026 explaining that agencies may reassess past telework accommodations and request appropriate supporting evidence. Decisions depend on the employee’s disability-related needs, essential duties and available effective accommodations.
What OPM's guidance actually says
This is the part worth knowing before you react to anything, because it cuts in two directions at once.
Agencies cannot take a blanket approach to rescinding telework accommodations. Each has to be an individualized determination — a categorical policy that sweeps away existing accommodations without assessing them one by one is not what the Rehabilitation Act contemplates.
At the same time, employees are not entitled to telework indefinitely, and agencies are permitted to reassess previously granted accommodations. An arrangement that was approved in 2021 is not immune from review in 2026.
So "they can't take this away" is wrong, and so is "they can do whatever they like." What the law requires is an individualized, interactive process — and whether your agency actually conducted one is a question worth documenting carefully as it happens, not reconstructing later from memory.
Two different tracks — don't confuse them
Reasonable accommodation under the Rehabilitation Act is about keeping you in your job by modifying how the work gets done, unless doing so would impose an undue hardship on the agency.
FERS Disability Retirement is a separate benefit for when your medical condition means you can no longer render useful and efficient service in your position, subject to the separate statutory and regulatory eligibility requirements.
One tries to preserve the job. The other applies when the job is no longer possible. Pursuing an accommodation — or an EEO complaint if one is wrongly denied — is a distinct process, often attorney or EEO territory, from applying for disability retirement.
Why the accommodation question is built into the disability retirement test
Here is what ties the two together, and why the order of your decisions matters so much.
FERS Disability Retirement eligibility specifically requires that accommodation of your condition in your position would be unreasonable (5 CFR § 844.103(a)(4)), and that you have not declined an offer of reassignment to a vacant position in the agency, within your commuting area, at the same grade or pay level and tenure, for which you are qualified and able to render useful and efficient service (§ 844.103(a)(5)).
In other words, the record of what your agency could or could not do to keep you working is not a side issue. It is an element OPM evaluates directly.
That cuts both ways. If an agency genuinely cannot accommodate your medical restrictions, that fact can support a disability retirement case. But if you turn down a reasonable reassignment that would have worked, that can be disqualifying. How an accommodation was requested, how the agency handled it, and how all of it was documented are not administrative details — they become evidence.
The medical documentation has to speak in terms of function
Whatever track you are on, the medical record does the heavy lifting. It needs to show the specific restrictions, how they conflict with your actual duties — including any in-person requirement now being imposed — and that the condition is expected to persist for at least one year from the disability-retirement application filing date (§ 844.103(a)(3)).
A physician's letter saying you cannot work is a conclusion. What OPM needs is the reasoning: which functions, which limitations, and what clinical basis supports them.
Where this leaves you
If a return-to-office order is pushing against real medical limits, you have decisions to make in a particular order, and getting them out of order can cost you options. Declining a reassignment without understanding § 844.103(a)(5) is the clearest example.
Before you react, it is worth mapping where you actually stand: whether accommodation, reassignment, or disability retirement fits your facts, what your medical record needs to say, and what to document while it is still happening rather than afterwards.
That mapping — an honest read and a written plan — is what a strategy consult is built for. And if your situation turns out to need an attorney, whether for a denied accommodation or an appeal, I will tell you that plainly rather than take the work.
Educational only — not legal advice, and not a determination of your eligibility, which rests solely with OPM. Rules and agency policy in this area are changing quickly; verify current requirements against official OPM guidance and your own agency's correspondence.