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Vaccine Exemptions & ADA Accommodations

COVID-19 Vaccines Required for Faculty & Staff

President Burwell announced on May 24, 2021, to ensure the health and safety of our community AU will require COVID-19 vaccinations for faculty and staff. All faculty and staff must complete the vaccine attestation form or request an exemption to the vaccine requirement by August 1, 2021. 

The University has developed a procedure for vaccine attestation and for requesting a medical or religious exemption that follows recent guidance from the Centers for Disease Control, DC Department of Health, and Equal Employment Opportunity Commission. For more information, please review the university’s Mandatory COVID-19 Vaccination directive and the frequently asked questions about vaccinations can be found on the University’s Health & Safety FAQs page. 

Contact hrpayrollhelp@american.edu for more information.

Vaccine Exemptions

Exemptions to the vaccine requirement will be considered for individuals with medical conditions that prevent them from being vaccinated and for individuals with sincerely held religious beliefs that prohibit them from being vaccinated, consistent with federal and DC law. Employees on approved leave will follow a revised attestation/exemption deadline and be required to submit the vaccine attestation within 30 days of returning from leave status. Those employed through nextSource will be excluded from the requirement because they do not have a campus presence. 

Exemption requests will be reviewed by HR Employee Relations, and employees will receive a confirmation that their request is in process within three business days. HR will work with Prudential Insurance Disability Services to assist with reviewing exemption requests due to a medical condition. 

Employees will be expected to comply with additional health and safety requirements including, but not limited to, weekly COVID-19 testing and required masking while on campus. 

Retaliation, intimidation or other adverse action related to the employment or education against an employee who requests and/or receives an exemption is inconsistent with AU’s values and prohibited by University policy. The vaccine requirement and associated exemption process supports the health and safety of our community and is designed to assist all members of the community.

Workplace Reasonable Accommodations

Faculty and staff will be returning to the classroom and to their offices on campus in the fall. Those requiring an accommodation due to a disability or medical condition to allow them to perform the essential functions of their job should complete the Reasonable Accommodation Request Form. Accommodations may include but are not limited to additional or enhanced protective measures, temporary modifications of work schedules, or revised office space. Generally, accommodations will not include remote work for duties that require campus presence. Accommodations are applicable for the employee only. Employees seeking modified schedules to care for a family member or other household members who are immune compromised may explore Family Medical Leave.

If you wish to request an accommodation due to a disability or medical condition, please complete the Reasonable Accommodation Request Form. Your request will be reviewed by HR Employee Relations and Prudential Insurance Disability Services who assists the University with reviewing reasonable accommodation requests and providing recommended accommodation options. HR will notify you of the outcome of your request. Medical accommodation documentation previously submitted to Prudential from fall 2020 to the present may be used to expedite the evaluation of a request for fall 2021.

Any request for a reasonable accommodation due to a disability or medical condition will be kept in the strictest of confidence and maintained in a separate file and will only be available to designated Employee Relations staff in the Office of Human Resources. Human Resources will seek input from the employee's supervisor, who has knowledge about the duties of the position and worksite, to help determine the feasibility and what may be a reasonable accommodation.

If you have any questions about these processes, please email employeerelations@american.edu.

ADA Reasonable Accommodation FAQs

What is a reasonable accommodation under the Americans with Disabilities Act (ADA)?

A reasonable accommodation is a modification or adjustment to the work environment or the way job is customarily performed that enables a qualified individual with a disability to perform the essential functions of their position. A reasonable accommodation under the ADA is for an employee’s own medical condition.  

What are essential functions? Where can I find the essential functions of my position?

Essential functions of a job are the basic position responsibilities that an employee must be able to perform with or without a reasonable accommodation. For staff, essential functions are found in their job description.

When should I submit a request for a reasonable accommodation for fall 2021?

An employee can submit a request for a reasonable accommodation at any time. 

What is the role of Prudential Insurance in this process?

The University works with a third-party disability administrator, currently Prudential, to assist with reviewing reasonable accommodation requests and providing recommended accommodation options. Employee Relations will submit AU employees’ requests for accommodation to Prudential who will provide the employee with forms for their medical provider to confirm their condition and requested accommodations. Prudential will then recommend accommodation options to AU HR. If you are having any challenges communicating with Prudential, please notify Employee Relations immediately. 

How long does this process take? Is there any way to expedite?

Depending on the unique circumstances of a request, requests for a reasonable accommodation may a few weeks to process. Prudential may utilize medical documentation submitted in fall 2020 to expedite the review process. If you anticipate that you will need to see your doctor or have any medical tests to substantiate your accommodation requests, we suggest you coordinate with your doctor as soon as possible.  

How will the medical information I provide be protected?

Any request for a reasonable accommodation due to a disability or medical condition will be kept in the strictest of confidence. Information regarding any medical conditions or history will be treated as a confidential medical record and maintained in a separate file and will only be available to designated Employee Relations staff in the Office of Human Resources.

What is the interactive process?

Upon learning of the possible need for a reasonable accommodation under the ADA, the University will engage in a process in which the employee, health care provider and Human Resources each share information about the nature of the disability and the limitations that may affect the employee's ability to perform the essential job duties. This process is referred to as the interactive process and involves a good-faith effort by the University and the employee to discuss the limitations or issues the disability may pose. The purpose of this discussion is to determine what (if any) accommodations may be needed. 

Who decides whether to approve an accommodation?

The University, through its third-party disability administrator, will assess if the employee has a disability under the ADA and determine what accommodations, if any, are necessary to help the employee meet the essential functions of their job. An accommodation can be a change or modification to the workplace, allowing the employee with a disability to perform their essential job. Human Resources will engage in the interactive process until we find the accommodation(s) that meets the needs of the employee and does not create an undue hardship on the University. Human Resources will seek input from the employee's supervisor, who has knowledge about the duties of the position and the worksite, to help determine the feasibility and what may be a "reasonable" accommodation.

How will I learn if my request has been approved?

Human Resources, or the University’s third-party disability administrator, will notify the employee in writing that their requested accommodation has been approved or denied. Details of the accommodation and the anticipated start date shall be included. The accommodation process is not set in stone and may need to be reviewed, especially if an employee's disability changes or the needs of the department change. 

Is an employee entitled to an accommodation under the ADA in order to avoid exposing a family member who is at higher risk of severe illness from COVID-19 due to an underlying medical condition?

No. Although the ADA prohibits discrimination of an individual with a disability, the ADA does not require that an employer accommodate an employee without a disability based on the disability-related needs of a family member or other person with whom they are associated. For example, an employee without a disability is not entitled under the ADA to telework as an accommodation in order to protect a family member with a disability from potential COVID-19 exposure. Employees may explore FMLA or other leave options in situations where they feel unable to return to work because they need to care for a family member.

When the University resumes campus presence in the fall, will employees automatically be granted telework as a reasonable accommodation to every employee with a disability who requests to continue this arrangement as an ADA/Rehabilitation Act accommodation?

No. Any time an employee requests a reasonable accommodation, the employer is entitled to understand the disability-related limitation that necessitates an accommodation. If there is a disability-related limitation, but the University can effectively address the need with another form of reasonable accommodation at the workplace, then the University can choose that alternative to telework.

The fact that the University extended telework for the purpose of protecting employees’ health and safety from COVID-19, and chose to permit telework even if job duties did not lend themselves to telework in all cases, does not mean that the University will permanently change a job’s essential functions as an accommodation on a going forward basis. Telework is not generally a feasible accommodation for duties such as teaching or other staff functions that are performed on campus.