ARCHIVED - Evaluation of the Policy for the Provision of Services for Employees with Disabilities - Number 4

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Evaluation of the Policy for the Provision of Services for Employees with Disabilities

Executive Summary

Management's Response

1. Introduction

2. Continued Relevance of the Policy

3. Implementation of the Policy

4. Results of the Policy

5. Conclusions

6. Suggestions for Improvement

Appendix 1

Appendix 2

Executive Summary

The policy to provide technical aids and specialized services to federal employees with disabilities was evaluated at this time in keeping with the Treasury Board's general practice of reviewing all its public service-wide policies one every six or seven years. The policy which was the subject of this evaluation was introduced in 1989 and had not been reviewed since that time.

The objectives of the evaluation were to determine if, as a result of the policy, the needs of federal public service employees with disabilities are being reasonably accommodated, if these employees and other persons involved in its implementation are aware of the policy and its provisions, if proper administrative procedures are being followed and records kept.

Interviews with a representative sample of policy stakeholders in nine federal departments and agencies were the principal means used to gather information and informed views about the policy and its implementation. Policy stakeholders included the original designers of the policy, the Officer of Primary Responsibility in the Treasury Board Secretariat, Employment Equity Coordinators, supervisors and managers of persons with disabilities and employees with disabilities themselves. Sixty-eight interviews in all were conducted, 46 of them with employees with disabilities.

The original rationale for the establishment of the policy in 1989 was found to be still relevant in today's circumstances. The evidence to support this conclusions is based on both political and demographic considerations. The President of the Treasury Board, in his Annual Report to Parliament, has indicated that his government continues to be committed to the application of the principles of Employment Equity in the public service of Canada and, has made specific reference to the relevance of this particular policy, among others, in achieving the government's goals in this area. In addition, the demand for the types of services offered by this policy can be expected to grow, rather than decrease, in the future, as the incidence of disability associated with an aging public service increased. The fact that a significant number of employees state that they need the policy in order to carry out their responsibility in the workplace, also attests to its continued relevance.

The policy, as written, was considered by respondents to be generally clear and understandable, except for the references in it to "reasonable accommodation" and "undue hardship". The majority of Employment Equity Coordinators and managers of employees with disabilities felt that the meaning of these terms needed to be further explained, through a re-writing of the policy or, through the use of supplementary case studies.

As regards implementation, the policy has not been regularly communicated in its totality to policy stakeholders in the departments. Few managers of employees with disabilities were aware of the policy before being asked to accommodate employee needs. The vast majority of employee respondents with disabilities had heard about the policy, had benefited from it, but had never actually seen it.

With few exceptions, the employee with a disability, his or her manager, and the Employment Equity Coordinator, together, are regularly involved in decisions to accommodate need. Respondents felt that this practice was essential for effective results.

The role of the Employment Equity Coordinator in decisions to accommodate need to advise on the procedures to be followed in accommodating need, to identify and, in some cased, to facilitate contacts with key personnel in the department and in the Diversity Management Technology Centre in the Public Service Commission. Respondents agreed that this role for the E.E. Coordinators was an appropriate one and should be exercised pro-actively.

Most respondents felt that the Diversity Management Technology Centre was providing a very worthwhile service to the departments in providing loans of technical aids and in testing technical aids. Some respondents felt that more attention needed to be given to the testing of software application for technical aids.

Arrangements for following up on accommodations made for employees with disabilities to ensure that they are truly meeting his or her needs, were found to be informal, but, nevertheless, were considered to be adequate for the purpose. Arrangements for the monitoring of requests for accommodation and for reporting on departmental responses to these requests appear to be satisfactory.

Departmental funds for the purchase of technical aids and specialized services are managed somewhat differently from department to department. These arrangements, however, appear to be satisfactory from a financial accountability standpoint.

Departments report that, to date, they have had sufficient funds in their budgets to meet accommodation requirements. However, virtually all stakeholders of the policy expressed concern about their department's ability to meet need in the future, as budgets are further reduced.

Overall, the policy is achieving the objectives set for it, in that the needs of a significant number of employees with disabilities are being reasonably accommodated and as a result, they are able to perform their responsibilities in the workplace in satisfactory manner. Approximately 75% of respondents, who are employees with disabilities, felt that their needs had been met in a satisfactory and timely manner.

The range and diversity of accommodations capable of being made under the policy are extensive. Virtually all types of disabilities among employees are being addressed, indicating that the policy is quite a flexible instrument for accommodating need.

Roughly 20% of respondents in the employee group were dissatisfied with the policy and/or its implementation. Delays in providing the technical aids requested was the reason most often cited by this group.

About 5% of employees with disabilities expressed disappointment with the policy because it did not address their career aspirations. This latter group were under the impression that the policy is intended to address not only the need for technical aids and specialized services, but their advancement in the public service as well.

With respect to alternatives, most respondents agreed that more training should be given to E.E. Coordinators and managers, so that they might respond in a timely and fitting manner to the work-related needs of employees with disabilities. Respondents felt that the training should address both the need for sensitivity to the problematic of disability in the workplace and knowledge of the procedures to be followed in acting upon employee requests.

Management's Response

The results of the evaluation were quite positive. Overall, the policy is meeting the objectives set out for it and the consensus of managers and employees interviewed during the evaluation was that the needs of a significant number of employees with disabilities are being reasonably accomodated with the assistance of this policy.

This report will serve as the basis for a review of the Provision of services to employees with disabilities Policy including the administrative and communication aspects surrounding its implementation. However as only minor adjustments were recommended in the evaluation, no significant modifications to the policy are expected.

Comments

This evaluation was completed in March 1995.

1. Introduction

1.1 Background

The present policy to provide services for federal public service employees with disabilities came into force in 1989.

The policy, which is intended to eliminate barriers that might otherwise prevent employees with disabilities from functioning effectively in the Public Service, has now been operational for approximately five years. In keeping with its practice of reviewing all its policies on a regular basis, the Treasury Board now wishes to ensure that the policy is achieving and will continue to achieve the objectives that have been set for it.

1.2 Purpose of the Evaluation

The purpose of the evaluation was to:

Determine whether the needs of Federal Public Service employees with disabilities are being reasonably accommodated;
Evaluate the effectiveness of the information/communications links between TBS, PSC and the Departments in bringing the existence of the policy to the attention of employees with disabilities;
Identify the strengths and weaknesses of the policy and suggest how it might be improved upon or an alternative system adopted to meet the needs of employees with disabilities more efficiently and effectively;
Assess the extent to which personnel officers in the departments are aware of the policy, the level of use of the policy and how accommodation is being funded; and
Determine whether departments are maintaining the required records of employees who have been provided attendant or other specialized services and the nature and cost of the services provided.

1.3 Methodology

The principal activities involved in carrying out the evaluation were:

- File and Documentation Review;
- Interviews;
- Information/Data Analysis and Synthesis;
- Draft Final Report and Working Session with Employment Equity Coordinators;
- Final Report Preparation; and
- Project Management.

The following is a description of the work undertaken under each of these activities.

1.3.1. File and Documentation Review

A number of departmental files and other documentation were reviewed and their contents noted for their relevance to the purposes of the study. A bibliography of these documents is presented in Appendix 1 of this report.

1.3.2 Interviews

Interviews were the principal means used in the study to gather information and informed views on all of the issues listed under 1.2, above.

Interviews were conducted with five groups of interviewees, namely, the designers of the original policy, the Officer of Primary Responsibility in the Treasury Board Secretariat, Employment Equity Coordinators in selected departments, supervisors and managers of employees with disabilities and, employees with disabilities. In all, approximately 67 interviews were carried out. The number of interviews conducted with each group of interviewees is presented in

Table 1-1.

Table 1-1: Interviews by Groups of Respondents

Interviews by Groups of Respondents
Groups	Number of Interviewees
Designers of Original Policy	2
Treasury Board OPR	1
Employment Equity Coordinators	13
Supervisors and Managers	6
Employees with Disabilities	46

Interviews were conducted in nine federal departments, representing a cross section of large, medium sized and small departments, as follows:

Large Departments

- Public Works and Government Services
- Transport Canada
- Revenue Canada
- Health Canada

Medium-Sized Departments

- Indian and Northern Affairs Canada
- CIDA
- Fisheries and Oceans
- Natural Resources

Small Departments

- National Library/National Archives

Interviews were conducted in Ottawa and in regional offices in Edmonton and Halifax over the three-month period of the study. The interviews with respondents in Edmonton were carried out by telephone. All other interviews were conducted in situ.

An attempt was also made to select employees possessing a cross-section of disabilities in the Federal Public Service. Table 1-2. indicates the range of disabilities involved and the number of persons interviewed with respect to each.

Table 1-2: Disabilities Represented in Interview Sample

Disabilities Represented in Interview Sample
Disability	Number of Persons Interviewed
Visually Impaired	13
Mobility Impaired	18
Hard of Hearing	8
Psychiatric Disability	1
Epilepsy	1
Dyslexia	1
Arthritis	2
Developmental Disability	1
Multiple Disabilities	1

Approximately 25% of interviewees with disabilities identified more than one form of impairment.

To preserve the anonymity of all who provided information and informed views during the interviews, no list of interviewees is presented in this report.

Separate interview guides for each of the groups to be interviewed were prepared, tested and approved by the client before being put into use. A copy of the Interview Guides can be found in Appendix 2 of this report.

1.3.3 Information and Data Analysis and Synthesis

Following the completion of the interviews and the review of files and documentation, the study team conducted an analysis of the information gathered through these activities and prepared a synthesis of the most important findings and tentative conclusions derived from the research activities specified in Section 1.2 of this report. The latter are grouped under the four principal evaluation issues, namely:

- Continued relevancy of the policy;
- Implementation of the policy;
- Results/Success of the policy; and
- Conclusions and Suggestions for Improvement.

The findings and tentative conclusions of the study were then converted to a draft final report and shared in a half-day discussion with a cross section of the Employment Equity Coordinators who had participated in the study. This exercise was carried out to clarify certain of the findings of the study and to elicit their reaction to the tentative conclusions and recommendations emerging from the interviews and the file and documentation reviews.

1.3.4 Final Report Preparation

Following the group discussion, a Final Report was prepared and submitted to the client in three copies, with all working papers.

1.3.5 Project Management

Contacts were maintained with the client throughout the study to receive information on the schedule of interviews. Mid-way through the interview task, a meeting was held with the client to brief on the tentative findings and to pick up on questions raised by the client.

1.4 Limitations of the Study

In the time available, it was not possible to interview persons in all regions of Canada. To that extent, the findings cannot be said to be representative of a cross section of views in all regions of Canada.

Employees with certain disabilities, such as profound deafness, psychiatric disability and epilepsy were under-represented in the total sample of employees. As a result, the study findings and conclusions may not adequately reflect the experience of these groups with the policy.

1.5 Report Structure

The report contains six chapters, including the Introduction (Chapter 1).

Chapter 2 presents the findings of the study with respect to the question of the continued relevance of the policy in today's circumstances.

Chapter 3 reports on the implementation of the policy.

Chapter 4 describes the results of the policy.

Chapter 5 contains conclusions about the strengths and weaknesses of the policy.

Chapter 6 offers suggestions as to how the policy and its implementation might be improved and suggests measures to improve it.

2. Continued Relevance of the Policy

In assessing the issue of the continued relevance of the policy, we sought evidence of:

Official statements by the Government attesting to its continued commitment to Employment Equity and specifically to this policy;
Growth or decrease in the number of employees with disabilities since the inception of the policy in 1989;
Growth or decrease in the demand for the services provided under the policy, since the inception of the policy in 1989; and
Opinions expressed by current users of the policy concerning the need for the policy in the future.

2.1 Government's Continuing Committment to Employment Equity

In determining the Government's continuing commitment to its policy on Employment Equity, we examined a number of official Treasury Board documents thought to be most relevant to this subject. The following is a quote from the Annual Report 1992-93 of the President of the Treasury Board to Parliament, which we would consider to be the most authentic evidence of the Government's continuing commitment to Employment Equity:

"The government is committed to the principles of employment equity in the Public Service, as is illustrated by the variety of programs discussed in this report. I believe that, overall, employment equity programs in the Public service have served Canadians well. They have helped to make the Public Service more representative of the Canadian public it serves and, therefore, contribute to the strength of Canada in its rich diversity. These programs have, as this report describes, already played an important role and I am confident that they will continue to do so.⁽²⁾

Specific reference is made in the President's report to the Treasury Board policy to provide technical aids and other specialized services to federal government employees with disabilities. We regard this reference, therefore, as an authoritative indication of the Government's commitment to continue to apply the policy in the future.

2.2 Growth or Decrease in number of Employees with Disabilities

The growth or decrease in the number of employees with disabilities in the federal public service over the lifetime of the policy was also examined as a possible indicator of the continued relevance of the policy in today's circumstances. A substantial increase in the number of such persons in the federal public service over this period of time could argue for a continuing need for the policy. A diminution in the numbers might imply that the need for the policy is less urgent today that it was in 1989.

The statistical data on the number of federal public service who identified themselves as having a disability, on a year-by-year basis in the period 1989-1994 is taken from the 1992-93 Report of the President of the Treasury Board to Parliament. The data indicates than the number of these employees increased from roughly 5,939 as of December 1989 to 6,623, as of March 31, 1994. The latter figure is slightly lower that the total as of March 31, 1993 and is proportionally lower than the increase for other special groups in that period. We were unable to find a satisfactory explanation for this anomaly.

2.3 Growth or Decrease in Demand

From a demographic standpoint, a very large percentage, if not the majority, of federal public servants today, fall into the baby-boomer or older age group. It is a well-established fact that the incidence of illness and disability, in some form, increases with age. It is also known that most serious long-term disabilities tend to be progressive. Employees in this category increasingly require technical aids and/or specialized services in order to function effectively in the workplace as they grow older. This suggests that the need for this policy in the federal public service will increase, rather than decrease, in the years ahead.

As noted later in this report, there are considerable differences among the departments included in our study with respect to organizational arrangements for accommodating the special needs of employees with disabilities and in the information gathered annually on both expenditures and service activities provided under the policy. For example, in some of the larger departments accommodations may be worked out and expenditures made for employees with disabilities, without reference to E.E. staff. Even among small departments, there are differences in terms of what information is gathered and reported. As a consequence, it is not possible to present data that would indicate, clearly and completely, the growth or decrease in the demand for service under the policy since its inception in 1989.

The interviews with employees with disabilities conducted during the study provide perhaps the best indication of the continued relevance of the policy and its attendant services. The following comment, or variations on it, was heard often during these interviews:

" I have synthetic speech on my computer. I also have reading services about 15 or 20 hours each week. Students or retired people read the most important documents to me. Without these things, I couldn't do my job."

In summary, statements made by the President of the Treasury Board in his annual report to Parliament for the years 1992-93 and 1993-94 appear to confirm the Government's intention to continue to apply the policy, at least for the foreseeable future. Consumers of the services provided under the policy also attest to its importance for their continued participation in the public service workforce and their integration into the mainstream of Canadian society. We conclude from this, therefore, that the policy continues to be relevant in current circumstances.

3. Implementation of the Policy

3.1 Introduction

In this chapter we present our findings concerning the implementation of the policy. The findings are arranged to respond to the following evaluation activities prescribed in the Terms of Reference for the study:

Assess the extent to which personnel officers in the departments are aware of the policy, the level of use of the policy and how accommodation is being funded;
Evaluate the effectiveness of the information/communications links between TBS, PSC and the Departments in bringing the existence of the policy to the attention of employees with disabilities; and
Determine whether departments are maintaining the required records of employees who have been provided attendant or other specialized services and the nature and cost of the services provided.

Our findings are grouped under the following headings:

Awareness of the Policy;
Communication and Understanding of the Policy;
Decision Regarding Appropriate Accommodation;
Follow Up on Accommodation Provided;
Training; and
Financial Accounting, Monitoring and Accountability.

3.2 Awareness of the Policy

In assessing awareness of the policy, we questioned not only personnel officers of the departments, but Employment Equity Coordinators, supervisors and managers of persons with disabilities, as well as the users of the policy, namely, employees with disabilities.

The question put to respondents in all groups in this connection was essentially the same:

"Are you aware of the T.B. policy for the provision of services for employees with disabilities? Could you describe how and when you first learned about the policy?"

Not surprisingly, personnel officers and Employment Equity Coordinators who had been in their jobs for a considerable period of time were familiar with the policy and could say whether or not their department had developed its own policy, based on the T.B. policy. The following comments are typical of the answers given by this group to the question:

"I knew the policy existed because, previously, I was an E.E. Coordinator for five years."

"I realized its existence when I started here about three years ago. We are in the process of developing a policy exclusively for the disabled. It's going before the Executive Committee this week."

Respondents in this group, who had only recently begun to work as personnel officers or as E.E. Coordinators, were less likely to be aware of the policy, as is indicated in the following comment:

"I learned about the policy about three weeks ago, when I was moved into this job. My portfolio is with Special Needs."

The size of the department did not seem to be a significant factor as far as awareness of the policy by persons in this group is concerned.

Understandably, personnel officers engaged in the staffing function in the departments were more likely to be aware of the policy that those involved in the classification function.

A few E.E. Coordinators indicated that they knew about the policy but were uncertain as to whether they had ever seen it or read it.

Supervisors and managers of employees with disabilities varied greatly in their awareness of the policy, as the following comments illustrate:

"I was aware there was a policy, but I've never seen it." and,

"I'm a manager. I'm still not aware of the policy, although I supervise several employees with disabilities. I don't know who the E.E. Coordinator is."

Supervisors and managers in the larger departments were less likely to be aware of the policy and to know whether their own department had developed its own policy to reflect the T.B. policy, than those in the smaller departments. It should be stressed, however, that lack of awareness of the policy by supervisors and managers does not mean that the policy is not being carried out, as is shown below in this report.

Awareness of the policy among employees with disabilities varied considerably. As might be expected, those with severe disabilities and who had been in the Public Service for some period of time were much more likely to be aware of the policy than those with lesser disabilities and fewer years of service. There are several reasons for this. For one, those with severe disabilities are also those who use the provisions of the policy in order to be able to function effectively in their jobs. This is also the group who witnessed and may have even been involved in the creation of the current policy in 1989 and the predecessor policy of earlier years. Some are or were members of one or more of the committees that exist within and across departments to advise senior management and ministers on the needs of employees with disabilities. In addition, this group tend to be "plugged into" the disability community in Ottawa and throughout Canada and are, therefore, up-to-date on a broad range of matters affecting their members.

Overall, the vast majority of employee respondents with disabilities had heard about the policy, had benefited from it, but had never seen or read it. The following is typical of the types of responses we received from this group:

"I don't think I have ever seen or read the policy, but I don't see this as a problem for me." and,

"I think I always knew about the policy. I've been with the government for 19 years (several places) but I haven't seen the policy in the last year or so."

In many cases, employee respondents did not differentiate between this particular T.B. policy and other policies affecting employees with disabilities, as the following comment illustrates:

"I've never heard of the policy, but in the last six or seven years or so they've made washrooms accessible."

3.3 Communication and Understanding of the Policy

Several questions were used to elicit comments from Employment Equity Coordinators, supervisors and managers of employees with disabilities and employees with disabilities themselves, on the frequency with which the policy is communicated within their department, the modes of communication used and, the extent to which the contents of the policy are understood.

The questions used to explore the issue of the communication of the policy were:

"Is the policy regularly communicated to persons with disabilities? Are alternative formats used?" (all interviewees)

"Do you communicate the department's willingness to provide services of an attendant, work-related technical aids, office modification or modified work instruments, or other specialized services or assistance, if required by employees with disabilities? How do you carry out this communication? (E.E. Coordinators)

Employees with disabilities and supervisors and managers of employees with disabilities believed that the policy was rarely communicated to them by their organization, as is obvious from the fact that only a few had ever seen the policy. This view was shared by employees with temporary disabilities as the following comment indicates:

"I didn't learn about it through the Department (i.e departmental management). I learned about it through my Union." and,

"The policy is certainly not communicated to persons with temporary disabilities." and,

Employees with disabilities, almost without exception, felt that they should be given a copy of the policy. One employee expressed her views on this point as follows:

"If I identify myself as a person with a disability, why should I not be given a copy of the policy?"

Supervisors and managers of employees with disabilities, as a group, while very supportive of the intent of the policy, did not expect to receive a copy of it, nor to be actively involved in communicating it to these employees. The following comment from one manager is the way this opinion was most often expressed by respondents in this group:

"The only thing I would do (i.e. to communicate the policy) is that if we get something from the E.E. Coordinator via the E Mail, I would flow it down to my staff."

A few E. E. Coordinators held somewhat similar views on this question. The following is fairly characteristic of the responses received from this group on this point:

"The policy is there, but we don't really communicate it. I think it would be a good idea to do this now and again."

Several E.E. Coordinators were quite proactive in communicating the policy in a manner that would reach all employees with disabilities, but recognized that this needed to happen more often and to be more effective, as the following comments show:

"We communicate the policy to employees with disabilities, using alternate formats, but we're trying to find a more effective way of doing it. Our internal policy will be sent to all employees and some will be put in braille, on request. Our communication will let employees know that they can get in touch with us if they want it in alternate formats. Also, the D.M.'s Newsletter, which is published every two months, will have a piece on the policy from time to time". and;

"When new people come to the department they are told about it. We are small enough to do this. Also, its part of the culture of this place. We have our principles and values and that's where it comes from. It (the policy) has presence. It's a question of whether you need to know. The policy should always be communicated at a practical level."

The matter of how well the policy is understood was explored with E.E. Coordinators, supervisors and managers and with employees themselves through two principal questions:

"Do you find the policy and the arrangements for its implementation readily understandable, or did you need to ask for clarification of all or some of its provisions? If the latter, which of the provisions or implementation measures did you find most difficult to understand? (all respondents) and,

"Do you recall which provisions of the policy or which aspects of the implementation of the policy evoke the greatest number of questions by employees with disabilities?" (E.E. Coordinators, supervisors and managers)

Respondents among employees with disabilities had very few comments to make on this subject, for the obvious reason that few of them had ever seen the policy. Those few who chose to comment on this question, thought that the policy itself was quite clear but that sometimes supervisors, managers and new E.E. Coordinators did not know how to act on requests for service. The distinction here is between the clarity of the policy and the procedures to be followed in responding to requests, as the following comment illustrates:

"The policy itself is clear, as I know it, but it isn't always implemented properly. I think generally they (managers) might know it, but they're frustrated by the bureaucratic arrangements they have to follow. There should be a manual to help managers handle requests."

Generally speaking, the more experienced E.E. Coordinators tended to have less difficulty understanding the policy than those who were newly assigned to this task. However, almost all respondents in this group felt that the policy was unclear with respect to the meaning of "reasonable accommodation" and "undue hardship". The following were typical of the comments made by these respondents on this aspect:

"The terms 'reasonable accommodation' and 'undue hardship' are too vague. They give us the most trouble."

When asked how this part of the policy could be made clearer, most of these respondents felt sample cases should be prepared and made available to them to guide them in determining "reasonable accommodation" and "undue hardship". A few respondents felt that Treasury Board staff should know their policies better so that they could provide more guidance to the departments. A small number felt that these terms should be simply and clearly defined in the policy itself.

3.4 Decision Regarding Appropriate Accommodation

The policy is prescriptive concerning the role that E.E. Coordinators, supervisors and managers are to play in determining and meeting the needs of employees with disabilities. In substance, the policy requires the former group to:

Consult with employees with disabilities and, where appropriate, medical authorities and rehabilitation consultants, to determine the need for attendant services, technical aids or other specialized services or accommodation; and,
Communicate their willingness to provide the services of an attendant, work-related technical aids, or other specialized services or assistance if required by employees with disabilities.

A series of questions were used to explore these requirements of the policy, the principal of which were:

"How is the decision made as to the most appropriate accommodation for the employee with disability? What is your role in this decision-making process?"

Since the policy also assigns a degree of personal responsibility to employees with disabilities in meeting their needs, we used the following questions to assess their contribution to decision-making:

"Have you made use of the policy? If so, did you identify your employment-related needs to your supervisor(s) or manager(s)? Could you describe the point at which you made known your needs?"

"Were you asked what accommodation you felt was most appropriate for your needs? Could you describe how you went about providing this information?"

The study found that, with few exceptions, the decision to meet need regularly involves the employee with a disability, his or her supervisor or manager and, in many but not all cases, the E.E. Coordinator and the relevant program or operational director.

External medical personnel are sometimes called upon to provide information and advice in assessing an employee's physical capacity in more complex cases and his or her need for a particular type of technical aid. The Diversity Management Technology Centre (DMTC) in the Public Service Commission also plays an active role as advisors in the choice of technical aids. This organization also regularly provides technical aids on loan to the departments to test the suitability of the equipment in specific cases.

The majority of the employees with disabilities who mentioned the DMTC felt that it was offering a very useful service in providing technical aids on loan and in testing out the usefulness of technical aids. Several employees in this group felt, however, that the time required to test some software packages was unduly long. Some employees have been unable to carry out their responsibilities for periods of up to six months while adaptive software packages, such as voice systems, were being tested. We were not able to explore these cases further in the time available.

Only two respondents in this group felt that the technical aids were not keeping apace with technical advances in this field.

Representatives of the Centre, when interviewed on their role under the policy, stated that some departments do not move as quickly as they might in purchasing aids for their employees once the need for aids had been demonstrated. This sometimes causes problems for the DMTC, in that the aids may not be available to meet demand, because departments continue to request the extension of loans.

We encountered a few cases where outside consultants, such as the Neil Squire Foundation, were called in to advise on worksite modifications, as part of the decision-making process.

E.E. Coordinators generally saw their role as one of advisor in the decision-making process. The following comment is fairly representative of the position taken by the Coordinators on this matter:

"My role is to advise. I'm not an expert on technical aids. I inform managers of the steps they need to take. I advise the employee to consult with other persons with similar disabilities. The decision (to meet need) is up to the manager and the employee."

Managers and supervisors generally share this view. By and large, experienced supervisors and managers also understand that the employee's participation is essential in making such decisions, as the following comment indicates:

"The decision is made by the manager and the employee. We moved into new accommodation about a year ago and (the mobility impaired employee) was told that his office was going to be modified slightly. But the proposed plan was no good and had to be modified further, this time, with advice from (the employee). That's the way it should be done."

Decisions involving significant expenditures of money, usually for the purchase of technical aids or workplace redesign, require the authorization of a director and occasionally a more senior manager in the department.

E.E. Coordinators were virtually unanimous in their belief that employees with disabilities, who wished to take advantage of the policy, had the responsibility to make known their needs to their supervisors and managers, as part of the decision-making process. In a few cases, this was set down in departmental guidelines that had been developed to reflect the T.B. policy, as the following comments indicates:

"The decision involves the employee, the manager and the E.E. Coordinator together. The manager is responsible to know and the employee to tell."

Employees with disabilities, as a group, accept that they have the responsibility to make known their needs to their supervisors or managers and are taking this action as part of the decision-making process.

3.5 Follow Up on Accommodation Provided

The following question was used to examine the procedures followed in ensuring that the accommodation, once made, did in fact, satisfactorily meet the employee's special needs:

"How do you ensure that the accommodation, once provided, meets the needs of the employee with a disability?"

All but a very few of the respondents in this group indicated that arrangements for following up on accommodations made for employees with disabilities tend to be informal in nature and should remain that way. The following are representative of the responses to our question on this matter:

"The employee will let us know if the accommodation is meeting his or her need." and,

"If I don't hear from the employee after the aid has been given, I assume it meets his or her needs. There is no automatic follow-up. Besides, we (E.E. Coordinators) know what's going on and we keep an eye on things."

This position seems generally consistent with the principle that employees have the responsibility to let the managers know of their needs and that employees are quite capable of reporting back if the accommodation is unsatisfactory. Most of the employees interviewed during our study supported this view.

3.6 Training

The issue of the need for appropriate training for Employment Equity Coordinators and supervisors and managers of persons with disabilities was raised with all interviewees in these two groups, through the following questions:

"Did you undergo special training to prepare you to carry out the responsibilities assigned to you under the policy? If so, could you describe the training you received? If you did not receive training, would training or guidelines be useful to you? (E.E. Coordinators, supervisors and managers)

Several E.E. Coordinators, and virtually all supervisors and managers of employees with disabilities interviewed during the study, had not received training of any kind. The following comments are representative of the responses received on this point:

"I did not undergo special training to act as a manager of employees with disabilities. I think it would be useful for the whole group (managers, supervisors and E.E. Coordinators and employees with disabilities) to have this (training) in a collective way." and,

"I think it would be useful, but it should be done within the context of the T.B. training program, now under development."

Most respondents in the employees with disabilities group stated that they thought the need for training for E.E. Coordinators, supervisors and managers would help both to make supervisors and managers aware of needs and capabilities of disabled employees (sensitivity/awareness training) and to acquaint them with the steps to be taken in responding to employee requests (procedures, or "how to" training). The following is a sampling of the responses received from the employee group on the need for training for these different purposes.

"A lot of people don't feel comfortable dealing with people with disabilities and this makes us (employees with disabilities) uncomfortable too." and,

"The problem I ran into was that my supervisor didn't know how to take action on my request. We had Windmills here. It's good, but not for teaching a supervisor how to act on a request."

Views on the types of training most suited to the demands of the policy varied greatly. Most of those who expressed views on the importance of training tended to favour awareness or sensitivity training as the best means of bridging the gap between managers and employees with disabilities and creating a better understanding of disabilities in general. We found no real consensus among respondents, however, as to the most appropriate model for this type of training, as can be seen from the following comments:

"The problem with (stylized) sensitivity training is that you have to make people go to it and people resent having to do things they think they don't need." and,

"When it comes down to delivering (a service), a different kind of training is needed. Maybe a manual is the answer."

In summary, most respondents agreed that more training should be provided to E.E. Coordinators, supervisors and managers so that they may respond in a fitting manner to the work-related needs of employees with disabilities. The requirement for training should address the need to make departmental staff aware of the needs, aspirations and capabilities of these employees and the policies that exist to address these needs. Members of these groups also require guidance with respect to the steps to be taken in responding to employee requests for technical aids and specialized services. Respondents varied considerably in their views as to the most appropriate training models to be used in both cases.

3.7 Financial Accounting, Monitoring and Accountability

The following questions were asked of E.E. Coordinators, supervisors and managers regarding the financial accounting, monitoring and reporting arrangements followed in carrying out the policy:

"Does your department have a special fund to cover the cost of accommodation of employees with disabilities or do the funds come out of operating budgets? Do you know if your department has ever made a submission to the Treasury Board for funding for this specific purpose? To your knowledge, has anyone ever been refused reasonable accommodation because of lack of funds within the department?"

"Does your department maintain a record of employees who have been provided attendant or other specialized services and the nature and cost of services provided? If so, could we view this record? Is there a trend upwards or downwards in the number of such requests over the past three years? If so, what is your explanation of the trend?"

With some exceptions, the expenditures for technical aids and special services are paid for out of the operating budgets of the relevant Branch in which the employee with a disability works. In one or two of the departments contacted, the E.E. unit has control over these funds. The Deputy Ministers also maintain a special fund for this purpose, which is accessed only when other budgets have been depleted. Large expenditures must be approved by the Deputy Minister of the department.

As might be expected, the level of budgets for technical aids and special services varies considerably, depending primarily on the size of the department and on historical spending experience. Some larger departments indicated resources of approximately $175K annually. The budgets of medium and small departments tended to range from $75K to $20K. In some years, budgets are under-spent, in others they are over-spent. Where the latter occurs, funds are transferred in from under-expended operating budgets, elsewhere in the department.

The policy requires departments to maintain a record of employees who have been provided attendant or other specialized services and the nature and cost of the service provided. While the policy does not explicitly mention the importance of meeting need in as cost-effective manner as possible, this expectation must be taken for granted.

Our findings on this matter indicate that responsibility for the maintenance of these records is generally vested in the E.E. Coordinator, although, as mentioned earlier, management of the funds used to meet the costs of technical aids and other special services is a responsibility of the operational units of the department.

The evaluation team did not ask to view the records because of the confidential nature of some of the material they contain. However, the contents of the records were described to us. The following comments by E.E. Coordinators and managers provide a sense of what the records contain and how they are maintained:

"I (manager) don't maintain a record of the assistance we have given, but the E.E. Coordinator does." and,

"We (E.E. Coordinator) keep a record that includes the type of service given, who the recipient was, who provided the service and what it cost." and,

"We keep a record, but its just for us (E.E. Coordinator). All activity (action taken) is kept on the employee's file."

Several of these comments speak to the fact that many accommodations involving expenditure of funds are made in departments for employees with disabilities without involvement of the E.E. Coordinator. This is not to be interpreted as an undesirable practice, but should be seen rather as an indication of a growing "culture" at least in some departments, that sees such accommodations as a normal requirement that must to be met in order to get the job done.

In examining the implementation of the policy we also queried E.E. Coordinators, supervisors and managers as to whether and how they exercise their respective accountability in carrying out the policy. This enquiry was approached through the following question:

"Could you describe how, when and to whom you report on activities under the policy?"

The responses to this question indicated that supervisors and managers of employees with disabilities consider that responsibility for reporting activity under the policy to be the responsibility of the E.E. group:

"We (E.E.) report to the Director General (Corporate Services) who reports to the Deputy Minister."

Most of the E.E. respondents felt that these reporting and accountability arrangements were logical and adequate. One of these respondents, however, had a different point of view on this matter:

"I think we should make managers accountable for the realization of Employment Equity goals."

In summary, arrangements for the monitoring of the policy vary somewhat from department to department. In most cases, E.E. Coordinators are aware of what is occurring under the policy and keep a record of requests for service, what accommodations have been made and the costs of doing so.

The amount of information in these records, however, is greater in some departments than in others. In some cases E.E. Coordinators may not be aware that an employee has been accommodated, at some cost to the department, because the action will have been taken without informing the Coordinator. Our general impression is, nevertheless, that the reporting arrangements are adequate for the purpose.

Employment Equity Coordinators exercise accountability for the implementation of the policy. Supervisors and managers (except at the very senior levels) do not believe that they are responsible for implementing this policy or for reporting the actions they take under the policy.

4. Results of the Policy

4.1 Introduction

The policy requires departments to:

Provide services or equipment considered necessary to enhance employee performance in the workplace;
Cover the costs of the technical aids and specialized services provided to indeterminate employees and, where reasonable, to term and seasonal employees; and
Cover the costs of attendant services arranged on a contract-for-service basis between the department or agency and the service provider.

The assessment of results involves determining not only if and how well departments were able to meet the work-related needs of their employees with disabilities, but whether, as a result of having done so, these employees were able to function effectively in their work in the federal public service.

For this, the core of the study, we used two somewhat different sets of questions, one set for E.E. Coordinators, supervisors and managers and another for employees with disabilities.

The following are the principal questions used to gather information and informed views on this subject from the E.E. Coordinators, supervisors and managers of employees with disabilities:

"Are you always able to provide services or equipment considered necessary to enhance the employee's abilities, career opportunities and productivity, or are there occasions where a request cannot be met because it is deemed unreasonable or where the request entailed a lengthy delay? If the latter, would you describe these occasions or circumstances?"

"Does your department have sufficient funds to cover the cost of the technical aids and specialized services provided to indeterminate employees and, where reasonable, to term employees? Could you indicate what percentage of these employees are term or seasonal employees?"

4.2 Funds to Meet Need

The responses received from E.E. Coordinators, supervisors and managers of employees with disabilities indicate that to date, with few exceptions, departments have been able to find the funds within their budgets to accommodate need under this policy. Senior management attitudes towards accommodation in some, if not all, of the departments contacted tend to facilitate the bureaucratic task of approving funds for this purpose, as the following comment will bear out:

"To date, we have had the funds in the budget to pay for these things. I think the funds are in the operating budget, but if there are no funds, we look elsewhere."

Respondents in the departments visited did not report any instance where their department had been unable to provide a technical aid because of lack of funds or where their department had approached the Treasury Board for funds because their own resources had been depleted. Virtually every E.E. Coordinator, supervisor and manager of employees with disabilities, however, expressed concern about the possibility of meeting need in the future, because of budgetary cutbacks.

In an interview with an official of the Diversity Management Technology Centre in the Public Service Commission we asked if he was aware of any instance where a request for a technical aid had been turned down by a department because the aid was too expensive or too employee-specific. He indicated that he was not aware of any such instance but could imagine this happening if someone were to ask, for example, for a new robot-type technical aid that has just come on the market but is still in a developmental stage.

Some departments have established committees of employees with disabilities to review and advise on the purchase of technical aids. This process helps to reduce the amount of time required to respond to employee requests and brings greater objectivity to the assessment of need. Several incidents were reported to us where committee deliberations resulted in less expensive solutions.

One employee respondent reported that his manager had indicated that, in principle, he could not support the provision of attendant care services, on the grounds that the department could not afford it. This occurred in a regional office of one of the departments visited during the study. The employee, however, did not challenge this position in any formal way.

We also encountered one case where an employee claimed that he had been refused an accommodation and had taken the matter to the Human Rights Commission on the grounds that his request was a reasonable one. This case, however, is still under review by the Human Rights Commission.

The evaluation team were told of several other cases where persons with disabilities had appealed to the Human Rights Commission. The grounds involved in these cases, however, fall outside the purview of the policy which is the subject of our evaluation.

4.3 Perspectives on Accommodating Employee Needs

Each group of respondents in the study, namely, E.E. Coordinators, supervisors and managers, and employees with special needs, were found to have somewhat different perspectives on the results of the policy. To capture these different perspectives, those of each group are dealt with here separately.

4.3.1 Perspective of E.E. Coordinators

E.E. Coordinators, by virtue of the very function they perform, tend to have a broader overview of what is happening with respect to the policy in the department, than is the case with individual supervisors, managers and employees. Their perspective, therefore, is department-wide, whereas that of supervisors, managers and employees tends to be limited to their particular Branch or Division.

E.E. Coordinators, as a group, state that, overall, the employment-related needs of employees with disabilities are being reasonably accommodated in their respective departments and that, in most cases, these needs are being met in a timely matter. These respondents also acknowledged, however, that there are exceptions to this rule and that, as mentioned above in this report, in some instances the definition of what constitutes "reasonable and timely accommodation" becomes a matter of personal judgement.

The following comments are typical of the responses given by members of this group in summing up the reasons for both the successes and failures of the policy:

"If there is visible and strong support for the policy at senior management levels it is more likely to be known and applied at lower levels" and,

"Managers need practical exposure to persons who manage their disabilities. Charity hardly belongs here. It's just getting the job done. The policy should be approached from that perspective."

More experienced E.E. Coordinators indicated that arriving at a reasonable accommodation to the needs of an employee with a disability could prove to be very difficult in certain situations, as described in the following comment from one such respondent:

"When its just equipment, there is usually no problem (reaching accommodation). There are other cases where it is more difficult, for example, where the employee has to work on shift. The work has to be done on shift and the employee may refuse because he or she has a disability. If you agree with that request and there are no other workers on this team, it affects the workload. You ask the remaining members to pick up the slack. You can be accused of preferential treatment if you do that. Should the request of the employee with a disability be accommodated here, or is this a case of undue hardship for the employer?"

4.3.2 Perspective of Supervisors and Managers

Supervisors and managers, as a group, also state that, in most cases, the work-related needs of their employees with disabilities are being accommodated in an effective and timely manner. This group also acknowledge, however, that there are instances where requests could not be accommodated or where accommodation could not be realized as quickly as it might have been.

The following is a sample of the comments made by this group of respondents on the core issue of accommodating need:

"I think we have been able to meet need, but we can't always get the top of the line. Someone who wants to go to a conference in California and needs attendant care may not get their wish, unless its absolutely important."

The accommodations made by some managers combine the provisions of the policy and a healthy measure of common sense, as evident in the following comment from one of these respondents:

"So far we've been able to meet need. (Employee's name) needed more space and non-traditional filing cabinets that he could easily reach from his wheelchair. In our job we have to move about and travel. I make allowances for that. When (employee) travels to (city) I expect him to take two days instead of one, because that's just part of doing his job well."

Virtually every respondent in this group, however, expressed concern about the department's ability to consistently accommodate the needs of employees with disabilities in the future. The following is typical of the comment we received on this matter:

"With the cuts, its getting more difficult all the time. Two (workers) now often have to do the work of three and both have to be able to do the work."

A significant finding concerning the perspective of this group is that some have made accommodations for employees with disabilities, while being quite unaware of the existence of the policy. These accommodations, however, do not generally involve the purchase of expensive technical aids.

4.3.3 Perspective of Employees with Disabilities

A substantial portion of the total time of the study was dedicated to assessing the results of the study for employees with disabilities. The following are the principal questions put to the interviewees in this group:

"In your view, do you feel that your specialized needs, once described were adequately understood and appreciated by your supervisor? Please elaborate on your answer."

"Was your request for accommodation accepted? If not, what reason was given?"

"Do you feel that your work-related needs, once identified, were met promptly or that there was an unnecessarily long delay in meeting your needs? Please elaborate on your reply."

"Are you generally satisfied with the policy and the arrangements for its implementation? Do you have any suggestions to offer as to how the policy and the implementation of the policy could be improved?"

In addition to these questions, employees with disabilities who had used the policy were invited to express their views as to whether its provisions had enhanced their performance on the job.

As noted above in this report, many of the respondents in this group had never seen the policy and, therefore, were uncertain as to whether the accommodations that had been made for them were the result of this policy or some other policy. However, this state of affairs does not constitute a serious obstacle in assessing the results of the policy since the accommodations in question flow from the policy regardless of whether the recipient is aware of this fact.

Since supervisors and managers figure prominently in accommodating employee needs, the views expressed by employees on the results of the policy tend to reflect positively or negatively on the former.

Approximately 75% of the respondents in this group felt that their work-related needs had been met to a satisfactory extent, and in a timely manner. This view was expressed unequivocally and without any apparent reservations. The following are typical of the responses received from individuals in this group:

"( ) was my supervisor and she came to see me when I arrived. I told her I was having difficulty hearing on the phone. She got me a special phone. She also arranged to have me work on (the name of the project). It is a lower position, but it was better for me. She also advised me to apply for a CR4 position in the File Room and I won. I'm really quite pleased with the help I received." and,

"I asked for a dictaphone and a braille display. In (another city) I couldn't get anywhere. In Ottawa, however, I made a shopping list of what I really needed and they agreed. 95% of that depends on the manager. We have resource people to read for us and also if we have to go to a conference we have people to help with lifting and moving things. When I was transferred to Ottawa I didn't have to wait long for the equipment I asked for."

Roughly 20% of respondents were dissatisfied with the policy and/or its implementation for one or more of the following reasons:

Too long a delay in providing the technical aid(s) requested;
Incompatibility of departmental software with technical aids used by employees with disabilities;
Limited use of alternate formats; and
Refusal on the part of management to provide the special services requested by the employee;

The delays in providing technical aids were attributed to:

Lack of familiarity on the part of supervisors or managers and, in a few cases, newly-appointed E.E. Coordinators, with the procedures to be followed in responding to employee requests;
The time required to determine the employee's technical needs and to obtain the relevant equipment; and
Prolonged discussions between supervisors and managers and sometimes between departments on where financial responsibility for accommodation expenditures should rest.

The following comments made by employees who complained about the length of time taken to meet their technical needs are illustrative of the factors involved:

"I (visually impaired employee) asked my immediate supervisor for a (special) computer. She said she had to ask the systems person about the computer, but this took months. It was just a manager who never had this experience before. I guess I should have communicated earlier in writing. I started the job in January (the year) and didn't get the equipment until October (of the same year). The policy is OK, but people don't know what steps to take and who to tap into."

The complaint about the incompatibility of departmental software and the employee's technical aid was heard in one department only, but the problem was adversely affecting a number of employees in this group, as the following comment will show:

"We find that people force the disabled through all kinds of difficult experiences. I don't feel I'm on an even footing with my employee colleagues. For example, even now, sight-impaired persons are not on the network. The new software (OS2) is not accessible by us. I know people try, but its been this way for the last six months. Also, they are using some colours (pale blue) which cannot be read by persons who are visually impaired."

The criticism concerning the limited use of alternate formats applies primarily to the use of braille. Those who commented on this problem felt that there was a tendency on the part of management to overstate the additional costs involved because they (managers) didn't take the time to consult with sight-impaired on inexpensive and practical applications of this format. The following remarks from sight-impaired respondents in one of the regions sums up the situation quite well:

"I'm not expecting the Bell Telephone book to be put in braille. I'd settle for just a list of the people in my building and their telephone numbers. This doesn't seem like a big deal to me."

Management's refusal to provide special services appeared to be limited to that of attendant services. While E.E. Coordinators, supervisors and managers of employees with disabilities are clearly concerned about the possible costs of providing attendant services on a large scale, we encountered only one case where this service was refused, as mentioned above

About 5% of employee respondents expressed disappointment with the policy because it did not address their career aspirations. This complaint deserves elaboration because of what it implies about employee understanding of the purpose and scope of the present policy. The following is representative of the comments made by these respondents:

"Technical aids are good for some people, but they don't level the field. It is only levelled through career planning. They should at least tell us how to set goals for ourselves, both long- and short-term goals." and,

"There's only one thing I find, I've been at this job as a CR since 1990. I feel I would like to move up the ladder. I feel I don't get enough career planning. I don't get information on job opportunities."

These respondents clearly believed that the policy is intended to address not only the need for technical aids and specialized services but advancement in the public service as well.

5. Conclusions

5.1 Introduction

In this chapter we lay out the principal conclusions of our study. Our conclusions are based on interviews with a statistically significant sample of persons administering and using the provisions of the policy that is the subject of our study. The conclusions address both the substance of the policy, as well the manner in which it is being implemented.

Our findings are arranged to reflect the requirement of the study, as expressed in the Terms of Reference:

Identify the strengths and weaknesses of the policy and suggest how it might be improved upon or an alternative system adopted to meet the needs of employees with disabilities more efficiently and effectively.

5.2 Policy Strength

Overall, the policy is meeting the objectives set for it, in that the needs of a significant number of federal employees with disabilities are being accommodated through the provision of technical aids and specialized services, with the result that they are able to perform their jobs in a satisfactory manner.

The range and diversity of accommodations capable of being made under the policy are extensive. Virtually all types of disabilities among employees are being addressed, indicating that the policy is quite flexible.

Generally speaking, implementation of the policy appears to be presenting no insurmountable obstacles to managers. Funds for technical aids and specialized services are being found from departmental operating budgets, although there is concern that this may become more difficult in the future, as departmental budgets continue to be reduced.

There is an encouraging level of consensus among E.E. Coordinators, managers and employees with disability about the fundamental value of this policy, from both a pragmatic as well as a human rights point of view, and a very strong conviction that it should continue in force and be improved upon.

5.3 Areas Requiring Attention

The following are areas that have been identified as requiring attention. The areas relate to the policy itself, as well as the manner in which it is being implemented.

5.3.1 Provisions of the Policy

The wording of the policy is considered to be unclear by many of the E.E. Coordinators and managers who participated in the study. The meaning of the term "reasonable accommodation" is cited most frequently as a term requiring clarification. This ambiguity sometimes results in disagreements that adversely affect management employee relations and may deprive employees with disabilities of a rightful accommodation.

5.3.2 Implementation of the Policy

The policy is not well communicated to supervisors, managers and employees with disabilities. Many supervisors and managers who are responsible for its implementation have never seen it, although they may have heard about it, may have been informed of its contents and may even have applied it. This sometimes results in uncertainty on the part of the supervisor or manager as to whether they are applying the policy in a proper manner.

Most employees with disabilities have not received a copy of the policy, although they may have been told of its provisions and have benefited from it, but with the result that they are unsure as to whether they have received what they are entitled to.

Many employees with disabilities are unable to distinguish between this particular policy and other E.E. policies. This raises expectations about the policy that cannot be satisfied and may create misgivings on the part of employees about management's sincerity and interest in them.

Few E.E. Coordinators, supervisors and managers of employees with disabilities have received training to prepare them to carry out their responsibilities under the policy.

As a result, the approach to meeting employee need is sometimes inappropriate and delays are encountered in accommodating need.

6. Suggestions for Improvement

The following suggestions for the improvement of the policy are based upon the information, perceptions and opinions garnered from all sources during the evaluation. They are offered here for consideration by the Treasury Board Secretariat.

General

The interests of the employees with special needs are more likely to be met and their productivity enhanced, where the department has succeeded in building a "culture" that recognizes the richness of diversity and is able to effectively manage diversity in its day-to-day affairs. This "culture" is not established through occasional effort but through the constant application of principles and values that support the recognition and management of diversity. Senior management in the departments are in the best position to influence employee thinking in these matters and to demonstrate commitment to these principles.

Awareness of the Problematic of Disability

Managers need practical exposure to persons who effectively manage their disabilities. The policy should be presented to all managers as constituting practical measures that can be taken to ensure that employees are able to get the job done efficiently and effectively.

The principal models of sensitivity/awareness training currently in use in the federal government should be assessed on a sound scientific basis for their effectiveness and rated, to the extent possible, for the guidance of E.E. Coordinators who will normally be involved in arranging training sessions.

Awareness of the Policy

The introduction to the policy should situate it within the family of E.E. policies and delineate its boundaries more precisely than is now the case.

Employees who identify themselves as being persons with a disability should be provided with a copy of the policy automatically, if this can be done in a manner that respects the individual's right to confidentiality. E.E. Coordinators should conduct information sessions with these employees to respond to any questions they may have about the policy and its applicability to them.

Newly-appointed E.E. Coordinators and managers of employees with disabilities should also be provided with a copy of the policy. Experienced E.E. Coordinators should meet with them to discuss the policy and to answer any questions they may have concerning its provisions.

Departmental newsletters (DM's) should draw attention to the policy on a more regular basis than annually.

Guidelines for Responding to Requests for Accommodation

Guidelines outlining the general steps to be followed in responding to employee requests under the policy should be prepared and made available to newly-appointed E.E. Coordinators and managers of employees with disabilities so as to minimize delays in accommodating employee needs. The guidelines need not be lengthy or detailed, but should indicate the key players in the decision-making process, the main steps in this process, the role of the DMTC in the PSC and reporting arrangements.

Clarification of Reasonable Accommodation and Undue Hardship

Sample cases of accommodations made under the policy should be prepared to assist employees with disabilities, E.E. Coordinators and managers of employees with disabilities and employees with disabilities in understanding the provisions of the policy, and particularly the term "reasonable accommodations" and "undue hardship".

The Case Studies on Effective Practices in the Employment of Persons with Disabilities, prepared by the Consultation Group on Employment Equity for Persons with Disabilities in May, 1994, provide a very useful frame of reference in developing the sample cases.

Accountability of Managers of Employees with Disabilities

All levels of management should be evaluated annually on their performance in carrying out the provisions of the policy.

Testing of Technical Aids and Software

Consideration should be given to the creation of a coordinating mechanism among the departments (including the PSC and Environment Canada) for the sharing of information on testing results for technical aids and software applications, in order to avoid duplication of effort and to reduce delays in accommodating need.

Appendix 1 - Bibliography

Employment Equity in the Public Service, Annual Report 1992-93, President of the Treasury Board.

Special Measures Initiatives, Employment Equity through Management of Diversity - Discussion Paper. Treasury Board Secretariat, August 18, 1993.

Alternative Formats, Access for all. Government of Canada, 1993

How to provide alternative formats. Government of Canada, December 1993

Looking Beyond What You See: Report of the Deputy Ministers' Advisory Committee on Employment Equity. Consultation Group on Employment Equity for Persons with Disabilities. April 29, 1992

Framework for Advancing Employment Equity in the Public Service of the 1990s. Employment Equity Council, July, 1993

Case Studies on Effectiveness Practices in the Employmentof Persons with Disabilities. Consultation Group on Employment Equity for Persons with Disabilities. Government of Canada, May, 1994

Appendix 2 - Interview Guides

Table of Contents

Introduction

A. Original Policy Designers

B. Program Officer - Employment Equity, Official Languages and Employment Equity, T.B.S.

C. Employment Equity Coordinators, Supervisors and Managers

D. Employees with Disabilities

E. Manager Responsible for the Diversity Management Technology Centre (PSC)

(For Use in All Interviews)

Introduction

The Treasury Board policy to provide services for federal public service employees with disabilities came into effect in 1989. The policy, which is intended to eliminate barriers that might otherwise prevent employees with disabilities from functioning effectively in the Public Service, has now been operational for approximately six years. In keeping with its practice of reviewing all its policies on a regular basis, the Treasury Board Sectrtariat now wishes to ensure that the policy is achieving and will continue to achieve the objectives that have been set for it.

The evaluation will:

Determine whether the needs of Federal Public Service employees with disabilities are being reasonably accommodated;
Evaluate the effectiveness of the information/communications links between TBS, PSC and the Departments in bringing the existence of the policy to the attention of employees with disabilities;
Identify the strengths and weaknesses of the policy and suggest how it might be improved upon or an alternative system adopted to more efficiently and effectively meet the needs of employees with disabilities;
Assess the extent to which personnel officers in the departments are aware of the policy, the level of use of the policy and how accommodation is being funded; and
Determine whether departments are maintaining the required records of employees who have been provided attendant or other specialized services and the nature and cost of the services provided.

The principal means of gathering information on these matters will be through interviews with a sampling of policy stakeholders in the Treasury Board Secretariat itself, with Employment Equity Coordinators and supervisors and managers of employees with disabilities in the departments, and with employees with disabilities who receive services under the policy. We also plan to interview the Manager of the Diversity Management Technology Centre in the Public Service Commission.

Your name has been given to us as a person we should interview during the evaluation. We would like your help in answering the questions that follow. Your answers will be taken into account in reaching conclusions about the issues mentioned above. However, in our report all answers will be treated as confidential and none will be attributed to the individuals who expressed them. Your contribution to the success of the evaluation is greatly valued.

A. Original Policy Designers

I. Introduction

The evaluation will:

Determine whether the needs of Federal Public Service employees with disabilities are being reasonably accommodated;
Evaluate the effectiveness of the information/communications links between TBS, PSC and the Departments in bringing the existence of the policy to the attention of employees with disabilities;
Identify the strengths and weaknesses of the policy and suggest how it might be improved upon or an alternative system adopted to more efficiently and effectively meet the needs of employees with disabilities;
Assess the extent to which personnel officers in the departments are aware of the policy, the level of use of the policy and how accommodation is being funded; and
Determine whether departments are maintaining the required records of employees who have been provided attendant or other specialized services and the nature and cost of the services provided.

Evaluation table
II. Questions	Priority
1. Could you describe for us the salient motivating factors, as you recall them, which prompted the development of the current policy for the provision of services for employees with disabilities, as you recall them?	high
2. Could you indicate the particular role you played in the articulation of the policy and the measures for the implementation of the policy?	low
2a. Could you talk about how the contracts for services were expected to function?
3. Was the policy and were the arrangements for its implementation approved as proposed by you, or were some changes and adjustments made to the proposal, when it was approved by Treasury Board?	medium
4. As you recall, were any particular conditions attached to the Treasury Board's approval of the policy that we should be aware of in carrying out our evaluation?	medium
5. Have any significant changes been made to the policy or to the arrangements for its implementation since its inception, that we should be aware of?	high
6. In your view, does the policy and do the measures for its implementation still make sense in today's circumstances?	high
7. In your experience over the years, is the policy generally achieving the objectives set for it?	high
8. How is the decision on the most appropriate accommodation for the employee made?	high
9. How does the policy ensure that the accommodation meets the needs of the employee with a disability?
10. What "trouble spots" should we be particularly aware of as we undertake the evaluation of the policy?	high
11. Do you have any suggestions to offer as to how both the policy and the implementation of the policy could be improved?	high
12. Would you care to suggest the names of persons we should interview during the evaluation?	medium

B. Program Officer - Employment Equity, Official Languages and Employment Equity, T.B.S.

I. Introduction

The Treasury Board policy to provide services for federal public service employees with disabilities came into effect in 1989.

The evaluation will:

Determine whether the needs of Federal Public Service employees with disabilities are being reasonably accommodated;
Evaluate the effectiveness of the information/communications links between TBS, PSC and the Departments in bringing the existence of the policy to the attention of employees with disabilities;
Identify the strengths and weaknesses of the policy and suggest how it might be improved upon or an alternative system adopted to more efficiently and effectively meet the needs of employees with disabilities;
Assess the extent to which personnel officers in the departments are aware of the policy, the level of use of the policy and how accommodation is being funded; and
Determine whether departments are maintaining the required records of employees who have been provided attendant or other specialized services and the nature and cost of the services provided.

The principal means of gathering information on these matters will be through interviews with a sampling of policy stakeholders in the Treasury Board Secretariat itself, with Employment Equity Coordinators and Supervisors of employees with disabilities in the departments, and with employees with disabilities who receive services under the policy. We also plan to interview the Manager of the Diversity Management Technology Centre in the Public Service Commission.

Evaluation table
II. Questions	Priority
1. How long have you been responsible for responding to requests for interpretation of the provisions of the policy?	medium
2. How do you publicize the existence of this policy?	high
3. Could you indicate which particular provisions of the policy have generated the greatest number of requests for interpretation?	medium
4. In your view, were these requests for interpretation the result of ambiguity in the wording of the policy? If not, why was interpretation required?	high
5. What percentage of these requests came from: Departmental coordinators ________ Supervisors ________ Employees with disabilities ________	high
6. Did such requests come from: Many departments/agencies ________ Just a few departments/agencies ________ If just a few departments, could you name them?	medium
7. Are you aware of any steps that were taken to reduce the need to seek interpretation of the provisions of the policy? If such steps were taken, did it in fact reduce the number of requests for interpretation?	medium
8. Do you keep annual statistics on the number of requests for assistance under the policy? If so, is there a trend up or down in the number of such requests over the past three years? If so, what is your explanation of the trend?	medium
9. Could you indicate the types of disability for which assistance was requested?	medium
10. Do you have any suggestions to offer as to how both the policy and the implementation of the policy could be improved?	medium
11. Could you suggest the names of persons we should interview during the evaluation?	medium
12. Can you talk a bit about the difficulties which have arisen on the subject of contracts for services?	medium

C. Employment Equity Coordinators, Supervisors and Managers

I. Introduction

The Treasury Board policy to provide services for federal public service employees with disabilities came into effect in 1989.

The evaluation will:

Determine whether the needs of Federal Public Service employees with disabilities are being reasonably accommodated;
Evaluate the effectiveness of the information/communications links between TBS, PSC and the Departments in bringing the existence of the policy to the attention of employees with disabilities;
Identify the strengths and weaknesses of the policy and suggest how it might be improved upon or an alternative system adopted to more efficiently and effectively meet the needs of employees with disabilities;
Assess the extent to which personnel officers in the departments are aware of the policy, the level of use of the policy and how accommodation is being funded; and
Determine whether departments are maintaining the required records of employees who have been provided attendant or other specialized services and the nature and cost of the services provided.

The principal means of gathering information on these matters will be through interviews with a sampling of policy stakeholders in the Treasury Board Secretariat itself, with Employment Equity Coordinators and Supervisors of employees with disabilities in the departments, and with employees with disabilities who receive services under the policy. We also plan to interview the Manager of the Diversity Management Technology Centre in the Public Service Commission.

Evaluation table
II. Questions	Priority
1. Could you describe how and when you first learned about the policy for the provision of services for employees with disabilities?	high
2. Do you find the policy and the arrangements for its implementation readily understandable or do you need to ask for clarification of all or some of its provisions? If the latter, which of its provisions or implementation measures do you find most difficult to understand? To whom do you turn if and where clarification is needed?	high
3. Is the policy communicated to persons with disabilities, using alternate formats?	high
4. Did you undergo special training to prepare you to carry out the responsibilities assigned to you under the policy? If so, could you describe the training you received? If you have not received training, would training or guidelines be useful to you?	high
5. Do you lend technical aids to employees with disabilities who are being interviewed for employment?	high
6. Do you communicate the department's willingness to provide the services of an attendant, work-related technical aids, office modification or modified work instruments, or other specialized services or assistance if required by employees with disabilities? How do you carry out this communication?	high
7. Do you recall which provisions of the policy or which aspects of the implementation of the policy initially have evoked the greatest number of questions by employees with disabilities?	high
8. How is the decision as to the most appropriate accommodation for the employee with a disability made? What is your role in this decision making process?	high
9. How do you ensure that the accommodation meets the needs of the employee with a disability?	high
10. Are you always able to provide the services or equipment considered necessary to enhance the employee's abilities, career opportunities and productivity, or are there occasions where the request could not be met, was deemed unreasonable or where meeting the request entailed a lengthy delay? If the latter, would you describe these occasions or circumstances?	high
11. Is your department consistently able to cover the cost of attendant services arranged on a contract-for-service basis between the department or agency and the service provider?	low
12. Does your department have sufficient funds to cover the cost of the technical aids and specialized services provided to indeterminate employees and, where reasonable, to term and seasonable employees? Could you indicate what percentage of these employees are term or seasonal employees?	low
13. Does the department have a special fund to cover the cost of accommodation of employees with disabilities or do the funds come out of your operating budget? Do you know if your department has ever made a submission to the Program Branch of the TB for funding for this specific purpose? To your knowledge, has anyone ever been refused reasonable accommodation because of lack of funds within the department?
14. Does your department maintain a record of employees who have been provided attendant or other specialized services and the nature and cost of the services provided? If so, could we view this record? Is there a trend upwards or downwards in the number of such requests over the past three years? If so, what is your explanation of the trend?	high
15. Are you generally satisfied with the policy and the arrangements for its implementation? Do you have any suggestions to offer as to how both the policy and the implementation of the policy could be improved?	high
16. Could you describe how, when and to whom you report on activities under the policy?	medium
17. Could you suggest the names of persons we should interview during the evaluation?	medium

D. Employees with Disabilities

I. Introduction

The Treasury Board policy to provide services for federal public service employees with disabilities came into effect in 1989.

The evaluation will:

Determine whether the needs of Federal Public Service employees with disabilities are being reasonably accommodated;
Evaluate the effectiveness of the information/communications links between TBS, PSC and the Departments in bringing the existence of the policy to the attention of employees with disabilities;
Identify the strengths and weaknesses of the policy and suggest how it might be improved upon or an alternative system adopted to more efficiently and effectively meet the needs of employees with disabilities;
Assess the extent to which personnel officers in the departments are aware of the policy, the level of use of the policy and how accommodation is being funded; and
Determine whether departments are maintaining the required records of employees who have been provided attendant or other specialized services and the nature and cost of the services provided.

The principal means of gathering information on these matters will be through interviews with a sampling of policy stakeholders in the Treasury Board Secretariat itself, with Employment Equity Coordinators and Supervisors of employees with disabilities in the departments, and with employees with disabilities who receive services under the policy. We also plan to interview the Manager of the Diversity Management Technology Centre in the Public Service Commission.

Evaluation table
II. Questions	Priority
1. Are you aware of the TB policy for the provision of services for employees with disabilities? Could you describe how and when you first learned about the policy?	high
2. Do you know if the policy is regularly communicated to persons with disabilities? Is the policy available in alternate formats?	medium
3. Do you find the policy and the arrangements for its implementation readily understandable or did you need to ask for clarification of all or some of its provisions? If the latter, which of its provisions or implementation measures did you find most difficult to understand?	high
4. Do you feel that the policy is generally well known and readily understood by other employees with disabilities?
5. Have you have made use of the policy? If so, did you identify your employment-related needs to your supervisor(s) or manager(s)? Could you describe the point at which you made known your need(s)?	high
6. Were you asked what accommodation you felt was most appropriate for your needs? Could you describe how you went about giving the department this information?	high
7. Did you identify the general nature of any attendant or other specialized services required and service delivery times?	medium
8. In your view, do you feel that your specialized needs, once described, were adequately understood and appreciated by your supervisor? Please elaborate on your answer.	high
9. Was your request for accommodation accepted? If not, what reason was given?	high
10. Do you feel that your work-related needs, once identified, were met promptly or that there was an unnecessarily long delay in meeting your needs? Please elaborate on your reply.	medium
11. In your view, do the technical aids available from the Diversity Management Technology Centre reflect the latest trends in these technologies or would you say they are lagging behind in this respect?	low
12. Are you generally satisfied with the policy and the arrangements for its implementation? Do you have any suggestions to offer as to how both the policy and the implementation of the policy could be improved?	high

E. Manager Responsible for the Diversity Management Technology Centre (PSC)

I. Introduction

The Treasury Board policy to provide services for federal public service employees with disabilities came into effect in 1989.

The evaluation will:

Determine whether the needs of Federal Public Service employees with disabilities are being reasonably accommodated;
Evaluate the effectiveness of the information/communications links between TBS, PSC and the Departments in bringing the existence of the policy to the attention of employees with disabilities;
Identify the strengths and weaknesses of the policy and suggest how it might be improved upon or an alternative system adopted to more efficiently and effectively meet the needs of employees with disabilities;
Assess the extent to which personnel officers in the departments are aware of the policy, the level of use of the policy and how accommodation is being funded; and
Determine whether departments are maintaining the required records of employees who have been provided attendant or other specialized services and the nature and cost of the services provided.

The principal means of gathering information on these matters will be through interviews with a sampling of policy stakeholders in the Treasury Board Secretariat itself, with Employment Equity Coordinators and Supervisors of employees with disabilities in the departments, and with employees with disabilities who receive services under the policy. We also plan to interview the Manager of the Diversity Management Technology Centre in the Public Service Commission.

Evaluation table
II. Questions	Priority
1. Have you been able to acquire a broad selection of work-related technical aids to meet the needs of employees with disabilities? Could you show us some of these aids and describe how they work?	high
2. Which of these technical aids is most in demand and why? Which are least in demand and why?	high
3. How do you keep up to date on technical improvements in this field? What is the greatest challenge you face in developing and maintaining this expertise? Do you feel you have been able to deal effectively with these challenges? If not, what could be done to help you?	medium
4. Is there a waiting period for the delivery of aids to employees who have requested them? If so, what is the reason for the waiting period?	medium
5. How do you ensure that technical aids are returned, if no longer needed? Do you routinely check technical aids that have been returned to determine their condition?	medium
6. Is your budget always sufficient to cover the costs of servicing, shipping and storing technical aids, as well as the general administration of the technical aids loan bank, or have you had to limit your services on occasion because of a shortage of funds?	medium
7. Are any of the technical devices requested too expensive or too individual-specific to warrant purchasing them?	medium
8. In your view, is the Treasury Board policy for the provision of technical aids and specialized services achieving the objective of accommodating the needs of employees with disabilities? Do you have any suggestions to offer as to how both the policy and the implementation of the policy could be improved?	high
9. Could you suggest the names of persons we should interview during the evaluation?	medium

Notes:

(1) This study was conducted by an external firm.

(2) Employment Equity in the Public Service, Annual Report, 1992-93, President of the Treasury Board.