ADA & Workplace Accommodations
For Colorado College Faculty & Staff
Colorado College (CC) is committed to supporting faculty and staff with disabilities through a fair, consistent, and confidential accommodation process. We are committed to providing reasonable workplace accommodations to qualified employees with disabilities and certain medical conditions.
A workplace accommodation is a modification or adjustment that helps an employee perform the essential functions of their job and participate fully in the workplace. Accommodation requests are reviewed on an individual basis through an interactive process involving the employee, Human Resources (HR), and, when appropriate, the employee's supervisor.
Employees with pregnancy-related limitations should review the Pregnant Workers Fairness Act (PWFA) guidance below.
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What is ADA?
The Americans with Disabilities Act (ADA) is a federal law that prohibits discrimination against qualified individuals with disabilities and requires employers to provide reasonable accommodations when needed to perform essential job functions.
CC complies with the ADA in all aspects of employment.
Examples of Reasonable Accommodations
Reasonable Accommodations May Include:
- Modified or flexible work schedules
- Temporary remote or hybrid work arrangements (when appropriate to the role)
- Ergonomic adjustments or equipment
- Assistive technology
- Reassignment of marginal (non-essential) duties
- Leave as an accommodation
- Workspace modifications
Not every requested accommodation will be considered reasonable if it:
- Eliminates essential job functions
- Creates significant operational hardship
- Fundamentally alters the position
Requesting a Workplace Accommodation
Step 1: Initiate a Claim with Sun Life
Employees requesting a workplace accommodation must first submit medical certification documentation through Sun Life.
Once certification is received, Sun Life will notify HR regarding eligibility and functional limitations (not diagnosis details).
Contact Sun Life
Phone: 1-800-SUN-LIFE (786-5433)Website: Sun Life Portal
Forms & Resources: Sun Life Forms Library
Sun Life Policy #: 996298
Step 2: Partnership with the Office of Human Resources
After certification is confirmed, HR will partner with the employee and, as appropriate, the employee's supervisor to discuss workplace accommodation needs, explore reasonable accommodation options, and begin the interactive process.
For questions about the process:
Office of Human Resources
Colorado College
Phone: (719) 389-6421
Email: leave@coloradocollege.edu
UNDERSTANDING THE INTERACTIVE PROCESS
This process includes:
- Reviewing certified functional limitations
- Identifying essential job functions
- Exploring reasonable accommodations
- Determining whether the accommodation creates undue hardship
Accommodation decisions are individualized and based on the specific role and circumstances.
MEDICAL PRIVACY & CONFIDENTIALITY
CC prioritizes employee privacy.
- Medical documentation is submitted directly to Sun Life, not to supervisors or HR.
- HR receives only information related to functional limitations and accommodation eligibility.
- Supervisors are informed only of approved accommodations, not medical diagnoses.
All records are maintained in accordance with applicable confidentiality and privacy laws.
ADA GUIDANCE
In accordance with the ADA and applicable federal and state laws, CC does not discriminate against qualified applicants or employees on the basis of disability.
The College complies with the ADA in all aspects of employment, including:
- Recruitment and hiring
- Job assignments
- Compensation and benefits
- Training and advancement
- Performance evaluation
- Leave policies
- Termination or separation
- All other terms, conditions, and privileges of employment
WHO IS COVERED UNDER THE ADA?
The ADA protects qualified individuals who have a physical or mental impairment that substantially limits one or more major life activities.
Conditions may include, but are not limited to:
- Chronic medical conditions
- Mental health conditions
- Mobility impairments
- Neurological conditions
- Sensory disabilities
- Certain temporary impairments
If you are unsure whether your condition qualifies, you are encouraged to begin the certification process through Sun Life.
RELATED LEAVE PROGRAMS & POLICIES
ADA accommodations may intersect with other policies, including:
- Family and Medical Leave (FMLA)
- Colorado Paid Family Leave (COPFML / FAMLI)
- Workers’ Compensation
- Health & Safety Leave (Sick Leave)
- Nondiscrimination and Anti-Harassment Policy and Procedures
HR can help determine which policies apply.
CC strictly prohibits discrimination, harassment, or retaliation against any employee for:
- Requesting an accommodation
- Initiating certification through Sun Life
- Participating in the interactive process
- Raising concerns about ADA compliance
Employees who believe their rights have been violated should contact:
Director of Employee Relations & Support
Office of Human Resources
Colorado College
Phone: (719) 389-6421
Email: hr@coloradocollege.edu
and
Office for Civil Rights & Title IX
Colorado College
Phone: (719) 389-6881
Email: titleix@coloradocollege.edu
Resources: Policy & Procedures
APPEALS PROCESS
If an employee wishes to appeal an accommodation determination, they may contact the ADA/504 Coordinator who serves as the designated contact for ADA appeals.
Information regarding the appeals process is available through HR.
PWFA GUIDANCE
Employees experiencing limitations related to pregnancy, childbirth, or related medical conditions must also initiate certification through Sun Life.
PWFA requires employers to provide reasonable accommodations for known limitations related to pregnancy and related medical conditions.
Examples may include:
- Additional rest breaks
- Temporary schedule modifications
- Light-duty adjustments
- Temporary reassignment of non-essential tasks
- Seating accommodations
The College will engage in the interactive process following certification, consistent with ADA procedures.
PWFA does not replace the ADA or other leave laws; employees may be eligible under multiple frameworks simultaneously.
ADA & Employee FAQs
The ADA protects qualified employees and applicants who have a physical or mental impairment that substantially limits one or more major life activities.
Protection applies to current employees, applicants for employment, and individuals with a record of such an impairment.
Employees must begin the process by initiating medical certification through Sun Life, CC’s third-party administrator.
Medical documentation is submitted directly to Sun Life to protect employee privacy.
Once certification is reviewed, HR will engage in the interactive process.
For process questions, contact:
Director of Employee Relations & Support
Office of Human Resources
Colorado College
Phone: (719) 389-6421
Email: leave@coloradocollege.edu
No. Employees are not required to disclose a diagnosis unless they are requesting an accommodation.
Medical documentation is submitted only to Sun Life — not to supervisors.
Yes. Employees requesting accommodation must complete the certification process through Sun Life.
This ensures:
- Legal compliance
- Fair and consistent review
- Protection of medical privacy
The process includes:
- Medical certification review by Sun Life
- Confirmation of functional limitations
- Interactive discussion with HR
- Review of essential job functions
- Determination of reasonable accommodation
Each request is evaluated individually.
Even if a condition does not qualify under the ADA, other policies may apply, including:
- FMLA
- Colorado FAMLI
- Short-Term or Long-Term Disability benefits administered through Sun Life
- Health benefits administered through Cigna
HR can help determine available options.
- Medical documentation is submitted to Sun Life only.
- HR receives information regarding functional limitations and eligibility.
- Supervisors are informed only of approved accommodations — not medical diagnoses.
All information is handled confidentially.
No. The College is required to provide a reasonable accommodation — not necessarily the employee’s preferred accommodation.
If multiple effective accommodations are available, the College may choose among them.
HR will communicate the determination directly to the employee.
If approved, HR will coordinate implementation with the supervisor.
If an accommodation is approved, the College is responsible for purchasing or arranging necessary work-related equipment, assistive technology, services, or workplace modifications needed to support the approved accommodation.
Employees should not independently purchase equipment without prior approval from HR.
Formalizing the request:
- Ensures legal compliance
- Protects the employee
- Ensures consistency
- Maintains documentation
- Protects supervisors and departments
Informal arrangements may not meet ADA requirements and may not continue if leadership changes.
If your medical condition changes or you need a different accommodation:
- Contact Sun Life to update certification
- Notify HR
- Engage in the interactive process again
Accommodations may be adjusted as needed.
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Supervisor FAQs
Yes. Once certification is confirmed, HR will contact the supervisor as part of the interactive process.
Supervisors will not receive medical details — only functional limitations and approved accommodations.
Supervisors should:
- Do not retain medical documentation
- Do not evaluate the documentation
- Refer the employee to initiate certification with Sun Life
- Notify HR
All medical documentation must go through Sun Life.
If an employee returns with work restrictions from:
- Sun Life
- A medical provider
- Cigna-related documentation
The supervisor should:
- Refer the employee to HR immediately
- Ensure certification is on file through Sun Life
- Wait for guidance from HR before modifying duties
All work restrictions must be reviewed through the formal accommodation process.
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Key Terms & Definitions
About These Definitions
The following definitions are intended to help employees understand common terms referenced throughout the accommodation process.
Sun Life
Colorado College's third-party administrator that receives medical documentation, reviews certification, and communicates eligibility and functional limitations to Human Resources.
Human Resources (HR)
The Office of Human Resources partners with employees and supervisors throughout the accommodation process, facilitates the interactive process, and helps ensure compliance with applicable laws and College policies.
ADA (Americans with Disabilities Act)
A federal law that prohibits discrimination against qualified individuals with disabilities and requires employers to provide reasonable accommodations when appropriate.
Disability
A physical or mental impairment that substantially limits one or more major life activities; a record of such an impairment; or being regarded as having such an impairment.
Substantially Limiting
A condition is substantially limiting if it significantly restricts an individual's ability to perform a major life activity compared to most people in the general population.
Qualified Employee
An individual who meets the skill, education, experience, and other job-related requirements of a position and can perform the essential functions of the job with or without a reasonable accommodation.
Major Life Activities
Activities that are important to daily life, such as walking, seeing, hearing, speaking, breathing, learning, concentrating, working, lifting, caring for oneself, and the operation of major bodily functions.
Essential Functions
The fundamental duties of a position. Essential functions do not include marginal or incidental job duties.
Reasonable Accommodation
A modification or adjustment that enables a qualified employee with a disability to perform essential job functions or enjoy equal employment opportunities.
Interactive Process
A collaborative discussion between the employee, Human Resources, Sun Life, and, when appropriate, the employee's supervisor to determine effective workplace accommodations.
Undue Hardship
An accommodation that would create significant difficulty, expense, or operational impact for the College.
Direct Threat
A significant risk of substantial harm to the health or safety of the employee or others that cannot be eliminated or reduced through a reasonable accommodation.
PWFA (Pregnant Workers Fairness Act)
A federal law requiring employers to provide reasonable accommodations for known limitations related to pregnancy, childbirth, or related medical conditions.
FMLA (Family and Medical Leave Act)
A federal law that provides eligible employees with job-protected leave for qualifying family and medical reasons.
COPFML / FAMLI
Colorado's Paid Family and Medical Leave program and Colorado College's private leave plan that provides paid leave benefits for qualifying family and medical circumstances.
ADA/504 Coordinator
The designated College official responsible for overseeing compliance with the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. The ADA/504 Coordinator serves as a resource regarding disability-related concerns and accommodation appeals.
Office for Civil Rights & Title IX
The Colorado College office responsible for addressing concerns related to discrimination, harassment, retaliation, and Title IX compliance. Employees may contact this office if they believe their rights have been violated or have concerns regarding discrimination or harassment.
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Need Assistance?
All ADA and PWFA workplace accommodation questions should be directed to:
Office of Human Resources
Colorado College
Phone: (719) 389-6421
Email: hr@coloradocollege.edu