Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794d)

Section 508 of the Rehabilitation Act (Section 508) requires all electronic and information technology (also referred to as information and communication technology or ICT) that is developed, procured, maintained, or used by a federal agency to be accessible to people with disabilities. Examples of ICT include web sites, telephones, multimedia devices, and copiers. Access available to individuals with disabilities must be comparable to access available to others. Standards for Section 508 compliance are developed and maintained by the United States Access Board. Further information about the Access Board’s standards and Section 508 generally may be found at www.section508.gov.

The Inter-American Foundation is committed to making its Web site accessible to all. The site has undergone rigorous review and redesign to ensure that it meets or exceeds the requirements of Section 508 of the Rehabilitation Act of 1973. E-mail comments or suggestions to inquiries@iaf.gov. In general, if you have problems accessing any information, viewing any page with adaptive technology, or using any forms, or wish to file a complaint, send email to inquiries@iaf.gov.

Architectural Barriers Act of 1968 (42 U.S.C. §§ 4151–57)

The Architectural Barriers Act (ABA) requires access to facilities that are designed, built, altered, or leased with Federal funds. The Access Board is the federal agency responsible for enforcing the ABA. The Access Board’s accessibility standards are available on their website at www.access-board.gov/guidelines-and-standards/buildings-and-sites/about-the-aba-standards, and information about filing a complaint may be found at https://www.access-board.gov/enforcement/complaint.html.

22 CFR 1003.4 – Inter-American Foundation system of records requirements.

(a) The Inter-American Foundation will maintain in its records any such information about an individual as is relevant and necessary to accomplish a purpose of the Inter-American Foundation required to be accomplished by statute or Executive order of the President.

(b) The Inter-American Foundation will collect information to the greatest extent practicable directly from the subject individual when the information may result in adverse determinations about an individual’s rights, benefits, and privileges under Federal programs.

(c) The Inter-American Foundation will inform each individual whom it asks to supply information, on the form which it uses to collect the information or on a separate form that can be retained by the individual of:

(1) The authority (whether granted by statute or Executive order of the President) which authorizes the solicitation of the information and whether disclosure of such information is mandatory or voluntary;

(2) The principal purpose or purposes for which the information is intended to be used;

(3) The routine uses which may be made of the information, as published pursuant to paragraph (d)(4) of this section; and

(4) The effects on him or her, if any, of not providing all or any part of the requested information.

(d) Subject to the provisions of paragraph (k) of this section, the Inter-American Foundation will publish in the Federal Register at least annually a notice of the existence and character of its system of records. This notice will include:

(1) The name and location of the system or systems;

(2) The categories of individuals on whom records are maintained in the system or systems;

(3) The categories of records maintained in the system or systems;

(4) Each routine use of the records contained in the system or systems, including the categories of users and the purpose of such use;

(5) The policies and practices of the Inter-American Foundation regarding storage, retrievability, access controls, retention, and disposal of the records;

(6) The title and business address of the Inter-American Foundation official or officials responsible for the system or systems of records;

(7) The Inter-American Foundation procedures whereby an individual can be notified at his or her request if the system or systems of records contain a record pertaining to him or her;

(8) The Inter-American Foundation procedures whereby an individual can be notified at his or her request how he or she can gain access to any record pertaining to him or her contained in the system or systems of records, and how he or she can contest its content; and

(9) The categories of sources of records in the system or systems.

(e) All records used by the Inter-American Foundation in making any determination about any individual will be maintained with the accuracy, relevance, timeliness, and completeness reasonably necessary to assure fairness to the individual in the determination.

(f) Before disseminating any record about any individual to any person other than an agency the Inter-American Foundation will make reasonable efforts to assure that such records are accurate, complete, timely, and relevant for Inter-American Foundation purposes unless the dissemination is required pursuant to 5 U.S.C. 552.

(g) The Inter-American Foundation will maintain no record describing how any individual exercises rights guaranteed by the First Amendment unless expressly authorized by statute or by the individual about whom the record is maintained or unless pertinent to and within the scope of an authorized law enforcement activity.

(h) The Inter-American Foundation will make reasonable efforts to serve notice on an individual when any record on such individuals is made available to any person under compulsory legal process when such process becomes a matter of public record.

(i) The Inter-American Foundation will establish rules of conduct for persons involved in the design, development, operation, or maintenance of any system of records, or in maintaining any record. Each such person will be instructed regarding such rules and the requirements of 5 U.S.C. 552a. The instruction will include any other rules and procedures adopted pursuant to 5 U.S.C. 552a, and the penalties it provides for noncompliance.

(j) The Inter-American Foundation will establish appropriate administrative, technical, and physical safeguards to insure the security and confidentiality of records and to protect against any anticipated threats or hazards to their security or integrity which could result in substantial harm, embarrassment, inconvenience, or unfairness to any individual on whom information is maintained.

(k) At least 30 days prior to the publication of a notice in the Federal Register at least annually regarding the routine use of the records contained in the Inter-American Foundation system or systems of records including the categories of users and the purpose of such use, pursuant to paragraph (d)(4) of this section, the Inter-American Foundation will also:

(1) Publish a notice in the Federal Register of any new use or intended use of the information in the system or systems; and

(2) Provide an opportunity for interested persons to submit written data, views, or arguments to the Inter-American Foundation.

Revised 9/25/2022

I. Purpose

This directive establishes the Inter-American Foundation’s (IAF) procedures for closing the agency temporarily in the event of a lapse in federal appropriations.

II. Applicability

The provisions of this directive are applicable to all Foundation organizational elements.

III. Authority

a. Memorandum for Heads of Executive Agencies M-18-05

b. Office of Management and Budget Bulletin No. 80-14

c. Office of Management and Budget Bulletin No. 80-14, Supplement 1

d. Office of Management and Budget Circular A-11, section 124

e. Anti-Deficiency Act (31 USC §§ 1341-1342 §§ 1511-1519)

f. Opinion from the Office of the Attorney General on the Anti-Deficiency Act, dated January 16, 1981

g. Article 1, section 9, clause 7 of the Constitution

h. Chapters 13 and 15, Title 31, United States Code

IV. Background

From time to time, the Congress fails to enact appropriations bills by the beginning of the fiscal year. As an interim measure, Continuing Resolutions are passed that allow agencies to continue their operations on a limited basis until the enactment of an annual appropriation. In some cases, an agency may be required to operate under a Continuing Resolution for the entire fiscal year. There have been other cases where neither an appropriation nor a continuing resolution was enacted in time to prevent a lapse in the current appropriations. When this happens, agencies, by law, may only provide services necessary to protect the lives and safety of their employees or the public, or to protect government property. All other activities must cease and an orderly shutdown of the agency must start. Because it was necessary for some agencies to start the shutdown process in the past, and some confusion arose, the Office of Management and Budget required each agency to develop procedures to be followed for an orderly shutdown in the event of an appropriation hiatus.

V. Procedures

The President of the IAF will order the initiation of preparations for the orderly shutdown of Foundation activities when there is either an impending appropriated funds shortfall or an absence of new appropriations. At that time the President will establish the target date for commencing shutdown activities. Employees will be notified and actions will be taken in accordance with the following guidance.

A. Authorized Activities during the Orderly Suspension of Agency Activities

As a general rule, the only activities authorized for IAF employees if appropriations are about to be, or are, exhausted are those that contribute to an orderly suspension of Foundation activities. Such activities include:

1. Activities required to plan, control, and maintain orderliness throughout the shutdown of operations, including the development of plans and schedules for the preparation of personnel, grant, property and financial files for appropriate transfer and for the inventory of IAF property;
2. Activities required to meet all the legal responsibilities of the IAF, such as processing personnel actions, payments of compensation owed to employees and taking necessary administrative actions related to contracts and purchase orders for which funds were obligated prior to the determination of a shutdown requirement. Such activities should be finalized to the maximum extent possible prior to the shutdown date;
3. Fiscal and accounting activities required to maintain accountability and reporting with respect to obligations and expenditures;
4. Activities required to inform employees, volunteers, the public, and the IAF’s grantees, fellows, and contractors of the effect of shutdown;
5. Emergency situations involving the safety of human life; and
6. Services necessary to protect Federal property, which include:

a) Necessary security service to protect Federal property.

b) Continuance of leases of property which contain Federal property.

c) Cost of any special maintenance required to protect information technology because without such maintenance data could be unreliable or be destroyed.

B. Prohibited Activities

The following activities are prohibited, except to the extent they are essential to directly support activities authorized to continue:

1. Awards of grants, contracts, fellowships, or other forms of awards, and memoranda of agreement.
2. Hiring of personnel, extension of appointments, or other personnel action that involve obligating funds.
3. Travel of persons or transportation of things. Persons in travel status on the target date will return to their duty stations as soon as possible. To the extent that a shutdown has been identified as reasonably likely to occur, travel should not be planned or authorized for the period in which a shutdown may occur.
4. Training classes or activities.
5. Use of equipment and utilities not related to authorized activities.
6. Cash expenditures of any kind even if related to authorized activities. If employees who are identified as essential to the orderly shutdown of agency activities as described below wish to expend their own cash in connection with authorized shutdown activities they may be authorized by their supervisor to do so, with the expectation of reimbursement for otherwise allowable expenses if an appropriation or continuing resolution is passed.

C. Phase-down Plan

During the period before actual shutdown, each office will review its activities to ensure that no unauthorized activities will take place after the shutdown date. If there is no Continuing Resolution or other new funding before that date, the following general actions will be taken.

Each office will identify activities that must be carried out to permit an orderly shutdown of activities. Offices will also provide information on a continuing basis to staff, grantees, fellows, and the public on the status of phase-down activities.

Each office head will notify their employees of the IAF’s shutdown policy and general furlough process. Employees being furloughed will receive formal notice from the Chief Operating Officer once the Continuing Resolution or appropriation lapses.

Inventorying property and reviewing files for appropriate disposition are considered an integral part of phase-down. Specific instructions for these and other similar functions will be issued when necessary.

D. Voluntary Services

Based on the Attorney General’s opinion, the IAF cannot accept the voluntary services of employees to work in periods of lapsed appropriations with the expectation that their services would be compensated after an appropriation is received. The only activities in which employees or volunteers may engage after the target date for shutdown are those which are authorized in connection with phase-down or in connection with the safety of life or protection of government property. Additionally, only the persons identified below are to remain on duty after the day the actual shutdown goes into effect. Authorizing any other kind of activity risks the very real possibility that the IAF will be unable to compensate the individual for such services at a later date, as well as the possibility of committing a violation of the Anti-deficiency Act, which could have administrative and/or criminal consequences for the employee(s) and/ or officer(s) involved in addition to the agency.

E. Day of the Agency Shutdown

Consistent with the policy and justifications discussed above, the only IAF employees to be considered excepted from furlough under a lapse of appropriation are those necessary to effectuate the orderly suspension of agency activities – i.e., the IAF President (or his/her designee), General Counsel, Chief Operating Officer and Chief Information Officer.

1. If neither an appropriation nor a continuing resolution is enacted in time to prevent a lapse in appropriation, all IAF employees will report for work on the first business day of the shutdown. Non-excepted employees will have no more than a half day to wind down the agency activities for which they are responsible, including notifying the grantee, proponent and/or contractor organizations in their portfolios. After completing their shutdown-related activities, employees will receive an official furlough notice and then be dismissed until the shutdown has ended. Beyond the first half day of the shutdown, only excepted employees may conduct any work, and their activities during that time will be limited to the activities necessary to effectuate the orderly suspension of agency activities as described below.
2. The President or his/her designee will notify the Office of Management and Budget, the Office of Personnel Management, the U.S. Treasury and the General Services Administration that a shutdown of the agency has begun and will be expected to be completed by the end of the first day of the shutdown.
3. In addition to the President or his/her designee, the Chief Operating Officer, the Chief Information Officer and the General Counsel will remain on duty as necessary to provide for an orderly shutdown of the agency’s operations by close of business on the first day of the shutdown.
4. The Chief Operating Officer will forward time sheets to the payroll office at the Interior Business Center, Department of Interior, and issue the paperwork effecting the furlough of all agency employees. IAF management will ensure that all affected IAF employees receive formal notice of the furlough. Additionally, as each employee necessary for agency shutdown activities completes his/her shutdown function, he/she is to be furloughed immediately and formally notified. The Office of Personnel Management will provide guidance for the custody of personnel records after the agency’s operation is shutdown.
5. The Chief Operating Officer, serving as the Property Officer, will notify the General Services Administration that the agency has shutdown. It is expected that disposition of property will not occur for at least 30 days after the beginning of the agency’s shutdown operations and then only after a determination is made that the funding hiatus will continue indefinitely.
6. IAF, through its CORs and following guidance provided by the General Counsel, will notify all major agency contractors of the actual shutdown of operations of the agency based on previous notification given by the Contracting Officer with the Bureau of Fiscal Services in preparation and anticipation of a shutdown. As needed, the General Counsel will make a legal assessment and provide a legal opinion on matters arising from the shutdown of agency operations.

F. Subsequent Actions

If there is no new appropriation within 30 days after the lapse of funding, the President or his/her designee, the Chief Operating Officer, the Chief Information Officer and the General Counsel will assess if it is warranted to return to the lAF offices to arrange for final disposition or protection of agency properties and records. Periodic assessments shall continue for the duration of the shutdown.

In addition, during the period of a shutdown, these four employees will be intermittently exempted from furlough to address exigencies that may arise that threaten human life or property, as follows:

1. President and CEO – to exercise executive authority of the IAF
2. Chief Operating Officer – to coordinate personnel, budgetary and financial impacts of shutdown
3. General Counsel – to provide legal guidance in connection with the shutdown and represent the agency’s legal interests during a shutdown
4. Chief Information Officer – to ensure maintenance of agency information systems

Although only these employees are pre-determined as being intermittently exempted, all employees are subject to being recalled to duty to perform activities as may be specified during the shutdown; such a recall would take place only if the General Counsel and Chief Operating Officer both agree that an employee is needed to perform excepted activities based on circumstances that have emerged during the shutdown. During the furlough period, employees should closely monitor media coverage as well as the Office of Personnel Management’s website for notice that an appropriation has been or will shortly be approved and agency operations may resume. In addition, the President of the IAF or his/her designee(s) will notify employees if and when funds to resume operations become available. Such notification will include the date and time that employees are expected to return to duty.

Original material produced by the IAF is in the public domain and may be freely reproduced. However, certain material on the IAF Web site and in IAF publications has been provided by other sources and might be copyrighted. Reproduction of such material may require prior permission from the copyright holder. Direct inquiries to inquiries@iaf.gov.

MEMORANDUM

Date: March 2, 2022

To: All IAF Employees

From: Lesley Duncan, Interim President & CEO

Subject: Equal Employment Opportunity and Diversity Non-Discrimination Policy

As Interim President & CEO of the Inter-American Foundation (IAF), I am committed to the total integration of Equal Employment Opportunity (EEO) and Diversity principles as a fundamental part of the guiding principles we have at the IAF. All employees, applicants for employment, and members of the public who seek to participate in IAF programs, activities, and services will not be discriminated against because of race, national origin, sex (including pregnancy, sexual orientation, gender identity), religion, color, age (40+), disability (mental or physical), genetic information (including family medical history), or status as a parent. Furthermore, the IAF does not tolerate reprisal against those who exercise their rights under applicable EEO laws.

I am committed to ensuring all employees the freedom to compete fairly and equitably. Equal employment opportunity covers all personnel/employment programs, management practices and decisions, including, but not limited to: recruiting/hiring, merit promotions, transfers, reassignments, training and career development, benefits, and separations. I will ensure EEO program requirements are enforced in accordance with the governing regulatory guidelines. Allegations of discrimination are addressed promptly and professionally. The IAF promptly investigates all allegations of workplace harassment, and where allegations are substantiated, appropriate action is taken.

Employees or applicants who believe they have been discriminated against by the IAF have the right to file an EEO complaint. The first step is to contact EEO within 45 calendar days of the alleged discriminatory action or of the date you became aware of the discriminatory action. You may then choose to participate in either counseling or in Alternative Dispute Resolution (ADR) if it is available. At the end of counseling, or if ADR is unsuccessful, a formal EEO complaint may be filed.

I am committed to enforcing the Foundation’s policy of fair and equitable treatment of all employees, applicants for employment, or members of the public who believe they have been subjected to unlawful discrimination.

This policy is to be posted in all personnel offices, and on the Foundation’s internal Web site as a means to communicate the high level of importance I personally attach to equal employment opportunity at the IAF. Any questions regarding either this policy or a specific situation relevant to this policy may be addressed by the IAF EEO Director by email at eeo@iaf.gov or by telephone at (202) 360-4530. You may also direct questions to your manager.

Download Equal Employment Opportunity and Diversity Non-Discrimination Policy 2022 (pdf)

EEO Reports

• FY 2020 (pdf)
• FY 2019 (pdf)
• FY 2018 (pdf)
• FY 2017 (pdf)
• FY 2016 (pdf)

Executive Order 12674

On May 4, 2019 the President signed E.O. 13798 “Promoting Free Speech and Religious Liberty,” which established a policy of promoting religious liberty. On October 6, 2017, the Attorney General issued a memorandum advising that:

Religious organizations are entitled to compete on equal footing for Federal financial assistance used to support government programs.

On January 16, 2020, OMB issued Memorandum M-20-09, Guidance Regarding Federal Grants and Executive Order 13798, which provides that:

Accordingly, grant awarding agencies shall ensure that the terms of the Federal grants they award make clear that states or other public grantees may not condition sub-awards of Federal grant money in a manner that would disadvantage grant applicants based on their religious character.

The IAF does not discriminate against religious organizations in grant-making activities. Religious organizations are eligible to compete for government grants and participate in government programs on an equal basis with nonreligious organizations. The IAF does not require religious organizations to alter their religious character to participate in grant programs, nor to cease engaging in explicitly religious activities outside the program.

The IAF has revised the Annex B, Terms and Condition of Agreement, of its grant agreement and cooperative agreement packages to ensure Grantees and Cooperators will not condition sub-awards of Federal grant money in a manner that would disadvantage applicants based on their religious character. The IAF takes its responsibility seriously to ensure IAF Grantee and Cooperators are in compliance with all relevant provisions of Federal laws, executive orders, regulations, and public policies governing financial assistance awards.

The IAF’s issuance of this notice complies with OMB’s direction to publish policies detailing how they will administer Federal grants in compliance with E.O. 13798, the Attorney General’s memorandum, and the OMB Memorandum.

Since 2007, Federal agencies are required by law to conduct an Annual Employee Survey (AES). The survey is designed to address overall employee satisfaction as well as leadership and management practices that contribute to an agency’s performance.

Management Reports

• 2019
• 2018
• 2017
• 2016
• 2015

Survey Results

• 2020
• 2019
• 2018
• 2017

Homeland Security Presidential Directive 12 (HSPD-12) mandates the development and implementation of a government-wide standard for a secure and reliable Personal Identity Verification (PIV) card issued to Federal employees and contractors. The overall goal of HSPD-12 is to achieve appropriate security assurance by verifying the identity of individuals seeking physical access to federally controlled government facilities and electronic access to government information systems.

The U.S. Agency for International Development’s Office of Inspector General (OIG) provides oversight services for the IAF. The OIG’s major responsibilities are to detect and prevent fraud, waste, abuse and violations of law and to promote economy, efficiency and effectiveness.

Complaints may be received directly from employees, program participants, or the general public. The IG Act and other pertinent laws provide the protection of persons making complaints. Complaints may be communicated via mail, the OIG’s telephone or on-line “Hotlines” at:

U.S. Agency for International Development
Office of Inspector General Investigations (USAID/OIG/I)
P.O. Box 657
Washington, DC 20044-0657
E-Mail Address: ighotline@usaid.gov
Telephone: 1-800-230-6539 or 202-712-1023

For more information, see the OIG website.

The Notification of Federal Employee Antidiscrimination Retaliation Act of 2002 (No FEAR Act), Public Law 207-174, was signed into law by President George W. Bush on May 15, 2002, and became effective October 1, 2003. Its purpose is to increase the accountability of Federal agencies for violations of antidiscrimination and whistleblower protection laws.

One of the requirements of the No FEAR Act is for Federal agencies to post on their public website statistical data concerning complaints of employment discrimination. This data is updated on a quarterly basis.

Latest IAF No FEAR report

• 3rd Quarter 2021 (pdf)

For more than 40 years, the Inter-American Foundation has been channeling development assistance that supports the self-help efforts of the organized poor in Latin America and the Caribbean. From the onset, each of our grantees expects their work to be monitored and evaluated.

Pursuant to examining the requirements of The President’s Open Government initiative the IAF reviewed the information it currently provides on its programs and its stewardship of U.S. tax-payer dollars.

This section of the IAF website contains shortcuts to items of interest to the public.

Special Announcement:
Information About 2015 OPM Cybersecurity IncidentThe U.S. Office of Personnel Management (OPM) recently became aware of a cybersecurity incident affecting its systems and data that may have exposed the personal information of current and former Federal employees.

Beginning June 8 and continuing through June 19, 2015, OPM will be sending email and U.S. mail notifications to current and former Federal employees potentially impacted by the incident. Email notices will be sent from opmcio@csid.com. Standard letters will be sent to individuals for whom OPM does not have an email address.

The communication will contain information regarding services being provided at no cost to individuals impacted by the incident, including credit report access, credit monitoring, identity theft insurance, and recovery services. Additional information will be made available beginning at 8 a.m. CST on June 8, 2015 at www.csid.com/opm.

Applying for Grants:
The guidelines for applying for an IAF’s grant are clearly displayed on the IAF website as evidenced by the hundreds of organizations from Latin America and the Caribbean submit their ideas to the IAF every year.

Annual Report:
The Annual Report offers a detailed account of the IAF’s awards and other activities during the relevant fiscal year. Visitors to our website can also review archive publications related to IAF funding history.

Grassroots Development Journal:
The journal of the Inter-American Foundation, published since 1972, reports on the experiences of IAF grantees and analyzes development themes. Many issues include updates on former grantees, reported long after their funding has ended, that show how our investments continue to yield results. All issues are available online.

Evaluations:
IAF’s annual Results Report compiles data submitted by grantees and verified by IAF’s contractors, on indicators selected from the Grassroots Development Framework, main evaluation tool. Visitors to our Web site can review these reports as far back as 1998.

Policy, Compliance Statements and Reports:
The Policy, Compliance Statements and Reports section offers for public scrutiny the following: Privacy and Security Statements, Buy America, Copyright Statement, FAIR Act, FOIA, Audits by the Inspector General, No Fear Act, and Section 508.

Transparency:
In 2012, the IAF demonstrated its commitment to transparency and prudent use of its allocated funds by being evaluated by the Foundation Center and receiving the “glasspockets” designation for transparency, accountability and accessibility of information.

The IAF is committed to examining ways to improve access to this information. Recommendations are welcome and may be submitted to inquiries@iaf.gov.

MEMORANDUM

Date: December 9, 2020
To: All IAF Employees
From: Paloma Adams-Allen, President & CEO
Subject: IAF Policy on Procedures on Personal Assistance Services (PAS)

It is the policy of the Inter-American Foundation (IAF) to provide personal assistance services (PAS) to employees with targeted disabilities. IAF is fully Committed to comply with Section 501 of the Rehabilitation Act of 1973 and EEOC’ s amended regulation of its implementation (29 CFR 1614). The IAF fully realizes its obligation to provide PAS to its employees with targeted disabilities unless doing so would cause an undue hardship on the Agency. PAS are services that help individuals with targeted disabilities to perform basic activities of daily living at work, such as eating and using restrooms. The IAF is prohibited from taking adverse actions against job applicants or employees based on their need for, or perceived need for, personal assistance services.

Additional information on PAS can be found at EEOC’s website.

PAS requests will be processed in similar manner as noted in IAF’s Reasonable Accommodation Policy. Employees with targeted disabilities may request PAS by contacting their supervisor, a more senior official in their chain of command, Ms. Felicia Ellis, Disability Program Manager, U S Geological Survey (USGS) at fellis@usgs.gov or (703) 648-7786, or Federal Relay Service at (800) 877-8339.*

*IAF has established an Inter-Agency Agreement with the USGS, Office of Diversity and Equal Opportunity (DEO) to provide
EEO Services to the IAF.

Download IAF Personal Assistance Services Policy and Procedures 2020 (pdf)

To ensure the seamless continuity of IAF operations and services during the transition to the current administration’s second term or a new administration, we are pleased to make available our 2020 Presidential Transition Brief. We provide it consistent with the statutory obligations in the Presidential Transition Act of 1963, as amended (3 U.S.C. § 102 note).

Download Presidential Transition Brief 2020 (pdf)

MEMORANDUM

Date: March 11, 2022
To: All IAF Employees
From: Lesley Duncan, Interim President & CEO
Subject: IAF Policy on Harassment

It is the policy of the Inter-American Foundation (IAF) to provide employees a harassment-free work environment. As described below, the IAF prohibits harassment and has established procedures to prevent and promptly correct any harassment that may occur.

The IAF prohibits both ( 1) employment-related harassment based on race, ethnicity, national origin, sex (including pregnancy, sexual orientation, and gender identity), religion, color, age, disability (mental or physical), genetic information (including family medical history), marital status, parental status, political affiliation, or veteran’s status; and (2) other harassing conduct that is detrimental to a safe and effective workplace, regardless if such conduct violates Eequal Employment Opportunity (EEO) law. All employees, including managers and supervisors, shall receive periodic training on this policy.

(1) Unlawful Harassment

Under EEO law, harassment is any verbal or physical conduct, based on race, color, religion, national origin, age, disability, sex (with or without sexual conduct), genetic information, or protected activities, that either results in a tangible employment action or is so severe and pervasive as to constitute an intimidating, hostile or offensive work environment, including, but not limited to: (1) verbal conduct that could include racial or sexual epithets, foul language, unwanted sexual flirtations, ethnic jokes, derogatory statements or slurs; (2) physical conduct that could include improper touching or assault; or (3) visual harassment that could include racially or sexually explicit or derogatory posters, cartoons or drawings, or obscene gestures.

One form of unlawful harassment is sexual harassment. Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature constitute sexual harassment when “1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment, 2) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or 3) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.” 29 C.F.R. § 1604.11.

The following is a non-exhaustive list of examples of behaviors that may constitute harassment, including sexual harassment:

• Making offensive or unwelcome remarks about looks, clothing, or body parts
• Pressure for dates
• Touching in a way that may make an employee feel uncomfortable
• Telling sexual jokes, hanging sexual posters, etc.
• Epithets, slurs, negative stereotyping or threatening, intimidating, or hostile acts that relate to race, color, religion, gender, national origin, age, disability, sexual orientation, genetic information, or status as a parent
• Written or graphic material that denigrates or shows hostility or aversion toward an individual or group because of race, color, religion, gender, national origin, age, disability, sexual orientation, genetic information, or status as a parent, and that is placed on walls, bulletin boards, or visible elsewhere on the IAF premises, equipment, or electronic circulation of such material

(2) Other Harassing Conduct

In addition to the prohibition of harassment that violates EEO law, IAF policy also prohibits other harassing conduct that is detrimental to a safe and effective workplace. Such conduct ma include but is not limited to:

• Bullying
• Blame without justification
• Exclusion or social isolation
• Excessive micro-managing
• Tampering with an employee’s personal belongings

Employees are encouraged to report any such conduct immediately to their supervisor, an appropriate management official, the EEO director or directly to the Chief Operating Officer, who will make every effort to prevent or eliminate conduct before it rises to the level of unlawful harassment.

The IAF will quickly gather the facts involved in a situation and take whatever remedial action or disciplinary action may be warranted under the circumstances. This process is administered by the Chief Operating Officer, who, whenever a concern about harassment comes to their attention, will, within ten days, commence the following thorough and impartial process: (1) assess whether it is appropriate to trigger the expedited process, (2) determine whether the fact finding phase of that process is most appropriately conducted by internal Agency personnel or an outside investigator, and (3) forward the results of the fact finding, along with their recommendation for any follow up actions, to the President and CEO for final decision on the matter. Employees or applicants may submit concerns about harassment directly to the Chief Operating Officer.

EEO Complaint Process

In addition to the process summarized above, individuals who believe they have been subjected to EEO based harassment, retaliation, or any other form of discrimination on the basis of a protected class (race, color, religion, sex (including gender identity, sexual orientation, and pregnancy), national origin, age (40 or older), disability or genetic information) may file an EEO complaint by contacting the EEO Director. Please be advised that, to be accepted as timely, a complaint of harassment must be submitted to the EEO Director within 45 calendar days of the alleged harassing incident. For further information on the EEO process, please contact the EEO Director at eeo@iaf.gov or (202) 360-4530.

Other possible resources available to the employees for reporting allegations of harassment include the IAF Office of Operations, the IAF Administrative Grievance procedure, the U.S. Office of Special Counsel if a prohibited personnel practice is involved, the Merit Systems Protection Board if an appealable adverse action is involved, and the USAID Office of Inspector General.

All actions taken to resolve and address issues of harassment will be kept confidential to the greatest extent possible, and retaliatory action against an employee or applicant who raises a claim of harassment, or who has witnessed harassment, will not be tolerated. The IAF will undertake immediate and appropriate corrective action, including discipline, whenever it determines that harassment has occurred in violation of the Agency’s policy. Any employee found to have participated in harassment of any kind, or retaliation, will be the subject of appropriate administrative or disciplinary action, which may include removal from federal service.

Download IAF Policy on Harassment 2022 (pdf)

While visiting IAF.gov, we will not collect any personal information unless you choose to provide it. If you choose to provide this information, it will be used for the express purpose for which it was intended, such as responding to a general inquiry. We remind you that if you visit a link outside of IAF.gov you are subject to the privacy policies of that site.

Information Collected and Stored Automatically

IAF.gov automatically collects some technical information when you visit the site in order to give you the best possible experience. IAF.gov uses web measurement technology (Google Analytics) to automatically track how visitors interact with IAF.gov including where they came from, what they did on the site and whether they completed any pre-determined tasks while on the site. This type of usage is classified by the Office of Management and Budget as Tier 2, since it is a multi-session web measurement. Aggregate data is used to help IAF improve our user interface and diversify our content offerings to meet the needs of our visitors, track operational problems, prevent fraud and improve the effectiveness, security and integrity of the site. This information does not identify you personally. For each page that you visit, we collect and store only the following technical information:

• Date and time of access
• URL address of the pages visited
• Internet domain and IP address from which our website was accessed
• Type of browser and operating system used to access our site (if provided by the browser)
• URL address of the referring page (if provided by the browser)
• Completion or success status of the request for a web page or other on-line item
• File size of the webpage visited

This information is only used to help us make the site more useful by tracking the number of visitors and the types of technology they use. We never track or record information about individuals and their visits and we do not share this data with anyone outside the IAF, unless necessary for law enforcement purposes.

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By default, persistent cookies and web measurement technologies are automatically used when you visit IAF.gov. Nevertheless, if you decide to disable or remove cookies from your browser, you will continue to have access to all information and resources on IAF.gov. To learn more about how to disable cookies please visit usa.gov/optout_instructions.html

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The E-Government Act requires agencies to conduct privacy impact assessments for collections of information through electronic information systems or otherwise and make them publicly available.

Inter-American Foundation PIA (pdf).

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IAF.gov complies with the Children’s Online Privacy Protection Act of 1998 (COPPA) and its accompanying regulations protect the privacy of children using the Internet. IAF.gov does not knowingly contact children under 13 or collects their personal information. IAF.gov is not intended to solicit information of any kind from children under 13.

It is possible that by fraud or deception we may receive information pertaining to children under 13. If we are notified of this, as soon as we verify the information, we will immediately obtain parental consent or otherwise delete the information from our servers. If you want to notify us of our receipt of information by children under 13, please do so by sending an e-mail to iafhelpdesk@iaf.gov.

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Except for authorized law enforcement investigations, no attempts are made to identify individual users and their usage habits. Raw data logs are used for no other purposes and are scheduled for regular destruction in accordance with National Archives and Records Administration General Schedule 20.

Unauthorized attempts to upload information or change information on this service are strictly prohibited and may be punishable under the Computer Fraud and Abuse Act of 1986 and the National Information Infrastructure Protection Act.

Social Media and Third Party Websites

The IAF uses social media and other websites to interact with the public. Social media websites are used to publicize programs and services and engage with members of the public. The IAF does not use third party websites to solicit and collect personal information from individuals. Any personal information collected by a third party website will not be transmitted to IAF unless required for law enforcement purposes or as otherwise permitted by law. IAF’s privacy and other web policies do not apply to these third party sites and we encourage you to read the policies of the third party site when deciding whether to use it. Official IAF social media sites are listed below:

Facebook: https://www.facebook.com/iafgrassroots

Vimeo: https://vimeo.com/user15989133/videos

Twitter: https://twitter.com/IAFgrassroots

Instagram: https://instagram.com/iafgrassroots/

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INTER-AMERICAN FOUNDATION POLICY ON REASONABLE ACCOMMODATION FOR QUALIFIED INDIVIDUALS WITH DISABILITIES

Download IAF Reasonable Accommodations Policy 2022 (pdf)

SECTION 1. PURPOSE

To establish the Inter-American Foundation’s (IAF or Agency) policy (Policy) on providing effective and reasonable accommodations (Reasonable Accommodations) to qualified individuals with disabilities (Qualified Individuals with Disabilities) who are employees (Employees) and applicants for employment (Applicants), and to ensure these individuals are offered the resources necessary to be successful and productive and enjoy equal access to all employment opportunities. Reasonable Accommodations enhance the ability of Qualified Individuals with Disabilities to apply for jobs, perform the essential functions of the job, and enjoy equal benefits and privileges of employment. This Policy also describes the procedures the IAF should use for processing requests for accommodations (Requests), unless the IAF can demonstrate that a particular accommodation would impose an undue hardship (Undue Hardship) on the operation of its program.

SECTION 2. AUTHORITY

On July 26, 2000, President Clinton signed Executive Order 13164 (Order), which requires each federal agency to establish effective written procedures for processing Requests for Reasonable Accommodation. The Order helps to implement the requirement of the Rehabilitation Act of 19732 that agencies provide Reasonable Accommodation to qualified Applicants and Employees with disabilities.

SECTION 3. DEFINITIONS

A. Applicant: An individual who has applied to a position or positions, including those who have been selected for an interview, whether the position(s) is paid or unpaid.

B. Authorized Individual: A third party individual acting on behalf of the individual with a disability requesting an accommodation. Examples of an Authorized Individual may include a family member, friend, health care professional, or other representative. When an Authorized Individual makes a Request on behalf of an Employee or Applicant, the deciding official (Deciding Official) should confirm with the Employee or Applicant whether they want to continue proceeding with the Request. If this is not possible, the Deciding Official will process the Request as appropriate and will consult directly with the individual whose accommodation is being processed as soon as practicable.

C. Deciding Official: a supervisor or manager who has the authority to determine whether a requested accommodation will be provided.

D. Disability: With respect to an individual: (i) a physical or mental impairment that substantially limits one or more major life activities of such individual; or (ii) a record of an impairment; or (iii) being regarded as having such an impairment .

E. Employee: An individual employed by the Federal government, specifically the IAF. This term excludes contractors.

F. Essential Job Functions: Those job duties that are so fundamental to the position that the individual cannot do the job without being able to perform them. A function can be “essential” if, among other things, the position exists specifically to perform that function, there are a limited number of other employees who could perform the function if it were assigned to them, or the function is specialized and the incumbent is hired based on his/her ability to perform it.

G. Interactive Process: Exchange between the individual and the employer that starts with a Request and continues with a dialogue to understand all the relevant factors necessary to accommodate the Request.

H. Major Life Activities: include, but are not limited to, functions such as caring for oneself, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, standing, bending, lifting, and working. Major Life Activities also include the operation of a major bodily function, including functions of the immune system, special sense organs and skin; normal cell growth; and digestive, genitourinary, bowel, bladder, neurological, brain, respiratory, circulatory, cardiovascular, endocrine, hemic, lymphatic, musculoskeletal, and reproductive functions. The operation of a major bodily function includes the operation of an individual organ within a body system. Determining whether an activity is a Major Life Activity does not require assessing whether the activity is of central importance to daily life, nor does the term “major” create a strictly demanding standard for determining Disability.

I. Personal Assistant Services (PAS): Services needed by a person with a targeted disability (Targeted Disability) to perform Essential Job Functions. These services include assistance with performing activities of daily living that an individual would typically perform if he or she did not have a Disability, for example, general administrative tasks such as carrying items, lifting and moving equipment and files, and other tasks needed to perform specific job functions or assistance with basic activities of daily living and Major Life Activities such as eating and using the restroom.

J. Physical or Mental Impairment: (a) Any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems: neurological, musculoskeletal, special sense organs, respiratory (including speech organs), cardiovascular, reproductive, digestive, genitourinary, immune, circulatory, hemic and lymphatic, skin, and endocrine. (b) Any mental or psychological disorder, such as an intellectual Disability, organic brain syndrome, emotional or mental illness, or specific learning disability.

K. Qualified Individual with a Disability: A person who meets the appropriate skill, experience, education, or other requirements of an employment position that he or she holds or seeks, and who can perform the Essential Job Functions of the position with or without Reasonable Accommodation.

L. Reasonable Accommodation: a change in the work environment or in the application process that would enable a Qualified Individual with a Disability who is an Employee or Applicant to enjoy equal employment opportunities.

There are three categories of Reasonable Accommodations:

i. modifications or adjustments to a job application process that enable a Qualified Individual with a Disability who is an Applicant to be considered for employment/appointment with the Agency, (such as providing application forms in alternative formats like large print or Braille);

ii. modifications or adjustments necessary to enable a Qualified Individual with a Disability who is an Employee to perform the Essential Job Functions of their position (such as providing sign language interpreters and personal assistance services); and

iii. modifications or adjustments that enable a Qualified Individual with a Disability who is an Employee to enjoy equal benefits and privileges of employment as are enjoyed by other similarly situated Employees (such as removing physical barriers in an office cafeteria).

A modification or adjustment is reasonable if it “seems reasonable on its face, i.e., ordinarily or in the run of cases.” An accommodation also must be effective in meeting the needs of the individual. There are some changes or things that are not considered to be Reasonable Accommodations, such as the removal of an Essential Job Function or the provision of personal use items (e.g., hearing aid that is needed on and off the job, eyeglasses, etc.).

Reasonable Accommodation may include, but is not limited to:

1. making facilities readily accessible to, and usable by, people with Disabilities;
2. job restructuring or modifying work schedules;
3. granting breaks or providing liberal leave;
4. altering how or when job duties are performed;
5. providing liberal telework;
6. moving to a different office space within Agency facility;
7. providing materials in alternative formats (e.g., Braille, large print);
8. acquiring or modifying assistive technology (e.g. information technology (IT), communications equipment, or specifically designed furniture);
9. appropriate adjustment or modification of examinations and training materials;
10. providing readers, interpreters and other auxiliary aids to enable Employees to perform Essential Job Functions, where the accommodation cannot be provided by current staff;
11. reassignment to a vacant position for which an Employee is qualified, without competition.

M. Reassignment: Reassignment, to a vacant position, is a form of Reasonable Accommodation. It may be provided to an Employee who, because of a Disability, can no longer successfully perform the Essential Job Functions of their current job, with or without a Reasonable Accommodation. Where possible, Reassignment is to an equivalent position, but if no equivalent position is available, may be to a lower level position that is as close as possible to the Employee’s current position. If the Employee is qualified for such a position, the Employee will be reassigned to the new job without competition. Reassignments are usually an accommodation of last resort.

N. Request: a statement by an individual with a Disability that h/she needs an adjustment or change at work for a reason related to a medical condition, whether oral or written and/or explicit or implicit. A Request may be made at any time when such an individual determines an accommodation is needed. A Request can also be made by an Authorized Individual of the Employee.

O. Targeted Disability: a subset of the larger Disability category. These Targeted Disabilities include: developmental disabilities; traumatic brain injuries; deafness or serious difficulty hearing; blindness or serious difficulty seeing even when wearing glasses; missing extremities; significant mobility impairments; partial or complete paralysis; epilepsy or other seizure disorders; intellectual disabilities; significant psychiatric disorders; dwarfism; and significant disfigurement.

P. Undue Hardship: when a specific accommodation would require significant difficulty or expense on the resources and circumstances of the Agency in relationship to the cost or difficulty of providing a specific accommodation. Undue Hardship refers not only to financial difficulty, but to Reasonable Accommodations that are unduly extensive, substantial, or disruptive, or those that would fundamentally alter the nature or operation of the Agency. This determination will be made on a case-by-case basis, considering factors including but not limited to the following:

1. nature and cost of the accommodation needed;
2. overall size of the organizational unit with respect to the number of employees, number and type of facilities and size of budget;
3. type of operation, including composition and structure of the workforce; and
4. the impact of the accommodation on the operations of the Agency.

SECTION 4. RESPONSIBILITIES

A. The President, Equal Employment Opportunity (EEO) Director, General Counsel and Chief Operating Officer (COO) of the IAF shall:

1. approve policies, directives and other materials outlining the IAF’s Reasonable Accommodation responsibilities;
2. foster an environment that supports Reasonable Accommodations; and
3. ensure Agency compliance with the provisions of this Policy.

B. The Office of Operations shall:

1. ensure that all vacancy announcements provide instructions for making Requests for accommodations;
2. assist supervisors and other relevant Agency Employees to search for available vacancies when considering reassignment as a Reasonable Accommodation;
3. ensure sufficient funds are provided for Reasonable Accommodations; and
4. determine when an accommodation request would result in an Undue Hardship.

C. The Office of General Counsel shall:

1. advise IAF officials regarding laws, regulations, and policies pertaining to Reasonable Accommodation;
2. consult with IAF management, appropriate Equal Employment Opportunity officers, and Human Resource officers on providing Reasonable Accommodation and making Undue Hardship determinations; and
3. conduct periodic reviews of this Policy to ensure compliance with applicable laws and regulations.

D. Deciding Officials shall:

1. promptly provide Reasonable Accommodations absent extenuating circumstances and expedite time sensitive requests;
2. engage in an Interactive Process and respond promptly (usually within 3 business days from the date the Deciding Official was made aware of the Request) to theaccommodation Request received from the Requestor or referred by other official;
3. keep Requestors, human resource, and EEO officers apprised of progress in responding to Requests for accommodation, as appropriate;
4. seek guidance from and consult with the General Counsel and the EEO Director on Reasonable Accommodation issues and Undue Hardship determinations;
5. provide written decisions on Requests for accommodations. When a Request is denied, the decision must include a written notice for the denial;
6. reassign Employees who are Qualified Individuals with a Disability(s), as a Reasonable Accommodation of last resort and if appropriate, to a vacant (funded) position for which they are qualified;
7. immediately initiate a corrective action where deficiencies in processing of a reasonable Request occurred; and
8. work with the EEO Director to establish a system to retain information about each Request which should include at a minimum: the specific accommodation requested and/or provided; the job (occupational series, grade level, and agency component) sought by requesting Applicant or held by the Employee; whether the accommodation was needed to apply for a job, perform the Essential Job Functions, or enjoy the benefits and privileges of employment; whether the Request was granted or denied; the identity of the Deciding Official; the basis of the denial; and the number of days taken to process the Request. Such information will be used to determine whether it is complying with the nondiscrimination and affirmative action requirements imposed under Section 501, and to make such records available to the Equal Employment Opportunity Commission (EEOC) upon their Request.

E. IAF Management, including Office Directors, shall:

1. promptly acknowledge receipt of Requests (usually within three (3) business days), in writing, to the Requestor; begin processing immediately and expedite time sensitive Requests;
2. request medical documentation to support the Request, as needed;
3. share medical documentation only with individuals who have a valid need to know for the purpose of processing a Request; this confidentiality requirement applies to all persons involved in the process;
4. work with EEO officers to ensure that subordinate managers, supervisors and other Employees are provided appropriate training on reasonable accommodations;
5. determine if the Requestor is a Qualified Individual with a Disability, as defined in Section IV above;
6. consult with the Requestor regarding the kind of accommodation needed and determine an effective method of accommodation to address the need;
7. address the Agency’s responsibility to provide Reasonable Accommodation to a Qualified Individual with a Disability, when it is observed that a Disability may be limiting an Employee’s ability to perform the Essential Job Functions at a fully successful level, or could otherwise improve an Employee’s job performance, or an Applicant’s ability to participate in the selection process;
8. seek guidance and consult with the EEO Director on Reasonable Accommodation issues, and before determining that an Undue Hardship exists; and
9. ensure that Requests for accommodation are not denied for reasons of cost, and that individuals with Disabilities are not excluded from employment due to the anticipated cost of a Reasonable Accommodation, if the resources available to the IAF would enable it to provide an effective Reasonable Accommodation without Undue Hardship.

F. The EEO Director shall:

1. assist management and employees with training on Reasonable Accommodation related issues at the IAF, as appropriate;
2. identify opportunities to provide training on Reasonable Accommodation; and
3. work with the IAF’s General Counsel to ensure that IAF management, supervisors and human resource officers understand the law and regulations regarding Reasonable Accommodation and advise on:
   i. Reasonable Accommodations;
   ii. the appropriateness of a Request as determined by whether it relates to the work to be performed and/or the work place environment; and
   iii. alternate methods of accommodations that would effectively meet the need.

SECTION 5. PROCESS AND PROCEDURES

A. Requests

Requests for accommodations may be submitted by an Employee or Applicant, or an Authorized Individual, orally or in writing at any time (using the form in Appendix I) when a need for such an accommodation arises. Written Requests are encouraged, however Requests need not include specific verbiage such as “Reasonable Accommodation,” “Rehabilitation Act,” or “Americans with Disabilities Act”.”

1. Employees

Employees with Disabilities may submit their accommodation Requests to their 1st or 2nd level supervisor, a more senior official in their chain of command, or the EEO Director at eeo@iaf.gov.

Employees who have recurring or on-going Requests for accommodation do not have to submit a new Request each time if it involves the same or similar accommodation Request that was previously provided and if the original accommodation was approved with the knowledge that the accommodation would be recurring or on-going.

Employees should give appropriate advance notice each time the recurring accommodation is needed, unless otherwise arranged with the Deciding Official. Where feasible, Employees should notify the Deciding Official at least 7 to 10 business days before the date the accommodation is needed to allow sufficient time to coordinate the accommodation. Examples of recurring or on-going Requests include, but are not limited to, sign language interpreter services, readers, and accommodations for participation in training programs (e.g., providing printed handouts in large font or ensuring access to assistive technologies at training sites).

2. Applicants

An Applicant should inform the vacancy announcement point of contact (POC) as soon as they realize the need for an accommodation for some aspect of the hiring process (absent extenuating circumstances). An Authorized Individual can make the Request if the Applicant is unable to do so. An Applicant may request an accommodation orally or in writing. Upon receipt of an accommodation Request from an Applicant, the POC should send the Request to the Deciding Official, the EEO Director, or other designated official no later than 3 business days after receiving the Request.

Requests for accommodation should include the Employee or Applicant name and daytime telephone number; a description of the disability; appropriate medical information where the disability or need for accommodation is not obvious; description of the accommodation requested, if known, and an explanation of how it would enable the Employee to perform the Essential Job Functions, or how it would assist an Applicant in the selection process; when applicable, the date of the request and signature of the Requestor, where applicable.

B. Medical Information

The IAF may request medical information that is sufficient to explain: (1) the nature of the individual’s Disability; (2) the need for Reasonable Accommodation; and (3) how the requested accommodation, will assist the individual in applying for a job, perform the Essential Job Functions, and/or enjoy the benefits and privileges of the workplace. The IAF will keep medical information confidential, in accordance with applicable laws and regulations, as well as the limited circumstances under which IAF may disclose such information.

If the Employee or Applicant does not provide sufficient documentation from their own health care provider or other appropriate professional to substantiate the existence of a Disability and the need for a Reasonable Accommodation, the Deciding Official may request additional information or deny the Request. The IAF has the right to have medical information reviewed by a medical expert chosen by the Agency at the Agency’s expense.

C. Personal Assistance Services

PAS requests will be processed in a similar manner to Requests for accommodations. Services provided are personal in nature and require a high degree of confidence/trust on the part of the employee in the PAS provider’s ability to perform their assigned tasks effectively and safely.

Services can include assisting with all daily living activities, including, but not limited to:

1. Toileting and bathroom hygiene, including transfers in and out of wheelchair; dressing and undressing; washing face/brushing teeth/washing body; and brushing hair;
2. Meal preparation, purchase, and consumption, including feeding and set up of plates and food; accompaniment to restaurants and cafeterias; washing dirty plates, dishes and drink containers; assistance handling medication under my direct supervision;
3. Assistance with clothing, including putting on and removing outer clothing; changing inner clothing, if necessary; changing into an out of formal professional wear;
4. Assistance with various office-related tasks, including arranging papers and office furniture; cleaning and organizing the office; assistance copying, faxing and handling documents; assistance setting up and moving electronic equipment such as laptops and mobile devices; assistance retrieving things from bags and putting items into bags;
5. Assistance with all manual logistics related to travel, if necessary. This includes all items listed above, as well as additional assistance changing wheelchairs and accessing various forms of transportation; and
6. Assistance with other manual tasks that cannot be performed due to limited use of my arms/hands and legs.

PAS must be provided by a PAS provider with extensive experience working with people with disabilities and providing direct and indirect assistance with activities of daily living. A PAS provider may be required to provide PAS to more than one individual and may be required to perform tasks unrelated to the PAS, if doing so does not result in a failure to provide PAS in a timely manner. PAS may also be provided during off-work hours or work-related travel if the person with a targeted disability needs assistance. Employees with Targeted Disabilities may request PAS by contacting their supervisor, a more senior official in their chain of command, or the EEO Director.

D. Interactive Process

The primary goal of the Interactive Process is to respond to Requests for accommodations and to remove obstacles in the workplace that interfere with Applicants’ and Employees’ opportunity for equal employment in as short a time frame as reasonably possible. Toward this end, managers, supervisors, and Employees at all levels involved in the process must make good faith efforts to participate in the accommodation process and help to ensure expeditious consideration of requests and delivery of effective Reasonable Accommodations.

A supervisor should be able to recognize when a Request for an accommodation is being made.

EXAMPLE– An Applicant who is vision-impaired asks for assistance with the Agency’s application materials. This is a Request for accommodation and triggers the Agency’s obligation to engage in its Interactive Process.

EXAMPLE– An Employee tells his supervisor, “I need six weeks off to get treatment for a back problem.” This is a Request for accommodation and triggers the Agency’s obligation to engage in its Interactive Process.

EXAMPLE– An Employee with a severe learning disability has great difficulty reading. The Employee requests that the Agency install speech output software and provide a headset. This is a Request for accommodation and triggers the Agency’s obligation to engage in its Interactive Process.

EXAMPLE– An Employee with major depression is often late for work because of medication side-effects that make him extremely groggy in the morning. His scheduled hours are 9:00 a.m. to 5:30 p.m., but he arrives at 9:00, 9:30, 10:00, or even 10:30 on any given day. A Reasonable Accommodation may be to modify his schedule so that he is not required to report for work until 10:00 a.m, and although the accommodation is one that can easily be granted by the supervisor, it is still considered a Request for an accommodation and should be documented as such.

The following links are provided to assist in identifying possible accommodations:

1. Equal Employment Opportunity Commission, Policy Guidance on Executive Order 13164: Establishing Procedures to Facilitate the Provision of Reasonable Accommodation (Oct. 20, 2000), https://www.eeoc.gov/policy/docs/accommodation_procedures.html.
2. Equal Employment Opportunity Commission Technical Assistance Document: Employer-Provided Leave and the Americans with Disabilities Act (May 9, 2016), https://www.eeoc.gov/eeoc/publications/ada-leave.cfm.
3. Enforcement Guidance: Disability-Related Inquiries and Medical Examinations of Employees Under the Americans With Disabilities Act (July 27, 2000), https://www.eeoc.gov/policy/docs/guidance-inquiries.html.
4. EEOC Enforcement Guidance on Reasonable Accommodation and Undue Hardship under the Americans with Disabilities Act (October 17, 2002), https://www.eeoc.gov/policy/docs/accommodation.html#reassignment.
5. EEOC Questions and Answers: Federal Agencies’ Obligation to Provide Personal Assistance Services (PAS) under Section 501 of the Rehabilitation Act (Sept. 18, 2017), https://www.eeoc.gov/federal/directives/personal-assistance-services.cfm.

E. Time Limits

A Request, whether oral or written and/or explicit or implicit, triggers the time limits for processing and providing or denying an accommodation. Once a Request is received, absent extenuating circumstances, the maximum time limits for finalizing Requests for accommodation are:

For Applicant Requests. (i) No more than fifteen (15) business days from the date of receiving the Request for accommodation, if the Request relates to an Applicant’s participation in the hiring process and medical information is not required. (ii) No more than twenty (20) business days from the date of receiving the Request, if the Request relates to an Applicant’s participation in the hiring process and medical information is required.

For Employee Requests. (i) No more than fifteen (15) business days from the date of receiving the Request for accommodation, when the Request is very simple, does not require medical documentation, and does not involve extenuating circumstances. (ii) No more than twenty (20) business days from the date of receiving the Request for accommodation, when the Request requires medical documentation. (iii) No more than thirty (30) business days from the date of receiving a Request for accommodation that requires considering reassignment to a vacant position as a possible accommodation. A complete Employee Request includes medical documentation, if applicable.

Where an accommodation can be provided in less than the maximum time frame, failure to provide an accommodation in a prompt manner may result in a violation of the Rehabilitation Act.

F. Expedited Processing

Expedited processing for Requests may be required if the accommodation is needed, for example: (1) to enable an Qualified Individual with a Disability to apply for a job; or, (2) the accommodation is needed for a specific Agency activity that is scheduled to occur shortly.

G. Approval

If the Reasonable Accommodation will be approved, the Deciding Officials should notify the Employee or Applicant in writing that their accommodation Request is approved and provide an estimated time frame of when the accommodation will be available, if appropriate.

H. Delay

When all the facts and circumstances known to the Agency make it reasonably likely that the individual will be entitled to an accommodation, but the accommodation cannot be provided immediately, the IAF must provide the individual with an interim accommodation that allows the individual to perform some or all of the Essential Job Functions, absent Undue Hardship.

Where there is a delay in either processing a Request for accommodation or providing an accommodation, the IAF will notify the individual of the reason for delay, including any extenuating circumstances that justify the delay.

I. Denial of a Request

The IAF will provide a Requestor who is denied a Reasonable Accommodation with a written notice at the time of denial. The written notice will explain the reasons for the denial and notify the Requestor of any available internal appeal or informal dispute resolution processes.

Denials of Requests for accommodation must include instructions on how to file an EEO complaint and explain that the individual must initiate contact with an EEO Counselor within 45 calendar days of the denial, regardless of whether the applicant or employee participates in an informal dispute resolution process. The written denial notice will be provided in an accessible format when requested. All denials must have a concurring official (second-line supervisor or other specifically designated management official) review and concur with decision. Prior to denying a Request, the Deciding Official must consult with the EEO Officer.

Before a Deciding Official denies a Request for accommodation based on Undue Hardship, the Deciding Official must consider all resources available to the Agency as a whole, excluding those designated by statute for a specific purpose that does not include Reasonable Accommodation.

SECTION 6. REDRESS

Procedures are available to individuals who are dissatisfied with the Agency’s response to a Request for an accommodation, and wish to seek redress.

A. Reconsideration

If a Request for an accommodation is denied, the Employee may request reconsideration (Reconsideration Request) of the decision. A Reconsideration Request does not toll the deadlines for filing an EEO complaint, a Merit Systems Protection Board (MSPB) appeal, an administrative grievance, or any other administrative process. If the Employee seeks Reconsideration Request, they must ask the Deciding Official to reconsider the decision within 10 business days of notification about the decision.

The Employee should present additional information, if any, to support their Reconsideration Request at that time. The Deciding Official will respond to the Reconsideration Request within 10 business days. The Deciding Official should notify the Employee or Applicant, in writing, of their decision on the Reconsideration Request.

If the Deciding Official does not reverse the decision, the Employee may ask the second-line supervisor, or another official, to review the denial and reconsider the decision. The Employee must seek this second level reconsideration within 5 business days of notification about the decision in the first level reconsideration. The second-line supervisor or other designated official will respond to the Reconsideration Request within 5 business days. The second-line supervisor or other designated official should notify the Employee or Applicant, in writing, of their decision on the second level Reconsideration Request.

B. Alternative Dispute Resolution Process

Alternatively, the Employee may request a mediator to assist the Employee and Deciding Official with reaching an agreement about a Request for accommodation. Requests to participate in the alternative dispute resolution (ADR) process (ADR Request) must be made within 10 business days of notification of the denial. The ADR Request should be submitted to the Deciding Official. Upon receipt of an ADR Request to participate in the ADR process, the Deciding Official should contact the General Counsel and the EEO Director within 3 business days. An Employee’s participation in the ADR process does not satisfy the requirements for timely filing an EEO claim, an appeal before the MSPB, an administrative grievance, or any other administrative process.

C. The EEO Complaint Process

An Employee or Applicant who believes they were unlawfully denied an accommodation, have been discriminated against based on a Disability, or experienced an undue delay in processing and granting an accommodation may file a complaint of discrimination and/or failure to accommodate within 45 calendar-days after receiving the written response to their Request for accommodation. An Employee or Applicant may also file a complaint alleging retaliation as a result of requesting an accommodation or otherwise participating in the process to obtain one. Employees and Applicants may contact the IAF EEO Director at eeo@iaf.gov or via the Telecommunications Relay Service (TRS) using 711.

D. The IAF Administrative Grievance Process

Employees and applicants for employment have the right to contact the IAF EEO Director promptly after receiving the decision, to find out the applicable procedures and time limits for filing a grievance under a negotiated grievance procedure or the administrative grievance system, as appropriate by contacting the EEO Director at eeo@iaf.gov or (202) 360-4530.

VII. POLICY ASSISTANCE

Questions concerning this Policy should be addressed to the IAF’s Office of General Counsel or the EEO Director.

The IAF shares openly the allocation of its resources and the results that its investments achieve. This Website describes the rationale for each new grant funding action, features a portfolio of active projects, explains IAF’s methodology for measuring results and shares the agency’s annual report on grant results and ex-post evaluations of projects five years after funding has expired. In 2012, the IAF demonstrated its commitment to transparency and prudent use of its allocated funds by being evaluated by the Foundation Center and receiving the “glasspockets” designation for transparency, accountability and accessibility of information.

April 26, 2021

Shalanda Young Acting Director
Office of Management and Budget
725 17th Street, NW
Washington, DC 20503

Dear Acting Director Young,

On January 26, 2021, President Biden issued a memorandum asking all government agencies to (i) consult with Tribal Leaders about the potential impacts of Federal policies and programming on Tribal Nations and Governments in the United States; and (ii) to submit to the Office of Management and Budget plans of action explaining how each agency intends to maintain “regular, meaningful, and robust consultation with Tribal officials in the development of Federal policies.”

In accordance with the President’s memorandum and Executive Order 13175, Consultation and Coordination with Tribal Governments (November 6, 2020), the Inter-American Foundation (IAF) submits the attached document.

The IAF drafted this plan after consulting with Tribal Leaders on how best to engage in meaningful dialogue. The attached document reflects the valuable feedback, comments, and best practices raised during that consultation, and lists several actions and principles that the IAF commits to adopting.

Separately, in keeping with the requirements listed in the President’s memorandum, the IAF designates Daniel Friedman, Director of IAF’s Office of External Government Affairs, and Edward Gracia, Congressional Affairs Specialist, as agency leads in charge of implementing the attached plan and preparing the agency’s progress reports.

The IAF is committed to respecting the rights, cultures, and traditions of all Tribal Nations and Indigenous peoples, and to upholding the United States’ unique legal responsibilities and relations with Tribal Governments.

Thank you for your attention.

Sincerely,

Paloma Adams-Allen President & CEO

Plan of Actions to Maintain Regular, Meaningful, and Robust Consultation with Tribal Nations

SUMMARY: In accordance with the requirements listed in President Biden’s January 26, 2021 memorandum on Tribal Consultation and Strengthening Nation-to-Nation Relationships, the Inter-American Foundation (IAF) submits this Plan of Actions to the Office of Management and Budget (“Plan”). The IAF drafted this Plan after the agency met and consulted with a number of Tribal officials on how to engage in meaningful dialogue. The actions and principles listed in this Plan reflect the concerns, suggestions, and comments voiced by Tribal Leaders who participated in a consultation organized by the IAF and eight other Federal agencies on Wednesday, April 14, 2021.

The IAF is committed to adopting the principles and actions listed in this Plan, and will periodically report to the White House on the agency’s progress. Daniel Friedman, IAF’s Office Director for External Government Affairs, and Edward Gracia, Congressional Affairs Specialist, are responsible for implementing the Plan and reporting on its progress with support from staff across the agency.

Plan of Actions to Maintain Regular, Meaningful, and Robust Consultation with Tribal Nations

The IAF commits to adopting several principles and steps to advance President Biden’s January 26 memorandum and Executive Order 13175, Consultation and Coordination with Tribal Governments (November 6, 2000). These include the principles derived from Executive Order 13175, which provide fundamental guidance on engagement with Tribal Nations:

• Respect tribal sovereignty and engage with Tribal Nations as separate, unique entities;
• Honor the government-to-government relationship;
• Acknowledge trust responsibility;
• Accept tribal self-determination and self-governance; and
• Regard consultation as an ongoing process.

In adopting these principles, the IAF recognizes the unique historical and legal relations between the United States and U.S. Tribal Nations and Indigenous Peoples. The agency commits to upholding and respecting these principles.

Separately, the IAF also commits to adopting several best practices recommended by Tribal Leaders to facilitate meaningful communication and engagement with Tribal Nations and officials:

Once the IAF starts contemplating a policy or action that may impact the interests of Tribal Nations, the agency will initiate timely contact with Tribal Nations to begin a consultation session process. The IAF recognizes that Tribal Nations should have the opportunity to provide input on whether an action requires consultation. The IAF also acknowledges that Tribal Nations are affected by both on-reservation actions and funding and personnel decisions related to Federal Indian programs and off-reservation plans.

The IAF also commits to respecting the time, capacity, and resource constraints of Tribal Nations in the United States. The IAF commits to notifying Tribal Nations about consultation sessions with enough time for Tribal officials to contemplate and review documents and develop related comments and recommendations. Such notices will be clear and include all necessary information on the consultation topic and any proposed plan.

To facilitate participation and ensure inclusivity, the IAF commits to sharing consultation documents and plans virtually with Tribal officials who have access to a digital communications device, and in physical form via express mail to those who do not. Additionally, the IAF commits to offering virtual and analog options for consultation sessions so that participants are not inhibited by a lack of options for participating.

The IAF commits to allotting enough time to each consultation session so that participants can meaningfully engage in dialogue. For sessions that go beyond the allotted time, the agency commits to scheduling additional sessions. The IAF also commits to sharing the results of each consultation session with participants and to providing opportunities for Tribal officials to share comments and feedback with the agency.

Download IAF Plan of Action on Tribal Consultation (PDF)

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Overview

OSC’s Disclosure Unit (DU) serves as a safe conduit for the receipt and evaluation of whistleblower disclosures from federal employees, former employees, and applicants for federal employment. 5 U.S.C. § 1213.

You may file a disclosure claim as follows:

• online: E-File
• via fax: 202-254-3711
• by mail: Office of Special Counsel, 1730 M Street, N.W., Suite 218, Washington, DC 20036.

You may use either OSC Form 12 (Whistleblower Disclosure), or you may submit your disclosure in writing to us without using the form. A disclosure does not focus on resolving personnel decisions involving or against the filer or other individuals. As a result, an employee who believes he or she has suffered reprisal for whistleblowing may elect to file both OSC Form 11 (Prohibited Personnel Practices), for reprisal or prohibited personnel practice allegation, and OSC Form 12 (Whistleblower Disclosure), for the underlying misconduct.

The Disclosure Unit evaluates disclosures, which are separate and distinct from complaints of reprisal or retaliation for whistleblowing activities. A reprisal or retaliation claim is reviewed by OSC’s Complaints Examining Unit as a prohibited personnel practice. 5 U.S.C. § 2302(8)(b). Claims of prohibited personnel practices, including reprisal for whistleblowing, may be pursued by filing a complaint with OSC’s Complaints Examining Unit (OSC Form 11, Complaint of Prohibited Personnel Practice). You can also alert OSC to possible wrongdoing in a federal agency through a whistleblower disclosure (OSC Form 12, Whistleblower Disclosure).

DU attorneys review five types of disclosures specified in the statute: violations of a law, rule or regulation; gross mismanagement; a gross waste of funds; an abuse of authority; and a substantial and specific danger to public health or safety. 5 U.S.C. § 1213(b). The disclosures are evaluated to determine whether or not there is sufficient information to conclude with a substantial likelihood that one of these conditions has been disclosed.

DU processes disclosures differently from other government whistleblower channels in at least three ways: (1) federal law guarantees confidentiality to the whistleblower; (2) the Special Counsel may order an agency head to investigate and report on the disclosure; and (3) after any such investigation, the Special Counsel must send the agency’s report, with the whistleblower’s comments, to the President and Congressional oversight committees.

As stated above, a whistleblower’s identity will not be revealed without his or her consent. However, in the unusual case where the Special Counsel determines there is an imminent danger to public health or safety or imminent violation of any criminal law, the Special Counsel has the authority to reveal the whistleblower’s identity. 5 U.S.C. § 1213(h).