CAN/ASC-1.1:2024 (REV-2025)-Employment
14. Development and maintenance of an accessibility support system
Information
Table of contents
14.1 Overview
This Clause specifies policies, processes, and programs for the development and maintenance of an Accessibility Support System, with the term accessibility support used synonymously with accommodation. An Accessibility Support System, which is part of the overarching Inclusive and Accessible Employment System, complying with Clause 10.4, aims to address the accessibility support (accommodation) needs of workers with disabilities, whether they are in the process of being recruited, hired, and onboarded, or have been at the organization for some time.
This Clause addresses issues of accessibility support (accommodation) requests, whether they arise with or without disclosure. It emphasizes the proactive removal of barriers and the provision of facilitators (defined as someone or something that assists with the end goal). Emphasis is on addressing requests for accessibility supports (accommodations) on a timely basis to ensure barriers to participation do not hinder engagement in work roles and a worker’s sense of inclusion and belonging.
14.2 Principles
To actively implement accessibility supports (accommodations), organizations shall adhere to the following principles:
- prevent or address workplace barriers to minimize adverse impact and support participation in work activities with responsive accessibility supports (accommodation);
take a worker-centred approach;
Note: A worker-centred approach prioritizes the person with a disability, including their psychological and social needs, and respects their integrity when they describe their needs.
- consider the environmental and social factors that create the disabling condition/situation (known as the social model of disability) when addressing a worker’s accessibility support (accommodation) needs to promote work engagement whenever possible, and ensure inclusion and belonging;
- actively discuss with the worker any external expert advice received and address the worker’s needs with strong consideration of their preferences, unless there is evidence of possible harm to the worker or others;
- in the case of health absence, apply a targeted, safe, timely, and documented return-to-work plan with a hierarchy that begins with:
- return to the worker’s own position;
- return to the worker’s own position with accessibility supports (accommodations);
- an alternative position; and
- if required, an alternative position with accessibility supports (accommodations);
- direct efforts to provide a worker with optimal level of accessibility supports (accommodations) at the workplace and in the work ecosystem;
- engage input from all workplace parties using a collaborative approach to achieving optimal effectiveness of accessibility supports (accommodations) and to promote the worker’s sense of inclusion and belonging; and
- ensure no contravention of a collective bargaining agreement by the Accessibility Support System.
14.3 Components of comprehensive Accessibility Support System
An Accessibility Support System is a framework of policies, processes, programs, procedures, practices, and plans designed to remove barriers experienced by workers with disabilities in the workplace. The Accessibility Support System is designed to proactively remove barriers. It ensures that workers with disabilities can fully utilize their skills, expertise, and experience in the workplace. This approach promotes a sense of inclusion and belonging for all employees. The Accessibility Support System also addresses stay-at-work and return-to-work processes following a health absence.
14.3.1 Policies
14.3.1.1 Accessibility Support System policy development
Accessibility Support System policies provide strategic direction to the organization and shall be documented and available to all workers in accessible formats, complying with Clauses 10.5.1 and 10.6. The organization shall develop policies that:
- ensure that the development of and modifications to the Accessibility Support System do not create new barriers;
offer individualized accessibility supports (accommodations) plans (e.g., through an accessibility passport) that support portability of a workers’ needs across the organization;
Note: An accessibility passport is a tool for workers to document the barriers they might encounter at work and the adaptive tools and support measures they need to succeed. The passport follows a worker from position to position. (This explanatory note was adapted from the Government of Canada Workplace Accessibility Passport.)
- ensure there are no disincentives arising from accessibility supports (accommodations) expenses being included as a part of departmental budgets;
- ensure accessibility supports (accommodations) are provided on a timely basis;
- ensure clear and honest explanations are provided when the requests for accessibility supports (accommodations) cannot be fully implemented;
take a “yes by default” approach to providing accessibility supports (accommodations) and have zero tolerance for the “policing” of them;
Note: a "yes by default" approach refers to the mindset and shift in culture within an organization. In such an approach the organization evaluates, responds, or both evaluates and responds to requests that embrace accessibility supports (accommodations) as a way to equip all workers to contribute to their full potential;
minimize the need for the disclosure of personal information (including medical or other disability-related information);
Note: For example, an organization would identify resources that are available to all workers without documentation or permission. Alternatively, organizations would identify thresholds of resources below which do not require medical documentation. Thresholds can depend on the size of the organization and the nature of the needs.
- ensure that documentation is used to fairly evaluate, rather than deny or delay, the requested accessibility supports (accommodations);
- integrate feedback mechanisms, including options for anonymous feedback, to inform the Accessibility Support System and support the identification and prevention of emerging barriers;
- include case examples where possible; and
- respect the dignity, confidentiality, and privacy of the worker.
In developing policies according to the above requirements, organizations shall comply with Clause 10.5.3 and Clause 14.3.2.
14.3.1.2 Policy requirements
Management of the organization shall establish and maintain the organization’s Accessibility Support System policies in consultation with workers, including those with varying disabilities, and other relevant internal workplace parties, including worker representatives. The policies shall:
- be appropriate to the nature and scale of the organization;
- be structurally supported and clearly documented;
- include a framework for setting and reviewing program objectives and targets;
- be documented, implemented, maintained, and periodically reviewed (e.g., after 6 months, a year, and then annually thereafter) based on an established and appropriate review frequency to ensure continual improvement;
- be communicated to all workers;
- be available to external interested parties, as appropriate; and
- be integrated with other programs and systems within the organization.
The Clauses that follow are about specific areas where policies need to be developed.
14.3.2 Disclosure and accessibility support (accommodations) provision
A successful Accessibility Support System ensures that workers feel safe to self-identify as a person with a disability. It fosters confidence that this disclosure will result in increased support, not reprisals, from others within the organization. It also fosters an environment where individuals with disabilities receive the necessary support to excel in their roles, independent of formal disclosure or request processes. The key to this is the development and implementation of a comprehensive, individualized accessibility supports (accommodations) policy and accompanying process.
An individualized accessibility supports (accommodations) policy is a policy that provides guidance on accessibility supports (accommodations) for job candidates and workers with lived experience of disabilities where the addressing of barriers encountered is beyond the level of accessibility of the organization.
Note 1: These policies can be categorized into policies applicable to job candidates (internal to and external to the organization) and policies applicable to workers.
Note 2: Policies applicable to job candidates address accessibility and individualized accessibility support (accommodation) in the context of the job application process, the interview, hiring, and onboarding.
Note 3: Policies applicable to workers address accessibility and individualized accessibility support (accommodation) in the context of the work environment, including the performance of work tasks, meetings and events, work-related travel, social, and informal settings.
This policy and accompanying process shall:
- outline the roles and responsibilities of all workers involved in the accessibility supports (accommodations) process;
- apply to all workers, regardless of lived experience with disability or position within the organization;
- provide for continuity of support while workers are employed by the organization (e.g., through an accessibility passport);
- acknowledge a worker’s request for accessibility supports (accommodations) in a timely manner and ensure they are in place before any evaluation of the worker;
- make accessibility supports (accommodations) available without medical documentation or disclosure, where possible, and in exceptional cases where it is not possible:
- require the employer to cover the cost of obtaining the medical, or other disability-related, documentation it requests, including any lost time, and
- minimize the amount of personal information requested, respecting the worker’s privacy and confidentiality regarding their medical condition;
- focus on the removal of barriers, to inform the provision of accessibility supports (accommodations);
- require the worker’s input and informed consent regarding how the implementation of accessibility supports (accommodations) will be communicated to others on a need-to-know basis;
- where the workplace is unionized, require the employer to inform the worker of their right to union representation and, in consultation with the worker, involve worker representatives in accessibility supports (accommodations), where needed;
- involve a disability organization representative or a competent alternative to assist workers with disabilities in accessibility supports (accommodations) processes in a non-unionized workplace, where needed;
- train managers and workers responsible for supporting accessibility supports (accommodations) requests on the Accessibility Support System and the duty to accommodate;
- keep the accessibility support (accommodation) provision process agile and adaptable to changes in a worker’s responsibilities to minimize the risk of losing accessibility supports (accommodations) through career development and advancement within the organization;
- promote equity across the organization by providing workers in all positions within the organization with access to reasonable accessibility supports (accommodations);
- make assistive technologies and adaptive workplace supports broadly available to maximize access;
- provide protection for workers and their allies making disclosures or requesting accessibility supports (accommodations), including a non-reprisal approach (avoiding any loss or negative impact of financial compensation) to prevent a negative impact on their career opportunities, growth, and advancement;
- disseminate information about the Accessibility Support System to all workers and have the information available to all workers without restrictions to accessing the information;
- include development and implementation of a feedback mechanism for workers to evaluate their experience accessing accessibility supports (accommodations);
- provide workers with frequent and meaningful opportunities to request accessibility supports (accommodations) prior to making a decision that would adversely affect them;
- require the organization to inquire with the worker about the need for accessibility supports (accommodations) when the organization is aware, or reasonably ought to be aware of a relationship between a disability and a worker’s job performance;
- require the organization to provide documented explanations for accessibility supports (accommodation) denials; and
- require documentation of accessibility supports (accommodations) provided to ensure continuity over the course of employment with the organization.
14.3.3 Benefits and other supports
The organization shall have a formal policy on the provision of benefits programs and services for workers. The policy shall:
- focus on supporting worker engagement, sense of inclusion and belonging, health and well-being;
- require that information on benefits and services and how to access them is readily available to workers in accessible formats;
- minimize the requirement for medical documentation and paperwork to access benefits; and
- include a worker-centred process for periodic identification of needs, gaps in needs, and opportunities to address them through additional programs and services.
14.3.3.1 Programs
The organization should consider the following in the development of programs:
- paid sick leave;
- Employee Assistance Plan (EAP)/Employee and Family Assistance Plan (EFAP);
- dental plan;
- extended health care;
- pharmaceutical plan;
- vacation time beyond the minimum requirement of the law;
- short-term disability (STD) and long-term disability (LTD);
- paid casual absences;
- personal/family leave;
- reimbursement of costs for securing supporting documentation required for benefits receipt;
- supplemental assistance for workers when the need for benefits coverage (e.g., health, dental) extends over or beyond what is currently covered;
- a centralized accessibility supports (accommodations) fund to address accessibility supports (accommodations) needs; and
removal of financial disincentives within operations to hire, retain, and promote workers with disabilities within a team or department, and support the duty to accommodate.
Note: An example of a financial disincentive would be a manager's concern that accessibility support (accommodations) costs will reduce their operating budget.
14.3.3.2 Implementation of the Accessibility Support System
The organization should:
- provide timely information sessions for workers on the benefits and services available from the organization and in the community, and how to access them; and
- review accessibility requirements of third-party programs and service providers to confirm that the needs of workers are met and seek out alternative providers as necessary.