You're listening to the Disability Law Lowdown podcast, Show number 57.

Jacquie Brennan: Hi, this is Jacquie Brennan and today's podcast show is about the new regulations that were recently released by the Equal Employment Opportunity Commission for the ADA Amendment's Act. The ADA Amendments Act was passed on September 25th 2008 and became effective January 1st 2009. And that law made a lot of changes to the definition of disability. And in the law, it actually directed the Equal Employment Opportunity Commission to amend its ADA regulations to reflect the changes that were made by the ADA Amendments Act. And the final regulations were published in the Federal Register making them official on March 25th 2011. The EEOC is making changes to both the Title 1 ADA regulations and to the interpretative guidance which is known as Appendix that was published with the original ADA regulations. And the regulations implement the law and the Appendix provides further explanation on how the regulations should be interpreted. The EEOC issued at the same time it issued the new regulations and the new Appendix, it issued questions and answers to provide information on the changes that were made to the regulations as result of the ADA Amendments Act and identify certain regulations that remain the same.

So we're going to go over some of those questions and answers to help you understand better the new regulations. So one of the questions is, do all of the changes in the ADA Amendments Act apply to other titles of the ADA and provisions of the Rehabilitation Act prohibiting disability discrimination by Federal Agencies, Federal Contractors, and Recipients of Federal Financial Assistance? The answer is yes. The ADAAA, the ADA Amendments Act, specifically states that all of its changes also apply to Section 501 of the Rehabilitation Act which covers Federal Employment, Section 503 of the Rehab Act which covers Federal Contractors, and Section 504 of the Rehab Act which covers Recipients of Federal Financial Assistance and services and programs of Federal Agencies.

How does the ADA Amendments Act define disability? I know we've covered this before in other Podcasts, but since we're talking about the new regs this is a pretty important detail. The ADA Amendments Act in the final regs define disability using a three-pronged approach, which is actually the same definition that we had before, but the interpretation is different now. So let me just go over the definition. "A physical or mental impairment that substantially limits one or more major life activities" also referred to in the regulations, if you read them a lot, as actual disability. So if you meet that first prong of the definition, then you are said to have an actual disability. And the second prong is a record of a physical or mental impairment that substantially limits a major life activity also known as record of. And then the third prong which is that, the covered entity the employer takes an action prohibited by the ADA because of an actual or perceived impairment that is not both transitory and minor. And that's the regarded as a prong of the definition.

Must individuals use a particular prong of the definition of disability when challenging an employer's actions? Not necessarily. Claims for denial of reasonable accommodation must be brought under one or both of the first two prongs of the definition of disability-. So it has to be either an actual disability or a record of disability if what your claim is for a denial of reasonable accommodation because the ADA Amendments Act specifically states that those who are covered only under the regarded as definition are not entitled to reasonable accommodation. And the reason for that is pretty clear because if you're only regarded as having a disability, then you don't actually have a disability or a record of a disability that might need an accommodation. You don't have a disability. You're just regarded as having one.

Other types of allegations though like failure to hire or promote or termination at your job or harassment can be brought under any part of the definition. And an individual will find it easier to claim coverage under the regarded as part of the definition norm. But it is important to remember that these are not like three parts of the definition. Well, I mean, it is three parts. But you don't have to meet all of them. So, it's not like three requirements. It's just each one separately. So you can meet one of the prongs of the definition and be covered. In fact, in most cases, that will be the case.

Another question is, how do the regulations define the term physical or mental impairment? The regulations the physical or mental impairment as any physiological disorder or condition, cosmetic disfigurement or anatomical loss affecting one or more body systems; such as neurological, musculoskeletal, special sense organs, respiratory including speech organs, cardiovascular, reproductive, digestive, genitourinary, immune, circulatory, hemic, lymphatic, skin, and endocrine. They also cover any mental or psychological disorder such as intellectual disability which was formerly called mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities. The definition of impairment in the new regulations is almost identical to the definition in the EEOC's original ADA regulations except that the immune and circulatory systems have been added to the list of body systems that may be affected by an impairment because these systems are specifically mentioned in the ADA's examples of major bodily functions.

What are major life activities? The final regulations provide a nonexhaustive meaning it doesn't have everything in the list, but it has a list of examples of major life activities: Caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, sitting, reaching, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, interacting with others, and working. Most of these examples are taken from the ADA Amendments Act which in turn adopted them from the original ADA regulations and EEOC guidances or from the ADA in Rehabilitation Act case law. The final regulations also state that major life activities include the operation of major bodily functions including functions of the immune system, special sense organs and skin, normal cell growth, digestive, genitourinary, bowel, bladder, neurological, brain, respiratory, circulatory, cardiovascular, endocrine, hemic, lymphatic, musculoskeletal and reproductive functions. Although these are not specifically listed, the final regulations state that major body functions include the operation of an individual organ within a body system like the operation of a kidney, liver, or pancreas. As a result of the ADA Amendment Acts, recognition of major bodily functions as major life activities, it will be easier to find that individuals with certain types of impairments have a disability.

When does an impairment substantially limit a major life activity? To have an actual disability or to have a record of a disability, an individual must be or have been substantially limited in performing a major life activity as compared to most people in the general population. Consistent with the ADA Amendments Act, the final regulations adopt rules of construction to use when determining if an individual is substantially limited in performing a major life activity.

These rules of construction include the following. An impairment does not need to prevent or severely or significantly limit a major life activity to be considered substantially limiting. Nevertheless, not every impairment will constitute a disability. The term "substantially limits" should be construed broadly in favor of expansive coverage to the maximum extent permitted by the terms of the ADA. The determination of whether an impairment substantially limits a major life activity requires an individualized assessment. In keeping with Congress' direction that the primary focus of the ADA is on whether discrimination occurred, the determination of disability should not require extensive analysis. Although determination of whether an impairment substantially limits a major life activity as compared to most people will not usually require scientific, medical or statistical evidence; such evidence may be used if appropriate. An individual need only be substantially limited or have a record of a substantial limitation in one major life activity to be covered under the first or second prong of the definition of disability.

Can impairments that are episodic or in remission be considered disabilities? Yes. The ADA Amendments Act in the final regulations specifically state that an impairment that is episodic or in remission meets the definition of disability if it would substantially limit a major life activity when active. This means that chronic impairments with symptoms or effects that are episodic rather than present all the time can be a disability even if the symptoms or effects would only substantially limit a major life activity when the impairment is active. The Appendix provides examples of impairments that might be episodic including epilepsy, hypertension, asthma, diabetes, major depressive disorder, bipolar disorder, and schizophrenia. An impairment like cancer that's in remission that may possibly return in a substantially limiting form will also be a disability under the ADA Amendments Act in the final regulations.

What are mitigating measures? Mitigating measures eliminate or reduce the symptoms or the effect of an impairment. The ADA Amendments Act in the final regulations provide a nonexhaustive, again that means this list doesn't have possible thing but it's a really good list of examples of mitigating measures. They include medication, medical equipment and devices, prosthetic limbs, low vision devices like devices that magnify a visual image, hearing aids, mobility devices, oxygen therapy equipment, use of assistive technology, reasonable accommodations, and learn behavior or adaptive neurological modifications. In addition, the final regulations add psychotherapy, behavioral therapy, and physical therapy to the ADA's list of examples.

May the positive effects of mitigating measures in limiting the impact of an impairment on performance of a major life activity be considered when determining whether someone has a disability? No, and that's a big change from the old ADA except for ordinary eye glasses or contact lenses. The ADA in the final regulations direct that the positive or what they call the ameliorative effects from an individual's use of one or more mitigating measures be ignored in determining if an impairment substantially limits a major life activity. In other words, if a mitigating measure eliminates or reduces the symptoms or the effect of an impairment that fact cannot be used in determining if a person meets the definition of disability. Instead, the definition of disability must focus on whether the individual would be substantially limited in performing a major life activity without the mitigating measure. This may mean focusing on the extent of limitations prior to the use of the mitigating measure or what would happen if the individual ceased using the mitigating measure.

Does the rule concerning mitigating measures apply only to people whose vision is corrected with ordinary glasses or contact lenses? No. Ordinary glasses or contact lenses defined in the ADA Amendments Act in the final regulations as lenses that are intended to fully correct visual acuity or to eliminate refractive error must be considered when determining whether someone has a disability. For example, a person who wears ordinary eye glasses for routine vision impairment is not, for that reason, a person with a disability under the ADA. The regulations do not establish a specific level of visual acuity for determining whether eye glasses or contact lenses should be considered ordinary. This determination should be made on a case by case basis in light of current and objective medical evidence.

May the negative effects of a mitigating measure be taken into account when determining whether a person meets the definition of disability? Yes. The ADA Amendments Act allows considerations of the negative effects of a mitigating measure in determining if a disability exists. For example, the side effects that an individual experiences from using medication for hypertension may be considered in determining whether that individual is substantially limited in a major life activity. However, it will often be unnecessary to consider the non- ameliorative effects or those negative effects of mitigating measures in order to determine whether an individual has a disability. For example, it's unnecessary to consider the burdens associated with receiving dialysis treatment for someone whose kidney function would be substantially limited without this treatment.

Can an employer require that an individual use a mitigating measure? No. An employer can't require an individual to use a mitigating measure. However, failure to use a mitigating measure might affect whether an individual is qualified for a particular job or even poses a direct threat.

Do the regulations give any examples of specific impairments that will be easily concluded to be substantially limiting in a major life activity? Yes. The regulations identified examples of specific impairments that should easily be concluded to be disabilities and examples of major life activities including those major bodily functions that the impairment substantially limit. These impairments include deafness, blindness, intellectual ability formerly called mental retardation, partially or completely missing limbs, mobility impairments requiring the use of a wheelchair, autism, cancer, cerebral palsy, diabetes, epilepsy, HIV infection, multiple sclerosis, muscular dystrophy, major depressive disorder, bipolar disorder, post -traumatic stress disorder, obsessive compulsive disorder and schizophrenia.

When is someone substantially limited in a major life activity of working? In certain situations, an impairment may limit someone's ability to perform some aspect of his or her job, but otherwise is not substantially limiting any other major life activity. In these situations, the individual may be substantially limited in working. However, with all of the changes made by the ADA Amendments Act, in particular the inclusion of major bodily functions as major life activities and revisions to the regarded as prong of the definition of disability, it should generally be unnecessary to determine whether someone is substantially limited in working. The final regulations don't even mention the major life activity of working other than by its inclusion in the list of major life activities, but the Appendix discusses how to determine substantial limitations in a number of major life activities including working. The Appendix discussion of working states that the substantial limitation in this major life activity will be made with reference to the difficulty performing either a class or broad range of jobs in various classes rather than a type of work. The Appendix also notes that a class of work may be determined by reference to the nature of the work like commercial truck driving or assembly line jobs or by reference to the job-related requirements that an individual is limited in meeting such as jobs requiring extensive walking, prolonged standing, and repetitive or heavy lifting. Demonstrating a substantial limitation in performing the unique aspects of a single specific job is not sufficient to establish that a person is substantially limited in a major life activity of working.

Does the ADA still exclude from coverage a person who is illegally using drugs? Yes. The ADA Amendments Act did not make changes to the part of the ADA that excludes from coverage a person who currently engages in the illegal use of drugs when an employer acts on the basis of such use. However, the ADA also still says that a person who no longer engages in the illegal use of drugs may be an individual with a disability if he or she has successfully completed a supervised drug rehabilitation program, or has otherwise has been rehabilitated successfully, or is participating in a supervised rehabilitation program.

Is pregnancy a disability under the ADA Amendments Act? No. Pregnancy is not an impairment and therefore cannot be a disability. Certain impairments resulting from pregnancy like gestational diabetes, for example, may be considered as disability if they substantially limit a major life activity or if they meet one of the other two definitions of disability.

When does an individual have a record of a disability? An individual who does not currently have a substantially limiting impairment but who has had one in the past meets this definition of disability. An individual can also meet the record of definition of disability if she was once misclassified as having a substantially limiting impairment, like someone who was deemed to have a learning disability but did not. All of the changes to the first definition of disability that we already talked about include the expanded list of major life activities, the lower threshold for finding substantial limitation, the clarification that episodic impairments or those in remission may be disabilities, and the requirement to disregard the positive effects of mitigating measures will also apply in evaluating whether an individual meets the record of definition of disability.

What does it mean for an employer to regard an individual as having a disability? Under the ADA Amendments Act in the final regulations, a covered entity that is an employer with 15 or more employees regards an individual as having a disability if it takes an action that's prohibited by the ADA based on an individual's impairment, or an impairment that the employer believes the individual has; unless the impairment is transitory, lasting or expected to last like six months or less and minor. This new formulation of regarded as having a disability is different from the original ADA formulation because that required that the individual who wanted coverage under this part of the definition had to show that an employer believed that the individual's impairment, or perceived impairment substantially limited a major life activity. An employer will regard an individual as having a disability any time it takes a prohibited action against the person because of the actual or perceived impairment regardless of whether the employer's certs are even ultimately establishes a defense for its actions.

Does the ADA Amendments Act change the definition of qualified direct threat, reasonable accommodation, and undue hardship? Or does it change who has the burden of proof in demonstrating any of these requirements? No. Nearly all of the Amendments Act changes affect only the definition of disability. None of those key ADA terms that I just listed, like qualified direct threat, reasonable accommodations, undue hardship; none of those have changed. And the burden of proofs that are applicable along the way have not changed. The only provision in the ADA affecting the reasonable accommodation obligation is that an employer does not have to provide one to an individual who only meets the regarded as part of the definition.

Why do the regulations no longer refer to a qualified individual with a disability? Consistent with the ADA Amendments Act, the final regulations now refer to an individual with a disability and qualified individual as separate terms. They also now prohibit discrimination on the basis of disability rather than against a qualified individual with a disability because of the disability. The changes to the regulations reflect changes made by the Amendments Act itself, which are intended to make the primary focus of the ADA inquiry whether discrimination occurred not whether an individual meets the definition of disability. But of course an individual must still establish that he or she is qualified for the job in question.

Will the EEOC be updating all of the ADA-related publication on its website to be consistent with the final ADA Amendments Act regulation? Yes. When EEOC updates a particular document, they'll note that on their website and they'll explain the changes that were made to the document. To avoid misunderstanding, all of the documents currently contain notices that the ADA Amendments Act exist and that some of the material and document may no longer reflect the law. And it should be noted that because the Amendments Act focused almost exclusively on changing the definition of disability, the contents that are in those documents that are unrelated to that definition like the meaning of qualified, essential functions, reasonable accommodations, and direct threat remain unaffected by the ADA Amendments Act and its final regulations. So individuals can continue to rely on those parts of the document that don't affect the definition of disability.

For more information about the regulations or any of the laws that are covered by the EEOC, please feel free to their website at eeoc.gov or of course call the ADA center's toll free number at 1800-949-4232. Thanks for tuning in.

The Disability Law Lowdown is brought to you by the Disability Business Technical Assistance Centers, which are a network of ADA centers that provide training, technical assistance and materials on the ADA and other disability-related laws. Funding for the centers is provided by a grant from NIDRR, the National Institute on Disability and Rehabilitation Research. Visit our website, DisabilityLawLowdown.com to listen to past shows or read the transcript of this and past shows. You can also subscribe to the Disability Law Lowdown at our web site or on iTunes.



The Southwest and Rocky Mountain ADA Centers are part of a program of Independent Living Research Utilization at TIRR - Memorial Hermann in Houston, Texas, and is funded by the National Institute on Disability and Rehabilitation Research. If you have questions about disability law or would like to request materials or training, please call 1-800-949-4232. This podcast is protected by the Creative Commons Attribution Non-Commercial No-Derivative-Works 2.5 License. For more information and transcripts, visit www.ada-podcast.com.