The Catholic University of America

ADA Guidelines


Recordkeeping: All personnel and employment records must be kept for a period of two years under Title VII and the ADA (29 C.F.R. § 1602.49). The two-year requirement applies to all institutions of higher education. Personnel and employment records include the following:

  • requests for reasonable accommodation;

  • application forms and other records having to do with hiring;

  • promotion records;

  • tenure records;

  • demotion records;

  • transfer records;

  • layoff or termination records;

  • rates of pay or other terms of compensation records;

  • selection for training records; and

  • any other employment records.

The records shall be preserved for a period of two years from the date of the making of the personnel action or record involved whichever occurs later. If litigation occurs, the records shall be maintained until final disposition of the action.

Filing: Every two years, the university must file Form IPEDS-S (Fall staff survey) (being used in place of the Higher Education Staff Information Report EEO-6) and keep a copy for three years. The recordkeeping requirements of the Rehabilitation Act that are applicable to CUA are in accord. The ADA Coordinator is responsible for retention of the above records. See also Affirmative Action Requirements for the Employment of Qualified Individuals with Disabilities (soon to be available on the OGC Web site).

Posting: The ADA requires that employers post a notice describing the provisions of the ADA. It must be made accessible, as needed, to individuals with disabilities. A poster is available from the EEOC summarizing the requirements of the ADA. The notice must be posted in prominent places where notices to employees and applicants are customarily maintained. Notices are posted at 170 Leahy (Office of Personnel Services) and at 103 McMahon (Office of the Provost), as well as other locations.

Source: 29 C.F.R. §§ 1602.48-49; 29 C.F.R. § 1602.14; 28 C.F.R. Part 36 Appendix B; and 29 C.F.R. § 1601.30.

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vetted by MLO 2/19/09