The accommodation record decides your disability retirement

1. Why this gate exists

FERS disability retirement has four eligibility elements. You need 18 months of creditable civilian service, a condition expected to last at least a year, an inability to perform the essential duties of your position of record — and the agency must be unable to reasonably accommodate you or reassign you.

The first three are largely medical and factual. The fourth is procedural, and it is where applications fail. Under 5 CFR 844.103, accommodation in your position must be unreasonable, and you must not have declined a qualifying reassignment. Your agency certifies what it tried on Form SF-3112D.

That form is only as good as the events it describes. If you never asked for an accommodation, there is nothing for the agency to certify except that nothing happened — and OPM is left to decide, on a thin record, whether accommodation might have worked. That inference does not usually go your way.

2. What counts and what does not

The distinction turns on essential functions. A reasonable accommodation lets you perform the essential duties of your position. Light duty typically removes them: it is a temporary arrangement in which you stop doing part of your job. That is why an agency saying "we put you on light duty for six months" does not establish accommodation for disability retirement purposes — if anything, a long light-duty period is evidence that the essential duties could not be performed.

The same distinction cuts the other way. An informal understanding with a sympathetic supervisor, however generous, is not an accommodation of record. It leaves nothing on SF-3112D and nothing in the file.

3. The reassignment search

If accommodation in your own position is not possible, the agency must consider reassignment to a vacant position at the same grade or pay level, within your commuting area, for which you are qualified. This is the last step before disability retirement becomes available, and it has to be documented.

Three things matter about it:

• It must actually be conducted, and the agency certifies the result. Even where both you and your supervisor know no such position exists, the search is still required.
• Declining a qualifying offer disqualifies you. Under 5 CFR 844.103, if you turn down a reassignment that meets the criteria, you are not eligible. If an offer is unsuitable, the response is to document precisely why it fails your restrictions — not to simply refuse it.
• Same grade or pay level, same commuting area. An offer at a lower grade, or outside the commuting area, is generally not a qualifying reassignment.

4. Building the record

Everything above is evidence. Here is how to produce it while you still can.

• Make the request in writing. Email creates a date and a record; a hallway conversation does not. Name the specific duties you cannot perform, not just the diagnosis.
• Give your physician your position description before they write anything. A medical statement that lists a diagnosis without linking it to named job duties is the most common reason applications fail, and the accommodation analysis depends on the same linkage.
• Keep every offer and every response. What the agency proposed, what you tried, how long it lasted, and specifically why it did not work.
• Ask for the reassignment search in writing and ask for the result in writing.
• Note the dates. When limitations began, when you disclosed them, when you requested accommodation, when each attempt started and stopped.
• Keep your own copies of everything. Access to agency systems ends at separation, and a retrospective request for records is slow at exactly the wrong moment.
• Watch for contradictions. Medical records, your position description, your physician's conclusions, your own statement, and the agency's certification should tell one coherent story. A silent contradiction lets OPM adopt the least favorable reading.

5. When the agency says it could accommodate you

Agency opposition does not decide the case — OPM makes the determination, and the agency does not approve or deny your application. But an SF-3112D asserting that accommodation was available, unanswered, is a serious problem.

The answer has to be specific. A proposed accommodation does not defeat eligibility if it fails to let you perform the essential functions of your position or conflicts with your documented medical restrictions. So the response identifies:

• Which essential duty the proposed accommodation still leaves unperformable, by name from the position description.
• Which medical restriction the proposal contradicts, quoted from the treating physician.
• What actually happened if the accommodation was attempted — how long, and what the outcome was.

Distinguish carefully among situations that look similar and are not: an accommodation that was never offered, one offered and refused, one attempted and failed, and one the agency claims was possible but never implemented. Those are four different records and they support different arguments. Use the one your evidence actually supports.

6. The performance rating problem

An awkward tension sits at the center of these applications. You are asserting that you cannot perform the essential duties of your position. Your last three performance ratings may say you performed them successfully.

OPM notices. Outstanding or Fully Successful ratings can create the impression that the job was being done, and the application has to account for that rather than ignore it. Usually the explanation is real: the ratings predate the onset or worsening of the condition, or you were maintaining performance through unsustainable effort, unused leave, or informal arrangements that concealed the limitation.

Whatever the explanation, it belongs in your statement explicitly. A silent gap between "rated Fully Successful" and "cannot perform essential duties" is the kind of contradiction that decides a close case.

7. Timing, and the one-year deadline

Apply while still employed if you have the option. Active employment gives you a live accommodation process, a current supervisor observing the limitations, and a medical narrative tied to your actual position description. Every one of those weakens after separation.

If you have already separated, the deadline is one year from separation, and OPM applies it strictly. There is no informal extension.

Two other timing points. You must also apply for Social Security disability; the FERS application cannot be fully processed without proof you filed, though SSDI approval is not required and a denial there does not predict OPM's answer — SSDI asks whether you can do any work, while FERS asks whether you can do your work. And if you are 62 or older with at least five years of service, compare an ordinary immediate retirement before going down this road; it may pay more with far less process.

8. If it is denied

Denial is common and is not the end. The sequence:

• Read the findings first. The denial letter states which elements OPM found unproven. That defines what reconsideration must answer.
• Request reconsideration within 30 calendar days of the initial decision. OPM may allow additional time to supplement the record; ask rather than assume.
• Do not resubmit the same package. Address each finding with targeted evidence, and explain any contradiction rather than leaving it to inference.
• If reconsideration is denied, appeal to the MSPB, generally within 30 days. Note that the MSPB retains jurisdiction over disability retirement appeals; the September 2026 transfer of RIF appeals to OPM did not cover them.

The forms, the annuity formulas, and the conversion at 62 are covered in the full disability retirement guide.

9. Frequently asked questions