In EISFELDER v. MICHIGAN DEPT. OF NATURAL RESOURCES, 847 F. Supp. 78 (W.D.Mich. 11/16/1993), the Federal District Court for the Western District of Michigan writes:

• Defendants also argue that Title II was not violated since they received no formal request for accommodation. However, defendants have cited no legal support for their contention that plaintiff's failure to follow a formal accommodation procedure eliminates her protection under the ADA. Moreover, this insistence runs counter to the language of the statute and regulations, which require accommodation of any "known handicaps."

This is the case cited as authority in Boice, and it appears to support the claim that the failure to follow procedure is not grounds to avoid the requirements of the ADA.

However, here's the problem: The ADA does not directly apply to the federal government. Rather it is the Rehabilitation Act that controls disability discrimination for federal government agencies. And while the Act generally follows ADA regulations in interpreting the Act, it is not entirely clear that the same case law found in Boice can be applied to a federal agency. Which means that, while you have a potentially viable argument, it may require a lot more case law research and briefing to conclude on this issue -- and that means a potentially complicated and expensive battle.

Hope this helps.

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I think that this case may be useful.

Thompson v. Rice, 422 F.Supp.2d 158 (USDC Dist. Ct. DC March 13, 2006):

• A request for accommodation under the Rehabilitation Act does not have to be formal, and the words “reasonable accommodation” do not have to be used, but the employer must be alerted to the condition and the need for accommodation.  Rehabilitation Act of 1973, § 2 et seq., 29 U.S.C.A. § 701 et seq.
• 
  
• Federal employee's request to employer in letter and medical questionnaire, for “support in following [her] doctor's instructions” with regard to upcoming bidding cycle on foreign service assignments, did not constitute “request” for reasonable accommodation as to her alleged impairment of chronic and severe fatigue, for purpose of her discrimination claim under Rehabilitation Act, since letter did not indicate that employee requested reassignment to another position as accommodation.

Hope this helps.

NOTICE: My goal here is to entertain while educating the public about the law. I hope my answer is useful and informative to you. During our conversation, the website may ask you to rate my answer. If you rate my answer lower than the middle rating, then the website retains your entire payment, and I receive nothing. It is entirely your choice as to how you rate my answer. However, because your payment to me is in the nature of a donation/gift, rather than as compensation for any services rendered, you are entitled to know how your rating affects the final distribution of your donation.

If you need to contact me again, please put my user id at the beginning of your question ("To Socrateaser"), and the system will send me an alert. Please Click the following link for IMPORTANT LEGAL INFORMATION. Thanks and best wishes!