Attachment A

Over the last several months, members of the WASO Human Resources Office, Ranger Activities Division and the Atlanta Public Health Service have given briefings on the Medical Standards Program at locations throughout the Service. At many of these briefings, some of the same questions were asked. The questions and answers listed below are as a result of the concerns raised at those briefings.

1. Are the medical standards for Park Rangers appropriate? That is, do the standards accurately reflect the medical condition necessary to do the work assigned to Park Rangers?

   Prior to implementation, the standards were developed and validated by a group of subject matter experts from the Office of Personnel Management, the Departmental Office of Risk Management, and Federal Occupational Health. They, along with representatives at the field and headquarters level of the Service, studied the work of Park Rangers and developed the standards. The standards were reviewed by the OPM and the Department of the Interior and were found to be appropriate and valid.

2. Are the medical standards for Park Rangers more stringent than standards for law enforcement positions in other agencies?

   In general, some agencies and some positions have more and less stringent standards. Our standards stand somewhat in the middle ground. In some respects, our standards are more stringent. Our standards reflect the difficult terrain and work conditions that Park Rangers face everyday. In many situations, Park Rangers work in greater isolation than other law enforcement professionals do. The medical standards were developed to reflect the medical condition necessary to work under those conditions.

3. Can the medical standards for Park Rangers be revised?

   The Department of the Interior may periodically review and revise medical standards for Park Rangers to ensure the standards accurately reflect the medical condition necessary to perform the duties of the position. The Service intends to review the standards on a regular basis, every two or more years, to re-validate the standards and recommend any changes. Any recommended change would need to be specifically justified. Only the Department or the Office of Personnel Management may approve changes.

4. Are medical standards for Park Rangers rigidly applied?

   Medical standards are rigidly applied without exception to applicants with no prior work history in law enforcement in the National Park Service. For current employees and applicants with a prior work history in law enforcement in the Service, a work history may be considered as a part of the medical evaluation.

5. Are many current Park Rangers expected to not meet medical standards?

   The experience of Federal Occupational Health in performing medical evaluations suggests that the typical rate of failure to meet medical standards for law enforcement professionals within the Federal Government is about 1 to 2 %. We expect the vast majority of Park Rangers to meet medical standards.

6. May prior law enforcement work experience be considered in making medical evaluations?

   Prior work experience in the National Park Service performing law enforcement duties may be considered in medical evaluation. The experience may be considered for either an employee or a returning applicant for temporary (seasonal) appointment. Experience in other law enforcement agencies is not considered, as the experience needs to be specific to conditions typically found in National Parks.

7. How does an employee/applicant have prior service considered?

   In order for the Medical Review Officer to consider successful previous experience in law enforcement, the employee/applicant must submit a brief work history with a minimum of three months seasonal work in the past calendar year. It should be verified by the employee/applicant’s supervisor and the park human resources officer and included within the medical examination paperwork. If no evidence of prior work history is included, the Medical Review Officer will assume there is no previous work history.

8. What should the work history include?

   The law enforcement work history should include the length of time working as a Park Ranger who was assigned law enforcement duties and maintained a law enforcement commission, the specific parks where the work was performed and the locations within those parks where work was performed, the dates the work was performed, a full description of duties successfully performed, the environment in which those duties were performed, verification of the information by the park chief ranger and human resources manager.

9. How are recommendations of the Medical Review Officer communicated to parks?

   All Medical Review Forms showing whether additional information is needed, additional tests are needed or there is a Significant Medical Finding, PHS will fax the information directly to servicing human resources offices or designated points of contact for parks. A copy of all Medical Review Forms except those not requiring further follow-up will be sent to the Chief, Staffing and Compensation in Washington for status tracking and for decision making purposes when this is needed.

10. If a finding is other than no significant medical finding (employee meets medical standards), what action should be taken?

    In the event of a finding of significant medical findings, the employee should not be assigned any hazardous or rigorous law enforcement duties. In the event of a finding of final decision cannot be made, the employee may continue to be assigned hazardous or rigorous law enforcement duties at the discretion of the supervisor and/or park management based upon the issues not yet resolved.

11. Should applicant/employees provide medical documentation of any past or current medical condition with them to the physical examination?

    Applicants/employees should be instructed to provide medical documentation with them to the examination with the understanding that this information will be included in the examination results for review by the Medical Review Officer. The documentation should include the diagnosis, treatment, outcome, and prognosis for recovery for any surgery or broken bones for the period three years prior to the examination.

12. Does an applicant/employee whose examination results indicate uncorrected vision that does not strictly meet medical standards

    If the applicant/employee submits a verified law enforcement work history in the NPS as stated above and has a examination result of uncorrected vision of 20/200 that is corrected to 20/20, the Medical Review Officer MAY recommend that the Human Resources Program Manager waive the standard based on prior successful work performance. If the vision is greater than 20/200, the applicant/employee will receive a finding of significant medical finding, but will have the opportunity to provide additional information and documentation of their ability to successfully perform rigorous law enforcement duties.

13. How soon may an employee return to work after surgery to correct or improve vision?

    As with any surgery, an employee should be examined and evaluation by the Medical Review Officer prior to returning to work. Depending upon the type of surgery performed, an employee may return to unrestricted duties upon recovery.

14. Will the use of a hearing aid enable a current employee or applicant to meet medical standards for hearing? Is the use of a hearing aid a reasonable accommodation for hearing loss?

    A hearing aid may not be used by an applicant to meet minimum standards but may be used to enhance hearing above the minimum levels. As with all medical evaluations, each situation is reviewed on an individual basis. However, a hearing aid is a mechanical device that may be displaced from the ear or may be subject to failure. In order to respond to the critical incidents that occur in law enforcement, Park Rangers must have sufficient hearing without the use of a hearing aid. Additionally, hearing aids do not allow an individual to pick out certain sounds against a background of noise. The likelihood is that an individual using a hearing aid is far more likely to be unsafe to his/herself or to others. Thus, generally a hearing aid may not be a reasonable accommodation of a Park Ranger for purposes of meeting the medical standard for hearing.

15. Are stress tests still being conducted? Why or why not?

    Stress Treadmill EKG tests are no longer being conducted. While the Stress Treadmill EKG has value as a diagnostic test, the frequency of both false positive and false negative test examination results have limited value in determining medical evaluations for medical standards.

16. Are psychological examinations conducted?

    Psychological examinations are not conducted as a part of preplacement or periodic examinations. Psychological examinations may be conducted for return to duty examinations and fitness for duty examinations if warranted.

17. Are there medical standards for criminal investigators in the National Park Service?

    Medical Standards have been written and validated for the Criminal Investigator occupation by the Office of Personnel Management (OPM). These general medical standards may be used by any Federal agency having this occupation. There are no medical standards that have been written specifically for this position in the National Park Service because we have limited numbers of employees in this occupation. We will, however, review the general standards with the OPM and the PHS to determine whether or not these standards are applicable to this position within the NPS. Given that the circumstances and physical setting which Criminal Investigators work in is similar to that of Park Rangers, it is likely that the Criminal Investigator medical standards will be similar to the standards for Park Rangers..

18. When are parks to implement medical standards for current employees?

    Upon issuance of RM-57, parks were instructed to begin implementation of medical standards for all employees as of the effective date of the Director’s Order. Any park, which has not begun to implement medical standards, must do so immediately. This includes both temporary/seasonal and permanent employment.

19. Who pays for medical examinations and evaluations?

    For medical examinations for Park Rangers performing law enforcement duties, initial examinations and evaluations are conducted through a Servicewide contract with the Public Health Service which is part of Federal Occupational Health and funding through a central, Servicewide account. However, in certain circumstances, additional testing is the responsibility of the employee and should be paid through his/her medical insurance. Please review the following situations:

    • If a specific test was not completed at the initial physical testing, then the employee returns to the original place of testing and requests that the test be completed. In this case, charges would be paid by the basic funding account.

    • If the Medical Review Officer recommends further testing because a final decision cannot be made until more information is received, it is the responsibility of the employee to seek this further testing and cover these expenses with his/her personal medical insurance.

    • If the MRO recommends additional information for applicants, the responsibility to provide that information and/or provide the results of additional medical tests is the responsibility of the applicant. Any expense incurred will be paid by the applicant.

    • Additionally, the Servicewide contract provides funding for fitness for duty examinations as ordered by the Service and for return to duty examinations after injury/incapacitation for duty.