An employee mentions that her back condition makes it hard to sit through full days at her desk. Another asks whether he can start an hour later because a new medication makes mornings difficult. Neither of them used the words "ADA" or "accommodation." Both of them may have just triggered your legal obligation to start the interactive process.
The Americans with Disabilities Act requires covered employers to provide reasonable accommodations to qualified employees and applicants with disabilities, unless doing so would cause undue hardship. The law does not hand you a list of required accommodations. Instead, it expects you to work with the employee to find one that works. That back-and-forth is called the interactive process, and handling it well is the single most important thing you can do to stay compliant.
Who is covered
Title I of the ADA applies to private employers with 15 or more employees, as well as state and local governments, employment agencies and labor unions. Many state and local disability laws apply to smaller employers and sometimes define disability more broadly, so even a company with fewer than 15 employees may have similar obligations. Check your state in the AskHrAI state HR law guides.
The ADA protects a qualified individual with a disability: someone who can perform the essential functions of the job, with or without reasonable accommodation. Since the ADA Amendments Act of 2008, "disability" is interpreted broadly, so in most accommodation situations the better use of your time is figuring out what will help rather than debating whether a condition qualifies.
What counts as a request
An employee does not need to put the request in writing, mention the ADA, or use the phrase "reasonable accommodation." A request can be as simple as telling a manager they need a change at work because of a medical condition. A family member or health care provider can also make the request on the employee's behalf.
That means managers need to recognize requests and route them to whoever handles accommodations. Train them on a simple rule: if someone links a work problem to a health condition, tell HR the same day.
The interactive process, step by step
- Acknowledge the request promptly. Respond quickly and in writing. Unnecessary delay can itself be treated as a failure to accommodate.
- Meet with the employee. Ask what limitations they are experiencing, which job tasks are affected, and what they think would help. Employees often know exactly what would work.
- Identify the essential functions of the job. Look at the real job: what tasks are fundamental, how much time they take, and what happens if they are not done. An accurate job description is useful evidence here.
- Request medical information only if needed. When the disability or need for accommodation is not obvious, you may ask for reasonable documentation from a health care provider that confirms the disability and explains the functional limitations. Do not ask for full medical records or a diagnosis beyond what is needed.
- Explore possible accommodations. Brainstorm options together. The Job Accommodation Network (JAN), a free resource funded by the US Department of Labor, publishes accommodation ideas for many conditions and job types.
- Choose an effective accommodation. You must provide an effective accommodation, but you do not have to provide the employee's first choice if another option is also effective. Consider the employee's preference seriously.
- Document and implement. Write down what was agreed, when it starts, and who is responsible.
- Follow up. Check in after a few weeks to see whether it is working, and revisit if circumstances change.
Common reasonable accommodations
| Type | Examples |
|---|---|
| Workspace changes | Sit-stand desk, ergonomic chair, relocated workstation, improved lighting, reduced noise |
| Schedule changes | Modified start times, part-time schedule, additional breaks, time off for treatment |
| Job restructuring | Swapping marginal (non-essential) tasks with coworkers |
| Remote or hybrid work | Working from home some or all days when the essential functions can be done remotely |
| Equipment and technology | Screen readers, captioning, speech-to-text software, amplified phones |
| Policy modifications | Allowing a service animal, adjusting a no-food policy for a medical need |
| Leave | Unpaid leave beyond company policy, when it is likely to allow the employee to return to work |
| Reassignment | Moving the employee to a vacant position they are qualified for, often treated as a last resort |
What you do not have to do
- Eliminate an essential function. You can adjust how a task is done, but you do not have to remove core duties of the job.
- Lower production or quality standards that apply to everyone in the role, although you may need to accommodate the employee in meeting them.
- Create a new position or bump another employee from theirs.
- Provide personal items needed both on and off the job, such as eyeglasses or a wheelchair.
- Provide an accommodation that causes undue hardship. This means significant difficulty or expense considering your size, resources and operations. It is assessed case by case, and for most small accommodations it is a high bar.
If you believe a requested accommodation creates undue hardship, keep talking. Look for an alternative that would be effective and reasonable instead of simply denying the request.
Pregnancy accommodations
The Pregnant Workers Fairness Act, in effect since 2023, requires employers with 15 or more employees to provide reasonable accommodations for known limitations related to pregnancy, childbirth or related medical conditions, unless doing so would cause undue hardship. It uses a similar interactive process, but it has some important differences from the ADA. For example, an employee may be accommodated even if they temporarily cannot perform an essential function. Many states have their own pregnancy accommodation laws as well.
Confidentiality and documentation
Medical information obtained during the process must be kept confidential and stored separately from the general personnel file. Supervisors may be told about necessary work restrictions and accommodations, but not the diagnosis. Your documentation should include:
- The date and content of the request
- Each meeting and communication, with dates
- Options considered and why each was or was not chosen
- The accommodation provided and the start date
- Follow-up check-ins and any adjustments
If litigation ever arises, a record showing that you engaged in good faith is one of your strongest defenses.
Mistakes that cause claims
- Ignoring a request because the employee did not use the right words
- Letting a request sit for weeks without response
- Demanding excessive medical information
- Applying a rigid "100% healed" or "no restrictions" return-to-work policy
- Automatically terminating someone when their leave runs out without considering whether additional leave or another accommodation is reasonable
- Disciplining or treating someone differently after they request an accommodation. Retaliation is prohibited, and requesting an accommodation is protected activity.
Key takeaways
- The ADA applies to employers with 15 or more employees; state laws often cover smaller employers.
- Any request linking a work issue to a medical condition can start the interactive process.
- Respond promptly, talk with the employee, focus on essential functions, and document each step.
- You must provide an effective accommodation, not necessarily the one requested.
- Keep medical information confidential and never retaliate against a request.
Handling your first accommodation request? The AskHrAI HR assistant can help you plan the conversation, draft follow-up letters and think through options.
This article is general information, not legal advice. Employment laws change and vary by state and city — confirm details with your state labor department or an employment attorney.