When an employee makes a reasonable accommodation request, it should trigger a documented process within the human resources department. The Americans with Disabilities Act (ADA) requires employers to engage in the interactive process to arrive at an effective accommodation for people with disabilities.
But how do you respond to a request for a reasonable accommodation, and why does each request need to be taken on a case-by-case basis? Let’s take a look at examples of reasonable accommodation requests, and when it’s appropriate for an employer to suggest an alternative accommodation instead.
What Is a Reasonable Accommodation Request?
A reasonable accommodation request is an employee's request to modify their work environment, job duties, or hiring process related to a disability. Under Title I of the ADA, reasonable accommodations can help qualified employees and applicants access equal employment opportunities, including the benefits and privileges of employment.
Failing to respond to a request could be considered employment discrimination; however, requests that aren’t directly related to a disability aren’t covered by the ADA.
The ADA defines a disability as a “physical or mental impairment that substantially limits one or more major life activities,” and the Equal Employment Opportunity Commission (EEOC) provides disability accommodation tips and enforcement guidance.
Here are some examples of reasonable accommodation requests:
- An employee who uses a wheelchair requests a modification to their workstation.
- An employee with a serious medical condition requests a modified work schedule or permission to telework to facilitate medical treatment.
- An employee with diabetes requests approval to eat or drink in the office.
- An employee with a communication disorder requests assistive technologies or a sign language interpreter.
- An employee with a mental health condition, such as anxiety, requests approval to bring their service animal to work.
Employers can also refer to official .gov resources from ADA.gov, the EEOC, and the U.S. Department of Labor for more information.
Identifying Reasonable Accommodation Requests
Not all reasonable accommodation requests are explicit. An employee who says “I’m having trouble with ….” or “I get migraines when….” could be eligible for reasonable accommodation, even if they don’t mention the ADA at all.
On the other hand, general complaints about the work environment may not trigger the ADA accommodation process unless they’re tied to a medical condition, impairment, or work-related limitation.
To identify a reasonable accommodation request, ask yourself:
- Is the employee a “qualified employee” (that is, they can perform the essential job functions with or without accommodation)?
- Is the request for a reasonable accommodation related to an impairment?
Job applicants may also be entitled to accommodation during the hiring process, so be prepared to modify the application process in line with equal opportunity guidelines.
Responding to a Reasonable Accommodation Request
When an employee makes a reasonable accommodation request, or you suspect they might be eligible for one, here’s how to respond:
1. Ask Clarifying Questions.
Start by asking clarifying questions to confirm the nature of their request. Determine that they are, in fact, requesting accommodation and what that might entail. You don’t need to know the specific details of their disability, just enough to understand their request.
This part of the process should feel inclusive, supportive, and informal. According to the U.S. Department of Labor, the “majority of ADA employment-related disputes are resolved through informal negotiation,” not lawsuits. Still, it’s important to document all of your discussions, even in the absence of a formal written request.
2. Begin the Interactive Process.
Once the need for an accommodation is established, it’s time to begin the interactive process. This is a two-way conversation with the employee to determine an effective accommodation. The timeline can vary depending on how straightforward the request is and whether you have experience with similar accommodations.
For example, if the employee needs a new workstation to accommodate a wheelchair, you may not need to have a lengthy discussion about it at all. For more complex cases where the disability is unclear or invisible, you’ll need to determine which job tasks the employee is struggling with and whether those tasks are essential to their position. An interactive process checklist or internal fact sheet can help ensure you don’t miss a step.
3. Request Medical Documentation When Needed.
If the disability or need for accommodation is not obvious, you may request reasonable medical documentation to evaluate the request. Typically, the employee’s health care provider will confirm the relevant limitation and describe the accommodation needs, such as “no heavy lifting” or “has difficulty concentrating.”
If an employee chooses to reveal that their difficulty concentrating is due to ADHD, they may do so. But employers need to honor the ADA’s confidentiality requirements and limit the amount of medical information they request or share with colleagues.
4. Explore Effective Accommodations.
If the employee hasn’t requested a specific accommodation, you can browse the Job Accommodation Network for more examples of reasonable accommodations. Job restructuring, reassignment to a vacant position, and flexible or part-time schedules are all possible accommodations, as are alternative training materials.
The employee can weigh in on their preferred accommodation, but the employer may choose a different effective accommodation if it meets the employee’s needs.
5. Propose Alternative Accommodations.
Not every accommodation will work out on the first try. If the first attempt isn’t effective, or if the accommodation would pose an undue hardship (financially or otherwise), you can propose an alternative accommodation.
Some accommodations are temporary and need to be re-evaluated as the employee’s circumstances change, while others are maintained for the duration of employment.
Benefits of an Accommodation Management System
Accommodations are determined on a case-by-case basis. From mental health needs to pregnancy-related conditions, every accommodation request is different. A modern accommodation management system like Pulpstream can help you track, document, manage, and monitor ADA accommodations. Here’s how it can help:
Formal Intake Process
Requests for a reasonable accommodation can fall through the cracks if they’re only mentioned in email threads or watercooler conversations. Providing an online intake form ensures that employees have an avenue to make a formal request, notify your HR team immediately, and initiate the interactive process.
Clear Communication
The interactive process involves multiple parties, including the employee, their health care provider, and often their manager. Employers need to be able to request medical information promptly, store it securely, and only disclose it on an as-needed basis. An accommodation management system streamlines communication and automatically integrates with other HR systems, including your leave management system.
Consistent Documentation
Most reasonable accommodation requests can be resolved without issue. But in those cases where the EEOC or another federal agency comes calling, you’ll want to have a paper trail showing that you complied with the ADA and other employment laws.
Pulpstream’s digital workflows automatically record each step: acknowledging the request, initiating the interactive process, and documenting your decisions. Making a good-faith effort to respond to each submission is key to supporting your employees with disabilities and maintaining HR compliance.
A Smarter Way to Stay Compliant
Reasonable accommodation requests range from simple to complex. An employee who has an ADA-qualifying disability might request changes to their schedule, modifications to their work environment, or more accessible training materials. Not all requests are specific or obvious, so employers should consider them on a case-by-case basis.
Employers aren’t required to provide the specific accommodation requested, but they must acknowledge the request, engage in good faith, and propose an alternative. An accommodation management platform like Pulpstream simplifies the process with an online intake form, automatic notifications, and secure document management.
Pulpstream’s cloud-based tools help you demonstrate good-faith compliance efforts, reducing the likelihood of a costly investigation by the EEOC. Even one ADA-related complaint can create significant legal costs, administrative burden, and reputational risk.
Request a demo today and see how Pulpstream can improve your record-keeping.
