Running the ADA Interactive Process: A Step-by-Step Guide for Managers
When an employee asks for help doing their job, the ADA's interactive process kicks in. Here's how to handle the conversation and document it.
By Nora Ellison · Senior HR Compliance Writer
Reviewed by theComplianceToolsLibrary Editorial Team · · 6 min read
Under the Americans with Disabilities Act (ADA), employers with 15 or more employees must provide reasonable accommodations to qualified employees with disabilities — unless doing so would cause undue hardship. The mechanism for getting there is the "interactive process": a good-faith, back-and-forth conversation.
No magic words are required. An employee saying they're "struggling to get to work because of a medical condition" can be enough to trigger your obligation to engage.
Step 1 — Recognize the request
A request doesn't have to mention the ADA or use the word "accommodation." Train managers to recognize that any communication linking a workplace barrier to a medical condition may start the process. When in doubt, treat it as a request and loop in HR.
Step 2 — Engage and gather information
Talk with the employee about the limitation and the barrier it creates. If the disability or need isn't obvious, you may request reasonable medical documentation — but only enough to confirm the disability and the need for accommodation, not the employee's entire medical history.
Step 3 — Identify and weigh options
Focus on the essential functions of the job and how to enable the employee to perform them. Reasonable accommodations can include modified schedules, equipment, telework, reassignment to a vacant position, or leave. You can choose among effective options — you don't have to grant the employee's exact preference.
Step 4 — Decide, implement, and document
Undue hardship — significant difficulty or expense — is a high bar judged on your specific resources, not guesswork. Document each step: the request, what was discussed, options considered, and the outcome. A clean record is your best defense if the decision is ever challenged.
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Frequently asked questions
What triggers the ADA interactive process?
Any request — formal or informal — for a change at work because of a medical condition. The employee need not mention the ADA or use the word 'accommodation' for the employer's obligation to engage to begin.
Can we require medical documentation?
When the disability or need for accommodation isn't obvious, you may request reasonable documentation confirming the disability and the need — but not the employee's complete medical records.
Do we have to grant the exact accommodation requested?
No. If more than one accommodation would be effective, the employer may choose which to provide. You must provide an effective accommodation absent undue hardship.