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ADA Reasonable Accommodation Tracker

Walk through the interactive process for handling accommodation requests under the ADA.

Reviewed by theComplianceToolsLibrary Editorial Team · Last updated

⚠ Disclaimer: This tool is for informational purposes only and does not constitute legal advice. Consult a qualified attorney or HR professional for guidance specific to your situation.
Overall: 0 of 22 items
Stage 1: Request Received

An employee (or someone on their behalf) has communicated a need for a change at work due to a medical condition. Note: the employee does not need to use the words 'reasonable accommodation' or cite the ADA.

Document the date received, who made the request, and the nature of the request.

The employee does not need to disclose a specific diagnosis. Focus on functional limitations.

You may ask for documentation confirming the disability and explaining functional limitations. Do NOT request full medical records.

This is a collaborative dialogue between employer and employee. Both parties must participate.

Key facts

Covered employers
Employers with 15 or more employees (ADA Title I)
What triggers the duty
Any request for a workplace change for a medical reason — no magic words required
Core obligation
A good-faith interactive process between employer and employee
Limit
No accommodation that imposes an undue hardship is required
Enforced by
The EEOC

What is a reasonable accommodation under the ADA?

Title I of the Americans with Disabilities Act (ADA) requires covered employers to provide reasonable accommodations to qualified employees and applicants with disabilities, unless doing so would cause an undue hardship. The law is enforced by the Equal Employment Opportunity Commission (EEOC) and applies to employers with 15 or more employees.

A reasonable accommodation is a change to the job, the work environment, or how things are usually done that enables a person with a disability to perform the essential functions of the job. Examples include modified schedules, assistive equipment, a period of leave, telework, or reassignment to a vacant position.

When a need isn't obvious, the employer and employee engage in an "interactive process" — a good-faith dialogue to identify limitations and effective options. The employer may request reasonable medical documentation, but inquiries must be job-related and consistent with business necessity.

How to use this tool

  1. 1

    Recognize the request

    Treat any request for a workplace change for a medical reason as the start of the process — no specific words are needed.

  2. 2

    Identify essential functions

    List the essential functions of the job the accommodation must support.

  3. 3

    Engage in the interactive process

    Have a good-faith dialogue and request reasonable medical documentation if the disability or need is not obvious.

  4. 4

    Identify effective options

    Find accommodations that work; you may choose among options that are equally effective.

  5. 5

    Decide and document

    Record the outcome, assess undue hardship case by case, and revisit if circumstances change.

Common mistakes to avoid

  • Waiting for the employee to say "ADA" or "accommodation" — there are no magic words.
  • Skipping the interactive process and denying the request outright.
  • Requesting excessive or unrelated medical information.
  • Assuming leave can never be a reasonable accommodation.
  • Failing to document each step of the process.

What to do next

  • Keep accommodation records and medical information confidential and separate from personnel files.
  • Train managers to escalate accommodation requests to HR.
  • Use the Job Accommodation Network (JAN) for free, confidential accommodation ideas.
  • Coordinate with FMLA and workers' compensation when leave is involved.

Sources

Frequently asked questions

Which employers must comply with the ADA's accommodation rules?

Title I of the ADA applies to employers with 15 or more employees.

Does an employee have to use specific words to request an accommodation?

No. Any request for a workplace change for a medical reason can trigger the employer's duty to engage in the interactive process.

What is the interactive process?

A good-faith, back-and-forth dialogue between employer and employee to identify the person's limitations and possible effective accommodations.

What is undue hardship?

Significant difficulty or expense for the employer, judged case by case against its resources. It is the standard for lawfully declining an accommodation.

Can leave be a reasonable accommodation?

Yes. A finite period of leave can be a reasonable accommodation when it allows the employee to return to work, absent undue hardship.

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