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Organizations invest heavily in finding and developing talent, only to lose it through accommodation process failures that are entirely preventable. The reason is structural: most accommodation processes are built to evaluate proposals, rather than identify effective solutions. An employee submits a request. The request is discussed. HR evaluates the accommodation the employee proposed. A decision is made: approve or deny. That structure is administratively familiar, but it does not align with how the Americans with Disabilities Act’s interactive process is intended to function. It also produces predictable failures.
Two Places the Process Breaks Down
The first breakdown point is at the front end. Most processes are structured around a single proposal: the specific accommodation the employee has requested, often with clinical documentation supporting it. The employer’s role becomes evaluating that proposal. But employees and their clinicians typically have limited visibility into operational constraints, available technology, workflow flexibility, or how work is actually organized. That information sits with the employer. Front-loading the burden of identifying reasonable accommodations onto the party with less information produces guesswork, not solutions.
The second breakdown point is at the back end. When a proposal is denied, the burden typically shifts back to the employee to propose an alternative. Many employees don’t. The process stays technically open while the search quietly ends. What looks like due diligence produces the same result as closing the file. No effective accommodation is found, and the employee is left without the support they need.
Both failures follow from the same design choice: a process organized around evaluating proposals rather than conducting a search.
The Business Case for Change
The cost is real. BCG research involving nearly 28,000 employees across 16 countries shows that inclusion scores drop 15 percentage points when accommodation requests are denied — a drop that significantly increases attrition risk. According to SHRM, replacing an employee typically costs between 50% and 200% percent of their annual salary. By contrast, the Job Accommodation Network (JAN) reports that more than half of all accommodations cost nothing to implement, and when there is a cost, the typical one-time expense is around $300. A process built to evaluate proposals rather than find solutions trades that modest expense for a much larger one.
Three Changes That Fix the Structure
Organizations can save money, remain compliant, and better engage employees by making a few small changes to their approach to workplace accommodations.
- Start with limitations, not proposals. Ask the employee to describe their functional limitations. If they have ideas about what might help, welcome them — but do not require them. If the employee’s suggestion is workable, implement it. If it isn’t, or if no suggestion is forthcoming, the employer assumes responsibility for the search. The standard is whether a reasonable accommodation exists, not whether the employee proposed one.
- Search systematically across all categories. The search should cover not just the familiar options—modified schedules, leave, equipment adjustments—but also less commonly explored categories: job restructuring, modification of workplace policies, and alternative methods of accomplishing essential functions. When organizations default to the familiar, the search narrows before it begins.
- Bring in outside expertise. If internal review fails to identify a reasonable accommodation, consult outside experts before concluding none exists. JAN offers free employer consultation. Among employers who used it, roughly 88% rated the resulting accommodations at least somewhat effective. If JAN consultation doesn’t identify a workable option, occupational therapists, workplace ergonomists, and vocational rehabilitation counselors should be consulted. Beyond the physical environment, these specialists can analyze how work is organized, whether tasks can be restructured, and whether current methods are truly essential or just customary. That is exactly the analysis the interactive process requires, and it costs a fraction of turnover costs.
The Diagnostic Question
One question reveals whether your process is built to evaluate requests or find solutions: who owns the search? If the answer is the employee, the process is built to evaluate proposals. If the answer is HR — initiating a structured search, covering the full range of options, and bringing in expertise when needed — it is built to find solutions.
Effective accommodations determine whether people can stay. Process design determines whether effective accommodations are found and implemented.
Karin Boxer is a philosopher and disability inclusion strategist whose work examines how workplace design determines who can stay.
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