Managing Disability Accommodations: A Comprehensive Toolkit for HR
Reasonable accommodation helps remove workplace barriers so qualified applicants and employees with disabilities can perform essential job duties and have equal access to job opportunities. Equip your HR team to recognize, document, and respond to accommodation requests.
While many individuals with disabilities can apply for and perform jobs without reasonable accommodations, some workplace barriers may keep others from performing jobs that they could do with some form of accommodation. Such barriers may be physical obstacles such as inaccessible facilities or equipment, or they may be procedures or rules such as those specifying when work is to be performed, when breaks are to be taken, or how essential or marginal functions are to be performed.
Reasonable accommodation removes workplace barriers for individuals with disabilities so that they may enjoy equal employment opportunities. Under the Americans with Disabilities Act (ADA), employers with 15 or more employees must provide reasonable accommodation to qualified applicants and employees with disabilities unless doing so would create an undue hardship
Employers can provide many accommodations at low cost or no cost. The process of providing accommodations for employees with disabilities is meant to be an interactive one dependent on timely communication, thoughtful review, and careful documentation.
This toolkit gives HR professionals a practical framework for recognizing requests, working through the interactive process, reviewing medical support when needed, and evaluating whether an accommodation is reasonable.
Benefits of Prioritizing Accommodations
A strong accommodation process creates immediate benefits for employees and employers. It removes workplace barriers, supports job performance, and helps organizations retain talent while improving access and participation. You gain these advantages when your organization makes accommodations a priority:
- Increasing employee trust: Addressing disability-related needs seriously and fairly builds confidence in the accommodation process.
- Improving employee retention: Supporting employees with disabilities can reduce turnover and help retain valued talent.
- Boosting productivity: Providing the right accommodations helps employees perform their roles more effectively and efficiently.
- Strengthening company reputation: Prioritizing accessibility demonstrates commitment to inclusion and can build goodwill with employees, customers, and the community.
- Reducing legal risk: A well-managed accommodation process supports ADA compliance and lowers the likelihood of disputes or legal claims.
Compassionate Solutions — Finding ADA Success Across Every Career Stage
In this episode of SHRM's Honest HR podcast, expert legal voices Amy Epstein Gluck, Esq., founding partner at Pierson Ferdinand LLP, and SHRM’s Allen Smith, J.D., share best practices in applying the ADA across the full employee life cycle, from recruitment to post-employment.
Pro Tip
The Job Accommodation Network offers free, expert, and confidential guidance to help employers and employees explore practical workplace accommodation solutions.
Reasonable Accommodation Requirements
Employers are required to provide reasonable accommodation to qualified job applicants or employees with disabilities except when such accommodation would cause an undue hardship. In practice that can include modifying parts of your talent acquisition process or facets of jobs.
Common Accommodations
Some examples of possible reasonable accommodations that an employer may have to provide in connection with accommodating applicants with disabilities, modifying the work environment, or adjusting how and when a job is performed include:
- Providing accessible application and interview processes.
- Providing reading or interpretation software for applications, interview processes, or job duties.
- Making existing facilities accessible.
- Restructuring a job.
- Permitting part-time or modified work schedules.
- Allowing work to be performed at home.
- Acquiring or modifying equipment.
- Changing tests, training materials, or policies.
- Reassigning an employee to an open position, though this is considered a last resort.
Recognizing Accommodation Requests
HR and managers need to recognize that requests for accommodations can be informal, and do not have to follow a set format. An employee or applicant may make a verbal or written request without mentioning the ADA or using the phrase “reasonable accommodation.”
An essential element of whether something is a request is whether the person connects a workplace problem or needed change to a medical condition. Examples of informal requests or statements that should prompt a conversation include:
- Statements about difficulty getting to work because of medical treatment may serve as accommodation requests.
- Requests for leave to receive treatment for a medical condition may begin the accommodation process.
- An applicant who indicates a building or office is inaccessible because of wheelchair use may be making an accommodation request.
Pro Tip
SHRM’s BEAM Framework is your one-stop shop to ensure fairness and equal opportunity in your workplace. Take its strategic assessment to see how well inclusion and diversity are embedded in your business.
Interactive Process
When an employee requests an accommodation, managers and HR must navigate the ADA requirements with care. Employers should engage in what’s known as an interactive process with the employee, which can include requesting medical documentation for the medical condition. The following best practices will help you maintain a fair, compliant, and open dialogue with your team members.
- Starting timely discussions: Responding promptly to accommodation requests helps prevent delay, confusion, and avoidable missteps.
- Focusing on job functions: Center the discussion on essential duties and the specific workplace barriers affecting performance.
- Inviting employee ideas: Ask which tools, schedule changes, or other adjustments have worked in the past or might help now.
- Considering multiple options: Evaluate a range of practical solutions rather than assuming there is only one effective accommodation.
- Documenting the process: Record conversations, options considered, decisions made, and follow-up actions to support consistency and compliance. Clear notes protect the organization and help track ongoing needs.
Determining What is ‘Reasonable’
After identifying and discussing a request for accommodation, HR must next assess whether the accommodation is reasonable, and if it is not, suggest other accommodations that would be reasonable.
An accommodation is reasonable when: It helps a qualified person perform the essential functions of their job or access equal opportunities and does not create an undue hardship for the organization. Ultimately, a reasonable request balances the practical needs of the individual with the everyday operational realities of the workplace.
An accommodation may be unreasonable when: It would require eliminating an essential function of the job, or if it would require lowering production standards, according to the U.S. Equal Employment Opportunity Commission (EEOC) This is because a person with a disability who is unable to perform the essential functions, with or without reasonable accommodation, is not a “qualified” individual with a disability within the meaning of the ADA.
Production standards: The EEOC states an employer does not have to lower production standards — whether qualitative or quantitative — that are applied uniformly to employees with and without disabilities. However, an employer may have to provide reasonable accommodation to enable an employee with a disability to meet the production standard.
Note that while an employer is not required to eliminate an essential function or lower a production standard, it may do so if it wishes.
Pro Tip
Bring the right internal stakeholders — such as direct managers, facilities, IT, or safety teams — into the interactive process early to collaborate on solutions and find workable accommodation options faster.
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Undue Hardship
The ADA requires an employer to provide reasonable accommodation to qualified job applicants or employees with disabilities except when such accommodation would cause an undue hardship.
The employer should bear in mind that undue hardship is difficult to show, particularly when it is arguing cost poses an undue hardship. Employers need concrete evidence about cost, operations, staffing, safety, or business impact.
Disruption is easier to show as an undue hardship, but it's still a high standard to meet. Leave might be considered as an accommodation if accommodation in the position for now won't work.
Examples of undue hardship include:
- Excessive financial strain: When the cost of the requested accommodation is disproportionately high compared to the financial resources of the employer or the specific facility.
- Operational disruption: Accommodations that significantly impact the operation of the business, such as altering essential workflows or reducing overall efficiency.
- Safety risks: An accommodation that would compromise workplace safety or increase the risk of harm to others.
- Impact on other employees: When an accommodation infringes on the rights or benefits of other employees or requires them to take on additional hazardous or burdensome tasks.
Communicating a Rejection for Undue Hardship
When an accommodation would cause an undue hardship, it is important to communicate this decision with transparency and respect. Begin by acknowledging the employee or candidate’s request and outlining the effort to explore possible solutions. Clearly explain the specific reasons why the employer cannot provide the accommodation, referencing the factors that contribute to the undue hardship.
This is all part of the interactive process, because employers who determine a certain accommodation poses an undue hardship should offer alternative accommodations, if available, that may address their needs in a different way. Maintain an open dialogue to demonstrate a commitment to finding a workable solution and to foster trust throughout the process.
Pro Tip
Although the EEOC has called reassignment an accommodation of last resort under the ADA, employers should not overlook transfer as a possibility before termination. Sometimes, an employee with a disability might even prefer it.
Medical Information and Documentation
When an employee's disability or need for accommodation is not obvious, you might need to request medical documentation. The following list outlines ways to help you respectfully gather, review, and manage medical information during the interactive process.
- Stick to job-related information: Limit requests to the information needed to understand the disability, the functional limitation, and the connection to the job.
- Avoid unnecessary records: Do not request unrelated medical files, broad health histories, or details beyond the accommodation issue at hand.
- Gather relevant details: Request specifics that explain how the condition affects job duties, attendance, communication, mobility, or other work tasks.
- Maintain confidentiality: Store medical information securely, keep it confidential, and maintain it separately from the personnel file.
- Use discussion as an alternative: In some cases, a direct conversation about the employee’s limitations and workplace needs may be enough without formal paperwork.
Pro Tip
Be aware of the potential coordination between the FMLA and the ADA. For example, there are situations where extended FMLA leave may qualify as a reasonable accommodation under the ADA.
Templates and Tools
Use these templates from SHRM to streamline your accommodation processes and ensure compliance with the ADA. These tools empower HR professionals to document interactive conversations, reduce risk, and enhance efficiency.
CHECKLIST
ADA Reasonable Accommodation Checklist
Identify the need for a reasonable accommodation under the ADA and the process for the employer to follow.
FORM
ADA Reasonable Accommodation Request Sample Form
The employee may want to put their request in writing, and it can be useful to the employer to have a paper trail.
POLICY
ADA/ADAAA Policy
Manage compliance, workplace accommodations, and inclusion to drive organizational success.
FORM
ADA Compliance Questionnaire
Evaluate your company’s ADA compliance with this user-friendly resource.
FORM
ADA Accommodation Approval Letter
Support employees with disabilities and maintain clear documentation in your HR workflow.
FORM
ADA Accommodation Denial Letter
Ensure your HR team responds to requests with clarity, professionalism, and legal compliance.
Legal Considerations
The ADA centers on making spaces, services, and digital experiences accessible so people with disabilities can participate fully and independently. It emphasizes equal access, reasonable accommodations, and inclusive design that removes barriers across physical and online environments. Keep these compliance guidelines in mind:
- Definition of disability: The ADA generally interprets disability broadly and may include physical, mental, and episodic conditions.
- Undue hardship: Because undue hardship is so hard to prove, to minimize risk, employers should consider suggesting alternative accommodations rather than issuing a denial based on undue hardship.
- Retaliation prohibition: The ADA protects employees from adverse action for requesting an accommodation or participating in the process.
- Confidentiality requirements: Medical information should be shared only with those who need it for accommodation or compliance purposes in order to avoid running afoul of HIPAA or other privacy laws.
- State and local laws: Additional legal requirements may apply beyond the federal ADA, so employers should account for state and local protections as well.
Expert Advice
Take advantage of these SHRM resources to get more expert insights related to the ADA, earn professional development credits (PDCs), and gain a competitive edge.
WEBINAR
FMLA and ADA: What’s Changing — and What HR Leaders Need to Do Now
This webinar takes a practical look at how the FMLA and ADA are playing out in today’s workplace.
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The PWFA, ADA and FMLA: How They Interact
Employers need to know how to handle requests and how protections under the three laws converge.
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What HR Doesn't Know About Federal Compliance Rules Could Cost You Millions
Learn what has changed, what it means for your organization, and what smart HR teams are doing about it.