Navigating the ADA: How to Respond to an Accommodation Request

One of your desk clerks just disclosed they have chronic back pain, making it difficult to sit for a prolonged period and a struggle to bend over. While they remain committed to their role and want to continue performing at a high level, they have documentation from their healthcare provider saying they need some type of accommodation to continue working.

While your first reaction is to express sympathy, you haven't experienced this type of scenario before as a manager. How should you respond?

Let's back up to explain a few things first.

What Is an ADA Accommodation?

The Americans with Disabilities Act (ADA) applies to most employers with 15 or more employees. It requires covered employers to provide reasonable accommodations to qualified applicants and employees with a physical or mental impairment or limitation, unless doing so would cause undue hardship.

What might be considered an ADA accommodation?

An ADA accommodation is any reasonable adjustment that enables an employee to perform essential job functions or have equal access to employment opportunities. Examples might include:

• Modified work schedules
• Remote or hybrid arrangements
• Adjusted equipment or workspace
• Reassignment to a vacant position
• Modified job duties
• Assistive technology

The ADA’s definition of disability is broad and includes physical, mental, and emotional impairments. Essentially, a physical or mental condition that substantially limits a major life activity, such as walking, talking, hearing, or a bodily function, could be a qualified disability.

What would be considered an undue hardship?

When an employee has a reasonable accommodation request, you must consider whether the request would create an undue hardship.

An undue hardship is something that creates significant difficulty or expense for a company when they implement a specific accommodation for an employee. This is beyond minor inconvenience or modest cost; you must consider the company's size, financial needs, operational needs, and whether the accommodation request would fundamentally alter business operations.

Each request must be individually evaluated. Although an employee may have a specific reasonable accommodation request in mind, employers are allowed to consider alternative accommodations that could satisfy employee requests without creating an undue hardship.

Why Having a Positive Response to an Accommodation Request Matters

Today’s workplace increasingly recognizes that flexibility and inclusion drive better performance. Many employers have seen more accommodation requests in recent years, which is a sign of growing trust between employees and leadership.

Rather than viewing requests as obstacles, you should treat them as opportunities to collaborate. This shifts the focus on an employee's ability rather than their perceived inability to perform fundamental job duties.

Below are ten best practices for how you could respond thoughtfully and effectively to a requested accommodation.

10 Best Practices for Responding to ADA Accommodation Requests

1. Thoughtfully Evaluate Undue Hardship

When reviewing a request, consider both cost and operational impact. While most accommodations are affordable and manageable, sometimes employees want a specific accommodation that could be better compromised to mutually benefit both the employee and the company.

Take time to evaluate:

• Company size and resources
• Available alternatives
• Long-term benefits

A careful assessment will show good faith and professionalism.

2. Engage in a Collaborative Dialogue

Even if a request initially seems challenging, start with an open conversation. Ask questions such as:

• What substantially limits your success at work?
• What solutions have helped before?
• What accommodations might work best?

This interactive process builds trust and leads to better outcomes.

3. Take Initiative in Finding Solutions

Employees may suggest ideas, but employers play a key role in exploring options.

Research alternatives, consult HR professionals (or even legal counsel), and think creatively. Shared problem-solving often leads to innovative solutions.

4. Maintain Clear Documentation

Strong documentation supports transparency and consistency. Keep records of:

• Requests
• Meetings
• Evaluations
• Decisions
• Implemented accommodations

Good documentation protects both you, the employer, and the employee.

5. Keep the Conversation Open

If one option doesn’t work, explore others. Possible alternatives might include:

• Temporary adjustments
• Modified schedules
• Job restructuring
• Reassignment

An ongoing dialogue shows commitment to your employee's success and helps the employee feel like you genuinely care.

6. Do Not Remove Essential Job Functions from the Position

Essential functions define the core of a role. If you feel strongly about temporarily eliminating an essential function of a job as an accommodation, be sure to emphasize that suspending or relaxing the essential function is temporary.

For example, let's say your desk employee with chronic back pain has an essential job function of maintaining physical files, including regularly retrieving, organizing, and storing documents in filing cabinets located throughout the office. It requires standing, bending, and walking for extended periods.

As an accommodation, you assign coworkers to manage all physical files. With time, you stop enforcing this duty for the employee's position altogether. But when a new employee in the same position is hired and told managing files is essential, they might question why it applies to them but not to others, saying it feels like unequal treatment. This could amount to unnecessary conflict that leads to a discrimination claim, particularly if one age group, gender, race, etc. is required to perform the job function, but not others.

To avoid this from happening, document any temporary changes due to accommodations and clarify expectations with everyone. Be clear and consistent to support fairness across your organization.

7. Review Essential Functions Carefully

Job descriptions should always reflect real workplace requirements. When evaluating essential functions:

• Review current duties
• Observe actual workflows
• Consult supervisors and employees

Because the ADA focuses on whether an employee can perform the essential duties of a position, having accurate, up-to-date job descriptions will help you determine which tasks must be performed, and which duties may be flexible or reassigned. This will help ensure any accommodations will support the employee's ability to succeed without fundamentally altering the role and will also prevent inconsistent treatment among employees.

8. Collect Medical Information with Care and Respect

Adhering to the ADA when responding to a requested accommodation requires employers to have medical documentation about the employee. Although full details do not need to be shared, employers do need to know which major life activities are affected to help them proceed thoughtfully.

Your goal is simple: understand how to support the employee effectively without invading their privacy.

Best Practices for Medical Documentation

• Request only information related to job performance
• Avoid unnecessary details
• Use standardized forms
• Focus on functional limitations
• Maintain strict confidentiality

If additional clarification is required, follow up respectfully and professionally.

9. Respect Employee Confidentiality

Few people are on a need-to-know basis for an employee’s disability. Even managers should only know the nature of the accommodation being provided rather than details about the disability. When a disability affects how the manager needs to interact with the employee, such as a hearing impairment, then more information can be shared.

Remember: share only what is necessary to implement an accommodation. Focus discussions on job-related needs rather than medical details.

10. Consider Other Applicable Laws

Accommodation requests may overlap with other regulations, such as the Family and Medical Leave Act (FMLA) or similar state laws. Coordinate compliance to ensure employees receive appropriate support while you also keep your company protected.

It's also important to be aware of what could be perceived as disability discrimination. This occurs when an employer treats an employee unfavorably because of their medical condition (physical or mental), even if it's just the perception of a disability. Refusing to make accommodations, denying equal employment opportunities, or making employment decisions that are not based on an employee's actual abilities can end in a lawsuit.

The Value of the Interactive Process

The interactive process is the heart of ADA compliance and workplace inclusion. It involves:

• Listening
• Exploring options
• Testing solutions
• Making adjustments
• Re-evaluating such requests when needed

When handled well, this process strengthens work relationships and reinforces organizational values. Be sure to document each step for accountability and clarity.

Bottom Line: Turning Accommodation Requests into Opportunities

Accommodation requests should not be seen as obstacles, but as opportunities to invest in people. They often unlock an employee’s full potential and typically lead to higher productivity, increased loyalty, reduced turnover, and stronger morale.

For more information, please contact your certified HR expert. Not a current Stratus HR client? Book a consultation and our team will contact you shortly.