How to Conduct an ADA Accommodation Assessment

2/6/2026

The Americans with Disabilities Act (ADA) requires employers to provide reasonable accommodations for qualified employees with disabilities. At the heart of this legal duty lies a critical, and often misunderstood, procedure: the accommodation assessment. This assessment, formally known as the "interactive process," is more than just a conversation; it is a structured, good-faith dialogue intended to identify an effective accommodation that allows an employee to perform their job.

Getting this process right is paramount. A poorly conducted assessment can lead to ineffective accommodations, frustrated employees, and significant legal risk, including claims of discrimination and failure to accommodate. Conversely, a well-executed assessment process protects your organization from liability and fosters a culture of trust and inclusivity. It demonstrates a genuine commitment to supporting your employees.

This article provides a comprehensive, step-by-step guide on how to conduct a compliant and effective ADA accommodation assessment. We will walk through each phase of the interactive process, from the initial request to the final documentation, highlighting best practices and common mistakes to avoid. Mastering this process is a core skill taught in any quality ADA compliance training and is essential for every HR professional.

The Foundation: Understanding the Interactive Process

Before diving into the steps, it's crucial to understand the goal of the interactive process. It is a collaborative effort between the employer and the employee to determine if the employee has a disability-related limitation and, if so, to identify a reasonable accommodation that will address it. It is not an adversarial negotiation. The Equal Employment Opportunity Commission (EEOC) places immense importance on an employer's good-faith participation in this process. A failure to engage in it properly can be a violation in itself.

The assessment begins the moment an employer becomes aware that an employee may need an adjustment at work due to a medical condition. This awareness can come from a direct request or from a manager observing an employee's struggle. This is why ADA training for managers is so critical—it teaches them to recognize these triggers and initiate the process correctly.

A Step-by-Step Guide to the ADA Accommodation Assessment

A compliant assessment follows a structured, logical progression. Using an ADA compliance checklist can help ensure no step is missed.

Step 1: Recognize and Acknowledge the Request

The process begins when an employee requests an accommodation. The request does not need to be in writing or use the words "ADA" or "reasonable accommodation."

• What to Do: Train managers and supervisors to spot trigger phrases like, "My back is making it hard to sit for so long," or "I'm having trouble concentrating with all the noise." Once a potential need is identified, the manager's role is to acknowledge it supportively and immediately escalate it to HR. Acknowledge the employee's request promptly, letting them know the company takes it seriously and will begin the formal process.
• Mistake to Avoid: Ignoring the request or telling the employee to "tough it out." Another common error is when an untrained manager tries to solve the problem themselves with an informal, undocumented solution, which bypasses the compliant process.

Step 2: Gather Necessary Information (The Job and the Limitation)

Once HR receives the request, the fact-finding phase begins. Your goal is to understand two things: the essential functions of the employee's job and the specific limitations caused by their medical condition.

• What to Do:
1. Analyze the Job: Review the employee’s official job description, but don't stop there. Speak with the employee and their manager to understand the job's actual essential functions. How much time is spent on each task? What are the consequences if a task is not performed?
2. Request Medical Information (If Necessary): If the disability or the need for accommodation is not obvious, you are permitted to request reasonable medical documentation. This request should be a formal, written communication from HR. It should be limited to information that confirms the existence of a disability and clarifies the employee's specific limitations. The Job Accommodation Network (JAN) offers excellent templates for these requests.
• Mistake to Avoid: Asking for the employee's entire medical record or asking for a specific diagnosis. The focus should always be on the limitation and how it affects the employee's ability to perform their job, not on the underlying medical condition itself. This nuanced approach is a key topic in any ADA certification program.

Step 3: Explore and Assess Accommodation Options (The Interactive Dialogue)

This is the core of the interactive process. It is a collaborative brainstorming session with the employee to identify potential accommodations.

• What to Do: Schedule a meeting with the employee (and their manager, if appropriate) to discuss their ideas. The employee is often the best source of information about what might work. Come prepared with your own research and ideas. Consider a wide range of possibilities:
• Modifying the work environment: Providing an ergonomic chair, noise-canceling headphones, or better lighting.
• Modifying the job: Restructuring non-essential tasks or allowing flexible work hours.
• Providing equipment or technology: Supplying screen-reading software or a voice-to-text application.
• Reassignment: As a last resort, moving the employee to a vacant position for which they are qualified.
• Mistake to Avoid: Presenting a single, take-it-or-leave-it solution. The process must be interactive. Also, avoid dismissing an employee's suggestion out of hand. If a requested accommodation is not feasible, you must explain why and work to find an alternative.

Step 4: Choose and Implement the Accommodation

Once you have explored the options, the employer has the right to choose among effective accommodations. You are not obligated to provide the employee's preferred accommodation if another reasonable option is available and effective.

• What to Do: Select an accommodation that is effective in removing the workplace barrier and does not create an "undue hardship" for the organization. "Undue hardship" is a high legal bar, meaning a significant difficulty or expense. Once the accommodation is chosen, implement it promptly. Delays in implementation can be viewed as a failure to accommodate.
• Mistake to Avoid: Choosing a less expensive but ineffective accommodation. The chosen solution must work. Another error is failing to consider creative or low-cost solutions before claiming undue hardship. The entire assessment, including the evaluation of undue hardship, is a central part of any detailedAgenda/Table Of Contents/Course Outline for ADA training.

Step 5: Monitor and Document Everything

The process does not end with implementation. You must follow up to ensure the accommodation is working, and you must document every single step of the assessment.

• What to Do:
1. Follow-Up: Schedule a check-in with the employee a few weeks after implementation to see if the accommodation is effective. Be prepared to make adjustments if it's not working as intended.
2. Document: This is your most important legal defense. Keep detailed, confidential records of the entire process: the initial request, medical documentation received (stored separately from the personnel file), notes from the interactive dialogue, the decision-making process, and the final outcome.
• Mistake to Avoid: Having "off the record" conversations. Every interaction related to the accommodation request should be documented. A lack of documentation makes it your word against the employee's in a legal dispute.

Real-World Example: A Successful Assessment in a Remote Setting

The Scenario: A graphic designer working for a marketing agency, now part of their ADA compliance for remote teams initiative, informs her manager that she is developing severe wrist pain and her doctor has diagnosed it as carpal tunnel syndrome. She states that using a standard mouse and keyboard for eight hours a day is becoming impossible.

The Assessment Process:

1. Recognize & Acknowledge: The manager, having completed ADA training for managers, recognizes this as an accommodation request. He tells the employee, "Thank you for letting me know. I'm connecting you with HR right now so we can start the process of finding a solution."
2. Gather Information: The HR professional, who holds an ADA certification, sends the employee a request for medical documentation. The form asks the doctor to confirm the limitation (e.g., "difficulty with fine motor movements," "pain with repetitive wrist motion") and its expected duration.
3. Explore Options: In a video call, the HR professional and the employee discuss options. The employee mentions she has heard about vertical mice and ergonomic keyboards. The HR professional researches these and also suggests speech-to-text software for drafting emails and reports.
4. Choose & Implement: The company agrees to provide a vertical mouse and an ergonomic split keyboard. They order the equipment, and it is shipped directly to the employee’s home office. The total cost is under $200.
5. Monitor & Document: Two weeks later, the HR professional follows up. The employee reports a significant reduction in pain and is back to her normal productivity. The HR professional documents the entire process, from the initial email to the equipment purchase order and the follow-up notes.

This is a perfect example of a smooth, compliant, and effective accommodation assessment. It was handled professionally and resulted in a positive outcome for both the employee and the company. The complexity of these situations, especially when they overlap with leave laws, is why programs like theCertificate Program In FMLA & ADA Compliance are so valuable.

Conclusion: A Process that Protects and Empowers

Conducting a proper ADA accommodation assessment is one of the most important responsibilities of an HR professional. It is a process that requires a delicate balance of legal knowledge, empathy, and creative problem-solving. When done correctly, it does more than just satisfy a legal requirement; it builds trust, enhances employee engagement, and reinforces your organization's commitment to being an inclusive employer.

A structured, well-documented process is your best shield against legal liability. It creates a clear record of your good-faith efforts and your sound decision-making. By investing in ADA compliance training and instilling a consistent assessment methodology across your organization, you transform the ADA accommodation process from a source of legal anxiety into a powerful tool for retaining talent and building a better workplace for everyone.

If you are ready to master this critical skill and ensure your organization's assessment process is fully compliant, the next step is education.Contact Us For More Information to learn how our training programs can equip you with the knowledge and tools you need to succeed.