The ADA Interactive Process: Step-by-Step Conversation Scripts for Managers

6/2/2026

The interactive process is a conversation, and most ADA liability is created in the first ninety seconds of it — by a manager who did not know a request had just been made, or who said something that will be quoted in a charge.

This guide gives managers the actual words. Not principles, not policy language: scripts they can use in the moment, with the reasoning behind each one.

Quick answer: The interactive process is triggered whenever an employee indicates they need an adjustment at work for a medical reason — regardless of the words used. The manager's job is to recognize it, respond neutrally, escalate to HR, and document. The manager's job is not to evaluate, diagnose, or decide.

Step 0: Recognizing the Request

There are no magic words. The EEOC has been explicit that an employee need not mention the ADA, use the phrase "reasonable accommodation," or submit anything in writing. Any of these statements starts the process:

• "My back has been really bad — I'm having trouble with the lifting part of the job."
• "I've been having panic attacks in the morning meetings."
• "My doctor says I shouldn't be standing this long."
• "The fluorescent lights are triggering my migraines."
• "I'm going to need some time off for treatment, and I might need a lighter schedule after."
• "Is there any way I could work from home a couple of days? My condition has gotten worse."

A family member, a health professional, or another representative may also request an accommodation on the employee's behalf. Managers must be trained to treat any of these as a trigger.

Step 1: The First Response — Script

The goal here is narrow: acknowledge, do not evaluate, and route. Nothing else.

Say this:

"Thank you for telling me — I want to make sure we handle this properly. You don't have to share medical details with me. What I'd like to do is connect you with [HR contact name] today so we can look at what adjustments might work. In the meantime, is there anything you need right now to get through the rest of today safely?"

Why this works: it acknowledges the request (starting the clock on the employer's obligation), explicitly declines medical detail (avoiding an unlawful inquiry), routes to the trained decision-maker, and addresses immediate safety without committing to anything.

Never say:

What Managers Say	Why It Creates Liability
"What's wrong with you?" / "What's your diagnosis?"	Disability-related inquiry outside the permitted scope
"We don't do remote work here."	A denial before any analysis — and a blanket rule the ADA does not permit
"Everyone's dealing with something."	Reads as dismissal of a protected request; quoted in nearly every charge
"You need to be able to do the whole job."	Presumes the answer to the essential-functions analysis
"Let me see what I can do — don't mention it to HR."	Undocumented side arrangements are unenforceable and look like concealment
"Are you sure you can still handle this role?"	Suggests the request itself is evidence of inability — a direct route to a regarded-as claim

Step 2: The HR Intake Conversation — Script

This is the substantive first meeting, held by HR within a few business days.

"I appreciate you raising this. I want to understand what's getting in the way at work so we can find something that works. I don't need your diagnosis. What I do need to understand is: which parts of your job are difficult right now, and what happens when you try to do them?"

Follow-ups, in order:

35. "Which specific tasks or conditions are creating the difficulty?"
36. "Is this constant, or does it come and go? If it varies, roughly how often and for how long?"
37. "Have you thought about what adjustment might help? I want to hear your ideas first."
38. "Is this something you expect to be temporary, or ongoing?"
39. "Are there other parts of the job we haven't discussed that are also affected?"

Then close the meeting with a commitment and a timeline:

"Here's what happens next. I'm going to review the essential functions of your position against what you've described, and look at the options we discussed. I may ask you to have your health care provider complete a short form about your functional limitations — not your diagnosis. I'll get back to you by [specific date]. If anything changes before then, or if things get worse, tell me right away."

The specific date matters enormously. Undue delay is itself a form of ADA violation, and "we were looking into it" without a date is the most common failure pattern.

Step 3: Requesting Documentation — Script

Only request documentation when the disability or the need for accommodation is not obvious. When it is warranted:

"To move forward, I'd like to get some information from your health care provider. The form asks about your functional limitations and what adjustments would help — it does not ask for your diagnosis or your medical records. Please have it returned by [date, generally at least 15 days out]. If your provider needs more time, let me know and we'll work with it. This information goes into a confidential medical file, separate from your personnel file, and your supervisor will only be told what accommodation is approved — not why."

That last sentence resolves the single biggest source of employee resistance in this process.

Step 4: Evaluating Options — The Internal Analysis

Before the next conversation, HR should complete a written analysis:

Question	What to Document
What are the essential functions?	Current job description, actual time spent, consequence of not performing, whether the function is why the position exists
Which functions are affected?	Map each limitation to specific functions
What accommodations could work?	Employee's suggestion, provider's suggestion, HR's alternatives, and options from external resources such as the Job Accommodation Network
Is each effective?	Would it enable performance of the essential functions?
Is any an undue hardship?	Actual cost, operational impact, evidence — not assumption
Is reassignment available?	Vacant positions the employee is qualified for, if no accommodation works in the current role

Step 5: Delivering the Decision — Scripts

Approval

"We're approving [specific accommodation], effective [date]. Here's exactly how it will work: [details]. Your supervisor will be told about the arrangement, not about the medical basis. Let's plan to check in on [date] to see whether it's working. If it isn't, or if your needs change, come back to me — this isn't a one-time decision."

Approval of an alternative

"I want to explain where we landed. We weren't able to approve [requested accommodation] because [specific reason tied to essential functions or hardship]. What we can do is [alternative], which addresses [the limitation] in this way: [explanation]. I'd like to try this for [period] and reassess. If it isn't working for you, tell me — we'll keep looking."

Denial

"I want to be straightforward with you. After reviewing the essential functions of the position and the options available, we're not able to approve [request] because [specific, documented reason]. Here's what we considered and why each option didn't work: [walk through]. I want to keep this open — if your situation changes, or if you or your provider think of an option we haven't considered, come back to me. I'd also like to review whether there's a vacant position that might be a better fit."

Never deliver a denial without also documenting it in writing to the employee, and never deliver one without having considered reassignment.

Step 6: Follow-Up

The interactive process is ongoing, not a single event. Schedule a check-in 30 to 60 days after implementation, and again when circumstances change. An accommodation that stops being effective creates a renewed obligation.

Document every touchpoint. Our guides to documenting ADA accommodation requests and ADA documentation and recordkeeping cover the file structure.

The Manager's One-Page Rule

If your managers remember nothing else, give them this:

• Recognize: any mention of a medical reason for a work adjustment is a request.
• Respond: thank them, do not ask for details, do not promise or deny.
• Route: contact HR the same day.
• Record: write down the date, what was said, and what you did — and send it to HR.
• Respect: do not discuss it with the team, and do not treat the employee differently afterward.

Frequently Asked Questions

Does the employee have to put the request in writing?

No. Employers may document the request in writing themselves, but cannot require a written request as a precondition to starting the process.

How quickly must we respond?

There is no fixed deadline, but unreasonable delay can itself be a violation. A first substantive conversation within a few business days and a decision within a few weeks is a defensible cadence, with documented reasons for any longer timeline.

Can we ask for a second medical opinion?

An employer may seek clarification from the employee's provider and, in limited circumstances where documentation is insufficient, may request an examination by a provider of its choosing at its own expense. This should be handled with HR and counsel, not by a manager.

What if the employee refuses to provide documentation?

If documentation is reasonably needed and the employee refuses after being told why, the employer may generally deny the accommodation — but document the request, the explanation, and the refusal carefully first.

Can a manager grant an accommodation directly?

Small, immediate adjustments are often granted informally, and that is fine. But it must be reported to HR and documented, because informal accommodations create precedent and expectations that HR needs to know about.

Give Managers the Training, Not Just the Policy

Every organization has an accommodation policy. Very few have managers who can execute the first conversation correctly, and that conversation is where the case is won or lost.

The ADA Training & Certification Program covers the interactive process, essential-function analysis, documentation, and permissible inquiries in depth. For HR teams handling accommodation alongside leave and pregnancy accommodation, the Certificate Program in FMLA, ADA, and PWFA Compliance teaches all three together.

👉 See upcoming HR training seminars →

Additional resources: ADA Compliance FAQs | ADA Interactive Process: Step-by-Step for Employers | Glossary of ADA Terms | Job Accommodation Network