Understanding "Reasonable Accommodation" Under ADA

1/30/2026

The term "reasonable accommodation" is the heart of the Americans with Disabilities Act (ADA). It is the mechanism through which the law's promise of equal employment opportunity becomes a reality for millions of qualified individuals with disabilities. Yet, for many HR professionals and managers, it remains one of the most confusing and intimidating aspects of ADA compliance. What exactly makes an accommodation "reasonable"? Where does an employer's obligation begin and end?

Misunderstanding this core concept can lead to serious compliance failures, exposing an organization to significant workplace liability and violating fundamental employee rights under ADA. A clear and confident grasp of reasonable accommodation is not just a legal necessity; it's a managerial superpower that allows you to support your employees effectively while protecting your organization.

This comprehensive guide will demystify the concept of reasonable accommodation. We will define the term, provide extensive examples, explain its connection to the interactive process, and debunk common myths. By the end, you will have a practical framework for analyzing and implementing accommodations, a skill best sharpened through dedicated ADA compliance training.

What is a Reasonable Accommodation?

The Equal Employment Opportunity Commission (EEOC) defines a reasonable accommodation as any change or adjustment to a job, the work environment, or the way things are usually done that enables a qualified applicant or employee with a disability to participate in the application process, perform the essential functions of a job, or enjoy equal employment benefits and privileges.

Let's break down the key elements of this definition:

Any Change or Adjustment: This is intentionally broad. Accommodations are not limited to a pre-approved list. They can be physical changes, policy modifications, or adjustments to work schedules.
Qualified Applicant or Employee: The individual must meet the skill, experience, and other job-related requirements of the position and be able to perform the essential functions of the job, with or without an accommodation.
Essential Functions: These are the core, fundamental duties of the job. An employer is not required to eliminate an essential function as an accommodation, but may need to restructure non-essential or marginal duties.
Equal Employment Opportunity: The goal is to remove workplace barriers, allowing an employee with a disability to have the same opportunities as their non-disabled peers. It is about creating a level playing field, not an unfair advantage.

The "Undue Hardship" Limitation

An employer's obligation to provide an accommodation is not limitless. You are not required to provide an accommodation if doing so would cause an "undue hardship." This is a very high legal standard, defined as an action requiring significant difficulty or expense.

The determination of undue hardship is made on a case-by-case basis, considering factors like:

The nature and net cost of the accommodation.
The overall financial resources of the facility and the business.
The type of operations of the business.

An employer cannot simply claim undue hardship based on minor cost or inconvenience. A thorough, documented analysis is required to legally deny an accommodation on these grounds, a process thoroughly covered in advanced HR training programs.

Examples of Reasonable Accommodations

The concept of reasonable accommodation is best understood through examples. The possibilities are vast and depend on the employee's specific needs and job duties. Accommodations generally fall into three categories:

Changes to the job application process.
Changes to the work environment or the way a job is performed.
Changes that allow an employee to enjoy equal benefits and privileges of employment.

Here are some common examples across various categories:

Physical and Environmental Modifications

Making facilities accessible: Installing a ramp, modifying a restroom, widening doorways, or creating accessible parking spaces.
Workstation adjustments: Providing an ergonomic chair, a sit-stand desk, or an anti-fatigue mat for an employee with a back condition.
Moving to an accessible location: Relocating an employee's workspace to the ground floor or to a quieter area of the office.

Modified Work Schedules and Leave

Flexible hours: Allowing an employee who has a medical appointment or experiences morning fatigue from medication to adjust their start and end times.
Modified break schedules: Permitting more frequent but shorter breaks for an employee with diabetes to monitor blood sugar levels.
Additional unpaid leave: Granting leave beyond what is provided under the FMLA or company policy as an accommodation for treatment or recovery. This is a critical area where the ADA and FMLA intersect, making a solid understanding from anFMLA Training & Certification Program highly valuable.

Job Restructuring and Reassignment

Reallocating marginal functions: Swapping a non-essential duty, like occasional heavy lifting, with another employee. The essential functions of the job must remain.
Altering when or how a function is performed: Allowing an employee to complete a task at a different time of day or using a different method.
Reassignment to a vacant position: If an employee can no longer perform the essential functions of their current job even with an accommodation, the employer must consider reassigning them to a vacant position for which they are qualified. This is an accommodation of last resort.

Technology and Assistive Devices

For visual impairments: Providing screen-reading software, a larger monitor, or a document magnifier.
For hearing impairments: Supplying an amplified telephone, providing a sign language interpreter for meetings, or using captioning services for virtual calls.
For manual dexterity issues: Offering voice recognition software, a modified keyboard, or other ergonomic tools.

Policy Modifications

Allowing a service animal: Permitting a service animal in a workplace that typically has a "no pets" policy.
Modifying communication methods: Agreeing to provide instructions and feedback in writing for an employee with an auditory processing disorder.
Telework: Permitting an employee to work from home as a reasonable accommodation, a topic that has become central to modern ADA compliance for remote work.

This is not an exhaustive list. The key is to be creative and flexible, focusing on finding a solution that works for both the employee and the business.

The Interactive Process and Its Role

A reasonable accommodation is not found in a vacuum. It is identified through a mandatory, collaborative dialogue known as the ADA interactive process. This process is triggered whenever an employer is aware that an employee may need an accommodation due to a medical condition.

The interactive process is the vehicle for determining what, if any, reasonable accommodation can be provided. Its role is to:

Identify the Barrier: Clarify the specific limitations caused by the disability and how they are impacting the employee's ability to perform their job.
Brainstorm Solutions: Collaboratively explore potential accommodations that could remove the barrier. This should involve input from the employee, the manager, and HR.
Assess Feasibility: Evaluate the effectiveness and reasonableness of the proposed solutions, including conducting an undue hardship analysis if necessary.

A failure to engage in this process in good faith is a violation of the ADA, even if no accommodation was ultimately possible. Mastering the steps of the ADA interactive process is a core competency taught in any high-qualityADA Training & Certification Program.

Common Misconceptions About Reasonable Accommodation

Myths and misunderstandings about reasonable accommodation are a primary source of compliance errors and workplace liability. Let's debunk some of the most common ones.

Myth 1: An employer must provide the specific accommodation an employee requests.

Fact: The employer has the ultimate discretion to choose among effective accommodation options. While you must give consideration to the employee's preference, you are not required to provide it if another, less expensive or less burdensome accommodation is also effective. The key is that the chosen accommodation must successfully enable the employee to perform their essential job functions.

Myth 2: An accommodation is not reasonable if it costs any money.

Fact: This is false. There is no "zero-cost" requirement. Many accommodations are free, but an employer is expected to bear some cost as long as it does not rise to the level of an "undue hardship." Studies from the Job Accommodation Network (JAN) consistently show that the majority of accommodations cost less than $500, with many costing nothing at all.

Myth 3: If an employee can't do one part of their job, they are not qualified and no accommodation is needed.

Fact: This depends entirely on whether that part of the job is an "essential" or "marginal" function. The ADA specifically anticipates that reallocating non-essential (marginal) functions may be a form of reasonable accommodation. You cannot disqualify an employee if the only barrier is a marginal duty that could be removed or reassigned.

Myth 4: Providing an accommodation for one employee means I have to provide the same for everyone who asks.

Fact: Accommodations are, by their nature, highly individualized. Providing a specific accommodation to one employee does not set a binding precedent for all others. Each request must be evaluated on its own merits, considering the specific employee's disability, their job functions, and the operational needs of the business at that time. What is reasonable for one may not be for another.

Myth 5: An employer does not have to provide an accommodation if it violates a uniformly applied company policy.

Fact: Modifying a company policy is a recognized form of reasonable accommodation. For example, you may need to make an exception to a "no animals in the office" policy to allow a service animal, or make an exception to a rigid attendance policy to allow for a flexible schedule. The question is not whether it violates a policy, but whether making an exception would cause an undue hardship.

Debunking these myths is a primary goal of effective ADA compliance training, as it helps shift the organizational mindset from "can we say no?" to "how can we find a solution?".

Conclusion

Understanding reasonable accommodation is the cornerstone of effective ADA administration. It is a concept rooted in flexibility, creativity, and collaboration. It requires employers to move beyond rigid policies and one-size-fits-all thinking, and instead engage in an individualized, good-faith effort to find solutions that work.

By grasping the definition, exploring the wide range of potential accommodations, and committing to the ADA interactive process, you can fulfill your legal obligations and support your employees. This proactive approach not only shields your organization from workplace liability but also builds a more inclusive, supportive, and productive environment where all employees have the opportunity to contribute their talents.

The nuances of this topic can be complex, and the stakes are high. Investing in specialized HR training programs is the best way to ensure that your team has the confidence and competence to handle accommodation requests correctly every time, upholding both the letter and the spirit of the law.