Common Misconceptions About ADA Requirements

2/4/2026

The Americans with Disabilities Act (ADA) is one of the most significant employment laws in the United States, yet it remains one of the most misunderstood. Decades after its passage, a host of myths and misconceptions continue to circulate, causing confusion for both employers and employees. These misunderstandings are not just academic; they can lead to serious compliance failures, resulting in costly legal battles and damaged workplace morale.

For HR professionals, separating fact from fiction is essential for effective ADA compliance. Relying on outdated information or workplace myths can lead to discriminatory practices, failure to provide necessary accommodations, and significant legal risk. The only way to navigate the complexities of the ADA is with accurate, up-to-date knowledge.

This guide will tackle some of the most common misconceptions about ADA requirements. By debunking these myths with factual information, we aim to provide clarity and empower HR professionals to manage their responsibilities with confidence and precision.

Myth #1: A Condition Isn't a "Disability" if It's Not Permanent or Severe

One of the most persistent misconceptions is that the ADA only applies to individuals with severe, permanent, or obvious disabilities, like someone who uses a wheelchair or is blind. Many believe that temporary injuries, manageable chronic conditions, or mental health issues don't qualify for protection.

The Reality: The Definition of Disability is Broad and Inclusive

This belief is fundamentally incorrect, especially after the ADA Amendments Act of 2008 (ADAAA), which was specifically passed to broaden the definition of disability. The law now protects a wide range of conditions.

• Substantially Limiting: A condition qualifies as a disability if it "substantially limits" one or more "major life activities." This is not an impossibly high standard. Major life activities include everything from walking, talking, and breathing to less visible functions like thinking, concentrating, and the operation of major bodily systems (e.g., the immune system, digestive system, or neurological functions).
• Episodic and Remission-Based Conditions: A condition that is episodic or in remission (like epilepsy, PTSD, or certain forms of cancer) is considered a disability if it would substantially limit a major life activity when active.
• Temporary Conditions: While minor, short-term ailments like the common cold or a sprained ankle are typically not considered disabilities, more significant temporary conditions can be. A broken leg that severely restricts walking for several months, for example, could qualify as a disability under the ADA, requiring an employer to consider reasonable accommodations.
• Mitigating Measures Don't Disqualify: The determination of whether an impairment is a disability must be made without regard to the positive effects of "mitigating measures." For instance, an individual with diabetes whose condition is well-managed with insulin is still considered to have a disability, because without the medication, their bodily functions would be substantially limited. The same applies to hearing aids, prosthetics, and psychiatric medications.

The takeaway for HR: Never dismiss an employee's condition out of hand. The legal definition of disability is intentionally broad. Proper HR training teaches that the focus should be less on diagnosing the condition and more on engaging in the interactive process to address the employee's limitations.

Myth #2: An Employee Must Use the Words "ADA" or "Reasonable Accommodation" to Make a Request

Many managers and HR professionals operate under the mistaken belief that their obligation to provide an accommodation only begins when an employee submits a formal, written request using specific legal terminology. They wait for the magic words, and if they never hear them, they assume they have no duty to act.

The Reality: A Request Can Be Simple, Informal, and Indirect

This is a dangerous misconception that leads to countless "failure to accommodate" claims. The law is clear that an employee's request for an accommodation can be plain and simple.

An employee does not need to be an expert in employment law to receive protection. The following are all examples of valid accommodation requests that trigger the employer's duty to begin the interactive process:

• An employee tells their manager, "My new medication is making it hard for me to focus in the mornings."
• An employee provides a doctor's note that says they need to avoid lifting more than 15 pounds.
• An employee emails HR saying, "I'm having trouble getting to work on time because of my physical therapy appointments."

A core component of anADA Training & Certification Program is learning to recognize these triggers. A trained professional knows that any time an employee indicates that a medical condition is causing a barrier at work, it's time to start the conversation. Waiting for a formal request is not a valid legal defense.

Myth #3: Reasonable Accommodations Are Always Expensive and Difficult

Many employers fear the reasonable accommodation process because they envision costly renovations, expensive high-tech equipment, or major disruptions to their business operations. This fear can cause them to deny requests prematurely or resist the interactive process altogether.

The Reality: Most Accommodations Are Free or Low-Cost

Studies by the Job Accommodation Network (JAN), a leading source of guidance on workplace accommodations, have consistently shown that the vast majority of accommodations are inexpensive to implement.

• According to JAN, more than half of all accommodations cost nothing at all. These often involve simple changes to policies or procedures, such as offering a flexible work schedule, modifying a supervisory method, or reallocating a marginal job duty.
• For accommodations that do have a cost, the typical one-time expenditure is around $500.

Examples of common, low-cost accommodations include:

• Providing an ergonomic chair or keyboard.
• Allowing an employee with anxiety to bring a support animal to work.
• Granting unpaid leave for medical treatment.
• Providing a quiet workspace for an employee who is easily distracted.

The fear of high costs is largely unfounded. A key aspect of ADA compliance is approaching each request with an open mind and focusing on finding a practical, effective solution, rather than assuming it will be an undue burden.

Myth #4: If an Employee Can't Do Their Original Job, The Employer Has No Further Obligation

A common scenario involves an employee who, due to a disability, can no longer perform one or more essential functions of their current role, even with an accommodation. Many employers believe this is the end of the road and that they can move directly to termination.

The Reality: Reassignment is the Accommodation of Last Resort

This belief overlooks a critical step in the accommodation process: reassignment. If an employee is unable to be accommodated in their current position, the ADA requires the employer to consider reassigning them to a vacant position for which they are qualified.

This is not an obligation to create a new job or to bump another employee out of their position. The requirements for reassignment are specific:

1. The Position Must Be Vacant: The employer must look for currently open positions or those they anticipate will become open in the near future.
2. The Employee Must Be Qualified: The employee must have the necessary skills, experience, and education to perform the essential functions of the new role, with or without an accommodation.
3. Equivalent Position: The employer should first look for a vacant position that is equivalent in terms of pay, status, and benefits. If one is not available, they must look for a vacant position at a lower level. The employer is not required to promote the employee as an accommodation.

Failing to consider reassignment before terminating an employee is a major compliance error and a frequent source of ADA litigation.

Myth #5: An Employer Can Terminate an Employee Who Has Exhausted Their FMLA Leave

The intersection of the ADA and the Family and Medical Leave Act (FMLA) is a minefield of misconceptions. Perhaps the most dangerous myth is that an employer's obligations end once an employee has used up their 12 weeks of FMLA leave. Many employers have policies that automatically terminate any employee who cannot return to work the day their FMLA leave expires.

The Reality: The ADA May Require Additional Leave as a Reasonable Accommodation

These "automatic termination" policies are illegal and have been the subject of major enforcement actions by the Equal Employment Opportunity Commission (EEOC). The end of an employee's FMLA leave is a critical trigger for an ADA analysis.

The law requires that if an employee still cannot return to work, the employer must treat their request for more time off as a request for a reasonable accommodation. This means the employer must:

1. Engage in the interactive process.
2. Determine if a finite period of additional unpaid leave would allow the employee to eventually return.
3. Grant the leave unless doing so would cause an undue hardship on the business.

Mastering the interplay between these laws is a crucial skill. It's a key reason why many professionals pursue aCertificate Program for FMLA, ADA, and PWA Compliance to gain specialized expertise in this high-risk area.

Myth #6: The ADA Requires Employers to Lower Performance Standards

Some managers worry that the ADA will force them to accept subpar performance from an employee with a disability. They believe they cannot hold these employees to the same standards as everyone else, which could be unfair to the rest of the team.

The Reality: The ADA Requires Equal Opportunity, Not Lowered Expectations

This is a fundamental misunderstanding of the law. The ADA does not require an employer to lower its quality or quantity standards for production. An employer has the right to expect all employees to perform the essential functions of their job and meet established performance metrics.

The purpose of a reasonable accommodation is to provide an employee with a disability with an equal opportunity to meet those standards. It is about removing workplace barriers, not eliminating expectations.

For example:

• If a salesperson is expected to make 50 calls a day, that standard applies to everyone. An employee with anxiety is not excused from this standard. However, an accommodation might involve providing them with a quieter workspace to help them concentrate and meet that goal.
• If a writer is expected to produce error-free copy, an employee with dyslexia is not exempt. An accommodation might be providing them with text-to-speech software to help them proofread their work and meet the quality standard.

Holding all employees to the same essential standards is not discriminatory; in fact, it is a key part of fair and equal treatment.

Conclusion: Replace Myths with Certified Knowledge

Navigating the landscape of ADA requirements based on hearsay, outdated practices, or workplace myths is a recipe for disaster. The law is too complex, and the stakes are too high. The only effective strategy is to build a foundation of accurate, expert knowledge.

By understanding the reality behind these common misconceptions, HR professionals can make informed, compliant decisions. They can foster a culture of workplace accessibility, build trust with employees, and protect their organizations from significant legal risk. TheBenefits of Getting an HR Certification in a specialized area like the ADA are immense, as it replaces uncertainty with confidence and transforms the HR function into a strategic asset.

Don't let myths dictate your compliance strategy. If you are ready to move beyond misconceptions and become a true expert in ADA administration, the best path forward is through professional education. Explore a comprehensiveADA Training & Certification Program to gain the skills and validated expertise needed to navigate the ADA with precision and integrity.