ADA and Job Descriptions: What to Include

10/23/2025

A job description is more than a hiring tool; it’s a cornerstone of your compliance framework under the Americans with Disabilities Act (ADA). When written correctly, it serves as a clear, objective guide for hiring, managing performance, and engaging in the reasonable accommodation process. When written poorly, it can become a source of legal risk, creating confusion and potential discrimination claims.

For HR professionals, compliance officers, and ADA coordinators, mastering the art of the ADA-compliant job description is not optional. This guide will walk you through everything you need to know, from defining essential functions to integrating job descriptions into your medical and return-to-work processes. We will explore how robust ADA compliance training can empower your team to create documentation that is both practical and legally sound.

Why Job Descriptions Matter for ADA Compliance

Under the ADA, a job description is a key piece of evidence that helps define the fundamental duties of a position. It provides a written record of an employer's judgment about what is essential for a particular role. This documentation becomes critical when determining if an applicant or employee with a disability is "qualified" and when exploring potential reasonable accommodations.

A well-crafted job description helps protect your organization by providing a clear, consistent, and defensible basis for employment decisions. It shifts the focus from an individual’s limitations to their ability to perform the core functions of the job, with or without accommodation.

How the ADA Defines “Essential Job Functions”

The ADA does not require employers to create job descriptions, but if you do, they are considered evidence of essential functions. The Equal Employment Opportunity Commission (EEOC) states that essential functions are the fundamental, not marginal, duties of a job. A function may be essential for several reasons:

• The position exists to perform that function. For example, the essential function of a pilot is to fly a plane.
• A limited number of employees are available to perform the function. A highly specialized task performed by only one person on a team would be essential.
• The function is highly specialized. The incumbent is hired for their expertise or ability to perform that particular function.

Failing to correctly identify these ADA essential job functions can lead to significant compliance gaps. Your job description should clearly distinguish between these core duties and any marginal tasks that could potentially be reassigned.

The Connection Between Job Descriptions and Reasonable Accommodation

The reasonable accommodation process is at the heart of the ADA. It is the interactive dialogue between an employer and an employee to identify a modification or adjustment that enables the employee to perform the essential functions of their job. A clear job description is the roadmap for this conversation.

Without a documented list of essential functions, it becomes difficult to determine what accommodations are necessary or effective. The job description allows you to:

1. Identify Barriers: Pinpoint which specific essential functions are affected by the employee's disability.
2. Explore Solutions: Brainstorm accommodations that directly address those barriers (e.g., modified equipment, flexible schedules, reassignment of marginal tasks).
3. Assess Undue Hardship: Determine if a proposed accommodation would pose a significant difficulty or expense, making it an undue hardship.

A precise job description keeps the interactive process focused and productive, ensuring that both parties are working from the same set of expectations.

How ADA Compliance Training Helps Employers Avoid Mistakes

Understanding the nuances of ADA compliance isn't intuitive. It requires specific knowledge of legal requirements, documentation standards, and interactive process protocols. This is where ADA compliance training becomes invaluable for employers.

Effective training programs equip HR staff and managers with the skills to:

• Analyze jobs to accurately identify essential versus marginal functions.
• Write clear, objective, and non-discriminatory job descriptions.
• Use job descriptions effectively during the hiring, accommodation, and return-to-work processes.
• Avoid common legal pitfalls that can lead to discrimination claims.

Investing in an ADA compliance training program is a proactive step toward building a legally defensible and inclusive workplace culture. It ensures that everyone involved in personnel management understands their obligations under the law.

What Employers Must Include in ADA-Compliant Job Descriptions

Creating a job description that stands up to legal scrutiny requires careful attention to detail. It should be a comprehensive document that provides a full picture of the role and its requirements. Here are the key components to include.

Essential Job Duties and Core Responsibilities

This is the most critical section for ADA job description requirements. List the primary responsibilities that are fundamental to the position. Instead of a long, unorganized list of tasks, group them logically and prioritize them by importance or time spent.

Employer Checklist: Defining Essential Functions

• Does the position exist primarily to perform this function?
• Would removing this function fundamentally change the job?
• Is this a highly specialized task?
• Do other employees have the capacity to perform this function if it were reassigned?
• What are the consequences if this function is not performed?

For each function, use action verbs and focus on the outcome. For example, instead of "Makes phone calls," use "Communicates with clients via telephone to resolve service issues."

Required Skills, Qualifications, and Physical Requirements

This section outlines the necessary qualifications an individual must possess to perform the essential functions. This includes education, certifications, experience, and specific skills. When it comes to physical requirements, be cautious and specific.

Any physical ability standards must be directly tied to an essential job function. Avoid generic or overly broad statements like "must be in good physical condition." Instead, describe the actual task.

Example: Physical Requirement

• Poor: Must be able to lift heavy objects.
• Better: Must be able to lift and move 50-pound boxes of inventory from the stockroom to the sales floor, up to 10 times per shift.

This level of detail is crucial for assessing accommodation requests and complying with ADA medical examination rules.

Environmental and Safety Conditions

Describe the work environment where the job is performed. This information is vital for an employee and their healthcare provider to understand the context of the job and any potential triggers or hazards.

Include details such as:

• Exposure to extreme temperatures (heat or cold).
• Noise levels (e.g., "works in a loud manufacturing environment requiring hearing protection").
• Exposure to chemicals, dust, or other potential irritants.
• The pace of work (e.g., "fast-paced environment with frequent deadlines").
• Whether the job is performed indoors, outdoors, or in a vehicle.

This information helps set realistic expectations and informs discussions about potential job accommodations related to the workplace environment.

Performance Standards and Expected Outcomes

How will you measure success in this role? This section should define the expected quality, quantity, and timeliness of work. Clear performance standards help managers evaluate all employees consistently and provide an objective basis for performance reviews.

From an ADA perspective, these standards help determine if an employee with a disability is meeting the job requirements, with or without accommodation.

Example: Performance Standard

• For a customer service role: "Responds to all customer inquiries within 24 hours and achieves a customer satisfaction rating of 90% or higher."

Documenting these expectations in the job description reinforces that performance, not disability, is the metric for success.

Using Job Descriptions in the ADA Medical and Return-to-Work Process

A well-written job description is an indispensable tool when managing employee medical leave and planning for a safe return to work. It provides objective information that helps healthcare providers make informed assessments about an employee's ability to perform their job.

Providing Job Descriptions to Health Care Providers

When an employee is on leave for a medical condition, communication with their healthcare provider is key. The employer may require that the individual undergo a medical assessment and should provide the health care provider with a written job description that includes the essential functions of the position.

This step is not just a best practice; it is a critical component of your ADA documentation requirements. Employers should provide written job descriptions to health care providers conducting the examinations. This will assist the health care provider in determining whether the employee can return to work and whether there will be any functional limitations or restrictions on the employee’s ability to do the job. It ensures the provider is evaluating the employee against the actual demands of the job, not a generic understanding of their role.

How Job Descriptions Support Medical Assessments

A detailed job description allows a healthcare provider to conduct a targeted, job-related medical assessment. Instead of simply clearing an employee to "return to work," the provider can offer specific guidance on the employee's capabilities.

For example, a provider might state that an employee can perform all essential functions except for "lifting over 25 pounds." This specific information gives the employer a clear starting point for the interactive process. Without the job description, the provider’s note might be too vague to be useful, leading to delays and confusion in the ADA return-to-work policy.

Coordinating Job Descriptions with Reasonable Accommodation Discussions

Once you receive a medical note with specific restrictions, the job description becomes your guide for the interactive process. You can sit down with the employee and review the essential functions one by one to determine where accommodations are needed.

Sample Dialogue Opener:
"Thank you for providing the note from your doctor. Let's look at your job description together. The note says you have a restriction on frequent keyboarding. One of your essential functions is 'documenting client interactions in the CRM system.' Let's brainstorm some ways we might be able to accomplish this, such as using voice-to-text software or providing an ergonomic keyboard."

This approach keeps the conversation focused, collaborative, and compliant with the reasonable accommodation process.

How to Write Job Descriptions That Support ADA Compliance

Writing a job description is both a science and an art. It requires precision, objectivity, and a focus on what truly matters for the role. Following these guidelines will help you create documents that are clear, legally defensible, and effective.

Focus on Outcomes, Not Just Physical Tasks

One of the most important principles of writing an ADA-compliant job description is to focus on the results or outcomes of a task, not necessarily the method used to achieve it. This opens the door for reasonable accommodations.

• Method-Based: "Types reports using a keyboard."
• Outcome-Based: "Prepares accurate and timely reports by inputting, transcribing, and compiling data."

The outcome-based description allows for alternative methods, such as using voice recognition software, which could be a reasonable accommodation. This approach ensures you are evaluating an individual's ability to achieve the job's objective, not their ability to perform a task in one specific way.

Use Clear, Objective Language

Your job description should be free of jargon, acronyms, and subjective or ambiguous language. Vague terms like "works well under pressure" or "is a team player" are difficult to measure and can be interpreted in discriminatory ways.

Instead, use clear, observable, and measurable terms.

• Subjective: "Must have excellent communication skills."
• Objective: "Clearly communicates complex technical information to both technical and non-technical audiences in written and oral formats."

Objective language provides a solid foundation for hiring decisions, performance evaluations, and accommodation discussions, minimizing the risk of bias.

Review and Update Descriptions Regularly

A job description is a living document. Jobs evolve, technology changes, and business needs shift. An outdated job description is not just unhelpful; it can be a significant liability. If a key function has changed but the description hasn't been updated, your legal defense in an ADA case could be weakened.

Employer Checklist: Job Description Review

• Review all job descriptions at least once a year.
• Update descriptions whenever a job's essential functions change significantly.
• Involve the current job holder and their supervisor in the review process to ensure accuracy.
• Date each revision to maintain a clear history of the role.

This practice is a fundamental part of any effective ADA compliance checklist.

Common Mistakes Employers Make with ADA Job Descriptions

Even with the best intentions, employers can make critical errors in their job descriptions that create legal vulnerabilities. Awareness of these common mistakes is the first step toward avoiding them.

Failing to Define Essential Job Functions

Perhaps the most common and damaging mistake is not clearly distinguishing between essential and marginal duties. If all tasks are listed as a single block of text, it becomes difficult to argue which ones are truly fundamental. This ambiguity can force an employer to accommodate tasks that could have been reassigned, or it could lead to a claim that an employee was wrongly terminated for being unable to perform a non-essential task.

Overemphasizing Physical Requirements Without Justification

Including a long list of strenuous physical requirements that are not directly tied to the job's essential functions is a major red flag. For example, requiring an office worker to be able to lift 50 pounds "just in case" is likely to be seen as discriminatory. Every physical requirement must have a clear business necessity and be directly linked to performing an essential duty of the job.

Not Updating Descriptions After Workplace Changes

When a new piece of technology is introduced, a team is restructured, or a business process is updated, the essential functions of a job can change. Many employers create a job description when a position is first opened and then file it away, never to be seen again. This neglect can render the document useless in an ADA context. An outdated description may not accurately reflect the job, undermining its value as evidence.

Best Practices for Aligning Job Descriptions with ADA Compliance

Building a compliant framework goes beyond just writing good job descriptions. It involves creating integrated processes and fostering a culture of collaboration and documentation.

Collaborating with HR, Legal, and Supervisors

The best job descriptions are not written in a vacuum. The process should be a collaborative effort between HR, the direct supervisor, and in some cases, legal counsel.

• Supervisors have the best firsthand knowledge of a job's day-to-day duties.
• HR Professionals bring expertise in job analysis and compliance requirements.
• Legal Counsel can review descriptions for potential risks and ensure they align with current case law and regulations.

This team-based approach ensures that job descriptions are both operationally accurate and legally sound.

Documenting the Interactive and Accommodation Process

Your ADA documentation requirements extend beyond the job description itself. It is crucial to document every step of the interactive process, from the initial accommodation request to the final decision. Keep detailed records of all meetings, conversations, medical information received, accommodations explored, and the rationale for the chosen solution.

This documentation, paired with a strong job description, creates a powerful defense against potential discrimination claims. It demonstrates a good-faith effort to comply with the ADA.

Integrating Job Descriptions into Your ADA Compliance Program

Job descriptions should be a central component of your overall ADA compliance program. They should be used consistently in:

• Recruiting and hiring.
• Onboarding and training.
• Performance management.
• The reasonable accommodation process.
• Leave management and return-to-work planning.

When job descriptions are woven into the fabric of your HR practices, they become a powerful tool for promoting consistency, fairness, and compliance.

How ADA Compliance Training Supports Accurate Job Descriptions

A policy is only as good as its implementation. Providing comprehensive ADA compliance training to your staff is the most effective way to ensure your job descriptions and related processes are managed correctly.

Training HR Staff on Essential Function Analysis

HR professionals need specialized training to learn how to properly conduct a job analysis and distinguish essential from marginal functions. This is a nuanced skill that involves looking at the position from multiple angles, including the employer's judgment, written descriptions, time spent on tasks, and the consequences of not performing them. An ADA training for HR program provides the tools and frameworks needed to perform this analysis accurately and defensibly.

Teaching Supervisors to Recognize Accommodation Needs Early

Supervisors are often the first to know when an employee is struggling with a job task due to a medical condition. ADA compliance training teaches them to recognize the signs of a potential accommodation need and to know when to escalate the situation to HR. A supervisor who understands the ADA is less likely to make a snap judgment or an inappropriate comment, and more likely to initiate the interactive process correctly.

Strengthening Your ADA Policy Through Continuous Training

The legal landscape is constantly evolving. What was considered a best practice five years ago may be outdated today. Continuous training ensures that your team stays current on new regulations, court decisions, and EEOC guidance. A commitment to ongoing education strengthens your entire ADA compliance policy and reduces your organization's risk profile over the long term.

Integrating Job Descriptions with FMLA and Return-to-Work Policies

The ADA rarely exists in isolation. It often overlaps with other leave laws, such as the Family and Medical Leave Act (FMLA) and state Workers' Compensation laws. A clear job description is essential for navigating these complex interactions.

How ADA, FMLA, and Workers’ Compensation Overlap

When an employee has a serious health condition that is also a disability, they may have rights under both the FMLA and the ADA. The FMLA provides up to 12 weeks of job-protected leave, while the ADA may require additional leave as a reasonable accommodation.

A job description helps manage this overlap. For example, during FMLA leave, an employer cannot require an employee to accept a light-duty position. However, after FMLA is exhausted, the job description helps determine if a modified or light-duty role could be a reasonable accommodation under the ADA. Understanding ADA FMLA coordination is crucial for compliance.

What to Include When Requesting a Return-to-Work Note

When an employee is ready to return from leave, your communication with their healthcare provider is paramount. When requesting a return-to-work note from the employee’s health care provider, the employer should provide a copy of the job description and ask that the provider indicate whether the employee can return-to-work, with or without reasonable accommodations.

Template: Request for Return-to-Work Information

"Attached is the job description for [Employee Name]'s position as a [Job Title]. Please review the essential functions, physical requirements, and environmental conditions. Based on your assessment, please indicate on the return-to-work form whether the employee:

1. Can return to work without any restrictions.
2. Can return to work with the temporary or permanent restrictions listed.
   Please be as specific as possible regarding any functional limitations so we can determine if reasonable accommodations are available."

This practice provides the clear, job-related information you need to manage the ADA return-to-work policy effectively and compliantly.

Final Takeaways for Employers

The Americans with Disabilities Act requires a thoughtful and systematic approach to personnel management. At the center of this system is the humble job description—a document with the power to either support or undermine your entire compliance effort.

Why Clear Job Descriptions Are Critical for ADA Compliance

Clear, accurate, and up-to-date job descriptions are your first line of defense in managing ADA compliance. They provide the objective foundation for making non-discriminatory employment decisions, engaging in a productive interactive process, and safely returning employees to work. They are not administrative paperwork; they are critical risk management tools.

Investing in ADA Training to Strengthen Your Compliance Framework

You cannot expect your team to navigate the complexities of the ADA without proper guidance. Investing in a high-quality ADA compliance training program empowers your HR staff and managers with the knowledge and confidence to handle sensitive situations correctly. It is one of the most effective investments you can make in building a fair, inclusive, and legally resilient workplace.