How to Document ADA Accommodation Requests

2/4/2026

In the administration of the Americans with Disabilities Act (ADA), few tasks are more critical than documentation. While engaging in the interactive process and exploring reasonable accommodations are the active components of ADA compliance, proper HR documentation is the bedrock that supports it all. In the event of a legal challenge, a well-documented record is often the single most important factor that distinguishes a legally defensible process from a costly compliance failure.

Many HR professionals understand the need to document, but they are often unsure about what to record, how to phrase it, and where to keep it. A casual note here and a stray email there are not enough. Effective documentation is a systematic practice that requires precision, consistency, and a deep understanding of the law. It is a skill that must be learned and honed.

This guide will provide clear, actionable best practices for documenting every stage of an ADA accommodation request. We will cover what to include, what to leave out, and why this meticulous record-keeping is your organization's most powerful tool for mitigating legal risk and ensuring fair, consistent treatment for all employees.

Why Meticulous Documentation is Non-Negotiable

Before diving into the "how," it's crucial to understand the "why." Proper documentation serves several vital functions:

1. It Creates a Legal Record: If an employee files a claim with the Equal Employment Opportunity Commission (EEOC) or pursues litigation, your documentation becomes your primary evidence. It provides a contemporaneous record that demonstrates you engaged in a good-faith interactive process, explored accommodations, and made decisions based on legitimate, non-discriminatory reasons. Without it, a legal dispute devolves into a "he said, she said" argument, which is difficult and expensive to defend.
2. It Ensures Consistency: A structured documentation process helps ensure that all accommodation requests are handled in a consistent manner across the organization. This consistency is critical for preventing claims of disparate treatment.
3. It Serves as a Roadmap: A well-kept record provides a clear history of the accommodation process for a specific employee. This is invaluable for managing long-term or intermittent accommodations, tracking what has been tried, and making informed decisions in the future.
4. It Clarifies Responsibilities: Documentation helps to clarify who is responsible for what actions and by when, keeping the interactive process moving forward and preventing requests from falling through the cracks.

In short, documentation is not just administrative busywork; it is a core risk management strategy.

Stage 1: Documenting the Initial Request

The clock starts ticking the moment an employee indicates they are having a problem at work due to a medical condition. Your documentation must start at this exact point.

What to Document:

• Date of the Request: Record the exact date the employee first raised the issue.
• Who Made the Request: Note the employee's name and title.
• How the Request Was Made: Was it in an email, during a formal meeting, or in a casual conversation with a manager?
• The Content of the Request: Capture the essence of what the employee said. Crucially, focus on the workplace problem, not the medical diagnosis.
• Good Example: "Employee Jane Doe stated that sitting for long periods is causing her severe back pain and that she is having trouble completing her 8-hour shift at her desk."
• Bad Example: "Jane told me her sciatica is acting up again."
• The Initial Response: Document the immediate next step. This should almost always be a variation of: "Thank you for letting me know. I will schedule a meeting with you to discuss this further and explore how we can support you. Please expect to hear from me by [Date]."

This initial entry creates a clear starting point and demonstrates the organization's immediate, good-faith response.

Stage 2: Documenting the Interactive Process

The interactive process is the ongoing dialogue between you and the employee. Every significant interaction must be memorialized. It's helpful to maintain a dedicated log or file for each accommodation request.

What to Document for Each Interaction:

• Date and Method of Communication: Note the date of every meeting, phone call, or email exchange.
• Attendees: List who participated in the conversation (e.g., HR professional, employee, manager).
• Topics Discussed: Summarize the key points of the conversation.
• What workplace barriers were identified by the employee?
• What potential accommodation solutions were brainstormed or suggested (by both the employee and the employer)?
• What medical documentation, if any, was requested?
• What were the agreed-upon next steps and deadlines?

A Word on Medical Documentation

This is a high-risk area. Your documentation should be precise and limited.

• Documenting the Request: Note that you provided the employee with a medical inquiry form and a deadline for its return. For example: "On 11/25/2025, provided John Smith with our standard ADA Medical Inquiry Form to be completed by his healthcare provider, with a return date of 12/10/2025. Explained that the purpose is to confirm the existence of a disability and to better understand his functional limitations at work."
• Storing the Information:Crucially, the completed medical form and any doctor's notes must NOT be kept in the employee's general personnel file. The ADA requires that all medical information be stored in a separate, confidential medical file with strictly limited access. Your documentation log can note that the information was received, but the medical records themselves live elsewhere.

The skills to manage these sensitive requests are a core part of advanced HR training. AnADA Training & Certification Program provides in-depth instruction on these critical compliance steps.

Stage 3: Documenting the Decision

Once you have gathered the necessary information and explored options, you must make a decision about the accommodation. This decision, and the rationale behind it, must be clearly documented.

If an Accommodation is Granted:

• The Specific Accommodation: Clearly describe the accommodation being provided (e.g., "Provision of an ergonomic chair, model XYZ," or "Approval of a modified schedule to work from 10 AM to 6 PM on Tuesdays and Thursdays").
• Date of Implementation: Note the date the accommodation will become effective.
• Follow-Up Plan: Document the plan to check in with the employee to ensure the accommodation is effective. For example: "Plan to meet with Jane Doe on 1/15/2026 to review the effectiveness of the new chair and determine if any adjustments are needed."
• Communicate in Writing: Send a formal letter or email to the employee summarizing the accommodation that has been approved. Save a copy of this communication in the accommodation file.

If an Accommodation is Denied:

This is the highest-risk documentation you will create, and it requires the utmost precision. You cannot simply say "no."

• The Specific Accommodation Requested: Clearly state the accommodation the employee asked for.
• The Reason for Denial: You must provide a legitimate, business-related reason for the denial. This usually falls into a few categories:
• Not Reasonable: Explain why the proposed solution is not reasonable (e.g., it would not enable the employee to perform the essential functions of their job).
• Undue Hardship: If this is the reason, you must document the specific analysis you conducted (e.g., "The request to hire a full-time assistant to read documents aloud was determined to be an undue hardship based on the significant cost relative to the department's $50,000 annual operating budget."). This defense is difficult to prove and requires robust documentation.
• Direct Threat: In rare cases, you might document that the accommodation would pose a direct threat to the health or safety of the employee or others.
• Alternative Accommodations Offered: A denial of a specific accommodation is not the end of the process. Your documentation must show that you offered other potential effective accommodations. For example: "While we could not approve the request to work from home 100% of the time due to the need for in-person client collaboration, we offered a hybrid schedule of 3 days remote/2 days in-office and the provision of a noise-canceling headset for in-office work."

This record proves that you continued to engage in the interactive process in good faith, even when you couldn't grant the employee's preferred option.

Ongoing Documentation and Maintenance

The process doesn't end once an accommodation is in place. Ongoing documentation is key to managing the relationship long-term.

• Follow-Up Meetings: Document all check-in meetings. Is the accommodation working? Does anything need to be adjusted?
• Reassessment: If the employee's condition or the job's essential functions change, document the process of reassessing the accommodation.
• Managing Integrated Leave: For complex situations involving FMLA, workers' compensation, and the ADA, meticulous documentation is even more vital. Understanding how to manage and document these overlapping leaves is a high-level skill, often taught in specialized courses like theCertificate Program for FMLA, ADA, and PWA Compliance.

What NOT to Document

What you exclude from your record is just as important as what you include. Your documentation should be objective, professional, and factual.

• Avoid Subjective Opinions: Do not include personal feelings, frustrations, or suspicions.
• Bad: "I don't really believe John needs this accommodation; I think he's just trying to get out of work."
• Good: "John requested an accommodation. We are proceeding with the interactive process and have requested medical documentation."
• Don't Guess at a Diagnosis: Stick to the functional limitations. Never write down your own medical theory about the employee's condition.
• Exclude Irrelevant Information: Keep the record focused strictly on the job-related limitations and the accommodation process. Personal details about the employee's family or social life do not belong in the file.

Conclusion: Documentation as Your Strategic Asset

Proper HR documentation of the ADA accommodation process is more than a best practice—it is an essential strategic function. It is your organization's memory, its proof of good faith, and its shield against legal liability. By creating a clear, consistent, and objective record of every step, you demonstrate a commitment to a fair and compliant process.

This level of meticulous record-keeping requires training and discipline. TheBenefits of Getting an HR Certification are particularly evident here, as a certified professional is trained to understand the nuances of what to record and how to phrase it to be both helpful internally and defensible externally. They learn to create a record that tells a story of compliance, collaboration, and respect.

Don't leave your organization's legal defense to chance or to a collection of scattered notes. Elevate your skills and build a rock-solid compliance foundation through expert training. Explore the comprehensiveADA Training & Certification Program to master the art and science of ADA documentation and transform your administrative process into a powerful strategic asset.