How to Evaluate ADA Accommodation Requests

1/30/2026

For any Human Resources professional, handling an employee's request for an accommodation under the Americans with Disabilities Act (ADA) is a moment that demands both empathy and legal precision. The process of evaluating ADA accommodation requests is one of the most critical functions of HR, as a misstep can lead to significant workplace liability, erode employee trust, and result in a failure to uphold fundamental employee rights under ADA. Getting this evaluation right is not just about following rules; it's about finding practical solutions that allow valued employees to continue contributing to the organization.

Many employers feel a sense of uncertainty when an accommodation request lands on their desk. What defines a "reasonable" request? How much information can you ask for? What if the requested solution seems impractical? This uncertainty often leads to paralysis or poor decision-making, both of which can have serious consequences.

This guide provides a clear, structured framework for evaluating ADA accommodation requests. We will break down the definition of reasonable accommodation, walk through the key evaluative steps, highlight common mistakes to avoid, and underscore the vital role of documentation. Mastering this process is a cornerstone of effective management and is a skill best honed through dedicated ADA compliance training.

Understanding Reasonable Accommodation

Before you can evaluate a request, you must have a firm grasp of what a "reasonable accommodation" is under the law. The Equal Employment Opportunity Commission (EEOC) defines it as any change in the work environment or in the way things are customarily done that enables a qualified applicant or employee with a disability to enjoy equal employment opportunity.

This broad definition can encompass a wide range of modifications. A key principle is that the accommodation must be effective in removing a workplace barrier. However, there are limits. An employer is not required to provide an accommodation that would impose an "undue hardship" on the operation of the business.

What Constitutes "Reasonable"?

• Effectiveness: The accommodation must be likely to help the employee perform the essential functions of their job.
• Feasibility: It must be plausible and possible to implement in the specific work environment.
• Examples: Common reasonable accommodations include modifying work schedules, providing assistive technology, restructuring non-essential job duties, or allowing an employee to work from home.

The "Undue Hardship" Exception

An employer can deny an accommodation if it would cause significant difficulty or expense. This is a very high legal standard and is not easy to prove. The determination is made on a case-by-case basis, considering:

• The nature and cost of the accommodation.
• The employer's overall financial resources.
• The size of the business and the number of employees.
• The impact of the accommodation on the facility's operations.

Claiming undue hardship without a thorough, well-documented analysis is a significant legal risk. Comprehensive HR training programs are essential for teaching leaders how to properly conduct and document this assessment.

Key Steps in Evaluating Accommodation Requests

A structured evaluation process ensures that every request is handled fairly, consistently, and in compliance with the ADA. This process should be integrated with the mandatory interactive dialogue between the employer and employee.

Step 1: Acknowledge the Request and Begin the Interactive Process

The evaluation begins the moment you recognize an employee needs help due to a medical condition.

• Action: Promptly acknowledge the employee's request in writing. This confirms you have received it and are taking it seriously.
• Initiate Dialogue: Explain that the company will engage in the interactive process to explore solutions. This sets a collaborative tone from the start. A manager's first response should not be "yes" or "no," but rather, "Thank you for bringing this to my attention. Let's talk about it."

Step 2: Determine if the Employee is a "Qualified Individual with a Disability"

To be eligible for an accommodation, the employee must meet two criteria under the ADA:

1. Have a Disability: The employee must have a physical or mental impairment that substantially limits one or more major life activities, have a record of such an impairment, or be regarded as having one.
2. Be "Qualified": The employee must possess the requisite skills, experience, and education for the job and be able to perform the essential functions of the position, with or without an accommodation.

To make this determination, you may need to gather medical information. You can request documentation from a healthcare provider that confirms the disability and explains the functional limitations. It's crucial to use a targeted certification form that doesn't ask for a broad medical history.

Step 3: Identify the Essential Functions of the Job

You cannot evaluate whether an accommodation is necessary or effective without a clear understanding of the job's core duties.

• Action: Review the employee's job description. A well-written, up-to-date job description that clearly separates essential functions from marginal ones is an invaluable tool.
• Consider Reality: Look beyond the written description. What are the actual, day-to-day responsibilities of the role? How much time is spent on each task? What is the impact if a certain function is not performed?
• Why it Matters: An employer is not required to eliminate an essential function as an accommodation. However, reassigning marginal or non-essential duties is often a form of reasonable accommodation.

Step 4: Explore and Analyze Potential Accommodations

This is the core of the evaluation. Working collaboratively with the employee, brainstorm potential solutions.

• Employee's Suggestion: The employee is often the best source of ideas. Start by discussing the accommodation they have proposed. If it is effective and does not cause undue hardship, it should be strongly considered.
• Explore Alternatives: If the employee's preferred solution is not feasible, the employer must explore other options. This could involve research into assistive technologies, consulting with vocational rehabilitation experts, or reviewing internal policies.
• Evaluate Effectiveness: For each potential accommodation, ask: Will this solution enable the employee to perform their essential job functions? Is it a durable solution, or just a temporary fix? For example, providing a larger monitor for an employee with a visual impairment directly addresses a barrier to performing computer-based tasks.

Step 5: Assess for Undue Hardship

Before denying a request, you must conduct and document an undue hardship analysis.

• Action: Analyze the cost and operational impact of the proposed accommodation. Consider direct costs, such as the price of equipment, as well as indirect impacts, like the effect on other employees' ability to do their jobs.
• High Standard: Remember, mere inconvenience or minor cost is not enough to establish undue hardship. The burden of proof is on the employer to show that the accommodation would be excessively costly, extensive, substantial, or disruptive. A detailed understanding of this standard, often gained through anADA Training & Certification Program, is critical.

Step 6: Make and Communicate the Decision

Based on your evaluation, make a final decision and communicate it clearly to the employee.

• Approval: If an accommodation is approved, provide the details in writing. Specify what is being provided, when it will be implemented, and set expectations.
• Denial: If the request is denied, you must provide a clear, business-related reason. The denial letter should explain why the employee is not eligible, why the proposed accommodation is not reasonable, or why it would cause an undue hardship. Documenting this rationale is crucial for limiting workplace liability.

Common Mistakes to Avoid

The evaluation process is fraught with potential pitfalls. Awareness of these common errors is the first step toward avoiding them.

Mistake 1: The "Knee-Jerk" Denial

Many managers deny requests on the spot because they seem unusual or inconvenient. This is a failure to engage in the interactive process and a direct path to a lawsuit.

• How to Avoid: Train managers to pause and consult HR before responding to any accommodation request. Their role is to listen and gather information, not to make unilateral decisions.

Mistake 2: Demanding a Specific Diagnosis

While you can request medical information to confirm a disability and its limitations, you generally cannot demand a specific diagnosis.

• How to Avoid: Focus your inquiries on function, not labels. The critical question is not "What condition do you have?" but "How does your condition limit your ability to perform your job?"

Mistake 3: Relying on a "One-Size-Fits-All" Approach

Treating all ADA accommodation requests the same way without considering individual circumstances is a major error. What is reasonable for one employee in one role may not be for another.

• How to Avoid: Conduct a fresh, individualized assessment for every single request. Consider the specific employee, their unique limitations, and the specific demands of their job.

Mistake 4: Confusing FMLA with ADA

Many employers assume that once an employee's FMLA leave is exhausted, their obligations are over. This is incorrect. Additional unpaid leave can be a form of reasonable accommodation under the ADA.

• How to Avoid: Understand that these are two separate laws with different requirements. Compliance with the FMLA does not excuse non-compliance with the ADA. AnIntegrating FMLA, ADA, COBRA, and Workers' Compensation Training Program is highly beneficial for HR staff managing these overlapping leaves.

The Role of Documentation in the Evaluation Process

Thorough documentation is your most powerful defense in any ADA-related dispute. It creates a clear, contemporaneous record of your good-faith efforts to comply with the law.

What to Document:

• The Initial Request: Note the date the request was made and what was specifically requested.
• The Interactive Process: Keep dated notes of every meeting, phone call, and email exchange with the employee. Summarize what was discussed and what decisions were made.
• Medical Information: Keep all medical certifications and notes in a separate, confidential medical file. Document when you requested the information and when you received it.
• Analysis of Accommodations: Document each accommodation that was considered. For each one, record your analysis of its effectiveness and feasibility.
• Undue Hardship Analysis: If you are claiming undue hardship, your documentation must be exhaustive. Include financial data, operational impact studies, and any other evidence supporting your conclusion.
• The Final Decision: The final decision letter, whether it's an approval or a denial, is a critical piece of documentation. It should be clear, professional, and stored appropriately.

Effective ADA compliance training will often include modules on documentation, providing templates and best practices to ensure your records are legally defensible.

Conclusion

Evaluating ADA accommodation requests is a complex but manageable process. It requires a commitment to collaboration, a clear understanding of the law, and a structured, consistent approach. By following a step-by-step evaluation method, you can move from a position of uncertainty to one of confidence. You can meet your legal obligations, reduce your organization's exposure to workplace liability, and, most importantly, find effective solutions that support your employees.

This is not a skill that can be learned from a memo. It must be developed through dedicated practice and education. Investing in high-quality HR training programs that provide deep, practical knowledge on the ADA is the best way to equip your team to handle these critical responsibilities with the skill and sensitivity they require. By doing so, you protect your organization and reinforce a culture where every employee has the opportunity to succeed.