Reasonable Accommodation Explained, Plus Examples

10/29/2025

Navigating the requirements of the Americans with Disabilities Act (ADA) can feel complex, but at its core, the law is about ensuring equal opportunity. A central piece of this is providing reasonable accommodations. For many employers and HR professionals, understanding this obligation is the first step toward building a compliant and inclusive workplace. This guide breaks down what a reasonable accommodation is, how to manage the process, and why effective ADA compliance training is essential for your organization.

We will walk through the step-by-step process, explore practical examples, and highlight common pitfalls to avoid. By the end, you will have a clearer understanding of your responsibilities and how to handle accommodation requests with confidence.

What Is a Reasonable Accommodation Under the ADA?

A reasonable accommodation is any change or adjustment to a job, the work environment, or the way things are usually done that enables a qualified individual with a disability to enjoy equal employment opportunities. It's a modification that helps an employee perform the essential functions of their job or enjoy the same benefits and privileges of employment as their non-disabled colleagues.

The Definition of “Reasonable Accommodation” Explained

The concept is intentionally broad to cover a wide range of situations. An accommodation can be a physical change, like installing a ramp, but it can also be a change to a policy, a schedule, or a job duty. The key word is "reasonable." An accommodation is considered reasonable if it does not cause an "undue hardship" for the employer. This means it shouldn't create significant difficulty or expense.

The goal is not to give an unfair advantage but to remove workplace barriers for individuals with disabilities. It’s about creating a level playing field so that performance is based on ability, not limited by a physical or mental impairment.

When Employers Are Required to Provide Accommodations

The obligation to provide a reasonable accommodation is triggered when a qualified employee (or job applicant) with a disability requests one. The disability must be known to the employer. This doesn't mean the employee has to use the specific words "I need a reasonable accommodation." Any communication indicating that they are having trouble at work because of a medical condition can be considered a request.

This is a critical point: recognizing a request is often the first and most fumbled step in the process. Employers with 15 or more employees are covered by the ADA's employment provisions and must provide accommodations unless doing so would cause an undue hardship.

How ADA Compliance Training Helps Employers Apply These Rules

This is where ADA compliance training becomes invaluable. Training equips managers and HR staff to spot an accommodation request, even when it's not explicit. It provides a framework for engaging in the interactive process, evaluating options, and documenting decisions. Without this knowledge, supervisors might inadvertently dismiss a request or make a snap judgment, exposing the company to significant legal risk. Proper training turns a complex legal duty into a manageable, structured process that protects both the employee and the organization.

The Legal Foundation for Reasonable Accommodations

The requirement to provide reasonable accommodations stems directly from federal law. Understanding this foundation helps clarify an employer's role and responsibilities.

ADA Title I and Employer Responsibilities

Title I of the Americans with Disabilities Act specifically addresses employment. It prohibits employers from discriminating against qualified individuals with disabilities in all aspects of employment, from hiring and firing to advancement and compensation. A major component of this non-discrimination mandate is the requirement to provide reasonable accommodations.

The law doesn’t just forbid negative actions; it requires proactive steps. Failing to provide a reasonable accommodation for a known disability is, in itself, a form of discrimination under the ADA unless the employer can prove undue hardship.

Who Qualifies for a Reasonable Accommodation

To be eligible for an accommodation, an individual must meet two criteria:

1. They must have a "disability" as defined by the ADA. A disability is a physical or mental impairment that substantially limits one or more major life activities. This includes major bodily functions like the operation of the immune system, digestive system, or brain. The definition is broad and includes conditions like diabetes, depression, cancer, and back injuries.
2. They must be "qualified" for the job. A qualified individual is someone who can perform the essential functions of the position, with or without a reasonable accommodation. "Essential functions" are the core duties of the job, not the marginal or secondary tasks.

Understanding the Concept of “Undue Hardship”

An employer is not required to provide an accommodation that would cause an "undue hardship." This is the primary limitation on an employer's ADA obligation. Undue hardship means an action requiring significant difficulty or expense.

When determining undue hardship, the following factors are considered:

• The nature and cost of the accommodation.
• The employer's financial resources, size, and operational structure.
• The impact of the accommodation on the operation of the business.

It is a high bar to prove. An employer cannot simply claim an accommodation is too expensive or inconvenient. The assessment must be based on objective evidence, which is why documenting the evaluation process is so important.

The Reasonable Accommodation Process Step-by-Step

A compliant ADA accommodation process is structured, interactive, and well-documented. Following a clear procedure helps ensure fairness and minimizes legal risk. This is often called the "interactive process."

Recognizing an Accommodation Request

The process begins when an employee indicates they need assistance due to a medical condition. As mentioned, the employee doesn't need to use legal language.

Examples of an ADA accommodation request could include:

• "My back is hurting, and I'm having trouble lifting these boxes."
• "I'm feeling very anxious in our open-plan office; is there a quieter place I can work?"
• An employee's doctor provides a note restricting certain activities.

Supervisors must be trained to recognize these as potential triggers for the interactive process and to escalate them to HR immediately.

Engaging in the ADA Interactive Process

Once a request is recognized, the employer and employee must engage in a good-faith discussion. This is the ADA interactive process. It's a collaborative dialogue to identify the precise limitations caused by the disability and explore potential accommodations that could overcome those limitations.

During this conversation, the employer can ask questions to understand:

• The nature of the employee's impairment.
• How the impairment affects their ability to perform job duties.
• What specific accommodations the employee thinks might help.

The employer may also request reasonable medical documentation to confirm the existence of a disability and the need for an accommodation.

Evaluating Accommodation Options and Feasibility

After understanding the employee's needs, the employer should explore various accommodation options. The employee's suggestion is a starting point, but the employer can propose alternative effective accommodations.

For example, if an employee requests to work from home full-time, but their job requires some in-person collaboration, the employer could propose a hybrid schedule as an alternative. The chosen accommodation does not have to be the employee’s preferred option, as long as it is effective. The employer should assess the feasibility of each option, considering its effectiveness and whether it poses an undue hardship.

Documenting Every Step for Compliance

Documentation is one of the most critical parts of the ADA reasonable accommodation process. Meticulous records create a clear trail showing the employer acted in good faith.

Your ADA documentation requirements should include:

• The date of the employee's request.
• Notes from every interactive process discussion.
• Copies of any medical information received (stored confidentially and separately from the personnel file).
• A record of all accommodations considered, including those rejected and the reasons why (e.g., undue hardship analysis).
• A formal letter outlining the accommodation provided.
• Notes on follow-up conversations to ensure the accommodation is effective.

This documentation is your best defense against a claim of discrimination or failure to accommodate.

Examples of Reasonable Accommodations in the Workplace

Accommodations vary widely depending on the job, the work environment, and the individual's needs. The following are common ADA accommodation examples in the workplace to illustrate the possibilities.

Physical or Environmental Accommodations

These are often the most visible types of accommodations. They involve changes to the physical workspace to improve accessibility.

• Installing a ramp for a wheelchair user.
• Providing an ergonomic chair or adjustable-height desk for an employee with a back injury.
• Modifying the layout of a workspace to accommodate a service animal.
• Improving lighting for an employee with a visual impairment.

Job Restructuring and Modified Duties

ADA job restructuring involves reallocating or redistributing non-essential job functions that an employee is unable to perform because of a disability. The essential functions of the job are not changed.

• An administrative assistant with a lifting restriction might have another employee handle the stocking of heavy supply boxes, while the assistant takes on some of their colleague’s filing duties.
• A retail employee who cannot stand for long periods might be assigned to work primarily at the cash register or in the stockroom, where sitting is possible.

Schedule and Leave Flexibility

Modifying a work schedule or providing leave can be a powerful form of accommodation.

• Allowing a part-time or modified work schedule.
• Permitting flexible start and end times to accommodate medical appointments.
• Granting unpaid leave for treatment or recovery after FMLA leave has been exhausted (ADA and FMLA coordination is key here).
• Providing telework or work-from-home options if the job's essential functions can be performed remotely.

Mental Health and Cognitive Accommodations

Accommodations for mental health conditions are just as important as those for physical ones.

• Providing a quiet, private workspace for an employee with anxiety or concentration difficulties.
• Allowing the use of noise-canceling headphones.
• Providing written instructions and checklists for an employee with a cognitive impairment.
• Offering flexible breaks to manage stress or medication side effects.
• Modifying supervisory methods, such as providing feedback in writing rather than verbally.

Technology and Communication Accommodations

Assistive technology can be a game-changer for many employees with disabilities.

• Providing screen reader software for an employee with a visual impairment.
• Offering sign language interpreters or captioning services for meetings for an employee who is deaf or hard of hearing.
• Supplying voice recognition software for an employee with limited use of their hands.
• Using adaptive software tools that make computer systems more accessible.

Real-World Case Examples of Reasonable Accommodation

Fictional scenarios can help illustrate how these principles apply in practice. These examples are for educational purposes and do not constitute legal advice.

Case Example #1 – Modified Work Schedule After Medical Leave

An employee returns from FMLA leave after surgery. Her doctor clears her to return to work but restricts her to a four-hour workday for the first month. The employer engages in the interactive process and determines that her essential functions can be completed within that timeframe by prioritizing tasks. They grant the modified schedule as a reasonable accommodation. This shows effective ADA and FMLA coordination, where the ADA provides accommodation after FMLA leave ends.

Case Example #2 – Providing Equipment for Physical Disabilities

A graphic designer develops carpal tunnel syndrome and provides a doctor's note stating he needs an ergonomic keyboard and mouse to continue working. The HR manager discusses the request with him, researches options, and purchases the necessary equipment. The total cost is $200. This is a clear example of an effective and low-cost accommodation that allows a valued employee to remain productive.

Case Example #3 – Mental Health Support and Privacy Considerations

An employee discloses to his supervisor that he has been diagnosed with major depressive disorder, which makes it difficult to concentrate in their busy, open-office environment. The supervisor contacts HR, and together they engage the employee in the interactive process. They offer him a vacant office at the end of the hall. The employee accepts. Throughout the process, the supervisor and HR are careful to keep his medical information confidential, only discussing the accommodation itself (a quiet space), not the underlying diagnosis.

Lessons from These ADA Accommodation Scenarios

These cases highlight several best practices:

1. Act Promptly: In each case, the employer responded quickly to the employee's need.
2. Engage Collaboratively: The solutions were found through discussion, not imposed unilaterally.
3. Focus on the Solution: The goal was to find an effective way to enable the employee to work, not to question the validity of their condition.
4. Maintain Confidentiality: Medical details were kept private, respecting the employee's privacy rights.

Common Employer Mistakes in the Accommodation Process

Even with the best intentions, employers can make missteps. Awareness of these common errors is the first step in avoiding them.

Failing to Recognize a Request as an ADA Accommodation

This is the most frequent mistake. A manager hears an employee complain about a physical challenge but dismisses it as "just whining" instead of recognizing it as a potential trigger for the ADA interactive process. Training is the only reliable way to prevent this.

Not Engaging in the Interactive Process Promptly

Delaying the conversation can be seen as a failure to accommodate. Once a request is made, the process should begin within days, not weeks. A prolonged silence from the employer can lead to frustration and legal claims.

Inconsistent Policy Application Across Departments

Applying accommodation policies differently for different employees or departments is a recipe for a discrimination lawsuit. If one manager approves telework for an employee with a disability, another manager cannot deny a similar request for a different employee in a comparable role without a strong, business-related justification (like a difference in essential functions).

Lacking Documentation to Prove Compliance

In an ADA dispute, the burden of proof is often on the employer to show they acted properly. Without written records of the interactive process, the undue hardship analysis, and the final decision, it becomes the employee's word against the employer's. A lack of documentation makes it incredibly difficult to defend an accommodation decision.

How ADA Compliance Training Helps Employers Manage Accommodations

Proactive training is the most effective tool for mitigating risk and building a compliant culture. It moves an organization from a reactive, fearful posture to a proactive, confident one.

Why ADA Compliance Training Is Critical for HR and Supervisors

Supervisors are the first line of defense. They are the ones who receive accommodation requests and observe performance issues. ADA compliance training empowers them to handle these situations correctly from the start. For HR professionals, training provides the deeper knowledge needed to manage the entire process, from documentation to coordinating with other laws like FMLA.

What an ADA Training Program Should Cover

A comprehensive ADA compliance training program should include:

• A clear explanation of ADA, including the definition of disability and qualified individual.
• How to recognize an accommodation request.
• A step-by-step guide to the interactive process.
• Practical examples of reasonable accommodations.
• An in-depth look at the concept of undue hardship.
• Detailed instruction on documentation and confidentiality requirements.
• Guidance on coordinating ADA with FMLA, PWFA, and workers' compensation.

How Training Prevents Legal Risk and Improves Inclusion

Well-trained managers and HR staff make fewer mistakes. They are less likely to deny a valid request, retaliate against an employee, or fail to document their actions. Beyond legal risk, training fosters an inclusive environment where employees feel safe asking for the support they need to succeed. This improves morale, retention, and overall productivity.

Coordinating ADA with FMLA and PWFA Requirements

The ADA does not exist in a vacuum. Employers must often navigate its requirements alongside other leave and accommodation laws, such as the Family and Medical Leave Act (FMLA) and the Pregnant Workers Fairness Act (PWFA).

Understanding Where These Laws Overlap

ADA and FMLA coordination is common. An employee with a serious health condition under the FMLA may also have a disability under the ADA. While FMLA provides up to 12 weeks of unpaid, job-protected leave, the ADA may require additional leave as a reasonable accommodation after FMLA is exhausted.

Similarly, the PWFA requires employers to provide reasonable accommodations for known limitations related to pregnancy, childbirth, or related medical conditions, unless it causes an undue hardship. This process mirrors the ADA interactive process.

Managing Leave, Pregnancy, and Accommodation Requests Together

When an employee requests leave or accommodation for a condition related to pregnancy or a medical issue, employers must analyze the request under all applicable laws. For example, a pregnant worker's request for light duty could trigger obligations under both the PWFA and the ADA (if she has a pregnancy-related disability like preeclampsia). A comprehensive ADA compliance checklist should include cross-references to these other laws.

Avoiding Double Counting or Policy Conflicts

It's crucial to understand that these laws provide separate but sometimes overlapping rights. An employee may be entitled to 12 weeks of FMLA leave and then be entitled to additional leave under the ADA. A light-duty assignment offered under workers' compensation does not eliminate the employer's duty to consider job restructuring under the ADA. Training helps HR untangle these obligations to ensure all rights are respected.

Best Practices for Employers

A successful accommodation program is built on a foundation of proactive, consistent practices.

Keep Job Descriptions Accurate and Updated

Job descriptions are a critical tool in the ADA process. They should clearly distinguish between "essential functions" and "marginal functions." This helps determine if an individual is qualified for the role and makes it easier to evaluate job restructuring as a potential accommodation.

Maintain Clear Communication and Follow-Up

The interactive process doesn't end once an accommodation is implemented. Managers should follow up with the employee to ensure the accommodation is effective. Open lines of communication build trust and allow for adjustments if the initial solution isn't working as intended.

Regularly Review Policies Through ADA Training and Audits

The legal landscape is always changing. Regular ADA compliance training and periodic audits of your accommodation procedures are essential. This ensures your policies remain current and that they are being applied consistently across the organization.

Final Takeaways

Managing reasonable accommodations is a fundamental responsibility for employers. A compliant and effective process protects your organization from legal risk while fostering an inclusive and supportive work environment.

The Key Elements of a Compliant Accommodation Process

Remember these core components:

1. Recognize: Train managers to spot accommodation requests.
2. Interact: Engage in a good-faith dialogue with the employee.
3. Explore: Consider all reasonable options without bias.
4. Document: Record every step of the process.
5. Implement & Follow-Up: Provide an effective accommodation and ensure it works.

How Ongoing ADA Training Strengthens Compliance and Inclusion

ADA compliance training is an ongoing commitment to excellence. By continuously educating your team, you empower them to handle complex situations with confidence, turning legal obligations into opportunities to support your most valuable asset: your people.