If you’ve ever had an employee ask for a schedule change, a different chair, or permission to work from home due to a medical condition, and you weren’t sure whether you were legally required to say yes , then you’re not alone. Reasonable accommodation under the Americans with Disabilities Act (ADA) is one of the most searched, and most misunderstood, areas of HR compliance.
Here’s what you actually need to know.
What is reasonable accommodation?
Under the ADA, employers with 15 or more employees are required to provide “reasonable accommodations” to qualified employees or applicants with disabilities unless doing so would cause “undue hardship” to the business. A reasonable accommodation is any change to a job, work environment, or the way work is typically done that allows a person with a disability to enjoy equal employment opportunities.
DON’T MISS THIS
An employee doesn’t have to use the word “accommodation” or even mention the ADA to trigger your obligation. If someone tells you they’re having a work problem related to a medical condition, that may be enough to put you on notice.
What counts as a reasonable accommodation?
The range is broader than many employers expect. Common examples include:
- Modified work schedules or shift changes
- Remote or hybrid work arrangements
- Ergonomic equipment or workspace adjustments
- Extended or additional leave beyond FMLA
- Reassignment to a vacant position
- Modified policies (e.g., allowing a service animal)
Do you have to say yes to every request?
No you don’t, but you do have to engage. The law requires employers to participate in what’s called the “interactive process,” a good-faith dialogue with the employee to explore what accommodations might work. You are not required to provide the exact accommodation the employee requests, nor are you required to lower performance standards or take on significant expenses. If an accommodation would cause undue hardship you may have grounds to decline. Undue hardship means having significant difficulty or expense given your company’s size and resources
However, “I don’t want to” or “It’s inconvenient” is not undue hardship. That’s where many employers get into trouble.
DON’T MISS THIS
The interactive process is not optional and skipping it is one of the most common and costly ADA mistakes employers make. When an accommodation is requested, a real, documented conversation must take place. Ask questions. Listen carefully. Understand exactly what the employee needs and why. A surface-level response isn’t enough, and silence is never an answer.
Where businesses most often go wrong
The most common ADA failures aren’t malicious. They are procedural failures. Failing to document the interactive process, denying a request because it wasn’t formal, or assuming a situation doesn’t rise to a disability can all lead to EEOC complaints and costly litigation. The risks are significant, and the stakes are high.
Not sure if you’re handling accommodations correctly?
ADA compliance doesn’t have to be overwhelming. Molt and Bloom has experienced HR professionals who can help companies navigate the interactive process, document decisions properly, and build policies that hold up. Let’s talk!
