Navigating Reasonable Accommodation Requests Under the ADA

Understanding Your Obligations

The Americans with Disabilities Act requires covered employers to provide reasonable accommodations to qualified employees with disabilities, unless doing so would cause undue hardship to the organization. If you have 15 or more employees, the ADA applies to you. But even smaller employers may have obligations under Minnesota state law, which offers broader protections.

Despite decades of ADA enforcement, accommodation requests remain one of the most mishandled areas of HR compliance. Many employers either ignore requests entirely or immediately say no out of fear. Both responses create significant legal exposure. The goal of this post is to give you a clear, practical framework for responding correctly.

What Counts as a Disability Under the ADA?

The ADA defines a disability broadly as a physical or mental impairment that substantially limits one or more major life activities. Following the ADA Amendments Act of 2008, courts and the EEOC interpret this definition very generously. Conditions that may qualify include:

• Chronic health conditions such as diabetes, cancer, or heart disease
• Mental health conditions including anxiety, depression, and PTSD
• Mobility impairments and physical disabilities
• Neurological conditions such as ADHD or epilepsy
• Temporary impairments that are severe enough in nature

When in doubt, err on the side of engaging the process rather than making a unilateral determination that someone does not qualify. That determination is not yours to make without going through the proper steps.

The Interactive Process: Your Most Important Tool

When an employee requests an accommodation or when you have reason to believe one may be needed, the law requires you to engage in what is called the interactive process. This is a good-faith, back-and-forth dialogue between the employer and employee to identify an effective accommodation.

The interactive process is not a formality. It is evidence of good faith. Courts and the EEOC look closely at whether employers genuinely engaged or simply went through the motions.

Steps in the Interactive Process

• Acknowledge the request promptly: Do not let a request sit unanswered. Respond within a few business days to confirm receipt and explain next steps.
• Gather information: You may request documentation from a healthcare provider confirming the disability and describing functional limitations. Keep this request narrowly focused on what you need to evaluate the accommodation.
• Explore options together: Meet with the employee to discuss potential accommodations. The employee does not get to unilaterally dictate the solution, but their input is essential.
• Evaluate feasibility: Assess whether the proposed accommodation is effective, reasonable, and does not pose undue hardship. Undue hardship considers cost, operational disruption, and organizational size.
• Implement and document: Once an accommodation is agreed upon, put it in writing. Note what was agreed, the effective date, and any planned review period.

Common Accommodation Examples

Reasonable accommodations are highly individual, but some common examples include:

• Modified work schedules or flexible start and end times
• Permission to work from home on a full or partial basis
• Ergonomic equipment such as a standing desk or specialized keyboard
• Reassignment of marginal, non-essential job functions
• Additional breaks for medication management or medical needs
• Leave of absence beyond what FMLA requires

What You Cannot Do

There are several common mistakes that can quickly turn an accommodation request into a discrimination claim:

• Ignoring the request: Silence is not a legal defense. Failure to engage is itself an ADA violation.
• Requiring a perfect solution: The accommodation must be effective, not perfect. An employer cannot reject a reasonable option simply because it is inconvenient.
• Disclosing medical information: Any medical documentation you receive must be kept strictly confidential and stored separately from the personnel file.
• Retaliating for a request: Taking adverse action against an employee because they requested an accommodation is illegal, full stop.

When You Can Deny a Request

Not every requested accommodation is one you must provide. If the employee is not qualified for the position even with accommodation, if the accommodation would eliminate an essential job function, or if it would create genuine undue hardship, you may be able to deny it. However, you must document your reasoning carefully and offer alternative accommodations if any exist.

Build a Process Before You Need One

The best time to establish your accommodation process is before you receive a request. Have a written policy, train your managers on how to recognize and respond to requests, and designate a point person, usually in HR, to manage the interactive process.

At Optima HR Solutions, we help businesses across the Twin Cities build ADA-compliant accommodation processes that protect both employees and employers. Getting this right is not just about avoiding liability. It is about building a workplace where everyone can contribute fully.