My Employee Has Requested an Accommodation – What Do I Do Now?

When an employee requests a workplace accommodation, it’s essential for employers to respond thoughtfully and in compliance with legal requirements. Accommodations help employees with disabilities or other needs perform their job effectively—without creating undue hardship for the employer. A smooth, supportive process benefits everyone involved.

1. Understand the Legal Obligations

First, it’s important that employers understand key laws like the Americans with Disabilities Act (ADA), which requires providing reasonable accommodations unless doing so causes undue hardship.

“Undue hardship,” as explained by Brooke Poling, Esq., SHRM-CP of Optimal Employee Relations, “is considered on a case-by-case basis, but is usually tied to costs associated with providing the accommodation.”

Additionally, the Equal Employment Opportunity Commission (EEOC) provides guidelines on what qualifies as a reasonable accommodation, including modifications to work schedules, physical environments, or job duties.

2. Encourage Open Communication

Creating a workplace culture where employees feel safe requesting accommodations is essential. This requires clear communication, an empathetic approach, and collaboration between the employer and the employee. This can be done a few ways: 

• Consider Your Policies First: Ask yourself, “do we have a written policy on how to handle accommodation requests?” Poling recommends that every employer have a written ADA-compliant policy and procedure. “This ensures that employees and management know how to handle accommodation requests.” 

• Train Your Team: make sure your managers and HR personnel know how to spot and respond to accommodation requests, especially if employees don’t explicitly use the words “accommodation,” “adjustment,” or “ADA.”

• Lead with Compassion: Make it clear that empathy and compassion are valued and expected to help create a sense of psychological safety amongst your team.

• Stay Collaborative: Approach the process as a two-way conversation with the employee. (More on this below.)

  
  

3. Assess the Request

No one request will likely be the same, so it’s important to carefully listen to your employees to understand their needs. Additionally, accommodation requests may not always come formally. For example, an employee might say, “I'm struggling to focus because of the loud noises around me," or "I need written instructions because I forget certain procedures.”

When an employee does express their needs, Poling likes to remind employers that when subject to the ADA, the employer must initiate an open dialogue with the employee about their needs and how that may be provided. This can be verbally or in writing, but any verbal communication should always be followed up in writing. 

Not sure what the disability is? Poling provides two routes for employers to consider: 

• Asking what job functions the disability affects

• Requesting documentation from the employee’s medical provider. 

This information will provide better insight into both the disability and potential accommodations that might be necessary. 

4. Explore Employee Accommodation Options

Accommodations vary depending on the employee’s specific needs, and it’s important to consider a variety of options to ensure the employee is receiving the support they need. Some common accommodations include:

• Flexible work schedules or remote work options.

• Assistive technology or ergonomic workstations.

• Modifying job duties or providing additional training.

• Designating quiet workspaces or offering noise-canceling headphones for sensory sensitivities.

• Allowing additional breaks for medical needs. 

While employers are not required to provide the exact accommodation that an employee requests if a different, yet sufficient, accommodation exists, it’s likely better for the relationship that the employer provides the requested accommodation (assuming there’s not an undue hardship). 

5. Implement and Monitor the Accommodation

Even though the accommodation is approved, there’s still more work to be done. Once an accommodation is approved: 

• Act Promptly: Implement it as soon as possible.

• Communicate: Inform relevant staff (like managers, impacted peers, or support teams) about their roles, without disclosing sensitive information.

• Follow Up: Check in with the employee to ensure the accommodation is working. Be ready to adjust if needed.

Flexibility is key. The first solution may not be the best long-term fit.

6. Keep Records and Maintain Confidentiality

Keeping proper documentation is important for several reasons – consistency being one of them. Keep consistent documentation of:

• Requests

• Discussions

• Decisions made

• Accommodations implemented

Make sure that in the process you’re storing any medical documentation securely and separately from personnel files.  “Employers have an obligation to keep employees’ medical information confidential from others in the workplace,” says Poling. “Even managers should not be told the specifics about an employee’s disability. Instead, managers should only be told that an accommodation has been set and what that accommodation includes.”

7. Train Managers and Staff

Educating managers and HR personnel on accommodation policies ensures requests are handled fairly and consistently. Training should cover:

• Legal requirements and company policies.

• Recognizing accommodation requests and engaging in the interactive process.

• Maintaining confidentiality and preventing discrimination or retaliation.

Poling warns employers of a key feature to keep in mind. “The ADA prohibits employers from taking adverse action against an employee who requests an accommodation,” she says. Retaliation might look like not adhering to the accommodation, disciplinary action associated with the request or accommodation, or humiliating the employee for their needs. 

Conclusion

Handling accommodation requests effectively benefits both employees and employers, fostering a more inclusive and productive workplace. By understanding legal obligations, engaging in open communication, and implementing thoughtful solutions, employers can create a supportive environment where all employees can thrive.

Employers should regularly review their accommodation policies and ensure employees are aware of their rights and options. For more information, consult resources from the EEOC or legal professionals specializing in workplace accommodations.

Special thanks to Brooke Poling, Esq., SHRM-CP of Optimal Employee Relations for her contributions to this article. 

The information contained herein is for educational purposes only. It does not constitute legal advice.