Reasonable Accommodation Process: How to Handle ADA Requests

By Nicole Hullihen, former SaaS Chief Operating Officer and Microsoft MVP · Updated October 18, 2026

Sooner or later, an employee will ask for a change at work because of a health condition. It might be a different chair for back pain, a modified schedule for medical treatment, extra breaks during pregnancy or time off to recover from surgery. Handling these requests well keeps good employees working, builds trust and helps you meet your legal obligations.

This guide walks through a simple, step-by-step reasonable accommodation process for small businesses. It covers who is covered, how requests are made, the interactive process, documentation, choosing an accommodation, undue hardship and pregnancy accommodations. It includes examples and a free request form.

Note: This is general information, not legal advice. Many states have their own disability and pregnancy accommodation laws, some covering smaller employers. Talk with an employment attorney about specific situations.

Who Is Covered?

Even if your business has fewer than 15 employees, check your state's law. Many small businesses also follow a similar process voluntarily, because it's a fair way to keep good people.

What Is a Reasonable Accommodation?

According to EEOC guidance, a reasonable accommodation is a change to the job application process, to the work environment or the way a job is usually done, or that enables an employee with a disability to enjoy equal benefits and privileges of employment. Accommodations must be effective.

What Employers Don't Have to Do

EEOC guidance explains that employers don't have to eliminate essential functions of the job or lower production standards, though they can choose to. Employers also don't have to provide personal-use items needed both on and off the job, such as eyeglasses or hearing aids, and accommodations look forward rather than excusing past misconduct.

How Employees Make a Request

This is where many small businesses go wrong. According to EEOC guidance:

• A request can be informal and spoken, not just written.
• The employee doesn't have to mention the ADA or use the words "reasonable accommodation."
• The employee doesn't have to know the exact accommodation they need, but should explain the barrier they're facing at work and that it relates to a medical condition.
• A family member, doctor or other representative can make the request on the employee's behalf.

So a comment like "My back injury makes it hard to stand for a full shift, can I get a stool?" is an accommodation request. Train managers to recognize these requests and pass them to the person who handles them.

The Reasonable Accommodation Process, Step by Step

Step 1: Acknowledge the Request Promptly

EEOC guidance says employers should respond promptly, because unnecessary delays can violate the ADA. Thank the employee, confirm you received the request and explain what happens next.

Step 2: Talk With the Employee (the Interactive Process)

The interactive process is an informal conversation to understand the limitation and find an effective solution together. Ask:

• What part of the job is difficult right now?
• What do you think would help?
• Is this temporary or ongoing?
• Have you used an accommodation that worked before?

Step 3: Ask for Documentation Only if Needed

If the disability or need for accommodation isn't obvious, EEOC guidance says you may ask for reasonable documentation, limited to what's needed to establish that the person has a disability and needs the accommodation. You generally can't ask for complete medical records. If the need is obvious, such as an employee who uses a wheelchair asking for a ramp, you don't need documentation.

Step 4: Identify Possible Accommodations

List options with the employee. Think about equipment, schedules, tasks, policies and location. Free resources such as the Job Accommodation Network (askjan.org) offer accommodation ideas by condition and job.

Step 5: Choose an Effective Accommodation

EEOC guidance says employers may choose among effective options, including one that is less expensive or easier to provide, while giving the employee's preference primary consideration. The key word is effective: it has to actually address the limitation.

Step 6: Put It in Place and Document It

Confirm the accommodation in writing, including any dates or review points. Keep medical information in a separate, confidential file.

Step 7: Follow Up

Check in after a few weeks. If the accommodation isn't working, restart the conversation.

Undue Hardship

Employers don't have to provide an accommodation that would cause an undue hardship. Under the PWFA, the EEOC describes undue hardship as significant difficulty or expense. EEOC guidance explains that undue hardship is assessed case by case, considering factors such as the cost and difficulty of the accommodation and the employer's resources.

A few practical points:

• If one accommodation would be an undue hardship, look for another that would work.
• Document the specific reasons if you conclude an accommodation would be an undue hardship, and talk with an attorney first.
• EEOC guidance says an employer cannot claim undue hardship based on employees' or customers' fears or prejudices, or on a possible negative impact on coworker morale.

Pregnancy Accommodations Under the PWFA

The Pregnant Workers Fairness Act took effect June 27, 2023, and applies to employers with 15 or more employees. The EEOC says covered employers must provide reasonable accommodations for known limitations related to pregnancy, childbirth or related medical conditions, unless the accommodation would cause undue hardship.

Examples the EEOC gives include:

• Additional breaks.
• Being allowed to drink water or eat at a workstation.
• Equipment or workstation changes, such as a stool.
• Schedule changes.
• Telework.
• Temporary reassignment.
• Time off for medical appointments.

The EEOC also says an employer can't require an employee to take leave if another reasonable accommodation would let them keep working. See paid parental leave policy.

Examples From Small Businesses

For injured employees returning to work, see return to work program: light duty for injured employees.

Confidentiality

EEOC guidance notes that the ADA specifically prohibits the disclosure of medical information except in certain limited situations. Keep medical information confidential and store it in a separate file from the regular personnel file. Share it only with those who need to know, such as a supervisor who needs to know about a schedule change, but not the diagnosis. If coworkers ask why someone has a different schedule or a special chair, you can say it's a private matter and that the business supports anyone who needs adjustments.

Free Accommodation Request Form

Make clear that using the form is optional, since requests don't have to be in writing.

Common Accommodation Mistakes

• Ignoring informal requests because they weren't in writing.
• Waiting weeks to respond.
• Asking for full medical records instead of limited documentation.
• Saying no without talking through options.
• Requiring leave when another accommodation would let the employee keep working.
• Sharing medical details with coworkers.
• Retaliating against employees who ask. Requesting accommodation is protected activity. See anti-retaliation policy.
• Never following up to see if it's working.

Reasonable Accommodation Checklist

Training Managers to Spot Requests

In a small business, the first person to hear an accommodation request is usually a direct supervisor, not the owner or an HR person. Managers don't need to be legal experts, but they should know three things:

1. Recognize the request. Any mention that a health condition is making part of the job hard may be a request.
2. Respond kindly and pass it on. "Thanks for telling me. I'll get this to [contact] so we can figure out what would help."
3. Keep it confidential. Don't share details with the team or speculate about the condition.

Temporary Conditions

Accommodations aren't only for permanent disabilities. A temporary condition, such as recovery from surgery, a serious injury or pregnancy-related limitations, may also call for adjustments. Set a review date for temporary accommodations so you can check in and adjust as the person recovers.

Accommodations and Attendance

Sometimes an accommodation involves time: a modified schedule, intermittent time off for treatment or a later start. Track these arrangements clearly so managers don't mistakenly count approved time against an attendance policy. Write the accommodation into the schedule and note it in your attendance records. See can an employer deny sick leave.

When You Can't Find an Accommodation

If you've worked through the options and none would be effective without undue hardship, document each option you considered and why it wouldn't work. Before making any decision that affects the person's job, talk with an employment attorney, and consider whether leave or reassignment to a vacant position might be possible.

Documenting the Process

Good records show that you took a request seriously and worked toward a solution. For each request, keep a short, confidential record:

Store this record with other medical information, separate from the general personnel file, and share it only with people who need it to put the accommodation in place.

A Quick Word on Cost

Many owners worry that accommodations will be expensive. Many common adjustments, such as a schedule change, a stool, moving a desk, allowing water at a workstation or swapping a task with a coworker, involve little or no cost. Start with the simplest effective option, and revisit it if the employee's needs change.

Make Schedule Accommodations Easy With Updoot

Many accommodations involve time: later starts, extra breaks, split shifts or time off for appointments. Updoot's scheduling makes it easy to build and keep modified schedules, the employee time clock records hours accurately and SOP management keeps your accommodation process where managers can find it.

Sources

• EEOC: Enforcement Guidance on Reasonable Accommodation and Undue Hardship Under the ADA
• EEOC: Fact Sheet on Disability Discrimination
• EEOC: What You Should Know About the Pregnant Workers Fairness Act
• EEOC: Retaliation

Frequently Asked Questions