Accommodations (ADA interactive process)

When an employee requests a workplace accommodation under the ADA (or your state equivalent — California FEHA, New York State Human Rights Law, etc.), the law requires a documented interactive process: the employer and employee work together in good faith to identify a reasonable accommodation that doesn't impose an undue hardship. This module gives you the structured workflow that produces that documentation as you go.

TL;DR — Requests land in EEO → Accommodations → Open requests. Click Begin interactive process to start the dialogue, document each touchpoint, and ultimately Grant, Grant alternative, or Deny (undue hardship). Every step goes into the case ledger so the interactive-process record builds itself.

Before you start

• The employee has already filed the request through their self-service portal at /account/privacy → "Request a workplace accommodation". (Managers can file on the employee's behalf with consent.)
• You'll want their functional limitation summary (what the employee says they cannot do, in plain terms) but you do not need their diagnosis. If documentation supports the limitation, you may receive it — but never store it outside the case file.
• Loop in the employee's manager early. Most accommodations involve schedule, equipment, or workspace changes the manager must operate. The manager sees an outcome notice, never a medical reason.

The five phases

Begin the interactive process

1. 1

   Open EEO → Accommodations → Open requests

   Requests are sorted by oldest-first; severity badges flag any safety-affecting limitation.

2. 2

   Click "Acknowledge"

   The employee receives an automatic message within their preferred channel: "We've received your request. An EEO specialist is assigned and will be in touch within 2 business days."

3. 3

   Click "Begin interactive process"

   The accommodation file opens. The intake form the employee filled out is pre-loaded; you can request clarifications inline.

4. 4

   Map the essential functions

   The form pulls the role's essential functions from the job description (if attached) and lets you add ones the description missed. Check the boxes the limitation affects.

5. 5

   Capture clarifications from the employee

   Use the Outreach tab to log a call / email / meeting with the employee. Each touchpoint is one row: date, format, who attended, what was discussed. Don't summarize multiple touchpoints into one row — the record needs the cadence.

6. 6

   Loop in the manager (with consent)

   If the accommodation touches schedule, equipment, or workspace, the manager confirms what's operationally possible. The manager sees only what they need: "Employee X needs Y; can the team accommodate?"

7. 7

   Document options considered

   Add each option to the Options considered list with a note on why it was selected or set aside. This list is the heart of the interactive-process record.

Reach a decision

Three terminal states.

The undue-hardship analysis

If you're denying, the analysis must cover:

• The nature and cost of the accommodation in concrete terms (not abstractions).
• The employer's overall financial resources, the size of the facility, the number of employees, and the budget realities for the unit (not just the team).
• The impact on operations — would the accommodation fundamentally alter how the role is performed by everyone?
• Alternative funding sources considered — tax credits, vocational- rehabilitation grants, etc.

A skimpy denial rationale is the single most common ADA litigation trigger. The form pre-flights for length and specificity and warns when an entry is too short to defend.

Implement and monitor

1. 1

   Send the implementation plan to the manager

   A workspace template fills in only the operational changes (e.g. "remote 2 days/week, ergonomic monitor stand by Tuesday"). No medical content.

2. 2

   Configure check-ins

   Default cadence: 30 / 60 / 90 days. The system schedules them automatically; the EEO specialist confirms or reschedules.

3. 3

   Capture the employee's status at each check-in

   Working as expected / not working / needs revision. If "needs revision", reopen the interactive process for a new round.

4. 4

   Close the file when steady-state is reached

   Typically at the 90-day check-in if the accommodation is stable. The accommodation stays in effect; the file closes (the accommodation itself doesn't expire unless explicitly revoked).

Every field, explained

Common gotchas

• "The employee gave us their diagnosis voluntarily — can we log it?" Don't put it in the accommodation file. If documenting it serves a purpose, route it to the workspace's PHI vault per workspace policy. The accommodation file should reflect limitations, not diagnoses.
• "The first-choice accommodation is expensive; can we just propose something cheaper?" Yes — that's the whole point of the interactive process — but you must show you considered the first choice and explain why the alternative is comparable. "It costs less" is not on its own a reason to deny.
• "The employee won't engage with our suggested options." Lack of engagement doesn't automatically end the process; document the attempts to engage. After several documented attempts with no response, the request may be closed as abandoned with appropriate notice — counsel review recommended.
• "A manager keeps asking why their report has an accommodation." Reiterate the workspace policy and shut down the line of questioning. Manager-side curiosity about medical reasons is itself a compliance risk; consider a brief refresher with the manager.
• "The accommodation worked for 6 months but the role changed." A material role change triggers a fresh interactive process — the original accommodation may no longer fit. Open a revision case from the file.

Troubleshooting

How this is recorded

Every interactive-process touchpoint, every option considered, every decision is written to the accommodation file's tamper-evident ledger. If a denied request is later challenged, the ledger is the artifact that demonstrates good-faith engagement. Retention follows EEOC § 1602.14 (one year from the later of accommodation grant or final decision) plus your state floor.