Reasonable Accommodation: The ADA Interactive Process

The interactive process fails at the front door more than anywhere else. There are no magic words: "my medication makes mornings hard," a doctor's note about lifting, a family member's call — each is a potential accommodation request under the EEOC's guidance, whoever receives it. The employer's duty is triggered by knowledge of the need, not by a form. So the first control is training: every supervisor routes medical-plus-work statements to HR the same day, and HR opens a documented process — date, what was communicated, next step. The ADA covers physical and mental impairments alike, on the definitions mapped in the protected classes guide.

Where the disability or the need isn't obvious, request documentation — but only what's reasonably needed: the existence of an impairment, the functional limitations, how the requested change helps. You're entitled to enough to evaluate; you're not entitled to the chart. Everything medical goes in a confidential file separate from the personnel file — the same segregation rule from the personnel-file structure. Keep the dialogue moving in writing: what was asked, when it came back, what happens next. In litigation, the party who let the process stall usually loses — and the paper trail decides who that was.

The menu is wider than equipment: modified schedules, reassignment of marginal (never essential) functions, remote work where the essential functions travel, policy exceptions, additional finite leave, or transfer to a vacant role the employee is qualified for — the accommodation of last resort. The employer picks among effective options; the employee's preference matters but doesn't control. Test each candidate against the essential functions in the written job description — which is why job descriptions maintained before disputes, as the handbook guide urges, carry evidentiary weight. Document the trial period and revisit: an accommodation that stops working restarts the process, not the exit.

Undue hardship — significant difficulty or expense in light of the employer's size and resources — is a defense courts read narrowly; morale concerns and minor cost rarely clear it, and a large employer claiming hardship on a cheap accommodation invites summary judgment for the other side. Before any separation touches a medical situation: confirm the process ran, the options (including reassignment) were genuinely explored, and the record shows why each failed. An employee terminated the week FMLA exhausts, with no ADA analysis in the file, is one of the most reliably lost cases in employment law — the termination guide's checklist exists for exactly this moment.