The six steps after an accommodation request run from recognizing the request to checking that the change works.
Key takeaways for six steps after an accommodation request
- Recognize the request immediately. You do not need to wait for specific legal language to identify an accommodation request. The EEOC notes that people do not have to use legal terms or mention the ADA to make one ( EEOC).
- Begin the conversation actively. Once a request is made, begin a conversation with the employee and remember to engage in active listening, work collaboratively, identify common ground, and demonstrate mutual respect according to Job Accommodation Network.
- Keep medical records separate. The ADA requires that all medical information—regardless of how it's obtained—be kept confidential, stored separately from personnel files, and accessible only to authorized personnel (such as human resources professionals or reasonable accommodation coordinators) according to Job Accommodation Network.
- Explore options before choosing. The process includes a distinct phase to explore and choose accommodations before finalizing any changes according to Job Accommodation Network.
- Implement and monitor effectively. Once an accommodation is chosen, proper implementation is key according to Job Accommodation Network. Accommodations must effectively meet the individual's needs by enabling them to perform the essential functions of the job or access equal benefits and privileges of employment according to Job Accommodation Network.
Steps 1 and 2: recognize the request and start the conversation
A request for a change does not require specific legal terminology to trigger the process. The person making the request may use plain language to describe their need. For example, an applicant or employee might say, "I'll need to take six weeks off for medical treatment related to my back," as illustrated in the Accommodation Process page by Job Accommodation Network. This example shows that a request can be made in plain language about medical treatment, without naming a statute or using the word "accommodation." You do not need to wait for a specific phrase to begin your duties. The moment a person indicates a need for a change due to a health condition, the process starts.
Once you recognize the request, you should begin a conversation with the individual. According to Job Accommodation Network, once an accommodation request is made, you should begin a conversation with the employee and remember to engage in active listening, work collaboratively, identify common ground, and demonstrate mutual respect. This initial dialogue is not a negotiation where you debate the validity of the condition. Instead, it is a collaborative effort to understand the situation. Your role is to listen to the person's perspective and work together to find a solution. Avoid making assumptions about what the person needs before they have explained it. The goal of this step is to establish a respectful foundation for the rest of the process.
The regulatory framework describes this interaction as an informal, interactive process. According to Legal Information Institute, to determine the appropriate reasonable accommodation it may be necessary for the covered entity to initiate an informal, interactive process with the individual with a disability in need of the accommodation. This means the conversation is a two-way street. You are not simply issuing directives; you are engaging in a dialogue. The term "informal" suggests that this does not need to be a rigid, bureaucratic meeting with a specific agenda format, but rather a genuine exchange of information. The term "interactive" emphasizes that both parties contribute to the discussion. You bring knowledge of the job functions and workplace constraints, while the individual brings knowledge of their specific limitations and needs.
Steps 3 and 4: what you may ask, and how you choose a change
The interactive process determines whether you need more information before moving forward. The U.S. Equal Employment Opportunity Commission notes that its Enforcement Guidance on Reasonable Accommodation and Undue Hardship under the ADA addresses an employer's ability to ask questions and seek documentation after a request has been made U.S. Equal Employment Opportunity Commission. You do not need to request medical records for every situation. For more on documentation requests, see Medical documentation requests. According to Job Accommodation Network, an employer cannot ask for documentation when both the disability and the need for reasonable accommodation are obvious. The same source states that documentation is not required when the individual has already provided sufficient information to substantiate that they have an ADA disability and needs the reasonable accommodation requested Job Accommodation Network. The process should identify the precise limitations resulting from the disability, according to Legal Information Institute.
When you reach the selection phase, the Job Accommodation Network identifies this as Step 4: Explore and Choose Accommodations Job Accommodation Network. The U.S. Equal Employment Opportunity Commission defines an accommodation as any change in the work environment or in the way things are customarily done that enables an individual with a disability to enjoy equal employment opportunities U.S. Equal Employment Opportunity Commission. The Commission lists three categories of reasonable accommodations, though the specific categories are detailed in the full guidance text U.S. Equal Employment Opportunity Commission. Your role is to explore options within these categories that address the essential functions of the job. You may discuss the hiring process with applicants, including whether it involves an interview, timed written test, or job demonstration, and ask if they will need a reasonable accommodation for this process U.S. Equal Employment Opportunity Commission. This transparency helps you identify needs early in the selection phase.
Choose a change that removes the barrier and effectively meets the individual's needs. Document your exploration of options. If the person has already provided sufficient information, skip the documentation request and move directly to exploring solutions. Write down the specific limitation and the potential changes you discussed. This record supports your decision-making and shows you followed the interactive process. For a related approach to recording decisions, see Hiring Decision Debrief: Notes to a Recorded Decision.
When can you ask for medical information?
An employer cannot ask for documentation when both the disability and the need for reasonable accommodation are obvious, or when the individual has already provided sufficient information to substantiate them. The Job Accommodation Network describes these two cases.
How do you choose a change?
You explore and choose from categories of reasonable accommodations defined by the U.S. Equal Employment Opportunity Commission. The change must enable the individual to enjoy equal employment opportunities. You select the option that best fits the job requirements and the individual's needs.
Steps 5 and 6: put the change in place and check that it still works
Once you and the person have selected a specific change, the process moves into the implementation phase. According to Job Accommodation Network, once an accommodation is chosen, proper implementation is key. This step requires you to put the agreed-upon change into practice. You should schedule the necessary setup, such as purchasing equipment, adjusting software settings, or rearranging a workspace, so the change is ready when the person needs it. The goal is to move from planning to action without unnecessary delay.
After the change is in place, you enter the monitoring phase. According to Job Accommodation Network, accommodations must effectively meet the individual's needs by enabling them to perform the essential functions of the job or access equal benefits and privileges of employment. Your role is not finished when the change is installed. You must check in with the person to verify that the change is working as intended. Ask if the adjustment allows them to perform their core duties effectively. If the change is not working, or if the person's needs have shifted, you may need to return to the interactive process to explore a different solution.
The legal framework for these steps is defined in the Americans with Disabilities Act of 1990, As Amended. According to ADA.gov, it is a violation not making reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee, unless such covered entity can demonstrate that the accommodation would impose an undue hardship on the operation of the business of such covered entity.
Furthermore, the law protects the person from being penalized for needing the change. According to ADA.gov, it is a violation denying employment opportunities to a job applicant or employee who is an otherwise qualified individual with a disability, if such denial is based on the need of such covered entity to make reasonable accommodation to the physical or mental impairments of the employee or applicant. You cannot reject an applicant or fire an employee simply because they require a reasonable accommodation to do their job.
Illustrative example: a stool request at a packing station
A packing-station worker tells a supervisor, "My back gets sore after long shifts, so I need a stool." The supervisor writes the request in one sentence, notes that it is at Step 1, and schedules a conversation within 2 days. At that meeting they list 3 possible changes, choose one, and store the notes apart from the personnel file. One week later, the supervisor checks whether the stool still meets the worker's needs.
Accommodation rules by publisher
Each publisher's rule, quoted from its own text.
| Publisher | Accommodation Rule or Definition | Source wording |
|---|---|---|
| U.S. Equal Employment Opportunity Commission | An accommodation is any change in the work environment or in the way things are customarily done that enables an individual with a disability to enjoy equal employment opportunities. | "In general, an accommodation is any change in the work environment or in the way things are customarily done that enables an individual with a disability to enjoy equal employment opportunities." |
| Legal Information Institute | To determine the appropriate reasonable accommodation it may be necessary for the covered entity to initiate an informal, interactive process with the individual with a disability in need of the accommodation. | "(3) To determine the appropriate reasonable accommodation it may be necessary for the covered entity to initiate an informal, interactive process with the individual with a disability in need of the accommodation." |
| ADA.gov | Not making reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee, unless such covered entity can demonstrate that the accommodation would impose an undue hardship on the operation of the business of such covered entity. | "(A) not making reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee, unless such covered entity can demonstrate that the accommodation would impose an undue hardship on the operation of the business of such covered entity; or" |
| Job Accommodation Network | The ADA requires that all medical information—regardless of how it's obtained—be kept confidential, stored separately from personnel files, and accessible only to authorized personnel (such as human resources professionals or reasonable accommodation coordinators). | The ADA requires that all medical information—regardless of how it's obtained—be kept confidential, stored separately from personnel files, and accessible only to authorized personnel (such as human resources professionals or reasonable accommodation coordinators). |
Track the next request
Track the next accommodation request as it moves through the six labeled steps. The first step is to recognize the accommodation request, as the Job Accommodation Network describes on its "Accommodation Process" page. Record the date you identified the request and the specific action you took to begin the conversation. Keep the medical notes separate from the ordinary personnel file, as recommended in the earlier section. Next step today: write the request in one sentence, using the person's own words, and note which of the six steps you are on.
Accommodation-request FAQ
Does the person have to name the law?
No. The EEOC notes that the person does not have to use legal terms or mention the ADA when requesting an accommodation ( EEOC). You should recognize the request based on the need for a change, not the specific vocabulary used.
What are the six steps?
There are six steps, in this order:
- Recognize the request.
- Start the conversation.
- Decide what you may ask.
- Explore and choose a change.
- Put the change in place.
- Check that it still works.
When can you ask for medical information?
An employer cannot ask for documentation when both the disability and the need for reasonable accommodation are obvious, according to Job Accommodation Network. You also cannot ask if the individual has already provided sufficient information to substantiate the disability and need.
Where do medical notes go?
Medical information must be kept confidential, stored separately from personnel files, and accessible only to authorized personnel, according to Job Accommodation Network. This requirement applies regardless of how the information is obtained. For related rules, see Verify rules before asking for employee medical records.
What do you write down today?
Write the request in one sentence using the person's own words, then note which of the six steps you are currently on.