ADA Reasonable Accommodation Checklist: Full Guide + Free Template 

ADA reasonable accommodations are outlined in the Americans with Disabilities Act (ADA) to prohibit discrimination against individuals with disabilities. ADA reasonable accommodations cover all areas of public life, including all public and private places that are open to the general public, services, transportation, and, specifically, relevant to HR professionals, employment opportunities, and working conditions.

This article provides an introduction to the ADA reasonable accommodation, with guidance on who qualifies and how to manage requests. We’ve also developed a helpful and free ADA reasonable accommodation checklist template to download. Plus, included is also a downloadable ADA reasonable accommodation request form word doc!

Contents
What is the Americans with Disabilities Act (ADA)?
Examples of disabilities
What is an ADA reasonable accommodation?
Who qualifies for ADA accommodations?
The legal framework and importance of ADA compliance
Reasonable accommodation requests: the ins and outs
Examples of reasonable accommodation
Checklist: 7 Steps to creating ADA reasonable accommodation
Template: ADA Reasonable Accommodation Request Form

What is the Americans with Disabilities Act (ADA)?

Disability rights are civil rights. From voting to parking, the American Disabilities Act (ADA) is a comprehensive federal law that protects people with disabilities in many areas of public life, including where and how they work, which is why it’s important for HR professionals to understand what the ADA is, who it is for and how it protects employees and employers.

The ADA guarantees that people with disabilities have:

• The same employment opportunities
• The ability to access goods, services, public accommodations, transportation, and; telecommunications
• The same right to participate in state and local government programs as anybody else.

 ADA list of disabilities:

Under the ADA, a person with a disability is anyone who:

• Has a physical or mental impairment that substantially limits major life activities
• Has a record of such an impairment
• Is regarded as having such an impairment.

Major life activities include performing manual tasks, caring for oneself, seeing, hearing, walking, speaking, breathing, learning, concentrating, communicating, and working. The operation of major bodily functions like circulation, individual organs, and reproduction is also included. The ADA protects any person who falls into these categories.

The term “substantially limits” is an intentionally broad interpretation because the ADA is designed to be inclusive rather than a demanding standard. However, not every condition will fall under the ADA. For example, a mild allergy to pollen, or even a more serious allergy to shellfish, will not substantially limit major life activities and, therefore, would not be included in the ADA.  

Examples of disabilities

There is a wide variety of disabilities—some visible and some not, such as mental health issues—and the ADA regulations do not list all of them. Some examples of disabilities include:

• Cancer
• Diabetes
• Epilepsy
• Post-traumatic stress disorder
• HIV
• Autism
• Cerebral palsy
• Blindness or low vision
• Deafness or hearing loss
• Mobility disabilities that require the use of a wheelchair, cane, or walker
• Intellectual disabilities
• Major depressive disorder, post-traumatic stress disorder, bipolar disorder, obsessive-compulsive disorder, and schizophrenia
• Traumatic brain injury.

What is an ADA reasonable accommodation?

Under the ADA, ‘reasonable accommodation’ essentially means taking appropriate steps to accommodate employees with disabilities so that they enjoy equal employment opportunities to their non-disabled colleagues. This requires eliminating any potential workplace barriers that might prevent them from performing their jobs, including:

• Modifications or adjustments that an employer may need to make in a physical work environment
• Adapting processes or the ways things have customarily been done
• Eliminating potential workplace barriers that might prevent a person from performing their job.

There are three general categories of reasonable accommodations to consider:

1. Modifications or adjustments to a job application process

• Ensure that the application process is accessible to people with disabilities
• Applications in a large print or electronically for those with visual impairments
• Provide a sign language interpreter for a deaf applicant during an interview
• Ensure any online job listings are accessible.

2. Modifications or adjustments to the work environment or to the way a job is customarily performed

• Making existing facilities readily accessible for people with disabilities, including installing wheelchair ramps or altering the layout of a workspace to ensure it can be navigated by an employee with a mobility impairment
• Job restructuring to reallocate non-essential functions of a job
• Creating part-time or modified work schedules
• Addressing when, how, and where an essential function is performed
• Allowing and enabling remote working
• Modifying workplace procedures, policies, or regulations to support additional needs, such as medical leave absences
• Providing specialized support for someone with a visual or hearing impairment, such as access to materials in Braille.

HR tip

You aren’t required to eliminate the job’s essential functions, reduce the quality or quantity of production standards, or provide employees with personal use items such as wheelchairs or hearing aids.

3. Modifications or adjustments that enable a covered employee with a disability to enjoy equal privileges and benefits of employment

• The benefits of employment often extend beyond being paid a salary for doing a job
• They may include social functions, training, and access to services or networks
• If other employees have access to these things, accommodation must be made for disabled employees as well, within reason.

What does undue hardship refer to?

Any modification to the workplace or processes that would be excessively costly, extensive, substantial, disruptive, or fundamentally alter the nature or operation of the business can be classified as an “undue hardship.” 

However, determining undue hardship is always made on a case-by-case basis, considering factors such as the nature and cost of the accommodation needed and the impact of the accommodation on the operations of the employer’s business. 

The ADA also doesn’t require employers to make unnecessary accommodations. This means that if an employee with a disability is able to perform their job functions without any accommodations, the employer is not required to provide them. 

The key is that the accommodation enables an employee or job applicant with a disability to have rights and privileges equivalent to those of employees without disabilities. It’s worth noting that the ADA is designed to support people with disabilities, and any ‘undue hardships’ will need to be proven.

HR tip

The key word in “reasonable accommodation” is reasonable. It should not cause “undue hardship” to the employer.

Who qualifies for ADA accommodations?

To qualify for accommodations under the ADA, an individual must meet 3 specific criteria:

1. They have a disability as defined by the ADA: The ADA broadly defines a disability as a person with a mental or physical impairment that substantially limits one or more major life activities. The ADA Amendments Act of 2008 (ADAAA) further clarified the definition of a disability by emphasizing that the definition should be interpreted in favor of a broad coverage of individuals.
2. They are qualified to perform essential job functions: Being qualified for the job means that the individual meets the education, experience, skill, and other job-related requirements of the position and can perform the essential functions of the job. For HR professionals, it is worth ensuring that the job application process is accessible to people qualified to perform the fundamental duties of the job to ensure no discrimination is taking place. This is a great way to build an employer brand that is recognized as supporting people with disabilities.
3. They are an employee of the organization: The ADA protections apply to employees working in a job, not independent contractors, freelancers, or job applicants. It applies to private employers, state and local governments, labor organizations, employment agencies, and labor-management committees. The employer also must have a minimum of 15 employees for the ADA requirements to apply.

The legal framework and importance of ADA compliance

The Americans with Disabilities Act (ADA) became law in 1990. The Act has 5 sections or titles, including:

• Title I: Employment practices of private employers with 15 or more employees, state and local governments, employment agencies, labor unions, agents of the employer and joint management labor committees (relevant to employers)
• Title II: Programs and activities of state and local government entities
• Title III: Private entities that are considered places of public accommodation.

ADA compliance is both a legal requirement and an important aspect of corporate responsibility for employers. As this guide outlines, the law aims to ensure that people with disabilities have the same rights and opportunities as everyone else. The Act, therefore, protects qualified individuals with disabilities from discrimination in the hiring process, as well as in the terms and conditions of employment. It also requires employers to provide reasonable accommodations to employees with disabilities, unless such accommodations would cause undue hardship.

It is enforced by the U.S. Equal Employment Opportunity Commission (EEOC), and non-compliance can result in legal action, financial penalties, and damage to an organization’s reputation.

The ADA resulted from a need to end the pervasive unequal treatment of people with disabilities in the United States. Prior to the ADA, people with disabilities faced numerous physical and societal barriers that limited their participation in mainstream American life and often prohibited them from the ability to earn a living. The ADA aimed to end this, extending civil rights protections to individuals with disabilities similar to those protections provided to individuals on the basis of race, color, sex, national origin, age, and religion.

The first Act did not afford enough protections, however, and in 2008, the Americans with Disabilities Act Amendments Act (ADAAA) was signed into law and became effective on January 1, 2009. The ADAAA made several significant changes to the definition of “disability.” The changes in the definition of disability in the ADAAA apply to all titles of the ADA.

Employer obligations under the ADA

• Employers cannot discriminate against individuals with disabilities in any aspect of employment, including job application procedures, hiring, firing, advancement, compensation, job training, and other terms, conditions, and privileges of employment.
• Employers must provide reasonable accommodations to the known physical or mental limitations of a qualified individual with a disability, unless doing so would impose an undue hardship on the operation of the business.
• Employers cannot retaliate against individuals for asserting their rights under the ADA.
• Employers must keep medical information on applicants or employees confidential, with certain limited exceptions.

ADA compliance should be viewed not merely as a legal obligation but as a cornerstone of an inclusive and fair society. As an added benefit for HR professionals promoting Diversity and Inclusivity (D&I) strategies within their organizations, ADA compliance is a crucial part of maintaining a diverse, inclusive, and equitable workplace.

It enhances an employer’s ability to attract and retain talent, increases employee morale, and helps create a work environment where everyone, including those with disabilities, can contribute fully and effectively.

Reasonable accommodation requests: the ins and outs

No specific policies or procedures are listed in the ADA on employee requests for a reasonable accommodation. However, it’s a good idea to develop a formal and uniform process to cover all reasonable accommodations. This will reduce your organization’s risk of legal liability and increase your overall brand reputation.

1. Who makes the formal written request

The reasonable accommodation process is usually initiated by the employee or job applicant with a disability who needs the accommodation. The individual or their representative (which could be a family member, health professional, or other representative) makes a formal written request to the employer.

This request, while it does not need to be in a specific format or use any special language, should clearly state that the individual is asking for changes at work due to a medical condition.

2. How to handle requests for reasonable accommodations

When an employer receives a request for a reasonable accommodation, they should respond promptly. Any undue delay can result in a violation of the ADA. The employer may ask for documentation when the disability and/or the need for accommodation is not obvious. This documentation should come from an appropriate healthcare or rehabilitation professional.

The employer should then engage in what the EEOC calls a ‘flexible, interactive process’ with the employee to identify how an effective reasonable accommodation can be reached. This might include discussing the precise nature of the impediment, how it affects the employee’s ability to perform the job, and what types of accommodation could be effective in enabling them to perform the job’s essential functions or enjoy equal benefits and privileges of employment.

3. Types of accommodation the organization should provide

Accommodations vary widely depending on the individual’s disability and the specific barriers encountered in the workplace. The employer should provide accommodations that best serve the needs of the individual and that are reasonable and do not cause undue hardship. Refer to our list earlier in this guide to get an idea of the various types of accommodation that may be required.

4. Challenges that HR could encounter

Understanding and applying the concept of ‘reasonable’ accommodation versus ‘undue hardship’ can be complex and is, therefore, an essential role that HR plays in this process. The interactive process to reach the reasonable accommodation also needs open communication and a willingness to consider various options, which can sometimes be time-consuming and requires an empathetic HR team looking for solutions.

Confidentiality of medical information is another challenge – maintaining privacy while managing accommodation requests is crucial to compliance.

HR tip

It can be difficult to determine reasonable accommodations without determining the essential functions of a job. This is critical in deciding whether an individual with a disability is qualified and needs an accommodation.

5. Training and sensitivity for HR and staff

It stands to reason that training of HR professionals and staff is an important aspect of the ADA compliance process. HR professionals need a deep understanding of ADA requirements and how to apply them in various scenarios.

They should also be trained on how to manage the reasonable accommodation process effectively. However, the foundation of the ADA is to create more equitable workplaces. This is why employees should also receive training on the organization’s ADA policies, their rights and responsibilities under the ADA, and the importance of creating an inclusive workplace environment. 

Sensitivity training can help staff better understand their colleagues with disabilities, promoting a more inclusive and respectful workplace. Regular training updates should also be provided to ensure ongoing compliance with ADA requirements.

Examples of reasonable accommodation

Still not sure what reasonable accommodation looks like within your workplace? First, remember that reasonable accommodations vary significantly based on an individual’s specific needs, the nature of their job, and the particular work environment. However, we have created three scenarios to show you what a reasonable accommodation might look like.  

Scenario 1: Flexibility in work schedule

• Flexible start and end times: An employee with a disability that interferes with their ability to sleep or causes them to require more time to get ready in the morning might need to start work later and end work later to compensate.
• Breaks: Additional short breaks might be required during the workday to manage a health condition, take medication, or rest.
• Part-time schedule: For some employees, reducing the number of work hours can enable them to continue performing their job’s essential functions. For example, someone undergoing intensive medical treatment might work part-time for a period.
• Remote work: Allowing an employee to work from home might be a reasonable accommodation. This can be particularly helpful for individuals whose disability affects their mobility or ability to commute.

Scenario 2: Technology and equipment

• Ergonomic office equipment: This could include specialized desks, chairs, or keyboard trays that help reduce strain and discomfort.
• Assistive technology: Specialized software or hardware might be needed. For example, screen reading software could help an employee with a visual impairment, or a telephone amplifier could assist an employee with hearing loss.
• Modified or adaptive equipment: This could include items like a hands-free telephone for someone with limited use of their hands or a one-handed keyboard for an individual using only one hand.

Scenario 3: Job restructuring

• Task reassignment: Non-essential tasks might be transferred from an employee with a disability to other staff members. For example, if a person has a job that sometimes includes data entry and answering phones, but a hearing impairment makes answering phones difficult, the phone task could be reassigned to another employee.
• Job redesign: An employer might alter how or when a task is performed. For instance, an employee with a learning disability might need written instructions rather than verbal ones.
• Modified supervisory methods: Supervisors might need to adjust their management style or communication methods for an employee with a disability. This could involve providing more detailed guidance, offering additional feedback, or using written communication rather than verbal.

Checklist: 7 Steps to creating ADA reasonable accommodation

Ready to get started on your ADA reasonable accommodation policy? Here is a step-by-step checklist to help you navigate the ADA accommodation process, ensure compliance with legal obligations, and uphold an inclusive and accessible workplace.

We’ve created an easy-to-use ADA reasonable accommodation Word doc checklist to download. Simply click on the button below:

Step 1: Inform employees and create an accommodation policy

• Proactively communicate to all employees about the organization’s commitment to inclusivity and accessibility, including the provision of reasonable accommodations under the ADA. 
• Develop a comprehensive reasonable accommodation policy outlining the procedures for making accommodation requests, the roles and responsibilities of HR and supervisors, and the interactive dialogue process. 
• The policy should be made easily accessible to all employees.

Step 2: Request for accommodation

• A request for accommodation should be a written communication from the employee or their representative. You can create a template that ensures all the necessary information is included. 
• It should detail the nature of the employee’s disability and the specific accommodation they need to overcome workplace barriers. 
• HR should acknowledge receipt of the request promptly and may ask for supporting documentation if the disability or the need for accommodation is not clear.

Step 3: Engage in an interactive dialogue

• Initiate an interactive dialogue with the employee once you receive an accommodation request. 
• This is a collaborative process involving open communication to understand the employee’s limitations caused by the disability and to identify potential accommodations that could overcome these barriers.
• Flexibility, creativity, and mutual respect are essential in this process.

Step 4: Evaluate accommodation feasibility

• Evaluate the proposed accommodations for feasibility and effectiveness. 
• Consider whether the accommodation will allow the employee to perform the essential job functions and whether it will impose an undue hardship on the organization. 
• The evaluation should consider the cost, the company’s financial resources, the impact on the operations, and the potential disruption to other employees.

Step 5: Implement the accommodation

• Once an appropriate accommodation is identified and agreed upon, implement it promptly.
• Clear communication is key in ensuring that all relevant parties, including the employee, the supervisor, and any other involved personnel, understand the nature of the accommodation and its implementation.

Step 6: Monitor and review the accommodation

• Regularly monitor and review the effectiveness of the accommodation. 
• This should involve soliciting feedback from the employee to ensure that the accommodation is working as intended and enabling them to perform their job effectively. 
• Any necessary adjustments should be made promptly.

Step 7: Maintain confidentiality

• Maintain strict confidentiality throughout the process. 
• All medical information obtained during the accommodation process must be kept confidential. 
• This information should be kept separately from general personnel files and shared only with staff who need the information to implement the accommodation or for emergencies.

Template: ADA Reasonable Accommodation Request Form

 Each ADA reasonable accommodation request form should align with a company’s specific needs and policies. However, it is a good idea to create a form that employees can use when making a request so that you receive all the information you need. 

This free ADA Reasonable Accommodation Request Form template (Word doc) will help you get started. Click on the button below to download your free form:

ADA reasonable accommodation and HR’s role

As an HR professional, it is your role to ensure that your organization has a reasonable accommodation policy and framework to follow, that employees know their rights, and that there is regular training for all staff and HR team members to know how to ensure the business is compliant with the Americans with Disabilities (ADA) Act.

Within the workplace, the ADA is designed to ensure that people with a broad range of disabilities are protected, can be employed, and can perform their essential work functions. 

Nadine von Moltke

Nadine von Moltke was the Managing Editor of Entrepreneur magazine South Africa for over ten years. She has interviewed over 400 business owners and professionals across different sectors and industries and writes thought leadership content and how-to advice for businesses across the globe.

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