ADA Accommodations: What Employers Must Do (and the Paper Trail Employees Need)

If you have a disability that affects your ability to perform your job, you may be entitled to a reasonable accommodation under the Americans with Disabilities Act (ADA). But here's what many employees don't realize: the accommodation process is highly technical, and how you request accommodations—and document everything—can determine whether your employer must help you or can legally ignore your needs.

What the ADA Requires

The ADA prohibits employers with 15 or more employees from discriminating against qualified individuals with disabilities. A key part of this protection is the requirement to provide reasonable accommodations that enable employees to perform their essential job functions.

Reasonable accommodations might include:

• Modified work schedules
• Reassignment to a vacant position
• Physical modifications to the workplace
• Assistive technology or equipment
• Modified policies or procedures
• Leave for medical treatment
• Remote work arrangements
• Ergonomic workstation adjustments

The Interactive Process

When an employee needs an accommodation, the ADA requires an interactive process—a collaborative dialogue between employer and employee to identify effective accommodations.

This process should include:

1. Request — The employee (or someone on their behalf) requests an accommodation
2. Discussion — Employer and employee discuss the disability's limitations and possible accommodations
3. Evaluation — The employer assesses options and their feasibility
4. Implementation — The employer provides an effective accommodation (or explains why none is possible)

Employers who refuse to engage in this process—or who go through the motions without genuine effort—may be liable for disability discrimination.

How to Request Accommodations

You don't need to use magic words. The request doesn't have to mention the ADA, use the term "reasonable accommodation," or be in writing (though writing is strongly recommended).

What you do need to communicate:

• You have a medical condition affecting your ability to work
• You need some kind of change or adjustment to do your job
• There's a connection between the condition and the need

Example Requests

• "I'm having trouble with the early shift because of my medication schedule. Can we discuss adjusting my hours?"
• "My back condition makes sitting for long periods very painful. I need an ergonomic chair or standing desk."
• "My anxiety disorder is making open-office noise overwhelming. Could I have a quieter workspace?"

Once you've communicated this information, the employer's obligation to engage is triggered.

Documentation: The Employee's Responsibility

Here's where many employees fail: your verbal request isn't enough. Create a paper trail:

Put It in Writing

After any conversation about accommodations, send a follow-up email:

"Per our conversation today, I'm requesting an accommodation for [medical condition]. As we discussed, I need [specific accommodation]. Please let me know the next steps."

Keep Copies of Everything

• Your written requests
• Employer responses (or non-responses)
• Medical documentation you provide
• HR communications
• Any denials or alternative proposals

Document Timing

Note the dates of:

• Your initial request
• When the employer responded (or didn't)
• Any meetings or discussions
• Implementation of accommodations (or refusal)

If litigation becomes necessary, this timeline is critical evidence.

What Medical Information Employers Can Request

Employers are entitled to verify that your disability and need for accommodation are legitimate. They may request:

• Documentation from your healthcare provider confirming the disability
• Explanation of the limitations caused by the disability
• How the requested accommodation would address those limitations
• Whether alternative accommodations might be effective

They cannot demand:

• Your complete medical records
• Your specific diagnosis (unless relevant to accommodation needs)
• Information about conditions unrelated to the workplace need
• Access to speak with your doctor without your consent

What Makes an Accommodation "Reasonable"?

An accommodation must be effective at enabling the employee to perform essential job functions. It doesn't have to be the employee's preferred accommodation.

Employers can choose among effective alternatives, considering:

• Cost and disruption
• Impact on operations
• Effects on other employees
• Safety concerns

When Employers Can Deny Accommodations

Employers may deny accommodations if:

Undue Hardship

The accommodation would cause significant difficulty or expense relative to the employer's size and resources. This is a high bar—especially for large employers.

Direct Threat

The employee poses a significant risk of substantial harm that cannot be eliminated through accommodation. This requires objective evidence, not stereotypes about disabilities.

Not Qualified

Even with accommodation, the employee cannot perform the essential functions of the job. But employers can't inflate "essential functions" to exclude disabled employees.

No Effective Accommodation Exists

Sometimes there truly is no accommodation that would enable the employee to do the job. But employers must actually engage in the interactive process to reach this conclusion.

Red Flags: When Employers Violate the ADA

Watch for these warning signs:

• Refusal to engage — Ignoring accommodation requests or refusing to discuss options
• Demanding medical records — Requesting more information than necessary
• Blanket denials — Rejecting requests without individualized assessment
• Retaliation — Adverse actions after accommodation requests
• Pretextual termination — Firing shortly after accommodation requests
• Creating hardship — Making the job harder to justify disability-related termination
• Unreasonable delay — Letting requests languish indefinitely

What You Should Do

If you need an accommodation:

1. Request in writing — Email is best; keep a copy
2. Be specific — Identify your limitations and what would help
3. Provide documentation — Submit medical information promptly
4. Document everything — Keep records of all communications
5. Follow up — If no response, follow up in writing
6. Escalate appropriately — Go to HR if your supervisor won't engage
7. Know your rights — Don't accept illegal denials

We Represent Employees in ADA Claims

If your employer has denied reasonable accommodations, refused to engage in the interactive process, or retaliated against you for requesting accommodations, contact us for a free consultation.

We help employees understand their rights and hold employers accountable for disability discrimination.