Reasonable accommodation Definition

Brief Historical Context and Why It Matters

The ADA, enacted in 1990, was a landmark civil rights law prohibiting discrimination against individuals with disabilities. The concept of reasonable accommodation redefined employer responsibility—from simple compliance to proactive inclusion. In today’s workplace, especially with remote and hybrid settings, reasonable accommodation is essential for supporting neurodiverse employees and individuals managing chronic or invisible conditions. The U.S. Department of Labor reports that 59% of accommodations cost nothing, and those that do typically have minimal costs compared to the benefits of retention and productivity.

Workplace Scenarios: Recognizing When Accommodation May Be Needed

Even when employees don’t explicitly ask for help, managers can sometimes recognize potential needs by looking for signs, including:

• Repeated absences for medical appointments or unexplained time off 
• Visible signs of discomfort or pain 
• Comments like, “I’m having some issues that are affecting my work.” 
• Noticeable changes in performance, energy, or concentration 

Important: People may not always ask for help due to fear of stigma, privacy concerns, or uncertainty about their rights.

What You Should Do When You Notice These Signs

• Talk to your HR partners about what you’ve seen or heard. 
• Let your HR team guide you on how to handle the situation while respecting privacy. 
• If an employee requests an accommodation, contact HR immediately and follow established policies to ensure the request is properly addressed and documented. 

Your role as a manager is to support, not diagnose. Approach the situation with empathy and confidentiality, and always defer to HR for next steps.

Common Types of Reasonable Accommodations

Employers may implement accommodations such as:

• Short-term leaves of absence 
• Adjusting or flexing work schedules 
• Making facilities or equipment more accessible 
• Providing assistive technology or ergonomic tools 
• Transferring the employee to a similar job or location 
• Modifying policies (e.g., attendance or dress code policies)

Employer Limitations and Boundaries

While employers must engage in the interactive process in good faith, the ADA does not require them to:

• Reduce performance standards 
• Remove essential job functions 

Additionally, employers are not obligated to provide accommodations that would cause:

• Undue hardship (significant difficulty or expense for the organization), or
• Direct threats to the health or safety of the employee or others.

Verification and Documentation

When necessary, HR may request medical documentation to verify a disability, medical condition, work restrictions, or ability to return to work. This process should always be handled by HR, not by the direct manager, to ensure confidentiality and compliance with privacy laws such as HIPAA.

Best Practices for Managers and HR Leaders

• Train regularly on ADA and state disability laws using programs like Emtrain’s Disability Protections (ADA) Training. 
• Engage early and empathetically when performance or attendance issues arise. 
• Document all communication in collaboration with HR. 
• Encourage an inclusive culture where employees feel safe to request support.
• Audit job descriptions to ensure essential functions are clearly defined and don’t unintentionally exclude capable individuals.

Reasonable accommodation is both a compliance obligation and a leadership opportunity. When HR, compliance officers, and people leaders proactively identify and address accommodation needs, they minimize legal risks and strengthen workplace trust. Creating inclusive systems where employees feel empowered to ask for help is the cornerstone of a healthy, productive culture.

For more guidance, visit:

• ADA.gov – Employers and the ADA 
• EEOC.gov – Reasonable Accommodation Guidance

Related Emtrain Resources:

• Disability Protections (ADA) Training
  
• Support Neurodiverse Employees with Reasonable Accommodations 
• Supporting Neurodiverse Workplaces Microlesson 
• EEO Policy Template 
• Ableism in the Workplace

Video Preview: Autism Employee Discusses Challenges at Work

Scene Summary:
A neurodiverse employee with autism meets with his manager to discuss workplace challenges. Despite having a private office, he struggles with sensory overload — the noise, the hum of overhead lights, and frequent interruptions from team members entering his space.

Employee: “It’s hard to focus. The lights hum and the office is too loud. Even with a private room, people come in constantly needing something.”

Manager: “I understand. You’re part of the team, and we all interact regularly. Maybe others just want to be friendly.”

Employee: “Could they email me instead? It helps me stay focused.”

Manager: “That’s a good idea. It may also help others understand how best to collaborate with you. I hadn’t realized how distracting it was for you. We can definitely address the lighting, and let’s find ways to balance your needs with team connection. You’re valued here—let’s pinpoint what we can do together to improve the team dynamic.”

Takeaway:
This conversation models an empathetic and constructive approach to the interactive process. It highlights the importance of listening, collaborating, and identifying tailored accommodations that benefit both the employee and the team.