Employment

Workplace Accommodation Requests: An Employer's Guide

An employer handling a workplace accommodation request.
Lee Clark, Business Attorney at Clark Meyers PC
Lee Clark — Co-Founder & Business AttorneyDraws on 60+ years of combined firm experience guiding owners through contracts, deals, and disputes. About Lee →

Quick Answer

When an employee requests a workplace accommodation for a disability, the employer generally must engage in an interactive process to find a reasonable accommodation, unless it would cause undue hardship. Handling requests correctly — recognizing them, engaging in good faith, and documenting the process — is both a legal duty and a way to reduce liability.

An accommodation request is the start of a process the law expects you to engage in — not a yes-or-no you get to decide alone.

A request for a workplace change due to a health condition can trigger significant legal obligations under disability law — most notably a duty to engage in an interactive process to find a reasonable accommodation. Employers who don’t recognize these requests, or who handle them dismissively, expose themselves to liability. Handled properly, accommodation requests are manageable and often resolvable. This guide is an employer’s guide to workplace accommodation requests. It is general information, not advice on any specific situation.

We help businesses get this right from the start. This is general information, not advice on a specific situation.
Problem

Mishandling accommodation requests

Ignoring or flatly denying a request breaches the duty to engage and creates liability.

Solution

Engage in the interactive process

Recognize the request, discuss options in good faith, and document the effort.

Resolution

Reasonable, compliant outcomes

Accommodations are handled properly, reducing risk and often resolving the need.

An accommodation request starts a process the law expects you to engage in.

Recognizing an accommodation request

The first step is recognizing when an employee has requested an accommodation — which, like leave requests, doesn’t require specific legal language. An employee who says a health condition is affecting their work and asks for a change may be requesting an accommodation, triggering legal duties, even without mentioning disability law. As the EEOC’s guidance on eeoc.gov reflects, the obligation arises from the substance of the request. Employers should train supervisors to recognize potential accommodation requests and route them appropriately rather than dismissing them, because failing to recognize a request is a common first misstep that leads to liability.

Flatly denying a request without engaging is where employers get into trouble.

The interactive process

Once an accommodation is requested, the employer generally must engage in an “interactive process” — a good-faith, collaborative discussion with the employee to identify the employee’s needs and explore possible reasonable accommodations. This is a two-way dialogue, not a unilateral decision. The employer can gather appropriate information about the need and the functional limitations, discuss options, and work toward a solution. The interactive process is itself a legal expectation, and failing to engage in it — or going through the motions in bad faith — is a frequent basis for liability, sometimes independent of whether an accommodation was ultimately owed. Engaging genuinely is central to compliance.

Dismissive vs. engaged handling
Illustrative — not a measured statistic.
DismissiveLiability
EngagedCompliant

Reasonable accommodation and undue hardship

The goal of the process is a reasonable accommodation — a change that enables the employee to perform their job — unless providing one would impose an undue hardship on the employer. Reasonable accommodations can take many forms depending on the situation. “Undue hardship” is a defined standard, not simply inconvenience or minor cost, and an employer claiming it must genuinely meet the standard. The employer isn’t always required to provide the exact accommodation the employee prefers, but must work in good faith toward an effective one. Understanding these standards — reasonable accommodation and the real bar for undue hardship — is key to handling requests correctly.

Documenting and handling requests well

Throughout, documentation and good faith protect the employer. Keeping a record of the request, the interactive process, the options considered, and the outcome demonstrates compliance if the handling is later challenged. Consistency across employees, confidentiality of medical information, and avoiding retaliation against employees who request accommodations are equally important. Because disability accommodation is a legally intricate area where the process itself matters as much as the result, employers benefit from handling requests carefully and seeking guidance on difficult ones. Done well, the process reduces liability and frequently produces a workable solution for both sides, which is the outcome the law is designed to encourage.

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Frequently asked questions

What is a reasonable accommodation?
A reasonable accommodation is a change to the job, workplace, or how work is done that enables an employee with a disability to perform their job, which an employer is generally required to provide unless it would cause undue hardship. Accommodations can take many forms depending on the employee’s needs and the role. The employer isn’t necessarily required to provide the specific accommodation an employee prefers, but must work in good faith toward one that is effective. Determining a reasonable accommodation is typically the goal of the interactive process between the employer and the employee following an accommodation request.
How do I know if an employee is requesting an accommodation?
An employee doesn’t need to use specific legal terms or mention disability law to request an accommodation. If an employee indicates that a health condition is affecting their ability to do their job and asks for some change or assistance, that may constitute an accommodation request triggering legal duties — even if phrased informally. This is why a common first mistake is failing to recognize a request. Employers should train supervisors to identify potential accommodation requests and route them to the right process rather than dismissing them, since overlooking a request can itself lead to liability.
What is the interactive process?
The interactive process is a good-faith, collaborative dialogue between the employer and the employee to identify the employee’s needs and explore possible reasonable accommodations after an accommodation is requested. It’s a two-way exchange rather than a unilateral employer decision: the employer can gather appropriate information about the limitation and the need, discuss options, and work toward an effective solution. Engaging in this process is itself a legal expectation, and failing to do so — or participating in bad faith — is a frequent basis for liability, sometimes regardless of the ultimate outcome. Genuine engagement in the interactive process is central to handling requests properly.
Do I have to grant every accommodation request?
Not necessarily — but you generally must engage in the interactive process in good faith and provide a reasonable accommodation unless doing so would impose an undue hardship. You aren’t required to provide the exact accommodation an employee prefers if an alternative effective accommodation exists, and you may deny an accommodation that would genuinely cause undue hardship (a defined standard, not mere inconvenience). What you generally cannot do is dismiss the request without engaging or refuse without a legitimate basis. The obligation is to work collaboratively toward an effective, reasonable accommodation, not to automatically grant whatever is requested.
What is undue hardship?
Undue hardship is the legal standard that can excuse an employer from providing a particular accommodation because it would impose significant difficulty or expense, considered in light of factors like the nature and cost of the accommodation and the employer’s resources and operations. Importantly, it’s a real, defined threshold — not simply minor inconvenience, modest cost, or a preference not to accommodate. An employer claiming undue hardship must genuinely meet the standard, and doing so typically requires more than a general objection. Because the standard is specific and fact-dependent, employers should be cautious about denying accommodations on this basis without careful analysis.
Can I ask for medical information about the disability?
Generally, an employer may request appropriate information reasonably needed to understand the disability-related limitation and the need for accommodation, but there are limits — the inquiry should be tailored to what’s necessary for the interactive process, and medical information obtained must be kept confidential. Employers should avoid overbroad or intrusive requests beyond what’s needed to evaluate the accommodation. Because there are legal rules governing what can be asked and how the information must be handled, employers should be careful and, where unsure, seek guidance. Properly and narrowly gathering the information needed — while protecting its confidentiality — is part of handling requests correctly.
How can Clark Meyers help with accommodation requests?
We help employers handle disability accommodation requests correctly: recognizing when a request has been made, conducting the interactive process in good faith, evaluating reasonable accommodations and the genuine standard for undue hardship, advising on what medical information can be requested and how to keep it confidential, and documenting the process to demonstrate compliance. We also help with difficult or contested requests and reducing retaliation risk. Because this is a legally intricate area where the process itself matters, guidance helps you handle requests both compliantly and practically. The first step is a conversation about the request you’re facing.

Sources

  1. U.S. Equal Employment Opportunity Commission — Disability Discrimination (ADA). eeoc.gov
  2. U.S. Equal Employment Opportunity Commission — Prohibited Practices. eeoc.gov
  3. U.S. Small Business Administration — Hire and Manage Employees. sba.gov

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