What Employers Should Know About Reasonable Accommodations

When it comes to reasonable workplace accommodations, how reasonable is “reasonable?” And what constitutes a reasonable accommodation? While “reasonable accommodation” is a familiar term in the workplace, it’s not always fully understood. Understanding what is considered a reasonable accommodation for a medical condition can require a knowledge base and effort some employers cannot shoulder alone. But failing to understand the many factors associated with making an accommodation can create significant issues for the company and requesting individual. Here’s what employers should know about reasonable accommodations.

Defining a reasonable accommodation

According to Americans with Disabilities Act (ADA) guidelines, an accommodation is defined 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.”¹ An accommodation is considered reasonable if it does not create an undue hardship for the employer. Because a reasonable accommodation can come in different forms, an employer must look at all factors, including the individual’s disability, the job functions, the work environment, and the impact the disability has on the individual’s ability to perform the job.

Undue hardships

According to the ADA, an undue hardship “refers not only to financial difficulty, but to reasonable accommodations that are unduly extensive, substantial, or disruptive, or those that would fundamentally alter the nature or operation of the business.”² An example of an undue hardship would be if an accommodation request involves hiring additional employees to help perform an individual’s job. Another example could be if a job applicant requests the removal of any lifting requirements for a role that specifies “Frequently moves boxes weighing up to 50 pounds” as a primary responsibility under the job description.

When is a reasonable accommodation required?

Under the ADA, reasonable accommodations are required for those who meet the ADA’s broad definition of a disability. Under the ADA, a disability is defined as any physical or mental condition that substantially limits a major life activity (e.g., walking, seeing, talking etc.).³ According to ADA guidelines, a person with a disability can also include individuals who were previously disabled. For example, someone in remission from cancer is protected by the ADA and could require a reasonable accommodation.⁴

Examples of workplace accommodations

If an accommodation request meets ADA guidelines for providing the accommodations needed for an individual to perform essential job functions, the employer must make the necessary workplace modifications or adjustments where an undue hardship is not incurred. Some common accommodations may include:

• Modified work hours
• Extra breaks or leave
• Modified job duties
• Remote/hybrid work schedules
• Assistive technology
• Interpreter services
• Accessible parking
• Alternative format for work materials (e.g., Braille, larger print)

Best practices

Assessing a reasonable accommodation request can be difficult for employers to navigate, especially if they’re unclear about what is expected of them. Applying certain best practices can help simplify the process for both the requesting individual and company while following ADA guidelines:

1. Remember that there is no federally mandated process for requesting an accommodation. An individual does not have to request a reasonable accommodation in writing, but an employer may request a written statement to initiate a company’s ADA accommodation process. An employer may establish a formal accommodation policy and procedure. By establishing company policy and procedures for accommodation requests, an employer can position itself for ADA compliance while helping ensure ADA accommodation requests are handled efficiently and consistently. A formal process can also help to provide clarity, so employees will know what to expect upon requesting an accommodation.
2. Manage each accommodation on a case-by-case basis. Every accommodation should fit the specific needs of the individual, and the factors that define a reasonable accommodation vary based on the requester’s circumstances.
3. Keep communication open. Allow the process to be a collaboration that includes the job applicant or employee. Encourage the individual to share ideas. Chances are the individual knows what accommodation is needed to meet the job qualifications or perform essential job functions.
4. Keep the overarching goal in mind. The reasonable accommodation process isn’t designed to give employees an unfair advantage. It’s designed to level the playing field for individuals with disabilities to ensure they can complete the job application process and perform essential job functions with no restraints.

Medical consultations for ADA accommodation requests

Through Medical ReviewStream™, Concentra® offers medical consultation services that can assist employers in evaluating the disability alongside the requested accommodation from the individual with the disability. Whether it’s from a job applicant, new hire, or long-time employee, an employer must address an accommodation request. But understanding how to evaluate a request from an individual who has indicated a need for reasonable accommodations is not always a straightforward process.

Concentra’s medical consultants offer practical medical guidance to company administrators who must evaluate ADA accommodation requests from employees or job applicants with a disability.

Concentra’s medical consultation services do not replace an employer’s existing policy on reasonable accommodation. Instead, the consultative program can supplement an employer’s ADA policy and training, adding a layer of occupational health expertise and medical insight that an HR administrator can consider while making decisions during the ADA accommodation process.

For more information about Concentra’s medical consultation services, or for assistance in evaluating the medical considerations of the reasonable accommodation process at your workplace, please visit our website or contact your nearby Concentra medical center. 

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Notes

1. Enforcement Guidance on Reasonable Accommodation and Undue Hardship under the ADA.U.S. Equal Employment Opportunity Commission.
2. Disability Discrimination and Employment Decisions. U.S. Equal Employment Opportunity Commission.
3. U.S. Equal Employment Opportunity Commission. Fact Sheet: Disability Discrimination.
4. Cancer in the Workplace and the ADA. U.S. Equal Employment Opportunity Commission.