The Americans with Disabilities Act (ADA) is one of the most important pieces of legislation governing the workplace. It’s also one of the more open-ended employment laws, with the ADA interactive process playing a key part in workplace accommodation compliance. While other laws tell employers exactly how to provide leave, break time, benefits or wages, the ADA gives organizations more flexibility and room for creativity.
This freedom is crucial to providing a high-quality employee experience. It enables employers to collaborate with employees on the type of support they need. But it also makes ADA compliance a little complicated. How can employers be certain they’re following the law’s requirements when it allows for so much leeway?
In this comprehensive guide, we’ll cover ADA compliance, reasonable accommodation, and ADA compliance software. We’ll show you how to leverage technology to meet employees’ unique needs while remaining compliant with the ADA.
What is a Reasonable Accommodation Under the ADA?
To fully understand how the ADA applies to the workplace, it’s important to grasp the definition of a reasonable accommodation. As the U.S. Equal Employment Opportunity Commission (EEOC) puts it, a reasonable accommodation is simply a change or adjustment to a job or work environment.
Crucially, a reasonable accommodation is something that permits a qualified applicant or employee to:
- Participate in the job application process.
- Perform the essential functions of a job.
- Enjoy the benefits and privileges of employment equal to those enjoyed by employees without disabilities.
The ADA covers any employer with 15 or more employees, which means that organizations must be ready to provide reasonable accommodations to individuals with disabilities. According to the statute, that group includes people with a physical or mental impairment that substantially limits a major life activity. Major life activities encompass things like walking, talking, thinking, and reading. An employee with migraines, ADHD, depression, or mobility impairments may have ADA-qualifying disabilities.
Many employees are asking for support for their disabilities. In fact, 56% of employers saw an increase in accommodation requests last year, according to AbsenceSoft’s 2026 State of Leave and Accommodations Report. Reasonable accommodations come in many different forms, but there are a few categories that provide some clarity. These include modifications to a work environment, schedule adjustments, tweaks to someone’s duties, and policy changes.
According to our survey, top-requested accommodations include remote work, reduced schedules, and continuous leave.
An employee in customer relations who is hard of hearing, for example, may need a special headset to communicate effectively. A worker with mobility issues may need a parking space reserved close to the office or the ability to work from home. An employee with depression may need a schedule adjustment and intermittent leave to attend therapy appointments.
It’s worth mentioning that the ADA isn’t the only law to provide reasonable accommodations. The Pregnant Workers Fairness Act compels employers to provide quick access to certain adjustments related to pregnancy. In fact, there are a few accommodations — for example: additional breaks for eating, drinking, and using the bathroom — that the PWFA says should be granted in virtually all situations.
While the ADA requires employers to provide reasonable accommodations in many circumstances, employers are not required to provide accommodations that would create what’s known as undue hardship. It can be difficult to determine when an accommodation poses undue hardship. According to our data, 50% of employers struggle to know when this is the case.
Undue hardship occurs when a proposed accommodation would create significant cost or disruption for an employer. The ADA does not offer a list of specific scenarios that meet this standard. Instead, employers must evaluate each request individually, weighing the law’s criteria against their own circumstances.
For more on accommodation requests, download The Modern ADA and PWFA Compliance Toolkit.
The Interactive Process: Step-by-Step Compliance Requirements
When an employee needs a reasonable accommodation, the EEOC requires employers to deliver it via the interactive process. The interactive process is a back-and-forth conversation between employer and employee that ends in the successful implementation of a reasonable accommodation.
While there are no strict guidelines regulating the interactive process, employers can take a number of steps to ensure compliance. It’s worth noting that the EEOC expects employers to respond to requests for accommodations promptly. Many organizations need to prioritize timeliness; according to our 2025 survey, 34% of employees waited more than a month for their accommodation.
Step 1: Recognize the request, even if it’s informal
An employee may not use the language of the ADA to ask for support. Their request for accommodation may look more like a cry for help. An employee, for example, may simply complain about how her knee pain or anxiety are interfering with her work. No matter how an employee phrases the request, employers should respond quickly and compassionately.
It’s at this point that employers should document the beginning of the interactive process. An organization may want to open a new case when an employee expresses frustration related to a disability. That way, the employer can track the developments that follow.
Step 2: Gather information, from medical documentation to job requirements
Once an employee has disclosed a limitation, employers should work to uncover the limitation and how it impacts their job duties. The employee will likely provide the best information about their disability. Employers can, however, make inquiries about a medical condition when necessary. However the employer gets this information, it should store it centrally and securely with the other details regarding this case.
Step 3: Explore accommodation options
Next, the employer should work with the employee to come up with potential accommodations. This effort should be collaborative. The employee may have suggestions about how she would like to deal with her knee pain or anxiety, for instance. The worker’s medical provider may also be able to share some ideas.
The employer or HR should document the accommodation options discussed at this point. This not only establishes a record of compliance but also creates a list of options the organization can return to if early attempts at accommodations fail.
Step 4: Choose and implement the accommodation
The EEOC does not require the employer to choose the accommodation most preferred by the employee. It’s a good idea, however, to go with the employee’s top choice when possible.
Remember, employers can offer a trial period for an accommodation to test whether it will be successful in the long term. When an accommodation is chosen, the employer must document that it picked and implemented a solution.
Step 5: Monitor and follow up with the employee
Once an organization has implemented an accommodation, it’s crucial to monitor its success. It’s best practice to set concrete dates for check-ins. The employer can chat with the employee to see whether the accommodation has created the change they wanted.
Common Compliance Risks and How to Avoid Them
The ADA may be somewhat open-ended, but that doesn’t mean compliance is unimportant. Your organization can maximize compliance by minimizing a few common risks.
Below, we walk through five issues that are persistent problem areas for employers. By paying attention to these blind spots, your organization can build an accommodations management program that’s effective, efficient, and compliant.
Risk 1: Delayed response or no response
When an employee approaches you or a member of your team with anything that resembles an accommodations request, it’s crucial to act quickly. According to our survey, 36% of employees waited more than a month to receive an accommodation. Most shockingly, a whopping 7% of our respondents never heard back about their request.
The ADA may not maintain specific timelines around the interactive process. But EEOC says employers should “act promptly” when providing an accommodation. The agency points out that unnecessary delays can be a violation of the ADA.
The PWFA is slightly more prescriptive. The EEOC has emphasized that the interactive process for PWFA-related accommodations should be quick.
Risk 2: Forcing leave over accommodations
It’s not uncommon for employers to put people on leave when they fail to find an accommodation. In fact, when AbsenceSoft surveyed employees about their leave and accommodation experiences, several people reported encountering this experience.
“I was denied the accommodation and had to leave work on disability,” one person reported.
While leave is a commonly requested and often productive accommodation, it’s a mistake to force individuals on leave when another solution is possible. Disability-related leaves provide employees the time they need to address their health needs while keeping their job and, sometimes, receiving compensation or benefits.
Someone with anxiety, for example, may need intermittent leave as an accommodation so they can attend therapy appointments during work hours. A worker with debilitating morning sickness may need a few weeks of leave while they navigate the beginning of pregnancy.
Leave may be the most appropriate accommodation for these workers. Depending on the specifics of the situations, however, HR could provide another equally successful accommodation. The worker with anxiety, for example, may have benefitted from a flexible lunch break during which they could attend telehealth appointments. The employee suffering from morning sickness may have been able to work from home.
The bottom line? While leave can be an appropriate accommodation, it’s important to explore other solutions and prioritize bringing people back to work.
Risk 3: Misguided managers
When employees want to request an accommodation, 45% of them go to their managers first, according to our data. But only 69% of organizations provide routine manager training on the ADA.
The organizations that don’t provide regular and robust manager training expose themselves to risk. Untrained managers create liability. When they don’t know how to recognize and respond to ADA-related requests, they may botch the interactive process — or fail to initiate it altogether.
This risk is only heightened by the PWFA. The PWFA requires employers to provide certain accommodations with no deliberation. When managers don’t know to implement such requests automatically, they could create legal trouble down the road.
Risk 4: Inadequate documentation
To establish a record of compliance, HR must document the interactive process thoroughly. Requests, communications, meetings, choices, and check-ins must be recorded and stored in a central location.
It’s important to remember that employees may disclose private medical information throughout the interactive process. Employers must be careful to avoid HIPAA violations by storing ADA-related information securely and maintaining confidentiality.
Risk 5: Inconsistent decision-making
The ADA allows for a certain amount of flexibility. Two employees with similar disabilities may require two different accommodations, depending on their jobs, situations, and challenges.
This flexibility is important, as it ensures employees can get the accommodations they need. But it also makes room for inconsistencies, which can create the appearance of bias or favoritism.
These outcomes are more likely when it comes to in-demand accommodations. Consider remote work, for example. If HR approves a remote work accommodation for one employee and denies it for another, employees may be understandably frustrated.
To reduce inconsistencies, organizations should use clear criteria for accommodation-related decision making. That way, they can make decisions with clarity and confidence, even when the accommodation is in high demand.
Managing Reasonable Accommodations at Scale
Accommodations management is a huge challenge for many organizations. Why? Because they’re taking the wrong approach.
Forty-three percent of organizations use manual processes to manage their accommodations programs, according to our 2026 survey. That means they’re turning to tools like spreadsheets and email to organize something as complicated, disparate, and open-ended as accommodations.
When employers use manual methods for accommodations, they expose themselves to several risks. Managing accommodations via email or spreadsheets may mean losing documentation, missing follow-up appointments, or making inconsistent decisions.
For the employers handling accommodations this way, the risk of mistakes is only growing. Request volumes are growing bigger, and the requests themselves are getting more complicated.
Our data shows that employers are seeing a cumulative 125% increase in requests. Among those, mental health is a top driver of accommodation requests. Meanwhile, 62% of employers have implemented return to office mandates, meaning that more employees are asking for remote work accommodations.
Benefits of centralized accommodation management
In light of these realities, many employers are implementing a centralized approach to accommodation management. This strategy entails using a purpose-built platform to create consistent, compliant processes driven by automation.
A technology-centric approach to accommodations creates a host of benefits for employers, including:
- Consistent interactive process: When organizations use an accommodations system, they ensure consistency within the interactive process. When they open a new accommodations case, the system will prompt them to follow a standardized procedure each and every time.
- Secure medical documentation storage: Documentation is a key part of accommodations management. But it’s essential to keep medical information accessible and secure. With the right platform, HR can organize medical documentation quickly and securely with each and every case.
- Audit trails for compliance: A centralized platform ensures that HR and managers can access all notes, decisions, and documentation
- Manager guidance and routing: When an organization implements an accommodations system, managers are less prone to mistakes. When a manager opens a new case, the platform will automatically prompt them to take the next recommended action, whether that’s planning a meeting, scheduling a check-in, or involving HR.
- Reporting on trends and decisions: A system like AbsenceSoft harnesses accommodations data to provide meaningful, actionable insights into your accommodations program. Reports like our accommodations overview report reviews open accommodations cases, accommodations requests by type, and the average duration of accommodations requests.
Integrating accommodations with leave management
Employers that use technology to optimize their approach to accommodations should consider using the same platform to improve their leave management strategy. The AbsenceSoft platform, for example, tracks accommodations and leave together.
This unity is important because accommodations and leave are often intertwined. Leave, of course, is a common accommodation. In fact, after remote work, leave is the most requested accommodation.
Leave is also a precursor to further accommodations. Let’s say an employee has a hip replacement surgery. The employee will need to take leave as part of his recovery. When he returns to work, there’s a strong possibility that he’ll return with restrictions due to his condition. These restrictions may require an accommodation. The employee may need to be on light duty. Or he may need extra breaks to stretch.
When employers manage leave and accommodations within one platform, their work will be streamlined by tracking the two subjects in one place.
Technology considerations
When your organization is considering adopting a leave and accommodations management platform, there are several key considerations to make.
First, determine whether the system at hand is purpose-built or an add-on module. A purpose built platform is one created expressly for leave and accommodations management. Add-on modules can do some of the basic functions, but aren’t built solely for these purposes.
You should also consider how the platform prioritizes compliance. The AbsenceSoft system offers a compliance engine that helps organizations manage compliance requirements, even across multiple states.
It’s also important to consider how a platform uses artificial intelligence. AbsenceSoft leverages AI to automate repetitive processes, but we build in plenty of human oversight. This is especially important as 51% of HR professionals use AI tools like ChatGPT in the accommodations process, according to our survey.
Best Practices for a Compliant Accommodations Program
As you hone your approach to accommodations, you’ll want to focus in on a few key areas to maximize your success. Here are the best practices of a compliant accommodations program:
- Clear policies: Maintain a written accommodations policy that explains your employees’ rights and your organization’s processes.
- Regular manager training: Frequent, robust training offered beyond onboarding will ensure your managers know how to handle accommodations.
- Strong employee communications: Simplify requests by implementing technology with self-service options. This makes it easy, efficient, and discreet for employees to request an accommodation.
- Documentation standards: HR and managers should understand what to document and where to store information securely.
- Consistency frameworks: Create criteria for difficult decisions like evaluating undue hardship and approving remote work eligibility.
- Follow-up protocols: An accommodation that works this year may not work next year. It’s important to check in on employee support to ensure their success.
- Privacy protection: Accommodations management often involves sensitive employee information. It’s crucial to protect employees’ privacy as you implement accommodations.
- Regular program review: Use data to analyze trends, identify gaps, and update policies.
- PWFA readiness: Expand accommodations and maximize efficiency for pregnancy-related conditions.
The ROI of Robust Accommodations
When employers prioritize compliance in employee accommodations, they won’t just eliminate the risk of expensive mistakes or embarrassing blunders. They’ll also elevate the employee experience.
Accommodations have a profound impact on workplace culture. According to our research, 68% of employees who had a positive accommodation experience felt valued and supported.
Unfortunately, the opposite is also true. Two-thirds of employees who had a poor accommodations experience no longer felt valued. And 40% started searching for a new job as a result.
These findings underscore the importance of accommodations. They also demonstrate the ROI of getting accommodations right. When employers provide quick, compassionate access to accommodations, they can boost retention, improve productivity, and reduce legal risk.
If you’d like to learn more about improving your organization’s approach to accommodations, check out these AbsenceSoft resources today or book a demo.