When an employee with a disability requests a reasonable accommodation, is it ever appropriate to say no?
The Americans with Disabilities Act (ADA) requires employers to provide eligible employees with reasonable accommodations that allow them to perform the essential functions of their jobs. However, employers are not required to provide accommodations that would create undue hardship.
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 many in HR, this determination is one of the most difficult parts of managing accommodations. In fact, according to a recent AbsenceSoft, deciding whether an accommodation is reasonable is a top challenge for HR teams. This challenge becomes even more complex as requests increasingly involve mental health needs, chronic conditions, or return-to-office considerations — especially for large and distributed organizations.
In this blog, we will unpack the ADA’s undue hardship standard, explore the challenges HR teams face when managing accommodations, and discuss how centralized technology can help create a more consistent and compliant process.
Why Reasonable Accommodation and Undue Hardship are Hot Topics in 2025
The majority of HR managers polled in AbsenceSoft’s annual survey reported an increase in accommodation requests — an uptick respondents have flagged for two years in a row. This rise in requests puts pressure on HR teams, who must keep up with an ever-lengthening list of requested accommodations.
But the number of requests isn’t the only thing impacting HR’s workload. The nature of these requests is also changing, with workers asking for more complicated accommodations like remote work and intermittent leave.
The popularity of these solutions is likely linked to the conditions causing employees to seek them. According to our respondents, mental health conditions and chronic conditions were the top two reasons employees requested job accommodations in the past year. Given the nature of these conditions, it’s no surprise that accommodations granting employees greater flexibility are requested often.
As HR teams field a growing number of complex requests, they’re experiencing several challenges. The challenge reported most often by our survey respondents was “knowing if an accommodation is reasonable.” HR has been particularly challenged by determining whether remote work can be a reasonable accommodation. Unfortunately, there’s no clear-cut answer; like many accommodations, its status as reasonable depends on the limitations of a worker and the context of the employer.
The Two Most Common — and Complex — Requests
Remote work and intermittent leave top the list of employee-requested accommodations, according to our report. These solutions represent a departure from more traditional accommodations.
Traditionally, accommodations most often involved physical solutions a ramp for wheelchair users; closed captions for the hard of hearing; an ergonomic stool for those with back problems. These accommodations were easy to administer: the organization simply provided the solution the employee needed. Accommodations like remote work and intermittent leave are much more challenging to carry out.
First, HR must reckon with what survey respondents named the top accommodation challenge — deciding whether a requested accommodation is indeed reasonable. Assuming it is, HR must work with the employee and their supervisors to create a new schedule or work arrangement, including how long the new status quo will continue.
This step highlights the importance of the interactive process, something the U.S. Equal Employment Opportunity Commission (EEOC) urges employers to take part in when working through an accommodation request. While the ADA does not explicitly require the interactive process, the EEOC strongly encourages it, and courts often view it as best practice.”
Finally, HR may need to be prepared to answer questions about someone’s accommodation from other employees. It’s understandable: accommodations like remote work are in high demand among all workers. But it’s important to remember that information regarding someone’s disability is confidential. Allow employees to choose if and when to disclose their own conditions.
What Counts as Undue Hardship?
The ADA obligates employers to provide reasonable accommodations to employees with disabilities, unless doing so would cause the employer undue hardship. According to the EEOC, undue hardship “means that an accommodation would be unduly costly, extensive, substantial or disruptive, or would fundamentally alter the nature or operation of the business.”
A few different factors should be considered in determining whether an accommodation is an undue hardship:
- The cost of the accommodation.
- The employer’s size.
- The organization’s financial resources.
- The nature and structure of the company’s operation.
To understand undue hardship as accurately as possible, it’s helpful to consider a few examples.
Let’s say that an emergency room nurse with major depressive disorder asks for intermittent leave as an accommodation. The emergency room already struggles with understaffing, and the nurse’s unforeseen absences could obstruct the hospital from meeting legally required staffing ratios. The employer would need to work with the employee to find another accommodation, as the one proposed would create undue hardship based on operational disruption.
Consider another example. Imagine that an elementary school teacher with chronic laryngitis asks for a microphone and speaker to communicate with his class more easily. The sound system is expensive, and likely more than the school itself can afford. If the school was a standalone organization, the price may have been grounds for undue hardship, and the parties would have had to seek another accommodation. But let’s say this school belongs to a large district. The school must consider the overall resources of the facility at large. In this imaginary case, the district could afford the sound system.
Let’s contemplate one more example. Imagine a big-box hardware store where employees restock heavy materials overnight. One of these employees asks for a schedule change due to her insomnia — she’d sleep better if she worked the dayshift. But this employee is one of the store’s only employees with a license to operate the machinery needed to lift its heaviest merchandise onto shelves. Because no one else is licensed to do what this employee does, the store cannot reassign her job duties. HR will need to work with the employee to determine another accommodation.
Why Undue Hardship Can’t Be a Guessing Game
Employers can’t afford to claim undue hardship wrongfully, for several reasons.
First, there are compliance and legal risks that come with improperly denying a requested accommodation. The EEOC files many lawsuits alleging disability discrimination each year. And many employers end up with hefty fines as a result. In 2024, one employer was ordered to pay more than $1 million following a disability discrimination lawsuit from the EEOC.
Organizations should also consider the impact the accommodations process has on their workplace and employees. According to our 2025 report, employees who felt they had a poor accommodations experience reported multiple frustrations, including:
- They weren’t able to get the accommodation they needed.
- Their request was denied and they struggled to do their jobs.
- They had to endure a difficult process to get their accommodation.
More than one-third of employees waited longer than a month for a decision regarding an accommodation, or never heard back at all.
When survey respondents experienced these frustrations, their relationship with their employer suffered. More than two-thirds of employees with poor accommodation experiences said they didn’t feel valued and supported by their workplace. About 40% said they weren’t motivated or started looking for a new job.
The good news? Poor accommodations experiences can be mitigated, even when employers run into undue hardship. By providing manager training, leaning into the interactive process, and using purpose-built technology, employers can provide a positive, consistent accommodations experience for all.
How AbsenceSoft Helps HR Get It Right
In addition to the challenges and frustrations HR encounters in managing accommodations, our report also revealed the solutions HR seeks to improve the employee experience and streamline their workload. The top change HR managers desired was improved technology. Employees, too, displayed a desire for streamlined, modern processes enabled by technology.
AbsenceSoft’s accommodations platform satisfies these needs directly. Our system standardizes and simplifies decision making. With it, HR can:
- Centrally track the interactive process.
- Document medical information and decision rationale.
- Set internal timelines to avoid unnecessary delays.
- Leverage intelligent automation to ensure consistency and efficiency.
The AbsenceSoft platform also provides real-time data, ensuring HR teams are equipped with the most relevant, up-to-date data on employees with accommodations. It also creates automated reminders that keep busy team members on task and on pace.
Supporting Employees While Protecting the Organization
Employers may be obligated to provide reasonable accommodations, assuming no undue hardship is present. But they’re not necessarily obligated to spend a lot of money to do so. According to the Job Accommodation Network (JAN), half of accommodations are free. These could include modified break schedules, extra managerial support, or alternative forms of training materials.
JAN also reported that most accommodations with a one-time expense cost less than $300.
It’s only fair to acknowledge that, while most accommodations are free or inexpensive, some will come with a heftier price tag. No matter the price, however, accommodations are highly valuable to employers.
When organizations readily provide accommodations, they create a supportive culture while also reducing legal exposure. Employers can also shore up retention and output through accommodations management. As our survey revealed, when employers offer employees an accommodations experience that’s efficient, compassionate, and discreet, employees are more loyal, motivated, and productive.
Enhance Your Approach to Accommodations Management
It’s difficult to understand when a requested accommodation constitutes undue hardship. But pinpointing this threshold is essential to maintaining a compliant accommodations program. Thankfully, it’s achievable, too.
With efficient processes and effective tools, HR can hone its approach to accommodations to ensure that every employee’s request for accommodation receives timely and fair consideration. When HR determines that the undue hardship standard has been met, the team can lean on the interactive process to come up with alternative solutions that work for the business and the employee.
Curious to learn more about managing accommodations with efficiency and compassion? Visit AbsenceSoft’s resource center. To discover how AbsenceSoft can refine your organization’s approach to accommodations, book a demo today.