When an employee requests some flexibility, an ergonomic chair, or an extra break to cope with their disability, you know it’s time for the ADA interactive process.
The Americans with Disabilities Act (ADA) requires employers to walk through the interactive process for each reasonable accommodation they provide. But the law doesn’t tell employers exactly how to go about it. This ambiguity is a source of trouble for many organizations. Without clear expectations, employers sometimes skimp on communication, which can cost them later.
It’s a good moment to get wise on the interactive process. Requests for reasonable accommodations rose for the third year in a row last year, according to AbsenceSoft’s 2026 State of Leave and Accommodations report. More than half of HR leaders (56%) reported increased requests at their organizations.
If your team is also starting to field more accommodations requests, it’s worth revisiting the interactive process. In this article, we’ll define what the ADA interactive process is, what steps you should be taking, and the mistakes to avoid.
What Is the ADA Interactive Process?
At its core, the ADA interactive process is a conversation. It’s a chance for you and your employees to talk about the support they need and the resources you can provide. Unlike lots of other processes in the world of leave and accommodations management, the interactive process is simple and straightforward.
The interactive process usually begins when someone asks for an accommodation under the ADA. The U.S. Equal Employment Opportunity Commission (EEOC) says employers may also initiate it, when they know an employee has a medical condition that’s affecting their work.
During the interactive process, you should learn why the employee needs an accommodation, how their limitations impact their work, and what type of support will allow them to perform the essential functions of their job.
You’ll do a lot of listening during this process. But you’ll also share some ideas of your own. The Job Accommodation Network (JAN) is a great resource during the interactive process. It can help you learn more about your employee’s limitations and what an effective accommodation might look like.
It’s worth noting that there’s another law that requires an interactive process: the Pregnant Workers Fairness Act (PWFA). This federal statute requires employers to provide reasonable accommodations for employees with pregnancy-related conditions. The PWFA’s rules regarding the interactive process are slightly different. Chiefly, it instructs employers to make it quick and provide accommodations without much or any delay.
Who Does the ADA Cover?
The ADA’s coverage is broad, especially compared to other federal laws like the Family and Medical Leave Act (FMLA). It applies to any U.S. employer with more than 15 employees. Eligible employees include anyone with a physical or mental impairment that substantially limits a major life activity.
Here’s what the ADA means by that. When an employee’s limitation is significant enough to impact the way they walk, talk, hear, see, or work, they have a disability. Disabilities can include many different conditions like allergies, migraines, bipolar disorder, and speech impairments, just to name a few.
The PWFA covers employees with pregnancy-related conditions. This includes employees whose limitations are made worse by pregnancy.
How Does the Interactive Process Work? A Step-By-Step Guide
As an employer, you’re required to engage in the interactive process when one of your employees asks for an accommodation. But the ADA doesn’t spell out exactly what the interactive process looks like. There is no official checklist or set of required steps.
Despite this, we do know that the interactive process is meant to help employers and employees get on the same page. It’s a conversation that should allow employees to express what they need, while giving employers a moment to figure out the kinds of support they can provide.
Below, we walk you through a six-step approach to the interactive process. This approach will allow you to lead a good faith conversation. You’ll identify requests, get the information you need, and create a plan that works for you and your employee.
Step 1: Recognize the Request
Requests can be hard to spot. An employee might be complaining about their symptoms getting in the way of their productivity. Or they might casually reference how they’d benefit from a change in their work schedule or a more supportive chair. These requests may not use the language of the ADA, but they’re still valid. Managers, in particular, need training so they can recognize all types of requests and get the rest of the process rolling.
Step 2: Open the Dialogue Promptly
Don’t wait around to start the interactive process. The U.S. Equal Employment Opportunity Commission, which enforces the ADA, warns employers that unnecessary delays may violate the law. So when an employee asks for help, open a dialogue right away.
Step 3: Gather Medical Information
Next, employers should find out what limitation the employee is dealing with, and how it impacts their job duties. Employers can make inquiries about a medical condition when necessary. For example, HR may ask employees to submit documentation when their disability is not obvious.
Step 4: Identify the Essential Functions of the Job
It’s important to identify the essential functions of the employee’s job to determine the support they need to carry out those duties, even with their limitation. This step is easier when job descriptions are documented and up to date.
Step 5: Explore Accommodation Options Together
At this stage, it’s important to get collaborative and creative. Your employee will likely have an idea of the support they need, whether that’s remote work, a modified schedule, an assistive device, or intermittent leave. Work together to find an option that works for both of you.
Step 6: Implement and Follow Up
Once you’ve selected an accommodation, it’s time to put it in place. Remember that the process doesn’t end at approval. Follow up with the employee at regular intervals to see whether the accommodation needs any adjustments.
Reasonable Accommodations and Undue Hardship
Sometimes, an employee asks for an accommodation that you can’t provide. The ADA has a name for this situation: undue hardship. Undue hardship occurs when an accommodation would require significant difficulty or expense given the employer’s size, resources, or the nature of the request. It’s not a blanket excuse. Employers must evaluate each request for accommodation on its own. This can be a challenging task. Half of HR leaders in an AbsenceSoft survey said determining undue hardship was a top challenge.
To provide some clarity, let’s walk through a couple of examples. Imagine a nurse who works in a hospital asks for remote work to help with their arthritis. The hospital could likely deny their request to work from home since working in person is an essential function of the job. Now imagine that a copywriter with arthritis asks to work from home. It’s harder to claim undue hardship for this request, as in-person work is not necessarily an essential function of copywriting or other desk roles.
Common Mistakes That Create Legal Risk
The ADA doesn’t tell employers how to handle the interactive process. But the law sets a few standards HR must follow. Below, we lay out the most common mistakes employers make when it comes to the interactive process.
- Ignoring Mental Health Requests
Mental health is the No. 2 driver of accommodation requests, just behind recovery from illness, injury, or surgery. Most employers recognize the importance of mental health support. But a few employees (7%) said their employer seemed skeptical that mental health conditions qualify for accommodations. - Don’t Dawdle or Delay
Delays are common in the interactive process. A quarter of employees said they waited more than two weeks for a decision regarding their request, according to an AbsenceSoft poll. This is a major risk for employers. The EEOC is clear that unnecessary delays can violate the ADA. - Inappropriate or Unnecessary Questions
Seven percent of employees in an AbsenceSoft survey reported they were asked invasive questions about their medical conditions. Employers may need to verify an employee’s limitation, but their questions shouldn’t probe too deeply. - Failing to Document
HR must document the interactive process thoroughly to establish a record of compliance. Record requests, communications, meetings, choices, and check-ins, storing them in one central location.
The Manager Problem
Managers play an outsized role in the accommodations process. They field requests, help implement solutions, and check in on employees to see how their accommodations are working out. Despite this, 42% of HR leaders believe managers don’t understand how to handle accommodation requests properly, according to AbsenceSoft research.
Managers’ lack of know-how may stem from a lack of training. AbsenceSoft research revealed that only 69% of organizations provide routine manager training on accommodations policies. A quarter cover it at onboarding only, and 7% give managers no accommodations training whatsoever.
The manager gap has serious consequences. Managers can unknowingly violate the ADA by missing requests, denying accommodations, or creating delays. Any of these outcomes can happen without HR knowing there’s been a request.
To ensure your managers are up to speed on the ADA, hold trainings regularly. Provide information in a variety of formats, from lectures to handbooks. And consider giving managers checklists or other visual reminders to help them spot requests and send employees to HR.
How Technology Optimizes the Interactive Process
It’s tempting to administer the interactive process with manual tools. After all, it’s just a conversation. Many teams take this approach: 43% of organizations track the accommodations process with spreadsheets and calendar reminders, according to AbsenceSoft research.
The interactive process can greatly benefit from technology. With the right set of tools, your team can make sure no request falls through the cracks. Purpose-built platforms can route requests, document each step, automate follow-up, and create an audit trail.
Tech also ensures the interactive process looks and feels consistent for every one of your employees. AbsenceSoft offers a guided interactive process so that employees experience the same steps any time they ask for support. Our platform supports compliance with the ADA and PWFA out of the box.
Ace the Interactive Process With AbsenceSoft
The interactive process is where most ADA mistakes happen. Your greatest compliance risks aren’t in your policy but in its execution and delivery.
More employees are asking for accommodations each year. As requests rise, your team’s workload gets bigger. So does the risk of mistakes.
Technology can help. With an accommodations management platform like AbsenceSoft, you can track, implement, and monitor support for your employees. AbsenceSoft provides employees an easy, discrete way to ask for help, and it gives managers and HR the infrastructure they need to respond in a way that’s compliant and consistent.
To learn more about how AbsenceSoft can help your team provide accommodations at scale, book a demo today.
FAQ on the ADA Interactive Process
-
The ADA interactive process is a good faith conversation between an employer and an employee with a disability to identify a reasonable accommodation. It typically begins when an employee requests support, though employers can also initiate it when they know a medical condition is affecting performance. There is no official checklist required by law, but the process should be prompt, documented, and collaborative. AbsenceSoft provides a guided interactive process that ensures every request follows the same compliant, consistent steps.
-
The ADA does not set a specific deadline, but the EEOC is clear that unnecessary delays can constitute a violation of the law. In practice, that means acting promptly once a request is made. According to AbsenceSoft research, a quarter of employees waited more than two weeks for a decision, which creates real legal exposure. Purpose-built platforms like AbsenceSoft automate follow-up and track timelines so requests never stall without anyone noticing.
-
Failing to engage in the interactive process is one of the most common ways employers run afoul of the ADA. Even if an accommodation is ultimately provided, skipping or shortcutting the process can be considered a violation. Documentation gaps are particularly risky: without a record of each step, employers have little to show in the event of an EEOC complaint or lawsuit. AbsenceSoft documents every stage of the interactive process automatically, creating an audit trail that is always ready if a complaint arises.
-
Undue hardship occurs when providing a requested accommodation would require significant difficulty or expense given the employer’s size, financial resources, or the nature of the business. It is not a blanket reason to deny accommodations, and each request must be evaluated individually. Determining undue hardship is one of the top challenges HR leaders report, according to AbsenceSoft research. When in doubt, document your reasoning thoroughly and consult legal counsel before denying a request.
-
Managers play a critical role in the interactive process, often receiving the initial request before HR is ever involved. But 42% of HR leaders say managers do not understand how to handle accommodation requests properly, according to AbsenceSoft research. Untrained managers can unknowingly deny accommodations, create delays, or miss requests entirely, all of which can create legal exposure. Regular manager training, combined with clear escalation protocols and a platform that guides managers through the process, significantly reduces that risk.