Managing ADA Accommodations Legally in 2026

The Americans with Disabilities Act protects employees from discrimination based on disability and requires employers to provide reasonable accommodations. To satisfy the law, HR must establish a repeatable, defensible process.

1. Triggering the Interactive Process

The interactive process is triggered as soon as an employee makes a request for accommodation or indicates they need help performing their job duties due to a medical condition. The employee does not need to cite the ADA or use terms like "reasonable accommodation." HR must acknowledge the request immediately and schedule a dialog.

2. Drafting a Defensible Meeting Agenda

During the good faith conversation, the employer should focus on:

• Identifying the essential functions of the employee's job description.
• Reviewing the precise medical limitations provided by the physician.
• Discussing the employee's preferred accommodation.
• Brainstorming alternative accommodations if the preferred option creates business hurdles.

3. Documenting the Decision and Next Steps

Once a decision is reached, it must be documented in writing. If the request is approved, issue an Accommodation Agreement detailing the start date, expectations, and a schedule to re-assess the arrangement (e.g. 90 days). If the request is denied due to Undue Hardship, ensure you have documented all financial and operational constraints.