Disability Accommodation Request Process

Purpose

To give managers and Human Resources a consistent, documented process for handling a request for reasonable accommodation — whether the request comes from an applicant, a new hire, or a current employee — so that requests are evaluated promptly, consistently, and on an individualized, case-by-case basis.

Definition of disability

This process uses the definition of "disability" as amended by the ADA Amendments Act of 2008 (ADAAA), which is broader than the ADA's original 1990 standard and did not exist at all under the 1994-96 predecessor of this process. Under the ADAAA-amended standard:

• The definition of disability is construed in favor of broad coverage — coverage determinations should not require extensive analysis, and the focus of any dispute should be on whether the Company met its accommodation/nondiscrimination obligations, not on litigating whether the individual qualifies as disabled.
• "Major life activities" include a broad, non-exhaustive list (for example, caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, and working) and the operation of major bodily functions (for example, immune system, normal cell growth, digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine, and reproductive functions).
• Mitigating measures are generally disregarded when determining whether an impairment substantially limits a major life activity — for example, medication, medical equipment, prosthetics, hearing aids, mobility devices, or learned behavioral modifications do not count against a finding of disability. The one exception: ordinary eyeglasses or contact lenses are considered.
• An impairment that is episodic or in remission (for example, cancer in remission, or epilepsy) is a disability if it would substantially limit a major life activity when active.
• The "regarded as" prong no longer requires the individual to show the employer believed the impairment was substantially limiting — it is enough that the Company took a prohibited action based on an actual or perceived impairment, unless that impairment is both transitory (lasting or expected to last six months or less) and minor. (The transitory-and-minor exception applies only to the "regarded as" prong, not to the "actual disability" or "record of" prongs.) Note that an individual covered only under the "regarded as" prong is not entitled to a reasonable accommodation — only to nondiscrimination — so this process's accommodation steps apply to individuals with an actual or a record of a qualifying disability.

Because of this broad-construction rule, this process should rarely turn on whether someone technically "counts" as disabled — assume coverage and move directly to essential functions, the interactive process, and reasonable accommodation.

When this process applies

Use this process any time:

• An employee or applicant discloses a disability and asks for a change to how or where work is done.
• A manager becomes aware of an obvious disability and the employee is having difficulty performing part of the job.
• A need for accommodation surfaces during a pre-employment or return-to-work medical evaluation.
• An employee is returning to work from a leave of absence or workers' compensation injury and may need a temporary or ongoing accommodation.

Do not require a "magic word." An employee does not need to say "I need an ADA accommodation" — any reasonably clear request connecting a medical condition to a workplace difficulty should trigger this process.

Roles and responsibilities

Role	Responsibility
Employee/applicant	Provides information about the limitation and, where requested, supporting medical documentation; participates in good faith in identifying possible accommodations.
Manager/local leadership	Identifies the essential functions of the role; participates in the interactive discussion; implements the accommodation once approved.
Human Resources	Owns and documents the interactive process; consults with the accommodations/ADA committee on close calls; tracks requests and outcomes.
Accommodations review committee (or equivalent central HR function)	Reviews denials before they are finalized; maintains consistency across locations; advises on complex cases.

Procedure

1. Identify the essential functions of the job. Review the current job description and, if needed, a job-analysis worksheet describing physical/cognitive demands, to separate essential functions from marginal ones. An employee's inability to perform a marginal function is not a valid basis for an adverse employment decision.

1. Confirm the person is otherwise qualified. Determine whether the individual meets the job's legitimate prerequisites (education, licensure, experience, skills) independent of the disability.

1. Open the interactive process. Have the employee (and, if relevant, their healthcare provider) complete an accommodation request describing the limitation and any suggested accommodation. Medical documentation requests should be limited to what is needed to confirm the disability and understand the functional limitation — not a general medical history.

1. Identify potential accommodations. Common categories include:

• Physical/facility modifications or accessible equipment
• Job restructuring (reallocating non-essential tasks)
• Modified or part-time work schedules
• Reassignment to a vacant, equivalent position
• Assistive technology or equipment
• Modified policies, training materials, or testing format
• Qualified interpreters or readers
• Leave for treatment or recovery
• Accessible/reserved parking

1. Assess reasonableness and undue hardship. For each potential accommodation, consider effectiveness, cost, timeliness of implementation, impact on the work environment, and available resources. The employee is not entitled to their preferred accommodation — only to an effective one.

1. Decide.

• If granting: implement the accommodation, document it, and set a follow-up check-in to confirm it is working.
• If denying (in whole or part): route the case to the accommodations review committee/central HR for a pre-decision review before finalizing the denial.

1. If the denial is confirmed: document the reasoning, communicate the decision (and the reasoning, at an appropriate level of detail) to the employee, and inform them of how to request reconsideration through Human Resources leadership.

1. If implementing: document the accommodation, retain the documentation with Human Resources (separate from the general personnel file, consistent with medical confidentiality requirements), and follow up periodically to confirm it remains effective as circumstances change.

Confidentiality

Medical information gathered in this process is confidential and must be stored separately from the employee's general personnel file, with access limited to those with a legitimate need to know.

Common pitfalls to avoid

• Assuming a disability is not "real" because it is not visible.
• Focusing on whether the employee can do 100% of listed duties rather than the essential functions.
• Treating a request for reconsideration as insubordination.
• Denying a request without a documented undue-hardship analysis and central-HR review.
• Letting the interactive process stall — delay itself can be treated as a failure to accommodate.