A Reasonable Accommodation Request Needs an Interactive Process File, Not a Snap Answer
A reasonable accommodation interactive process checklist helps small employers recognize a request, clarify the work barrier, compare effective options, protect medical information, and document the decision.
An accommodation request becomes manageable when the employer separates the employee's work barrier, the essential job functions, possible effective changes, and the final decision into one prompt and confidential process.
When an employee asks for a work change because of a medical condition, treat it as a possible reasonable accommodation request even if the employee never says "ADA" or "accommodation." Confirm the request, identify the job barrier and essential functions, gather only permitted information, compare effective options, document the decision, and set a follow-up date.
Do not force the request into a performance review, demand a diagnosis before discussing the work problem, promise the employee's preferred option immediately, or let a supervisor keep medical details in ordinary personnel notes.
The Reasonable Accommodation Interactive Process Kit adds editable intake, essential-functions, option-comparison, documentation-request, decision, implementation, and follow-up tools behind this free checklist.
Build six lanes before making the accommodation decision
| Lane | What to capture | Control question |
|---|---|---|
| Request | Employee words, date, recipient, requested change, and why the employee says it is needed. | Did the business recognize the possible request and respond promptly? |
| Job | Current job description, actual essential functions, schedule, location, equipment, standards, and marginal tasks. | What opportunity or task is blocked? |
| Function | Work-related limitation and its connection to the barrier, without collecting unrelated medical history. | What information is actually needed to evaluate an effective change? |
| Options | Employee suggestion, alternatives, effectiveness, timing, operational impact, cost, resources, and trial terms. | Which options remove the barrier and remain workable? |
| Decision | Approved option, alternative offered, reason, implementation owner, confidentiality controls, and advisor review. | Can the business explain the decision from the documented facts? |
| Follow-up | Start date, employee check-in, manager check-in, effectiveness, adjustments, and next review. | Is the accommodation working in practice? |
The EEOC's small-employer accommodation guidance explains that a request may be made in plain English and need not be written. The EEOC's reasonable accommodation enforcement guidance describes the informal process of clarifying the need and identifying an effective accommodation. Coverage, disability status, essential functions, documentation rights, direct threat, leave, reassignment, undue hardship, pregnancy, workers compensation, and state-law duties are fact-specific. Use qualified employment counsel for case-specific decisions.
Use four rules during the interactive process
The supervisor says the schedule cannot change, asks for a diagnosis, writes "attendance problem" in the review file, and never explores a different effective option.
The employer confirms the request, identifies the opening-shift barrier, checks the essential functions, compares effective options, protects medical information, and records a review date.
Copy this accommodation request control row
Accommodation intake and decision row
Employee or applicant: [name or case ID]
Request received: [date, method, and recipient]
Employee's words: [exact short summary]
Requested workplace change: [change]
Job and location: [role and site]
Essential function or access point affected: [task or barrier]
Current performance facts kept separate: [objective facts, if relevant]
Functional information needed: [none / narrow question for qualified review]
Confidential documentation location: [restricted file]
Employee option proposed: [option]
Alternative option 1: [option and effectiveness]
Alternative option 2: [option and effectiveness]
Operational impact facts: [schedule, staffing, equipment, cost, safety, or other]
Interim measure considered: [measure and dates]
Qualified advisor question: [question]
Decision: [approve / alternative / trial / pending / deny after review]
Decision reason: [fact-based summary]
Implementation owner and date: [person and date]
Employee communication delivered: [date and method]
Effectiveness check: [date and findings]
Next review: [date and owner]
Use a neutral interactive-process invitation
Employee meeting draft:
Thank you for telling us that [workplace task, schedule, or access issue] is creating a problem related to a medical condition. We want to understand the work barrier and discuss possible effective changes. You do not need to share unrelated medical details with your supervisor. At our meeting on [date], please be ready to describe the job task or access issue, the change you believe would help, and any timing concern. We may discuss alternatives and, if permitted information is needed, [authorized contact] will explain the narrow request and secure method. No final decision has been made. We will confirm the next step by [date].
Customize this operational draft to the facts and governing law. It is not a medical-information demand, an approval, a denial, or a substitute for legal advice.
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Worked example: an opening shift becomes difficult
A hypothetical twelve-person bakery has an experienced employee who says a new treatment schedule makes the 5:00 a.m. opening shift difficult and asks to start later. The supervisor is tempted to say no because opening coverage is thin. Instead, the owner confirms the request, keeps the employee's medical comment out of the shared schedule notes, and maps which opening tasks are truly essential for that role.
The employee proposes a permanent 7:00 a.m. start. The business also identifies a temporary shift swap and a revised task split as options for discussion. After a confidential conversation and qualified review, the employer chooses a short trial that appears effective and sets two check-in dates. The example shows a process; it does not decide ADA coverage, the required accommodation, or undue hardship for a real employer.
Reasonable accommodation interactive process checklist
- Train supervisors to route plain-language requests to one authorized owner.
- Confirm the request and next step promptly without demanding legal terminology.
- Record the employee's words, the requested change, and the work barrier.
- Use the actual job to identify essential functions and marginal tasks.
- Separate objective performance facts from disability-related information.
- Request only permitted, necessary information through a restricted channel.
- Invite the employee's ideas and identify other potentially effective options.
- Compare effectiveness before cost or convenience becomes the conclusion.
- Document operational impact with facts, not labels or assumptions.
- Obtain qualified advice before a denial, undue-hardship conclusion, direct-threat decision, leave limit, or reassignment issue.
- Communicate the decision, implementation owner, start date, and confidentiality boundaries.
- Check whether the accommodation works and reopen the process if the barrier remains.
FAQ: must the employer grant the employee's first choice?
Not necessarily. EEOC guidance says an employer may choose among effective accommodations, including a less costly or easier option, as long as the chosen accommodation is effective. That does not make a cheaper but ineffective option sufficient. Compare the actual barrier and effectiveness, continue the dialogue when an option fails, and get qualified advice before treating the process as closed.
Connect accommodation to leave and performance records
If the request arrives with medical leave paperwork, use the incomplete FMLA certification follow-up checklist to keep leave certification and accommodation analysis in separate lanes. The employee evaluation form guide helps managers document objective job facts without turning medical information into a rating. Before discipline or separation near a request, use the employee termination risk checklist and obtain qualified counsel.
Free version vs. full kit
This article gives you the free version: the six-lane decision map, intake row, meeting invitation, worked example, and employer checklist. The paid kit adds editable request, essential-functions, information, option, undue-hardship review, decision, implementation, and follow-up tools.
Get the Reasonable Accommodation Interactive Process Kit
The All-Access membership includes the complete kit library while membership is active. The one-time accommodation kit remains the primary next step for this article.
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