What’s the most critical step in an employee’s request for ADA accommodation?

Is it when HR figures out what accommodation, if any, can be offered? Or is it when HR discusses the accommodation with the employee, or when the person accepts or rejects it?

Really, it’s none of the above. In many ways, the most critical phase – and the one where everything can go wrong, fast – is that moment when the employee first brings up the accommodation idea with his or her supervisor.

Why do we say this?

Reason #1: An accommodation request may not be all that simple to spot. Here’s an example: An employee tells her supervisor, “I haven’t been feeling so good, and I wonder if you could help me out.” As vague as that is, it might still be enough to trigger an organization’s duty to accommodate a disabled employee.

Reason #2: Supervisors often don’t know how to respond. They may consider that it’s a personal medical issue for the employee and her doctor to deal with, or that somebody else in the organization should handle such matters.

Here’s what makes the supervisor’s role so key: The Americans With Disabilities Act (ADA) contains a provision known as the “interactive process.” This means that as soon as an employer is put on notice that an employee may have a disability, and the person asks for a job accommodation to deal with it, the employer must engage in a good-faith discussion of whether a reasonable accommodation is possible.

First responder
And who is the first person in the organization to learn about a possible disability, and hear the accommodation request? You guessed it: the line supervisor.

The supervisor is the one who has to begin the “interactive process,” even if only by recognizing the accommodation request and passing it on. If the supervisor puts the employee off, or doesn’t take the request seriously, on the other hand, the employee might have legal grounds to sue for a refusal to accommodate.

What’s especially tricky is that accommodation requests don’t have to be couched in any particular language, and don’t have to use the words “accommodate” or “accommodation.” An employee may say something like:

  • “I hurt my back and I need to get off the production line for a couple days.”
  • “I can’t stand for more than 10 minutes without pain. Can you get me a stool?”
  • “I’m getting migraines from the bright lights on the show floor. Could I work in the stockroom for a while?”

Any of these might qualify as a request for accommodation under the ADA, triggering the interactive process. And while line supervisors probably won’t be running the process through to a resolution – that’s more likely to be HR’s or higher management’s job – they need to know how to recognize an accommodation request, and how to react properly.

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