Under the Americans with Disabilities Act, an employee with a disability can ask for a change to the job or the work environment — different equipment, a modified schedule, a policy exception, reassignment — and the employer must respond by engaging in a good-faith conversation about what would work. That conversation is called the interactive process. It is not a formality: courts and the Equal Employment Opportunity Commission treat a breakdown in the process as evidence about which side failed its obligations.

The ADA's reasonable accommodation duty applies to employers with 15 or more employees, and many state laws extend similar duties to smaller employers. The employee does not have to use legal vocabulary to start the process, and the employer does not have to grant the exact accommodation requested — only an effective one, unless every effective option would impose an undue hardship.

How a request actually gets made

No magic words are required. A statement in plain English — "I'm having trouble standing all shift because of a back condition; can I use a stool?" — is enough to put the employer on notice. The request can be oral or written, and it can come from a family member, doctor, or other representative acting for the employee.

Even so, writing the request down serves both sides. A short email that names the medical condition in general terms, describes the job task that is difficult, and suggests one or two possible changes creates a date-stamped record that the process began. Employers, for their part, should route requests to a designated person — usually HR — and say so in the handbook, a topic covered in our guide to building a handbook that matches actual practice.

Practical step: The Job Accommodation Network at askjan.org, a free service funded by the U.S. Department of Labor, publishes accommodation ideas searchable by condition and by job task. Both employees drafting a request and employers evaluating one can use it to identify options neither side had considered.

The interactive process, stage by stage

Neither the statute nor EEOC regulations script the dialogue in detail, but in practice it follows a recognizable arc:

  1. Recognition. The employer identifies the communication as an accommodation request, even if the employee never says "ADA" or "accommodation."
  2. Clarification. The employer asks what limitation is interfering with which job function. If the disability or the need is not obvious, it may request reasonable medical documentation at this stage.
  3. Option generation. Both sides propose possibilities: equipment, schedule changes, remote work for some tasks, restructured marginal duties, leave, or reassignment to a vacant position as a last resort.
  4. Assessment. The employer evaluates whether each option is effective and whether it imposes an undue hardship — significant difficulty or expense judged against the employer's real resources and operations.
  5. Selection and implementation. The employer chooses among effective options. It may pick a cheaper or easier alternative than the one requested, so long as the alternative actually works.
  6. Follow-up. Accommodations get revisited. Conditions change, jobs change, and an accommodation that worked in March may fail in October. Either side can reopen the dialogue.

Speed matters throughout. There is no fixed federal deadline for responding, but unexplained delay can itself support a failure-to-accommodate claim, and some state agencies read delay harshly.

Medical documentation: what may be asked, what may not

When a disability and its workplace effects are not obvious, the employer may ask for documentation — but only documentation sufficient to establish that the employee has a covered condition and needs the change requested. That usually means a short letter from the treating provider describing functional limitations and expected duration. It does not mean complete medical records, genetic information, or diagnoses unrelated to the request.

  • A provider letter tying specific limitations to specific job tasks, in functional terms ("cannot lift more than 20 pounds," not just a diagnosis code)
  • Expected duration, if the condition is temporary or episodic
  • The employee's own description of what has and has not worked so far
  • For employers: a written job description listing essential functions, prepared before the dispute rather than after
  • Notes or emails memorializing each meeting in the dialogue, with dates

Employers must keep medical information in files separate from the regular personnel file and share it only with those who genuinely need it, such as a supervisor implementing a schedule change. Note that if the employee also needs time off, the medical certification rules of the FMLA run on a separate track with different forms and deadlines; the interaction is mapped in our article on how FMLA, ADA, and state leave laws overlap.

Who picks the accommodation — and what "undue hardship" really means

The employee's preference gets consideration, not a veto. If a screen reader and a human reader would both let a visually impaired analyst do the essential job, the employer may choose either. What the employer cannot do is substitute an ineffective option and declare the process complete.

Undue hardship is a demanding standard, and it is specific to the employer. Cost is measured against the employer's overall resources, not the value of the employee's position. Disruption must be real and operational — proof that other employees would resent the change, or generalized fears about morale, do not qualify. An employer that denies a request on hardship grounds should be able to document what it considered, what each option would cost or disrupt, and why no effective alternative existed.

Keep the label straight, though. "Undue hardship" also appears in Title VII, which requires accommodation of religious practice, and for decades it meant something far weaker there — until the Supreme Court raised the bar to substantial increased cost. A schedule or grooming request grounded in religious belief rather than disability runs on that separate statutory track, with its own definition of hardship and its own record-keeping, even when it lands on the same HR desk as an ADA request.

Watch out: Removing an essential function, creating a brand-new position, or bumping another employee out of their job are generally not required. But reassignment to an existing vacant position the employee is qualified for is a required accommodation of last resort under EEOC guidance — an option employers often skip.

When the dialogue stalls or the answer is no

Breakdowns usually look like silence, an unexplained "we can't do that," or a demand for far more medical detail than the request warrants. An employee facing a stall should restate the request in writing, ask what additional information the employer needs, and keep performing the job as best they can. An employer facing an employee who refuses to provide reasonable documentation should explain, in writing, exactly what is missing and why it is needed.

If the process ends in a denial the employee believes is unlawful, the next step is usually a charge with the EEOC or a state fair employment agency — federal charge deadlines are short, generally 180 or 300 days depending on the state. Punishing an employee for requesting an accommodation is itself unlawful; how those claims work is covered in our guide to retaliation and whistleblower protections. For the broader set of workplace rules that interact with accommodations, see the Workplace Rights & HR pathway.

Quick answers

Does an accommodation request have to be in writing?

No. Federal law recognizes oral requests, and a request made in plain language without legal terms still triggers the employer's duty to respond. Writing is still wise: it fixes the date, the content, and the recipient, which matters if the process later breaks down and an agency or court has to decide who stopped cooperating.

Can my employer ask for my full medical records?

Generally not. When the need is not obvious, the employer may request documentation sufficient to confirm a covered condition and the need for the specific change — typically a provider letter describing functional limitations. Demands for complete records, unrelated diagnoses, or genetic information exceed what the ADA permits, and the information received must be kept confidential in separate files.

How long can the employer take to decide?

There is no fixed federal deadline, but the process must move at a reasonable pace given the urgency of the need. Courts have treated months of unexplained silence as evidence of bad faith. Interim measures — a temporary schedule change while equipment is ordered, for example — are a common way to keep a slow process lawful.

Is working from home a reasonable accommodation?

Sometimes. The question is whether the essential functions of the particular job can be performed remotely, and the employer's actual experience — including how the role operated during past remote stretches — is relevant evidence. Remote work is not automatically required, but a blanket "we never allow it" policy does not excuse the employer from individualized analysis.

A sensible order of operations

For employees: describe the limitation and the task in writing, propose an option or two, provide focused documentation when asked, and respond to every employer communication so the record shows you engaged. For employers: acknowledge the request quickly, ask only for what you need, consider options beyond the one requested — including reassignment — and document each step and each reason. Most accommodation disputes are lost not on the merits of any single option but on the record of who kept talking and who went quiet.