Every employee deserves a fair chance at doing their job well. Sometimes that means they need a little support to get there. Title I of the Americans with Disabilities Act (ADA) applies to private employers with 15 or more workers. A “qualified individual with a disability” is someone who meets job requirements and can perform essential functions with or without adjustments. The law covers both applicants and employees, aiming for equal access rather than special treatment.
What you’ll learn
What you’ll learn
Key takeaways
- The ADA requires some private employers to provide qualified individuals with disabilities with reasonable accommodations
- Accommodations range from flexible schedules to assistive technology, but they do not include changes that create an undue hardship
- A consistent, interactive process helps employers fairly evaluate accommodation requests and document decisions
- Many accommodations are inexpensive to implement
The Equal Employment Opportunity Commission (EEOC) enforces these rules, and states often add stricter standards. In 2024, the number of discrimination cases increased, and many involved disability claims. For employers, it’s a reminder that handling reasonable accommodations is part of HR’s job and a smart way to lower risk. In this article, we’ll look at a list of reasonable accommodations, how the process works, and simple steps to stay compliant.
What counts as a reasonable accommodation (and what doesn’t)
So, what are reasonable accommodations under the ADA? They are adjustments to a job, how it is performed, or a workplace environment that allow individuals with disabilities to carry out their job functions and are afforded equal opportunities.
Some common examples of reasonable accommodations include:
- Flexible or modified work schedules
- Assistive technology such as screen readers or adaptive keyboards
- Restructuring a job to shift nonessential tasks
- Allowing service animals in the workplace
- Providing interpreters or accessible communication tools
This said, the ADA does not require accommodations that create undue hardship. This is a change that would be overly difficult or expensive for a business to take on, such as a small restaurant being asked to redesign its kitchen to accommodate one employee. Small businesses are expected to consider requests in good faith, but hardship is evaluated on a case-by-case basis.
Along with cost considerations, employers are not required to remove essential job functions or approve accommodations that create a direct safety risk. Knowing where the limits are helps small business owners balance employee needs with the realities of running their operations.
The interactive process: A simple, repeatable playbook
The accommodation process begins when an employee asks for help. They don’t have to mention the ADA or use legal terms. A simple request is enough to require a response from an employer.
Once a request is made, employers need a clear way to handle it. A repeatable process makes compliance easier and more consistent. Here’s a step-by-step guide:
- Log the request: In plain language, note the date and what the employee is asking for.
- Clarify the role: Identify the key day to day tasks that the employee is responsible for. Focus on what’s essential to get the job done, not every minor duty.
- Discuss solutions: Talk through options with the employee, focusing on what they need to do the job, not their medical details. Help keep the conversation compliant by reviewing guidance on questions to ask your employees about their health.
- Select the most efficient and effective option: Choose an accommodation that works without creating undue hardship.
- Implement and document: Put the decision in place and record it.
- Review and adjust: Periodically check back to confirm that the arrangement still works.
This collaborative process helps employers avoid accusations of neglect while showing employees their concerns are taken seriously. It also creates documentation that supports HR compliance if an EEOC complaint later arises. With a system in place, the next step is to look at accommodations that work well for small businesses and how practical they are to provide.
Accommodations that work for SMBs (with realistic costs)
Once examples are on the table, many employers start to think about what it takes to provide them. The reality is encouraging.
Most accommodations cost less than expected. Nearly half don’t cost anything at all. And for those that do, the median one-time cost is only $300. Some of these improvements might even qualify for tax relief through the disabled access credit, which gives small businesses a break for investing in accessibility.
Here are some examples of accommodations small businesses frequently provide.
Scheduling
- Flexible hours
- Part-time arrangements
- Intermittent leave
Tools and technology
- Screen readers
- Adaptive keyboards
- Ergonomic hardware
- Noise-reduction headphones
Duties and environment
- Adjustable desks or ergonomic chairs
- Workspace modifications
- Reassigning minor tasks
Communication
- Interpreters
- Captioned meetings
- Accessible written instructions
Accommodation requests went up in 2024, largely tied to mental health needs and remote work. When small businesses see these requests as chances to support inclusion, they build stronger trust and keep employees longer. From there, employers need to document adjustments and follow through on them.
Compliance without the headaches: Documentation, timelines, and hardship
Every decision should be backed up with clear records. Once an accommodation is chosen, keep documentation for:
- The request
- Notes from discussions
- The option selected and when it was implemented
- Any follow-ups or changes
Employers must also respond in a timely manner, keep medical documentation confidential, and revisit accommodations if job duties or medical conditions change. Clear records matter in every workplace, whether you’re operating under at-will employment rules or need to follow stricter state standards.
Undue hardship remains a high standard to meet. Employers must individually evaluate hardship, weighing costs, resources, and specific circumstances. Keep in mind that blanket denials rarely hold up under EEOC scrutiny.
Good records help you meet legal requirements and offer protection if a dispute comes up. Also, the table below sums up the accommodation process so you can see how it typically unfolds.
| Step | What to do |
| 1. Log the request | Note the date and what the employee is asking for (no legal terms required). |
| 2. Clarify the role | Focus on essential job duties, not minor tasks. |
| 3. Discuss solutions | Talk with the employee about options without probing into medical details. |
| 4. Select an option | Choose the most effective solution that avoids undue hardship. |
| 5. Implement & document | Put the decision in place and record it. |
| 6. Review & adjust | Revisit periodically to ensure the accommodation still works. |
Moving on, let’s find about about how to make informed decisions as they arise.
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Simple guidelines: Choose, implement, review
The interactive process is a strong start, but managers still need a way to make clear and consistent choices. A simple guide can help employers stay fair when requests come in:
- Does the request allow the employee to perform essential job functions?
- Can the business reasonably handle the expense?
- Does the accommodation create any safety risks?
- Is there a less costly option that is equally effective?
- How quickly can the adjustment be made?
- Can the accommodation be tested and later reviewed?
When evaluating requests, this guide encourages thoughtful decisions and gives managers confidence. Clear documentation helps on paper, but employers also need processes that include scheduling, payroll, and time-off tracking.
Below is also a sample request template with information most employers try to gather.
Sample accommodation request form
Employee information
- Name:
- Job Title:
- Department:
- Date:
Accommodation Request
Please describe the medical condition or limitation that affects your work. You do not need to share detailed medical history.
- What job tasks are difficult because of this condition?
- What changes, tools, or support would help you perform these tasks?
- Have you used accommodations before, either here or in another job? If yes, please describe.
Supporting documentation (if needed)
- Name of healthcare provider:
- Documentation attached: Yes/No
Employee signature
- Signature:
- Date:
For employer use
- Date received:
- Notes from interactive process:
- Accommodation approved: Yes/No
- Accommodation provided:
- Implementation date:
- Follow-up/review date:
All this said, getting the mechanics right from payroll adjustments to documentation matters. But it’s worth stepping back to remember why.
Make it operational: Connecting HR, payroll, and time-off systems
Reasonable accommodations mean more than staying compliant with federal rules. For employees who need adjustments to navigate the workplace, they signal respect, build trust, and improve performance. When handled well, accommodations show your entire team that everyone has what they need to contribute and succeed.
To stay focused on fostering this type of work environment, OnPay makes it easier to set up flex schedules and PTO rules with HR and payroll software built for small businesses. Best of luck as you build your team and we are here to help with your payroll-related questions!
Take a tour to see how easy payroll can be.
Jon Davis is the Sr. Content Marketing Manager at OnPay. He has over 15 years of experience writing for small and growing businesses. Jon lives and works in Atlanta.