ADA Reasonable Accommodation Policy template
An ADA reasonable accommodation policy is your organization's written procedure for handling requests from applicants and employees who need a change to the job, the workplace, or the way things are usually done because of a disability — how requests are made and recognized, how the interactive process runs, what medical information can be requested, who decides, and how accommodations are implemented and reviewed.
Accommodation disputes are rarely about the accommodation — most are about process: the manager who did not recognize a plain-English request, the form that never reached anyone, the request that sat unanswered for months. The ADA does not prescribe a fixed procedure, which means your policy is the procedure — and a written one, followed every time, is what turns a legal duty into a routine.
This template gives you the full policy: how to request an accommodation, the interactive process step by step, the limits on medical documentation, how decisions and undue hardship are handled, confidentiality, and the no-retaliation commitment.
Full text, ready to adapt.
Highlighted fields are placeholders — replace them with your organization's specifics. A starting point, not legal advice.
ADA Reasonable Accommodation Policy
Policy · Company Policies
1. Purpose and scope
This policy explains how {{org.name}} handles reasonable accommodation for disability, from a request first being made to an accommodation being reviewed after it is in place. It applies to applicants at every stage of hiring and to employees in every role, and it covers every aspect of employment — the application process, performing the job, and access to the benefits and privileges other employees enjoy.
This policy is not a contract of employment and does not change the at-will nature of employment at {{org.name}}. Requests connected to pregnancy or religious practice go through the same front door — tell [name/role] — though the legal frameworks differ; see our [EEO policy].
2. Policy statement
{{org.name}} provides reasonable accommodations to qualified applicants and employees with disabilities unless the accommodation would impose an undue hardship on the business. We treat every request seriously, we engage in the interactive process in good faith and without delay, we keep medical information confidential, and we do not retaliate against anyone for requesting an accommodation — whatever the outcome of the request.
3. What a reasonable accommodation is
A reasonable accommodation is any change to a job, the work environment, or the way things are usually done that enables a qualified person with a disability to apply for a job, perform its essential functions, or enjoy equal benefits and privileges of employment. Common examples:
- Modified schedules — adjusted start or finish times, additional breaks, or part-time arrangements.
- Equipment and technology — acquiring or modifying tools, or providing assistive software or devices.
- Job restructuring — reallocating marginal duties to someone else; essential functions stay with the job.
- Leave — time off for treatment or recovery, including unpaid leave beyond normal entitlements.
- Policy modifications — adjusting an attendance, uniform, or workplace rule where the rule itself is the barrier.
- Accessibility changes — to the workspace, facilities, or the application and interview process itself.
- Reassignment to a vacant position the person is qualified for, generally where no accommodation works in the current job.
4. How to request an accommodation
- Tell [name/role], or any manager, that you need a change at work for a reason connected to a health condition or disability. Plain English is enough — you do not need to mention the ADA or use the words "reasonable accommodation".
- Requests can be made in any form: in conversation, by phone, or in writing. A family member, health professional, or other representative can make the request on your behalf.
- A manager who receives a request, however informal, passes it to [name/role] the same day. Recognizing a request is a management responsibility, not the requester's.
- We may ask you to confirm the request using [form/system] so nothing gets lost — but the process starts when you ask, not when a form is filed.
5. The interactive process
The interactive process is a conversation, not a courtroom: what is the barrier, what does the job require, and what change would work. {{org.name}} runs it like this:
- 1[Name/role] acknowledges the request within [number] working days and arranges a conversation with the requester.
- 2We discuss the limitation and the workplace barrier together. The requester does not need to arrive knowing the answer or naming a specific accommodation.
- 3Where the disability or the need is not obvious, we may request reasonable medical documentation — limited to what the medical information section below allows.
- 4We explore options with the requester, including options neither side had thought of. Where we are unsure what could work, we consult the Job Accommodation Network (askjan.org), the free expert service funded by the US Department of Labor.
- 5We choose an effective accommodation. The requester's preference is weighed seriously; where more than one option would be effective, {{org.name}} may choose which to provide.
- 6We implement promptly — ordering equipment, adjusting the schedule, briefing only the people who genuinely need to know — and confirm the arrangement in writing.
- 7If we decline a request, [name/role] gives the reason in writing, along with any alternative accommodation we can offer instead.
- 8[Name/role] checks in after [interval] and reviews the arrangement [frequency, e.g. annually]. Accommodations that stop working are revisited, not abandoned.
6. Medical information and confidentiality
Where the disability and the need for accommodation are obvious, or already documented with us, we do not ask again. Where they are not, we may request reasonable documentation from an appropriate health professional — enough to establish that the person has a disability covered by the ADA and that it creates the need for an accommodation, and no more. We never request complete medical records, and we do not ask about conditions unrelated to the request.
All medical information gathered in this process is confidential. It is kept in a separate, secure medical file — never in the personnel file — with access limited to [roles]. Managers are told what they need to implement the accommodation, not the diagnosis behind it.
7. Deciding requests and undue hardship
Decisions are made case by case by [name/role], on the actual facts of the job and the request — not on assumptions about a condition or about what an accommodation "usually" costs. In practice, most accommodations turn out to be inexpensive or free.
{{org.name}} may decline a specific accommodation that would impose an undue hardship — significant difficulty or expense judged against our real size, resources, and operations — or that would fundamentally alter the nature of the business. A hardship finding ends one option, not the process: if one accommodation is a hardship, we look for an effective alternative that is not, and we put what we can offer in writing.
8. No retaliation
Requesting an accommodation, or helping someone else request one, will never be held against anyone at {{org.name}} — in pay, scheduling, assignments, promotion, or anything else. That protection stands whether the request is granted, modified, or declined. Retaliation for requesting an accommodation is prohibited by this policy and by federal law. Report suspected retaliation to [name/role] or through [reporting channel]; it is investigated under the [employee complaint policy].
9. Responsibilities, records and review
[Name/role] owns this policy, coordinates every interactive process, keeps the medical file separate and secure, and trains managers to recognize and route requests. Managers route requests the same day and implement agreed accommodations without commentary. Everyone treats a colleague's accommodation as none of their business unless told otherwise.
Requests, interactive-process notes, decisions, and follow-ups are logged in [system/location]; medical documents live in the separate medical file. This policy is reviewed [frequency, e.g. annually] and when federal, state, or local law changes. Owner: [name/role]. Next review: [date].
How to adapt this template.
Name one accommodation owner plus a deputy, and train every manager that a plain-English request routes to them the same day — failure to recognize requests is the classic breakdown.
Check your state and local disability law before publishing — many cover employers below the ADA's 15-employee threshold, and some require more than the ADA does.
Set up the separate, confidential medical file before the first request arrives, and decide exactly who can access it.
Fill in response timeframes you can actually meet — a request that sits unanswered reads as a denial.
Keep the essential functions in your job descriptions current — the interactive process leans on them when the hard questions come.
Bookmark the Job Accommodation Network (askjan.org) — free, funded by the Department of Labor, and searchable by limitation and job type.
Turn this template into trained, proven behavior
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ADA Reasonable Accommodation Policy template FAQs
Is a written ADA reasonable accommodation policy required by law?
No federal statute requires the written policy itself — but for employers the ADA covers, the accommodation duty applies whether or not a policy exists. A written procedure is how requests get recognized, handled consistently, and documented, and if a charge is ever filed, evidence that you engaged in the interactive process in good faith is central to the defense.
How many employees does a company need before the ADA applies?
Title I of the ADA applies to private employers with 15 or more employees, and to state and local governments, employment agencies, and labor unions. Below that threshold the ADA does not reach — but many state and local disability discrimination laws cover far smaller employers, so check your state's fair employment agency before concluding you are outside the rules.
Does an employee have to say "reasonable accommodation" to trigger the ADA?
No. EEOC guidance is explicit that no magic words are needed — a plain-English statement that the person needs a change at work for a reason connected to a medical condition is a request, and a family member, friend, or health professional can make it on their behalf. This is why the policy trains managers to recognize requests and route them, rather than waiting for a form.
Can an employer ask for medical documentation for an accommodation request?
Yes, within limits. When the disability or the need for accommodation is not obvious, the employer may request reasonable documentation from an appropriate health professional — enough to establish the disability and the need, and no more. Complete medical records are out of bounds, and whatever is received must be kept confidential, in a file separate from the personnel file.
What counts as undue hardship under the ADA?
Significant difficulty or expense, judged case by case against the specific employer's size, resources, and operations — or an accommodation that would fundamentally alter the nature of the business. It is a high bar, and it applies to a specific accommodation rather than the duty itself: if one option is a hardship, the employer still looks for an effective alternative that is not.
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