Purpose and Scope
This policy outlines the procedure at [Organisation Name] for handling reasonable accommodation requests related to disabilities, from initial request through implementation and periodic review.
This policy applies to:
- Job applicants throughout all stages of the recruitment process.
- Employees across all roles and departments.
- All aspects of employment, including application procedures, job performance, and access to benefits and privileges of employment.
This policy does not constitute an employment contract and does not alter at-will employment status where applicable. Requests related to pregnancy or religious practices must be directed to [Role] and are processed under [Policy Name].
Working through related paperwork at the same time? See also our US Employee Complaint & Open-Door Policy Template, Reference Request & Provision Template (UK) and US Reference Request & Provision Procedure Template.
Policy Statement
[Organisation Name] provides reasonable accommodations to qualified applicants and employees with disabilities, unless doing so would impose an undue hardship on operations. [Organisation Name] is committed to:
- Engaging in the interactive process in good faith and without unnecessary delay.
- Maintaining the strict confidentiality of medical information.
- Ensuring that no individual is subject to retaliation for requesting an accommodation or participating in the process.
Definition and Scope of Reasonable Accommodation
A reasonable accommodation is any modification or adjustment to a job, the work environment, or the manner in which tasks are customarily performed that enables a qualified individual with a disability to apply for a job, perform essential job functions, or enjoy equal benefits and privileges of employment.
Examples of reasonable accommodations may include:
- Schedule modifications, such as adjusted working hours, additional rest breaks, or part-time arrangements.
- Equipment or technological provisions, including acquiring or modifying tools, software, or assistive devices.
- Job restructuring, such as reassigning non-essential or marginal duties (essential functions remain with the role).
- Leave of absence for medical treatment or recovery, including unpaid leave beyond standard allowances.
- Policy modifications, such as adjusting workplace rules regarding attendance or uniforms where the rule creates a barrier.
- Workplace modifications to improve physical accessibility in working spaces or candidate assessment processes.
- Reassignment to an open, vacant position for which the individual is qualified, when accommodation in the current role is not feasible.
Requesting an Accommodation
- An individual may request an accommodation by informing [Role] or any manager that a workplace change is needed due to a health condition or disability. No formal or technical terminology is required.
- Requests may be communicated verbally or in writing, and may be initiated by the individual or their designated representative (such as a family member or medical professional).
- Managers who receive an accommodation request must forward the request to [Role] on the same calendar day.
- Requesters may be asked to complete a documentation form in [System Name] to ensure tracking; however, the formal interactive process begins upon initial communication, regardless of when forms are submitted.
The Interactive Process
- [Role] acknowledges receipt of the request within [Number] working days and schedules an initial consultation with the requester.
- [Role] and the requester discuss the individual’s functional limitations and the specific workplace barriers.
- Where the disability or need for accommodation is not obvious, [Role] may request reasonable medical documentation limited strictly to necessary functional details.
- Both parties explore potential accommodation options, consulting external public accommodation resources or technical experts as appropriate.
- [Organisation Name] selects an effective accommodation. While the individual’s preference is considered, [Organisation Name] reserves the right to choose among multiple effective options.
- [Role] promptly implements the agreed accommodation, communicates necessary arrangements to relevant personnel on a need-to-know basis, and confirms details in writing.
- If a requested accommodation is denied, [Role] provides written justification and outlines any suitable alternative accommodations being offered.
- [Role] conducts a follow-up review after [Interval] and performs recurring reviews every [Frequency] to ensure the accommodation remains effective.
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Medical Information and Confidentiality
- Documentation is not requested if the disability and need for accommodation are obvious or already documented.
- When documentation is required, it must come from an appropriate healthcare professional and be limited strictly to verifying the existence of a disability and the functional necessity of the accommodation. Full medical histories are not requested.
- All medical information obtained during the accommodation process is confidential and maintained in a secure medical file separate from personnel files. Access is restricted exclusively to [Role].
- Managers are informed only of functional limitations and necessary workplace adjustments, not diagnoses or medical details.
Decisions and Undue Hardship
- Accommodation decisions are evaluated on a case-by-case basis by [Role] using objective job requirements and functional considerations.
- An accommodation request may be declined if it presents an undue hardship, defined as causing significant difficulty or expense relative to [Organisation Name]’s size, overall resources, and operational structure, or if it fundamentally alters the nature of the operations.
- If a specific accommodation creates an undue hardship, [Organisation Name] will evaluate alternative accommodations to identify a viable solution and provide written documentation of the findings.
Non-Retaliation
- Retaliation against any individual for requesting an accommodation, reporting a barrier, or assisting with the accommodation process is strictly prohibited.
- Protection against retaliation applies regardless of whether the accommodation request is granted, modified, or denied.
- Suspected retaliation must be reported to [Role] or via [Reporting Channel] and will be investigated in accordance with [Complaint Policy Name].
Responsibilities, Records, and Review
- Responsibilities:
- [Role] oversees policy administration, manages the interactive process, secures medical records, and provides training to managers.
- Managers are responsible for forwarding accommodation requests to [Role] on the day received and assisting with implementing approved accommodations.
- All employees must respect the privacy of colleagues receiving accommodations.
- Records:
- Accommodation requests, interactive process notes, decision records, and follow-up documentation are securely logged in [System Name]. Medical documentation is retained exclusively in separate confidential medical files.
- Review Cycle:
- This policy is reviewed every [Frequency] or upon changes to applicable statutory requirements.
Policy Owner: [Role] Next Review Date: [Date]
FAQs on an ADA reasonable accommodation policy
What is an ADA reasonable accommodation policy?
An ADA reasonable accommodation policy outlines the procedure at your organisation for handling reasonable accommodation requests related to disabilities, from initial request through implementation and periodic review.
Having it written down means the same rules apply to everyone, so managers are not making judgement calls case by case under pressure.
What does an ADA reasonable accommodation policy include?
This template covers definition and scope of reasonable accommodation, requesting an accommodation, the interactive process and medical information and confidentiality.
Every section is written to be filled in. The bracketed placeholders mark the decisions that are yours to make, such as timescales, approval owners and retention periods.
How to implement an ADA reasonable accommodation policy with Whale
Copy this template into Whale and work through the bracketed placeholders so it reflects how your organisation actually operates.
Assign it to the teams it applies to so it sits where people work rather than in a shared drive, and set a review date so it gets revisited on schedule instead of quietly going out of date.
Use our templates to fast-track your documentation
Customize this template and 100s of others for free in Whale, the fastest way to get your team aligned.
