When an employee tells a manager they need a change at work because of a medical condition, federal law requires the employer to start a conversation, not a form. It's called the "interactive process," and under the Americans with Disabilities Act, an employee never has to say the words "reasonable accommodation" or even mention the ADA to trigger it — "plain English" describing a work-related need is enough, according to the U.S. Equal Employment Opportunity Commission (EEOC), the federal agency that enforces the law.
That plain-language threshold is one of the most misunderstood parts of the ADA, and it shapes how millions of workplace requests — for a schedule change, a piece of equipment, a modified task, or remote work — actually get handled once someone asks.
What Counts as a "Reasonable Accommodation"?
A reasonable accommodation is any change to a job or workplace that lets a qualified employee with a disability do the job, without imposing "significant difficulty or expense" — the legal standard for "undue hardship" — on the employer, per EEOC enforcement guidance. In practice, the agency's guidance for small employers lists accommodations that cost little or nothing: restructuring a minor job task, a modified or part-time schedule, unpaid leave, changes to a supervisor's communication method, or an adjustment to an existing policy for one employee.
The standard is individualized. What counts as reasonable — and what counts as an undue hardship — is assessed case by case, based on the specific job, the specific limitation, and the specific employer's resources, the EEOC's guidance states.
How Does an Employee Actually Ask for One?
The request can come from the employee, or, per EEOC guidance, from "a family member, friend, health professional, or other representative" acting on the employee's behalf. It can be made verbally, in writing, or through any other means of communication, and at any point — during a job application or at any time during employment, not just at hiring.
There's no script. An employee doesn't need to name a diagnosis or cite the ADA by section number. They need only indicate they require "an adjustment or change at work for a reason related to a medical condition," in the EEOC's language. That low bar is deliberate: the law is written so a request doesn't get lost because someone didn't use the right legal phrase.
What Happens After the Request Is Made?
Once a request lands, the employer and employee are supposed to engage in what the EEOC calls "an informal process to clarify what the individual needs and identify the appropriate reasonable accommodation." That can include the employer asking clarifying questions about the limitation and the kind of adjustment that would help.
If the disability or the need for accommodation isn't obvious, the employer may ask for "reasonable documentation" — but only enough to establish that the person has a disability covered by the ADA and that the disability requires the accommodation. The EEOC is explicit that this doesn't extend to complete medical records or information unrelated to the specific limitation. If the documentation an employee provides is incomplete, the employer has to say why and give the employee a chance to fill the gap before requiring an evaluation by a health professional of the employer's choosing, at the employer's expense.
Employers can choose among effective options when more than one accommodation would work, but the EEOC guidance says "the preference of the individual with a disability should be given primary consideration." And the whole process is supposed to move — the guidance says accommodations should be provided "promptly," and that unnecessary delay itself can violate the ADA.
What Can an Employer Say No To?
An employer can deny an accommodation that would cause undue hardship — again, "significant difficulty or expense" — or one that would be "unduly extensive, substantial, or disruptive," or that would fundamentally change the nature of the business, per the EEOC. Smaller employers can also point to outside funding, such as state vocational rehabilitation agencies, or ask an employee to help cover costs above the undue-hardship line, the agency's small-employer guidance notes. What an employer can't do is deny a request without engaging in the process at all.
What Does It Look Like When the Process Breaks Down?
The process isn't automatic, and disputes over what counts as a legitimate accommodation surface in real workplaces regularly. In September 2025, the Centers for Disease Control and Prevention paused approvals of remote-work accommodation requests from disabled employees after the Department of Health and Human Services issued an updated telework policy that did not list remote work as a reasonable accommodation, NPR reported. The agency told staff it was deferring to HHS for guidance and would keep approvals paused "until further notice." Yolanda Jacobs, president of the American Federation of Government Employees Local 2883, told NPR the disruption was landing on employees with no clarity about where the decision was actually being made: "If there's any discussions happening, it's happening between the CDC's leadership and HHS, it's not happening with the employees." NPR reported that roughly 250 disabled CDC employees at the agency's Atlanta headquarters had raised concerns about losing existing telework arrangements.
The episode is a reminder that the interactive process described in EEOC guidance is a floor, not a guarantee — a legal framework that still depends on individual employers, and individual conversations, to function as written.
Where to Go for Help
The EEOC's small-employer guidance points to two federally supported resources for anyone navigating a request: the Job Accommodation Network, a free consulting service, and the ADA's regional Disability and Business Technical Assistance Centers, which offer training and referrals. The EEOC itself also distributes its guidance documents free of charge to employers and employees who call its public information line.
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