ADA Reasonable Accommodation Five-Step Interactive Dialogue

Use this guide to provide reasonable accommodation to employees under the Americans with Disabilities Act.

STEP 1
Identify the essential functions of the job

  • Scrutinize / revise job descriptions
  • Distinguish “essential” functions from “marginal” functions
  • Document mutual agreement with employee, or any disagreement

STEP 2
Identify all barriers to performance of essential functions

  • Obtain information from employee and his/her medical provider, if necessary, to understand impact of disability on job performance
  • If necessary ask for functional capacity assessment from outside provider
  • List barriers or restrictions, note whether agreed to or not

STEP 3
Identify all possible solutions or ways to eliminate the barriers

  • Elicit input from all players (e.g. HR, management, health care providers, the employee)
  • Compile a list of solutions that is as complete as possible, regardless of cost or practicality

STEP 4
Identify which possible solutions are reasonable

  • Employer identifies which of the Step 3 solutions, if any, is actually a reasonable accommodation
  • Is a potential accommodation an undue hardship, and/or does is pose a direct threat to health or safety?
  • Consider all circumstances: size and type of department, number of people performing job, nature of job, cost, safety considerations

STEP 5
Select & implement one or more identified reasonable accommodations

  • Employer determines which, if any, from among identified reasonable accommodations will enable the employee to perform the essential functions
  • Seek agreement from employee
  • Implement selected accommodation(s)