Accommodations for Managers: Recognize the Request Before You Answer

Honestly,

I’m an HR person. I’m not your HR person. Colleen Honestly provides general educational information based on my professional experience and perspective. Nothing here is legal advice, individualized HR advice, or a substitute for guidance from your employer, attorney, healthcare provider, or other qualified professional. Laws, policies, and individual circumstances vary, so use this information as a starting point—not a decision made for you.

Imagine an employee says, “My treatment schedule is changing. I’m going to have trouble getting here at eight.” You may be thinking about coverage, customers, and a calendar that already looks like a game of Tetris.

Those concerns matter. First, recognize that the employee may need a work change for a medical reason. Focus on the work limitation and how it affects the job.

An accommodation request can be made in ordinary language; the employee does not need to use legal terms.¹ Federal ADA employment coverage generally begins at 15 employees, while state and local laws may protect workers at smaller employers. Other laws may also provide accommodation rights.²

Your job is not to diagnose the employee or resolve the legal question on the spot. Do not infer a medical condition from behavior or assume every performance concern is health-related. Focus on what was said and the work barrier identified.²

Try: “Thank you for letting me know. What part of the schedule is becoming difficult? Let’s connect with our accommodation contact so we can work through the next steps.”

Avoid: “You don’t look disabled.” “Everyone would want that.” “We never make exceptions.” Do not promise a specific adjustment before review. A warm response can still leave room to understand the facts.

The interactive process addresses the limitation, affected work, and possible effective adjustments, and should begin promptly. Relevant documentation may be appropriate when the disability or need is not obvious; that is different from collecting an employee’s entire medical history.¹

Performance does not determine whether an accommodation request is approved or denied. Essential job functions and performance expectations still matter, but the request should go through the appropriate process rather than being treated as a reward or consequence. Ignoring or rejecting it without review can create serious risk if the employee later says, “I asked for help, the company did not provide it, and that is why I was not performing.” Document work-related facts, protect medical information, and keep the review moving.

Managers should also seek guidance when circumstances suggest an accommodation may be needed, even if the employee has not identified a medical condition. Do not diagnose or ask intrusive questions. Pay attention to significant changes in attendance, performance, communication, or ability to complete a task; comments about treatment, medication, appointments, restrictions, or health-related difficulty; or workplace barriers that may be medically connected. Before taking consequential action, contact HR or the designated accommodation resource.

Review cost assumptions carefully. In JAN’s survey of employers who contacted the service, 61% of 1,425 respondents providing cost information reported no implementation cost. Among respondents reporting a one-time expense, the median cost was $300. These are survey findings, not a promise about your workplace.³

From the toolbox:

• Listen for a possible request for a work change related to a medical condition.
• Before making a consequential attendance, discipline, scheduling, or performance decision, refer any medical issue or possible accommodation for review, even if the employee has not expressly identified a medical condition.
• Do not approve or deny an accommodation based on performance. Use the appropriate review process before taking action that could support a claim that help was requested and denied.
• Treat comments about treatment, medication, appointments, restrictions, or health-related difficulty as signals to seek guidance, not invitations to investigate or diagnose.
• Ask what part of the work or schedule is difficult without requesting unnecessary medical details.
• Contact HR or the designated accommodation resource.
• Keep medical information within the designated confidential process and separate from ordinary personnel records, consistent with applicable law and organizational procedures.
• Document the request or work-related concern accurately and state when the employee will hear back.
• If you do not know the answer, say so and provide a clear next step.

You do not have to be an accommodations expert. You do need to recognize when help may be needed, respond with care, and connect the employee with the right person. That helps employees succeed while giving the organization a fair opportunity to meet its responsibilities.

Frequently Asked Questions

The FAQ offers quick guidance, but accommodation questions rarely have one-size-fits-all answers. Recognize the possible request, focus on the work-related limitation, and connect the employee with HR or the designated accommodation resource before making a consequential decision. The answers below are general information only. Consult the appropriate HR, accommodation, or legal resource.

Does an employee have to use the words “reasonable accommodation”?

No. An employee may use ordinary language to communicate that a medical condition or disability is affecting work and that a change or assistance may be needed. Listen for the substance rather than specific legal terminology, and contact HR or the designated accommodation resource.

Can a manager ask for the employee’s diagnosis or complete medical records?

Usually, no. Do not seek unnecessary medical details. Ask only what is needed to understand the work-related limitation and connect the employee with HR or the designated accommodation contact. Handle any appropriate documentation through the employer’s confidential process, separate from ordinary personnel records and consistent with applicable law and company procedures. Consult HR, the designated accommodation contact, or legal counsel.

Can an accommodation be denied because it seems expensive or disruptive?

Not automatically. Cost and operational impact may matter, but they must be evaluated in context. Document specific concerns and refer them for an undue-hardship analysis rather than deciding based on assumptions or general inconvenience. Do not approve or deny the request yourself; contact HR, the designated accommodation contact, or legal counsel.

Undue hardship generally means significant difficulty or expense considering the employer’s resources, the accommodation’s nature and cost, the organization’s size and structure, and the effect on operations. Inconvenience, unpopularity, or departure from usual practice is not enough. The analysis must address the specific accommodation and workplace. Managers should provide accurate information about the job and operational impact, route the request for review, and avoid promising or rejecting an accommodation beforehand.

What should I do if I am unsure whether the employee is making an accommodation request?

Respond neutrally and ask a work-focused question, such as, “What part of the job or schedule is becoming difficult, and how can we connect you with the appropriate resource?” Then contact HR or the designated accommodation resource before taking consequential action. If unsure, consult your organization’s HR or accommodation contact or a legal professional.

Accommodations 101 Series