Managing a Reasonable Accommodation Request: 5 Steps

As in any field, healthcare workers can experience a range of medical disabilities or impairments. It’s important that facility leaders strive toward workplace inclusivity by accommodating employees who are living with underlying conditions. Granting a reasonable accommodation request is one way to remove barriers and enable staff to deliver quality care.

But what exactly are requests for ADA accommodations and how should you go about granting them? If you’re new to this process, we’ll cover the fundamentals of ADA accommodations and the steps you can take to help manage requests efficiently, effectively, and in compliance with ADA law.

Providing Reasonable Accommodations Under the ADA Law: FAQ

The Americans with Disabilities Act (ADA) is a federal law protecting individuals with disabilities against discrimination. Under the ADA, employers with 15 or more employees must provide reasonable accommodations to qualified individuals with limiting physical or mental conditions. State laws may have similar regulations for employers with fewer employees. This means that as a healthcare facility leader, you may be in the position of receiving reasonable accommodation requests from potential employees or staff already on your payroll.

Below, we’ll answer some of the most frequently asked questions about ADA accommodation requests and the ways that you, as a facility leader, can foster an inclusive workplace and stay compliant.

What is an ADA request for accommodation?

Under Title I of the ADA, employees with certain medical conditions can make accommodation requests to their employers if they’re struggling to carry out their job due to their medical conditions. Unless doing so would create an undue hardship, facilities are generally required to grant reasonable accommodation for persons with disabilities as long as they fall under all relevant ADA rules and policies.

How will I recognize a reasonable accommodation request?

Requests for accommodation may come to you verbally or in writing from a potential hire, a staff member, or even a family member or healthcare representative. The request will express that a work-related change is needed for an individual due to a medical condition.

The request may not use any legal or technical wording, so it’s important to be aware during any conversation about medical conditions and their impact on work performance. Both formal and informal requests are valid and must not be ignored.

What are my obligations if I receive a reasonable accommodation request?

Healthcare employers who fall under the scope of the ADA are obligated to treat requests as a first step in the accommodations process. This means that requests should be taken seriously and trigger the appropriate series of actions, including discussions and, potentially, implementation of the accommodation. Receiving a request doesn’t necessarily mean that a modification or adjustment will be made, but it does mean that it must be considered.

Who qualifies for ADA accommodations in healthcare?

The ADA requirements for healthcare facilities are the same as what’s expected of any other type of employer. Any private healthcare facility that employs 15 or more people should follow federal ADA requirements. Workers at these facilities are entitled to receive accommodations if they:

• Are employees and not independent contractors (e.g., 1099 contract nurses from staffing agencies).
• Have a physical or mental health condition.
• Require accommodations to carry out essential functions of their job.
• Request accommodations that are considered reasonable under the ADA.

What are some examples of ADA accommodations in healthcare?

There’s a variety of ways that healthcare leaders can provide reasonable accommodations for their staff. Examples of reasonable accommodations may include:

• Switching a night-shift nurse to day shift because they have a condition requiring them to maintain a regular sleep schedule.
• Providing accessible telephone equipment for a doctor who has a hearing impairment.
• Installing an air vent for a radiology technician with asthma after they report breathing difficulties in the dark room.

What illnesses are covered under the ADA?

The ADA doesn’t list specific conditions that qualify a worker to receive a reasonable accommodation. Some conditions are visible and others are not. Fundamentally, if a worker is struggling to carry out their job due to their condition and work environment, they are eligible to receive modifications. Below are some common examples of ADA medical conditions:

• Diabetes
• Deafness or hearing loss
• Blindness or impaired vision
• Post-traumatic stress disorder (PTSD)
• Major depressive disorder
• Cerebral palsy
• Intellectual disabilities

ADA Reasonable Accommodation Checklist: 5 Steps To Manage Requests

Now that you’ve learned the significance of reasonable accommodation requests, we’ll walk you through five steps you can take to manage them.

1. Establish a System for Receiving Requests

There’s no standard way for healthcare workers to submit accommodation requests, and it’s also not legally required to use the term “reasonable accommodation” or mention the ADA. Nursing, medical, and administrative staff who ask for modifications linked to a medical condition are expected to receive an appropriate response from their employer.

Because of this, facility leaders should implement a clear system for staff to prevent an ADA request for accommodation from being overlooked. This could entail:

• Creating a facility-specific ADA accommodation request form.
• Asking workers to send an “ADA request for accommodation” letter via email.
• Holding office hours for requests to be made and discussed in-person.

When creating your facility-specific forms to document requests, it may be useful to start with a reasonable accommodations request template.

2. Review the Request

After receiving a request, it’s important to review all necessary information that can help you understand how an employee’s medical condition might impact their work. The following table lists factors that may need to be reviewed.

3. Discuss Reasonable Accommodations

Accommodations are considered reasonable if they don’t pose an undue hardship to a facility under the ADA. Healthcare facilities can differ broadly in size, budget, and structural capacities, so what’s considered reasonable for one facility may not be reasonable for another.

If you determine that your facility’s capacities can’t support specific accommodations requested by a worker, it’s important to open up dialogue with the worker and explore alternative ways to remove workplace barriers.

4. Implement Accommodations

Once you and your employee have discussed their ADA request for reasonable accommodation and identified a feasible modification, you should work to implement changes in a timely manner. Keep your employee in the loop throughout this process and have a clear plan for how accommodations will be made. Additionally, notify any other members of the healthcare team that may also be affected by these changes, but be cautious about not disclosing any confidential medical information in the process.

5. Follow Up After Implementation

Sometimes, finding the most suitable way to provide an accommodation may take ongoing evaluation and tweaking. Once an accommodation has been made, follow up with the employee who submitted the request and ensure any barriers have been successfully removed. If not, it’s important to reevaluate what further steps can be taken. Remember, this is an interactive process, so ongoing communication is the key to mutually beneficial outcomes.

Stay Current With the Compliance Issues Facing Your Facility

As a facility leader, you face many complex compliance issues — and responding to reasonable accommodation requests is an important one. We know that staying up to date takes a lot of time, so we’re here to do the heavy lifting for you with trusted, expert-backed healthcare compliance resources and guides.

Legal Disclaimer: This article contains general legal information, but it is not intended to constitute professional legal advice for any particular situation and should not be relied on as professional legal advice. Any references to the law may not be current as laws regularly change through updates in legislation, regulation, and case law at the federal and state level. Nothing in this article should be interpreted as creating an attorney-client relationship. If you have legal questions, you should seek the advice of an attorney licensed to practice in your jurisdiction.