JAN Workplace Accommodation Toolkit

Recruiting, hiring, and managing people with disabilities throughout the employee life cycle need not be difficult or complicated. It starts with understanding and recognizing the applicant’s or employee’s disclosure of a disability and the associated request for an accommodation.

As a recruiter, hiring manager, or supervisor, you play a critical role in ensuring that your applicants, candidates, and employees feel comfortable and safe disclosing a health condition and believing that they will continue to be provided with equal opportunity and a workplace free from discrimination. Research shows employees with disabilities are more likely to disclose to the supervisor than to the human resources department.

Emerging Employment Issues for People with Disabilities: Disability Disclosure, Leave as a Reasonable Accommodation, Use of Job Applicant Screeners by Sarah von Schrader, Valerie Malzer, William Erickson, Susanne Bruyère. http://digitalcommons.ilr.cornell.edu/edicollect/1288

Thus, the goal of this toolkit is provide resources to support your efforts in accommodating applicants and workers with disabilities.

Note: Throughout this toolkit the word “accommodation” will be used synonymously with the words “adjustment” and “productivity enhancements.” Employees who are coming to terms with a disability may or may not know how to refer to their health situation in a work context and/or accommodations they need to meet performance requirements. It is incumbent upon a manager to seek to understand what the employee is trying to convey and then help them to navigate the process your company utilizes of providing a reasonable accommodation.

In the early stages, it can feel daunting to fully get your arms around and then, as needed, adjust your current hiring, stay-at-work, and return-to-work practices to be fully disability-inclusive and compliant. The reward merits the effort, as research shows that the return on investment includes increasing your talent pool, higher retention rates, enhanced engagement and productivity, and a stronger brand as an employer of choice for all talent.

To learn more about the value proposition for hiring, retaining, and advancing people with disabilities, go to:

• JAN's The Value Proposition for Engaging People with Disabilities
  • This 11-minute training module and accompanying transcript provides a brief overview of the value proposition for hiring, retaining, and marketing to people with disabilities.
• JAN's Disability Awareness to Increase Your Comfort, Confidence, and Competence
  • This 27-minute training module and accompanying transcript provides technical assistance on how to increase your comfort, confidence, and competence through disability awareness.
• Read what JAN’s employer customers report about the cost and benefits of workplace accommodation in our annual publication Low Cost, High Impact.

JAN has developed a guide to enable employers to better understand the ADA and Reasonable Accommodation. The Employers' Practical Guide provides information in a simple question-and-answer format. There is information in the Guide specific to the context of recruiting and interviewing and retaining an employee.

Employers can and should expect employees with disabilities to meet productivity/performance standards. To sustain productivity, it may be necessary to update and or refine essential job functions of the positions for which you are evaluating and/or recruiting.

• To learn more about reviewing your job descriptions to establish essential functions, go to JAN's resources on job descriptions.

Good communication is essential to a productive workplace. This is particularly important with individuals with disabilities who may be reluctant to ask for what they need to do their best work because they are unsure what response they might receive. In a study conducted by Cornell University, researchers found the following:

And

Emerging Employment Issues for People with Disabilities: Disability Disclosure, Leave as a Reasonable Accommodation, Use of Job Applicant Screeners by Sarah von Schrader, Valerie Malzer, William Erickson, Susanne Bruyère. http://digitalcommons.ilr.cornell.edu/edicollect/1288

For recruiters or hiring managers*:

One of the questions recruiters and hiring managers often have is whether they can ask applicants if they will need an accommodation to participate in the hiring process. According to the Equal Employment Opportunity Commission (EEOC), the answer is yes — “an employer may tell applicants what the hiring process involves (for example, an interview, timed written test, or job demonstration), and may ask applicants whether they will need a reasonable accommodation for this process.”

A best practice would be to add an accommodation statement to your career portal, application, or other recruiting materials. Below is sample language.

“If you require reasonable accommodation in completing this application, interviewing, completing any pre-employment testing, or otherwise participating in the employee selection process, please direct your inquiries to…”

But what happens if you invite applicants to request accommodations for the hiring process and an applicant with an obvious disability shows up for a job interview, has not requested an accommodation, but it is clear to you that one is needed to complete the interview? Can you ask the applicant about it?

This is not spelled out in formal EEOC guidance, so rather than specifically asking whether an accommodation is needed, one approach that might work is to indicate that you have noticed a challenge that is going to interfere with completing the interview process, describe that challenge, and ask whether there is anything you might do to help overcome the challenge so the interview can be completed. This way you are not mentioning disability or accommodation, but you are addressing the challenge.

Example: An applicant with an obvious hearing impairment does not ask for accommodations for the interview, but you notice immediately that he is missing some of what you are saying to him. You might want to let him know that it appears he is missing some of what you are saying and ask him if there is anything you can do to improve communication.

Another question hiring managers have is whether they can ask applicants if they will need accommodations on the job if they are hired. Here the answer is generally no. However, according to the EEOC, “when an employer could reasonably believe that an applicant will need reasonable accommodation to perform the functions of the job, the employer may ask that applicant certain limited questions. Specifically, the employer may ask whether s/he needs reasonable accommodation and what type of reasonable accommodation would be needed to perform the functions of the job.”

The employer could ask these questions if:    

1. The employer reasonably believes the applicant will need reasonable accommodation because of an obvious disability;
2. The employer reasonably believes the applicant will need reasonable accommodation because of a hidden disability that the applicant has voluntarily disclosed to the employer; or
3. An applicant has voluntarily disclosed to the employer that s/he needs reasonable accommodation to perform the job.

Unless these conditions are met, a recruiter or hiring manager should not raise the issues of disability.  

For more information, see Preemployment Disability-Related Questions and Medical Examinations.

Most often, the workplace accommodation process begins when a person with a disability requests an adjustment because of a challenge faced during the hiring or onboarding process. Applicants with disabilities have the responsibility to request an accommodation.

If an applicant has disclosed or has an obvious disability, then begin to ask yourself, “How does this information impact the interview?” and, “How does this information about a disability impact assessment of qualifications and ability to perform the job?” Recruiters or hiring managers may ask a particular applicant or candidate to describe or demonstrate how they would perform a job when there is reasonable belief that the person will not be able to perform the function because of a known disability.  

Disclosure of a disability and a request for accommodation has two parts:

1. disability, chronic health condition, or impairment causes the challenge, and
2. the specific challenge they are having related to the task at hand.

An example of a request for an accommodation during the hiring process might be “The online application won’t work with my screen reader” or “I keep getting timed out during the test.” To accommodate the applicant or candidate, you will want to ask additional information about the challenge related to their disability.

*Note: It is important for recruiters and hiring managers to be aware of the company’s policy and process for accommodation. Particularly when it comes to medical information. At times, candidates may offer information to accompany their request for accommodation. So be prepared. The confidentiality of this information is key to inclusion and compliance.

For supervisors:

On the job, employers often want to know whether they must ask employees if they need accommodations. The accommodation process most often begins when an employee requests an adjustment because of a medical issue; generally it is an employee’s responsibility to let the employer know that an accommodation is needed. However, employers are allowed to ask if an accommodation is needed under certain circumstances. According to the EEOC, “an employer may ask an employee with a known disability whether s/he needs a reasonable accommodation when it reasonably believes that the employee may need an accommodation. For example, an employer could ask a deaf employee who is being sent on a business trip if s/he needs reasonable accommodation. Or, if an employer is scheduling a luncheon at a restaurant and is uncertain about what questions it should ask to ensure that the restaurant is accessible for an employee who uses a wheelchair, the employer may first ask the employee. An employer also may ask an employee with a disability who is having performance or conduct problems if s/he needs reasonable accommodation.”

Supervisors may only ask whether or not an employee needs and accommodation when:

1. The employee has an obvious or known disability, and
2. The employer has a reasonable belief that the employee may need an accommodation because of the disability.

For more information, see Reasonable Accommodation and Undue Hardship under the ADA.

Also, you may want to read a JAN Enews Article entitled Mother May I? Must I? Should I?

Disclosure of a disability and a request for accommodation has two parts:

1. disability, chronic health condition, or impairment causes the challenge, and
2. a specific challenge they are having related to their job duties.

An example of a request for an accommodation during the employee life cycle might be “I hurt my back last week and cannot lift over 25 pounds” or “I have been diagnosed with diabetes and need a private space to give myself an insulin injection.” To accommodate the employee, you will want to ask additional information if necessary about the challenge related to a disability. This challenge may be related to the employee’s performance of the essential functions of the job or when a disability prevents the employee from enjoying the benefits and privileges of work such as attending an offsite training.

In order to support an inclusive and compliant workplace, recruiters, hiring managers, or supervisors need to anticipate requests for accommodation or adjustments at work. In anticipating requests, it is important to begin thinking through the process before a request is made. Below are a number of questions to be ready to ask when a disclosure of a disability and a request for an accommodation is made.

Questions to Consider:

1. What limitations is the employee experiencing?
2. How do these limitations affect the employee and the employee’s job performance?
3. What specific job tasks are problematic as a result of these limitations?
4. What accommodations has the person had in the past that were successful, or does the person know of accommodations available to reduce or eliminate these problems?
5. If accommodations are not known or obvious, what internal and external resources are available to me to find an effective accommodation (e.g., internal accommodation consultant or subject matter expert or JAN)?
6. Once the accommodation is made, what other company personnel do I need to inform of this adjustment (e.g., Do I need to communicate with security so they know an individual has been granted a flexible schedule and therefore will be working late on certain days)?
7. Is training required because of the accommodation (e.g., a person accommodated with text enlargement software may require training on the software)?
8. How often do I need to follow up to ensure the accommodation continues to be effective?

Making adjustments to the workplace, with the goal of bringing out the best in everyone and fostering enhanced inclusion, requires an understanding of what is referred to as the interactive process.

The interactive process is simply the ongoing conversation between you and the candidate or employee. This productive dialogue needs to accomplish two purposes:

1. Provide you with the information necessary to make the workplace adjustment consistent with your commitment to equal opportunity, and

2. Demonstrate you engaged in a good faith effort to resolve the workplace challenge with the individual.

To learn more, or use JAN’s process, please follow these links to access training on the interactive process.

Interactive Process Module

Interactive Process Publication

The six training videos below highlight solutions to situations we hear about at JAN. These include interviewing a young person on the autism spectrum, managing an accommodation request from a veteran with hearing loss and post-traumatic stress disorder, managing an accommodation that surfaces during a performance review, retaining an individual with a chronic health condition, hiring an individual with an anxiety disorder resulting in a stutter, and returning a back-injured employee to work . Along with each presentation is a roleplay video that demonstrates how these situations can be successfully managed.

NOTE: The presentation and video are designed to be used together. The videos should not be used as a standalone training, but instead should be used along with the PowerPoint presentation.

Video 1 - Interviewing an individual on the Autism Spectrum

Hiring Individuals with Disabilities (.ppt)

Download High Definition (948 MB) Download Standard Definition (489 MB)

Video 2 - Accommodating an employee with non-apparent disabilities

Retaining Employees with Disabilities (.ppt)

Download High Definition (630 MB) Download Standard Definition (324 MB)

Video 3 - Managing the performance of an employee with a non-apparent disability

Managing Performance of Employees with Disabilities (.ppt)

Download High Definition (1.03 GB) Download Standard Definition (540 MB)

Video 4 - Hiring an Individual with an Anxiety and Stuttering Disorder

Hiring an Individual with an Anxiety and Stuttering Disorder (.ppt)

Download High Definition (254 MB) Download Standard Definition (70.1 MB)

Video 5 - Retaining an Individual with Chronic Health Conditions

Retaining an Individual with Chronic Health Conditions (.ppt)

Download High Definition (168 MB) Download Standard Definition (49.0 MB)

Video 6 - Returning a Back-Injured Employee to Work

Returning a Back-Injured Employee to Work (.ppt)

Download High Definition (359 MB) Download Standard Definition (94.2 MB)

Video 7 - Advancing an Individual Who is Deaf

Advancing an Individual Who is Deaf (.pptx)

Download High Definition (238 MB) Download Standard Definition (82.4 MB)

Video 8 - Retaining an Individual with an Intellectual Disability After a Change in Supervisor

Retaining an Individual with an Intellectual Disability After a Change in Supervisor.pptx

Download High Definition (161 MB) Download Standard Definition (62.1 MB)

As depicted in the video scenarios, workplace adjustments go hand in hand with equal employment opportunity and disability inclusion. 

Accommodations = Equal Opportunity = Inclusion

Based on our experience at JAN, these are the types of workplace adjustments that are typically requested:

Adjustments for recruiting and hiring:

• Ensure equal employment opportunity statement and how to request an accommodation is front and center on hiring materials and career portal
• Modify applicant tracking system/career portal to ensure accessibility
• Modify (caption and audio describe) recruiting videos or multimedia to ensure accessibility
• Inform candidates of the entire hiring process so they may decide if an accommodation is needed
• Ensure physical accessibility of interview site
• Provide readers or interpreters for interviewing/onboarding process after discussion with applicant/new hire
• Ensure accessibility of pre-hire tests and inform candidates of the process for pre-hire tests in advance
• Provide pre-hire and onboarding materials in alternate formats (Braille, audio, large print) as needed
• Ensure accessibility (captioned and audio described) of training videos or multimedia
• Ensure accessibility of online HR systems
• Allow a service animal

Adjustments for retention:

• Modifying schedules or allowing flex time and/or remote work
• Making the workplace or work station accessible for someone returning to work with a change in mobility or range of motion
• Modifying or creating policies enabling a person to bring their service animal into the workplace
• Assistive technology such as screen readers for someone who is blind
• Purchasing a service for someone who is deaf and requires an interpreter, closed captioning, phone with captioning, and/or computer-aided transcriptions
• Restructuring a job for someone on the autism spectrum where a minor portion of the job requires strong communications skills
• Adjusting the work location to one with fewer distractions for individuals with attention, learning, or other conditions that are aggravated by noise and interruptions
• Reassignment to another position for someone whose disability has caused them to be unable to perform the essential functions of their current job.
• Adjusting the supervisory method to enhance productive communication
• Ensuring effective means of communication for individuals with hearing loss or safe means of egress for individuals with mobility impairments during emergency evacuation process.

To view more examples of accommodation situations and solutions, please go to JAN’s Searchable Online Accommodation Resource (SOAR). SOAR is designed to let users explore various accommodation options for people with disabilities in work and educational settings. These accommodation ideas are not all-inclusive. If you do not find answers to your questions, please contact JAN directly. The staff of experienced consultants is available to discuss specific accommodation needs in a confidential manner.

Visit SOAR!

In addition to the resources provided, below are a number of articles you might find valuable.

Articles specific to hiring managers and talent acquisition:

• Resources for Finding Qualified Applicants With Disabilities
• Opening Doors to All Candidates: Tips for Ensuring Access for Applicants with Disabilities
• Making a Statement – About Reasonable Accommodation and Equal Opportunity
• Affirmative Action and Disability: What Can Employers Ask?
• Job Application/interview Stage Dos and Don’ts
• Incorporate Reasonable Accommodation Practices into your Onboarding Process
• Making Pre-employment Testing Accessible: WellPoint Offers a Best Practice
• Testing Accommodations
• Job Applicants and the ADA - Fact Sheet
• Disability-Related Inquiries and Medical Examinations of Employees Under the ADA
• Tips for Designing Accessible Websites, Including the Self-Assessment SNAP Tool

Articles specific to supervisors/managers:

• What to say when an employee asks about a co-workers' accommodation
• Employers' Practical Guide to Negotiating and Requesting Reasonable Accommodations Under the Americans with Disabilities Act (ADA)
• Educating the Workforce about the ADA & Accommodations
• Job Descriptions
• How to Determine Whether a Person Has a Disability under the Americans with Disabilities Act Amendments Act (ADAAA)

All personnel must respect employee confidentiality. Ensuring the confidentiality of all medical information obtained in connection with a request for reasonable accommodation, as well as the confidentiality of all associated communications during the interactive process, is required by federal law.

All documentation must be kept in a file separate from an individual’s personnel file. Non-medical information obtained during this process is shared on an as-needed basis with those involved in providing a reasonable accommodation.

Ensuring a robust interactive process in order to negotiate effective workplace adjustments for people with disabilities throughout the employee life cycle can feel daunting, but we are here to help make the complex simpler. The most important aspect is to have transparent, actionable policies and processes as well as a robust training on these processes for all involved, but with a particular focus on people managers.

It Starts with Your Role:

In organizations who are getting ready to designate or hire a Reasonable Accommodation Subject Matter Expert (RA SME) is helpful to have a solid job description to start with and customize. We have three sample job descriptions.

1. Review Job Descriptions

In many cases the RA Consultant may be asked by managers to review their job descriptions and guide them in understanding how to describe the essential functions of a position. Guidance that will be helpful when supporting managers in this regard can be found at JAN's Accommodation and Compliance Series: Job Descriptions.

2. Develop Robust Actionable Policies and Processes

Whether you are refreshing your RA policies and processes or creating them from scratch, you may want to review the sample JAN policies and procedures, containing a number of best and emerging processes, as well as review many of the examples provided by companies known for being disability-inclusive. Public sector examples of accommodation policies may be helpful as well.

Often it is good to conceptualize the process as a flow chart to more clearly understand how accommodation requests will be handled. In developing or refreshing your accommodations program, a good source for information is Deb Dagit's The Value Proposition for Engaging People with Disabilities and Disability Awareness to Increase Your Comfort, Confidence, and Competence.

3. Develop Accompanying Accommodation Forms

Good processes include forms to support communication and implementation at all phases of the interactive process. You may also want to review and consider adapting JAN’s sample accommodation-related forms or adapting example forms provided by disability-inclusive companies.

4. Develop Checklists

Process checklists can helpful to manage the accommodation process. When hiring individuals with a disability, consider our sample onboarding checklist. When accommodating existing employees, consider examples of accommodation checklists offered by our partners. 

5. Communicate and Educate

Communicate and educate company employees, including the program’s executive sponsor and others whose cooperation is important to the program’s success. First, be sure to develop and prominently display an equal opportunity statement. And second, train employees so everyone understands the value of engaging people with disabilities. Sample JAN trainings include The Value Proposition for Engaging People with Disabilities and Disability Awareness to Increase Your Comfort, Confidence, and Competence. For more information, see examples of training offered by disability-inclusive companies. EY also has a few resources you may find of value, including a Non-Visible Disabilities Guide as well as two inclusion-related checklists.

6. Track Requests

Tracking accommodation requests is essential for an inclusive and compliant workplace. For ideas in tracking requests, please review examples of accommodation tracking from our partners or consider purchasing tracking software. For a list of potential metrics to track, please reference the "Sample Accommodation Metrics" section within this drawer.

The workplace accommodation process most often begins when a person with a disability, chronic health condition, or impairment requests an adjustment at work when their medical condition creates a challenge at work. This challenge may be related to the application or onboarding process, their performance of their job, or when their medical condition prevents an employee from enjoying the benefits and privileges of work. However, if it is obvious that an applicant or employee’s disability is creating challenges at work, then the hiring manager or supervisor may initiate the accommodation process.

Now You are Ready to Facilitate the Conversation otherwise known as the Interactive Process (IP). Making adjustments to the workplace, with the goal of bringing out the best in everyone and fostering enhanced inclusion, requires an understanding of what is referred to as the interactive process.

The interactive process is simply the ongoing conversation between you and the candidate or employee. This productive dialogue needs to accomplish two purposes:

1. Provide you with the information necessary to make the workplace adjustment consistent with your commitment to equal opportunity, and
2. Demonstrate you engaged in a good faith effort to resolve the workplace challenge with the individual.

With you as a resource; a clear job description to work with; and policies, forms and checklists spelling out what needs to happen, the next element needed is a well-communicated and actionable accommodation process that is defensible and consistently implemented. Strong accommodation processes have the following elements:

• A step-by-step process for disclosing the need for and negotiating an accommodation throughout the employee lifecycle including pre-hire, onboarding, stay-at-work, and return-to-work (includes occupational workers' compensation and non-occupational)
• Roles of Key players - Making workplace adjustments is a team effort. A supervisor may be responsible for providing a flexible schedule; facilities may need to widen a doorway; absence management may need to offer additional leave. Everyone understanding and being vested in performing their role on a timely basis ensures effective accommodations.
• Timeframes for various steps of the process are essential. How soon after the disclosure and request for an adjustment is the supervisor required to communicate with the employee? How long before the accommodation is implemented? Commitments to when the person can expect a response are essential towards understanding whether or not your process is effective. That said, it is normal for timeframes to shift due to specific circumstances involved. Stating a timeframe does not mean that it is not changeable, it just means the commitment is revisited and shifted if/as needed.
• Keeping the lines of communication open is critical: Applicants, new hires, and employees need to know that they are valued and that progress is occurring in relation to the accommodation being requested. A good process stipulates how and how often this communication should occur.

Consistency in implementation of the accommodation processes is essential to the success of the program. JAN has developed process steps that are easily adaptable for your program. This includes six distinct steps including:

Step 1: Recognizing an Accommodation Request

Step 2: Gathering information

Step 3: Exploring Accommodation Options

Step 4: Choosing an Accommodation

Step 5: Implementing the Accommodation

Step 6: Monitoring the Accommodation

To learn more, or use JAN’s process for training your staff, please follow these links to access training on the interactive process.

Interactive Process Module

Interactive Process Publication

The six training videos below highlight solutions to situations we hear about at JAN. These include interviewing a young person on the autism spectrum, managing an accommodation request from a veteran with hearing loss and post-traumatic stress disorder, managing an accommodation that surfaces during a performance review, retaining an individual with a chronic health condition, hiring an individual with an anxiety disorder resulting in a stutter, and returning a back-injured employee to work . Along with each presentation is a roleplay video that demonstrates how these situations can be successfully managed.

NOTE: The presentation and video are designed to be used together. The videos should not be used as a standalone training, but instead should be used along with the PowerPoint presentation.

Video 1 - Interviewing an individual on the Autism Spectrum

Hiring Individuals with Disabilities (.ppt)

Download High Definition (948 MB) Download Standard Definition (489 MB)

Video 2 - Accommodating an employee with non-apparent disabilities

Retaining Employees with Disabilities (.ppt)

Download High Definition (630 MB) Download Standard Definition (324 MB)

Video 3 - Managing the performance of an employee with a non-apparent disability

Managing Performance of Employees with Disabilities (.ppt)

Download High Definition (1.03 GB) Download Standard Definition (540 MB)

Video 4 - Hiring an Individual with an Anxiety and Stuttering Disorder

Hiring an Individual with an Anxiety and Stuttering Disorder (.ppt)

Download High Definition (254 MB) Download Standard Definition (70.1 MB)

Video 5 - Retaining an Individual with Chronic Health Conditions

Retaining an Individual with Chronic Health Conditions (.ppt)

Download High Definition (168 MB) Download Standard Definition (49.0 MB)

Video 6 - Returning a Back-Injured Employee to Work

Returning a Back-Injured Employee to Work (.ppt)

Download High Definition (359 MB) Download Standard Definition (94.2 MB)

Video 7 - Advancing an Individual Who is Deaf

Advancing an Individual Who is Deaf (.pptx)

Download High Definition (238 MB) Download Standard Definition (82.4 MB)

Video 8 - Retaining an Individual with an Intellectual Disability After a Change in Supervisor

Retaining an Individual with an Intellectual Disability After a Change in Supervisor.pptx

Download High Definition (161 MB) Download Standard Definition (62.1 MB)

As depicted in the video scenarios, workplace adjustments go hand in hand with equal employment opportunity and disability inclusion. 

Accommodations = Equal Opportunity = Inclusion

Based on our experience at JAN, these are the types of workplace adjustments that are typically requested:

• Modifying schedules or allowing flex time and/or remote work
• Making the workplace or work station accessible for someone returning to work with a change in mobility or range of motion
• Modifying or creating policies enabling a person to bring their service animal into the workplace
• Assistive technology such as screen readers for someone who is blind
• Purchasing a service for someone who is deaf and requires an interpreter, closed captioning, phone with captioning, and/or computer aided transcriptions
• Restructuring a job for someone on the autism spectrum where a minor portion of the job requires strong communications skills
• Adjusting the work location to one with fewer distractions for individuals with attention, learning, or other conditions that are aggravated by noise and interruptions
• Reassignment to another position for someone whose disability has caused them to be unable to perform the essential functions of their current job.
• Adjusting the supervisory method to enhance productive communication
• Ensuring effective means of communication for individuals with hearing loss or safe means of egress for individuals with mobility impairments during emergency evacuation process.

To view more examples of accommodation situations and solutions, please go to JAN’s Searchable Online Accommodation Resource (SOAR). SOAR is designed to let users explore various accommodation options for people with disabilities in work and educational settings. These accommodation ideas are not all-inclusive. If you do not find answers to your questions, please contact JAN directly. The staff of experienced consultants is available to discuss specific accommodation needs in a confidential manner.

Visit SOAR!

The frequently cited axiom “What Gets Measured Gets Done” illustrates that metrics matter, including those associated with a reliable and sustainable accommodation process. Documentation and metrics that are recommended as best practice for an RA program may include the following:

• Accommodation inquiry tracking
• Disclosed reason/need for RA and associated type of request for accommodation
• Accommodations provided and reported by supervisor
• Accommodations provided and reported by RA team
• Total accommodation time - from request to implementation
• Actions taken by interdepartmental team to implement RA
• Accommodations denied with documentation
• Accommodations appealed
• Appeal notations and outcome
• Days lost from work by employee

There are software programs to assist with tracking metrics. JAN has a list of accommodation tracking tools to consider.

Satisfaction with RA Is Important Too:

In order to measure the effectiveness of your program, it is considered a best practice to conduct a post-accommodation satisfaction inquiry and document the outcome with the new hire or employee receiving the accommodation and their manager. This step allows you to verify that the accommodation is working for all parties and ideally should not only occur right after the accommodation is provided, but at six-month intervals thereafter.

There are a number of best and emerging practices in developing a successful accommodations program. Below are a number of such practices.

• Create a single point of contact for accommodation requests – a reasonable accommodation consultant. Managers need to have readily available support and should not be expected to implement the RA process alone.  It is very important they know who can assist them and not have to spend too much time searching for this information.
• Build an internal business case that is communicated to everyone in the company. Analyze your company’s lost productivity time, cost of short-term leave, long term leave, and cost of recruitment and hiring.
• Train everyone in the company about the importance of engaging people with disabilities and how to engage. For more information, see:
  • JAN's The Value Proposition for Engaging People with Disabilities. This 11-minute training module and accompanying transcript provides a brief overview of the value proposition for hiring, retaining, and marketing to people with disabilities.
  • JAN's Disability Awareness to Increase Your Comfort, Confidence, and Competence. This 27-minute training module and accompanying transcript provides technical assistance on how to increase your comfort, confidence, and competence through disability awareness.
  • Inclusion consultants
  • Disability etiquette trainers
• Start with a robust return-to-work program and build out a stay-at-work program from there. For more information see JAN's Accommodation and Compliance Series: Return-to-Work Programs.
• Purchase or develop an accommodation tracking system customized to your company. It can be as simple as a spreadsheet, but ensure you capture sufficient information about accommodations granted so that new supervisors and others such as your information technology team are alerted to an employee’s accommodation status. For ideas in tracking requests, please review examples of accommodation tracking from our partners or consider purchasing tracking software. For a list of potential metrics to track, please reference the "Sample Accommodation Metrics" section within this drawer.
• Encourage use of outside resources like JAN to obtain accommodation ideas or discuss a specific situation in confidence.
• Develop a centralized accommodation fund with expedited procurement. For more information see JAN's Best Practices in Establishing a Centralized Accommodation Fund.
• Ensure the accessibility of your Applicant Tracking Systems or Career Portal. For more information, see JAN's Online Applications and Web Accessibility resources and PEAT's TalentWorks.
• Ensure your  pre-hire tests are accessible. For more information, see JAN's ENews article on Making Pre-employment Testing Accessible: WellPoint Offers a Best Practice and Testing Accommodation resource page.
• Incorporate good accommodation practices into your onboarding process (includes checklist).
• Identify and collaborate with your IT Team on issues of accessibility. Suggest an accessibility expert be embedded or developed for the team. Request an IT Team member join the International Association of Accessibility Professionals.
• Learn more about assistive technologies. There are three excellent forums where they can learn more:
  • CSUN Conference on Disabilities
  • M-Enabling Summit
  • ATIA
• Develop a list of preapproved accommodation items not requiring a full RA assessment and the associated process. These “fast track” adjustments might include things like stand/sit desks, ergonomic chairs, flexible work arrangement guidelines, and obtaining closed captioning for large meetings.
• Focus on performance, equal opportunity, and business requirements instead of delving into the medical diagnosis details. This will avoid privacy concerns and ensure that the conversation is about the business needs.
• Harmonize the accommodation program including investing in creating and sustaining collaborative relationships with other departments that often can assist with an RA including:  Safety, Procurement, Benefits (leave), Information Technology, Employment Legal, HR Business Partners, and Facilities.
• Provide boilerplate accessibility contract language when purchasing products and services to those involved in procurement. For more information see the GSA's BuyAccessible Wizard. Use the PEAT BuyIT! Guide, the online resource that helps employers and their purchasing staff build accessibility and usability into their information and communication technology procurement processes.
• Identify and collaborate with your IT Team on issues of accessibility. Suggest an accessibility expert be embedded or developed for the team. Request an IT Team member join the International Association of Accessibility Professionals
• Assess your technology accessibility practices using the PEAT TechCheck benchmarking tool.
• Develop a “Task Bank” for return to work. A Task Bank is a list of tasks and jobs that an injured employee is able to perform given his/her medical restrictions while transitioning back to into the workplace. For more information, see this whitepaper on The Task Bank
• Provide training and tips for enhancing informal communication and participation with employees who have disabilities. This includes manager training to foster inclusion by encouraging employees with disabilities to be included in informal lunch and after work gatherings, team building, and developmental opportunities such as training and professional meetings. For more information, see JAN's resource page on Disability Etiquette.
• Create a disability-inclusive culture. You can read more on how in EARN’s Inclusion @Work: A Framework For Building a Disability-Inclusive Organization and read EARN Employer Success Stories

   

• ADA leave as an accommodation
• Family Medical Leave Act (FMLA) resources
• Conduct and performance
• Medical exams and inquiries
• ADA definition of disability
• Employee parking
• Service animals in the workplace
• Telework resources
• Providing temporary or trial accommodation solutions
• Employee harassment
• A guide to help you navigate, plan, and create accessible meetings
• American Bar Association Commission on Disability Rights – Planning Accessible Meetings and Events: A toolkit
• Accessible presentations – W3C How to Make Presentations Accessible to All
• Help Colleagues With Disabilities Succeed in Meetings

Disability-related guidance documents from the Equal Employment Opportunity Commission.

As an RA SME/Consultant, you will want to invest in your own ongoing development. This may include attending training conferences such as the:

• U.S. Business Leadership Network
• JAN’s Webcast series
• Disability Management Employers Coalition
• National Industry Liaison Group
• Return-to-Work Institute at the WCI 360 Workers' Compensation Conference
• CSUN Conference on Disabilities
• M-Enabling Summit
• ATIA

All personnel must respect employee confidentiality. Ensuring the confidentiality of all medical information obtained in connection with a request for reasonable accommodation, as well as the confidentiality of all associated communications during the interactive process, is required by federal law.

All documentation must be kept in a file separate from an individual’s personnel file. Non-medical information obtained during this process is shared on an as-needed basis with those involved in providing a reasonable accommodation.

• Resource Groups 101: A Primer on Starting Them & Using Them for Business Goals - DiversityInc
• Disability Employee Resource Group Compendium: Employer Best Practices - Viscardi Center
• Do You Need an Employee Resource Group for People with Disabilities? - SHRM
• EY’s Resource Groups Connect Members With Its Culture, Community and Clients - DiversityInc

Disclosing a disability or chronic health condition and Requesting an Accommodation

It is the responsibility of a candidate or employee to request an accommodation or adjustment from an employer, therefore all employees need to invest the time to seek out and understand the organization’s RA policy, process steps, and, when requested, forms associated with requesting and receiving a workplace adjustment.

Government regulatory guidance specifies that there are no “magic words” required to request an accommodation. That said, it is suggested that you look into and understand your organization’s reasonable accommodation (RA) process and then think through how you want to request an accommodation so that you feel fully prepared and are clear about the nature of your request and what you think would help you to reach/sustain your full potential to contribute at work. 

If you are not a person with a disability yourself, you should know that many times coworkers feel more comfortable speaking with a peer than talking with a manager or HR professional. By making the time to learn how the accommodations process works in your company, you can be prepared to help someone who may be feeling vulnerable and help to enhance inclusion.

It is important to remember that most disabilities are not obvious/visible and there is stigma associated with many health conditions. By supporting your colleagues, you are creating an environment where, in the event you acquire a temporary or long-term health condition, you will be more likely to receive similar support.

Disclosure and requesting an accommodation has two parts:

1. Telling your employer you are living with a disability, chronic health condition, or injury and
2. Describing the challenge your disability, chronic health condition, or injury presents in your workplace.

By informing your employer that you have a disability and any associated challenges you are experiencing, both you and your manager will then be able to identify an accommodation solution that is effective. It is important to focus on what you need to perform the duties of your job when requesting the accommodation. It is not suggested you focus on your medical diagnosis, and only provide the health information required by your employer. You can read more about whether to or how to disclose at JAN's Disclosure resource page.

Based on our experience at JAN, these are the types of workplace adjustments that are typically requested:

• Modifying schedules or allowing flex time and/or remote work
• Making the workplace or work station accessible for someone returning to work with a change in mobility or range of motion
• Modifying or creating policies enabling a person to bring their service animal into the workplace
• Assistive technology such as screen readers for someone who is blind
• Purchasing a service for someone who is deaf and requires an interpreter, closed captioning, phone with captioning, and/or computer-aided transcriptions
• Restructuring a job for someone on the autism spectrum where a minor portion of the job requires strong communications skills
• Adjusting the work location to one with fewer distractions for individuals with attention, learning, or other conditions that are aggravated by noise and interruptions
• Reassignment to another position for someone whose disability has caused them to be unable to perform the essential functions of their current job.
• Adjusting the supervisory method to enhance productive communication
• Ensuring effective means of communication for individuals with hearing loss or safe means of egress for individuals with mobility impairments during emergency evacuation process.

To view more examples of accommodation situations and solutions, please go to JAN’s Searchable Online Accommodation Resource (SOAR). SOAR is designed to let users explore various accommodation options for people with disabilities in work and educational settings. These accommodation ideas are not all-inclusive. If you do not find answers to your questions, please contact JAN directly. The staff of experienced consultants is available to discuss specific accommodation needs in a confidential manner.

Visit SOAR!

If you company does not have a form to use in order to request an accommodation, consider using our sample accommodation request letter. You can use this information and suggestions to engage in a productive conversation with your supervisor.

Some companies also have a disability-focused Business/Employee Resource Group. If this grassroots team is available, they can be a rich and supportive resource as well.

To learn more about accommodations and/or your rights as an individual with a disability, chronic health condition, or injury you can go to JAN's Employees' Practical Guide to Negotiating and Requesting Reasonable Accommodations Under the Americans with Disabilities Act (ADA).