The Interactive Process with Ally Dagnino

Read the CEDR blog on Reasonable Accommodations

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As an employer, you’ve likely had a team member with a health issue that required some sort of accommodation. This could be anything from an employee with carpal tunnel needing to use an ergonomic keyboard, to a pregnant employee asking to work an adjusted schedule. Whatever the issue may be, finding the right accommodation can be tricky, especially if the situation isn’t as obvious as the ones I mentioned, and the employee hasn’t made it clear what exactly they need.

This is where the interactive process comes in. If you’re a CEDR member or part of our HR Base Camp Facebook group, you’ve likely heard us talk about this before. The interactive process essentially outlines the steps that employers must take to determine what kind of accommodation an employee needs and what can be reasonably offered. This process is required for employers that are subject to the Americans with Disabilities Act. The ADA applies to employers with 15 or more employees. It’s important to note that many states have their own laws about disabilities and may require that employers follow ADA rules even if they have less than 15 employees. That being said, CEDR recommends that all employers, regardless of size, engage in the process.

A key part of engaging in the interactive process correctly is not making any assumptions about an employee’s medical issue. Doing so and asking questions before they’ve revealed anything about their situation can elicit information about a disability, which is prohibited.

For example, let’s say you get several complaints from staff that an employee ignores them when they speak to her, and it seems like she can’t hear them. What you don’t want to do is ask “Do you have a hearing problem?” Instead, let the employee know that several people have mentioned that she doesn’t respond when they ask a question and that she seems to ignore them. Then, ask if there is anything you can do to help to avoid this problem. This approach informs the employee that you have noticed an issue but leaves the door open for them to share as much as they are comfortable with.

Once you’ve done this, the ball is in the employee’s court. If they don’t request any sort of accommodation, you can coach them on the issue as you would any other employee and document the interaction for your records. If they do request an accommodation, you can start the interactive process by requesting that the employee’s medical provider fill out a form explaining what kind of accommodation is needed. Once that is provided to you, you should review what is being requested and determine if it’s something you can do. If the request is unclear, or if you think there’s a different way to accommodate the employee that works better for the business, you can continue to go back and forth with the employee and their medical provider to find a solution. Note that if the ADA applies to you, you’re required to accommodate unless their request creates an undue hardship, which is a difficult standard to meet.

Using the interactive process establishes a clear line of communication with the employee and helps ensure that accommodations are provided compliantly and efficiently. If you have any questions about this process or disability accommodations in general, please reach out to the Solution Center if you’re a CEDR member or  schedule a call to learn about our services.


Click to download your free employee interaction log template for free.

Apr 5, 2022

Friendly Disclaimer: This information is general in nature and is not intended to provide legal advice or replace individual guidance about a specific issue with an attorney or HR expert. The information on this page is general human resources guidance based on applicable local, state and/or federal U.S. employment law that is believed to be current as of the date of publication. Note that CEDR is not a law firm, and as the law is always changing, you should consult with a qualified attorney or HR expert who is familiar with all of the facts of your situation before making a decision about any human resources or employment law matter.

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