For nonprofit leaders, responding to employee accommodation requests means walking a line between compliance and compassion. The Americans with Disabilities Act (ADA) requires employers to engage in a timely, good-faith interactive process which is a structured conversation that explores whether a reasonable accommodation can be made to support an employee with a disability. Failing to do so can expose an organization to legal risk, including discrimination claims or costly settlements.
At the same time, most nonprofits don’t need a legal mandate to want to do the right thing. Creating a work environment where employees feel supported and seen is part of what makes mission-driven organizations thrive. The interactive process isn’t just about legal boxes to check — it’s a chance to live out your organizational values in real time.
The step-by-step guide below is designed to help nonprofit HR teams and leaders navigate these conversations with clarity, care, and confidence.
Steps to follow:
Step 1: Recognize the Request
- A request for accommodation doesn’t need to be formal or use legal language.
- If an employee mentions a medical condition or limitation and asks for help performing their job, this likely triggers the ADA interactive process.
Examples:
- “I need help with lifting duties due to my injury.”
- “Can I adjust my schedule for medical treatments?”
Tip: Train supervisors to recognize these cues and refer them to HR right away.
Step 2: Acknowledge the Request
- Respond promptly—ideally within 1–3 business days.
- Let the employee know you’ve received the request and will begin a collaborative discussion.
- Emphasize that the process is meant to support their ability to perform the job.
Suggested language:
“Thank you for bringing this to our attention. We’d like to talk more with you to understand how we can support you in your role.”
Step 3: Gather Information
Meet privately to explore:
- The nature of the limitation (not necessarily the diagnosis)
- How it affects essential job functions
- Any ideas the employee has for possible accommodations
You may request medical documentation only if the disability or need for accommodation is not obvious. Requests for information must be job-related and limited to what’s necessary to understand the functional limitations.
Step 4: Explore Accommodation Options
Collaborate with the employee to identify accommodations that would help.
Examples include:
- Modified work schedules
- Ergonomic equipment
- Telework options
- Extended or intermittent leave
- Reassignment to a vacant position
Be creative and open, while also realistic about operational needs. Tools like askjan.org can help generate ideas.
Step 5: Evaluate Appropriateness and Feasibility
Not all accommodation requests will be feasible, appropriate, or legally required. When evaluating options, consider:
- Effectiveness: Will it enable the employee to perform essential job duties?
- Impact on others: Does the request involve displacing another employee, such as taking away their schedule or responsibilities?
It’s generally not reasonable to remove an existing benefit or schedule from one employee to give it to another. While it’s appropriate to explore options, such a request may not be feasible or fair.
- Undue hardship: Would the accommodation cause significant difficulty or expense based on your organization’s specific resources?
“Undue hardship” varies by employer. What may be too costly or disruptive for one organization may be reasonable for another with more resources.
Step 6: Make and Communicate the Decision
Share the decision with the employee, including:
- What accommodation will be provided (if any)
- When and how it will be implemented
- A contact for questions or follow-up
If you deny the request, do so with great care.
- Explain the decision respectfully and clearly
- Document the specific reasons (e.g., direct threat, undue hardship, impact on other employees)
- Offer to continue the conversation to identify alternatives
Important: Denying a request carries legal and relational risk. Employers are expected to demonstrate that they made a good faith effort and considered alternatives before denying an accommodation.
Suggested language for a partial or full denial:
“After reviewing your request and exploring options, we are unable to accommodate [specific request] because [brief explanation]. However, we remain committed to working with you to find another solution that meets your needs and the organization’s requirements. Let’s revisit this together.”
Step 7: Implement and Follow Up
- Put the accommodation in place as agreed
- Monitor how it’s working, and check in regularly:
- “How is this going?”
- “Is this adjustment helping?”
- “Do we need to modify anything?”
Circumstances can change, so accommodations may need to be adjusted over time.
Step 8: Document Everything
Maintain a confidential record of:
- The request
- All conversations
- Medical documentation (if any)
- Decisions made and why
- Any follow-up
Keep ADA-related documentation in a separate, secure medical file (not in the general personnel file and not in the same lockable cabinet).
The interactive process is not a one-time event, it’s an ongoing, collaborative conversation rooted in empathy, practicality, and respect.
Employers are not required to grant every request, but they must engage meaningfully, explore reasonable options, and document their decision-making process.
The goal is to support employees while balancing the needs of the broader team and organization.
If you’d like to discuss this in greater detail, or any other HR situation, don’t hesitate to contact us at HRServices@501c.com or (800) 358-2163.
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For more than 40 years, 501(c) Services has been a leader in offering solutions for unemployment costs, claims management, and HR support to nonprofit organizations. Two of our most popular programs are the 501(c) Agencies Trust and 501(c) HR Services. We understand the importance of compliance and accuracy and are committed to providing our clients with customized plans that fit their needs.
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The information contained in this article is not a substitute for legal advice or counsel and has been pulled from multiple sources.
Images by: Rawpixel-com and Val Suprunovich.
