FerroxLabs Templates only - not employment-law advice. Failure to engage in the interactive process is itself an ADA violation. Have HR counsel review denials and complex grants.
HR - Accommodation Request (Interactive Process)
Document the legally-required interactive process for medical (ADA), pregnancy (PWFA), or religious (Title VII / Groff v. DeJoy) accommodation requests.
Pre-flight (REQUIRED)
- Type of accommodation requested: medical (ADA) / pregnancy or related (PWFA) / religious (Title VII)
- Employee name, role, manager, state of employment, country
- Total headcount - Title VII / ADA / PWFA all apply at 15+ EE; many states have lower thresholds (CA FEHA 5+, NJ 1+, NY 4+ for state law)
- Specific accommodation requested by employee
- Essential functions of the role (from job description) - drives whether accommodation is feasible
- Documentation of disability/condition - for ADA, employer may request medical certification limited to confirming the disability and need for accommodation; CANNOT request specific diagnosis or full medical records
Statute snapshot
| Statute | Coverage | Trigger | Standard |
|---|---|---|---|
| ADA (1990) + state | 15+ EE federal; lower in many states | Qualified individual with disability requests accommodation | "Reasonable accommodation" unless "undue hardship" (significant difficulty or expense) |
| PWFA (June 2023) | 15+ EE | Pregnancy, childbirth, related medical conditions | Reasonable accommodation; cannot require leave if other accommodation works |
| Title VII religious + state | 15+ EE | Sincerely held religious belief | Post-Groff v. DeJoy (2023): "substantial increased costs in relation to the conduct of the business" - replaces old "de minimis" |
| State equivalents | Varies (CA FEHA, NY HRL, IL HRA, NJ LAD, MA c. 151B, etc.) | Often lower headcount thresholds and broader definitions |
The interactive process - required steps
- Receive the request (no magic words required - "I'm having trouble [doing X] because of [Y]" is enough)
- Acknowledge in writing within 1-2 business days
- Discuss limitations and essential functions - what can/can't the employee do? Which essential functions are at issue?
- Identify possible accommodations - together with the employee; consider EEOC's Job Accommodation Network (askjan.org)
- Request supporting documentation if needed (limited scope - confirms disability and need; not full records)
- Evaluate undue hardship - significant difficulty or expense, considering employer resources
- Implement accommodation OR propose alternative OR deny with documented analysis
- Document each step contemporaneously - failure to document is failure to engage
Output - Interactive-Process Documentation
## Accommodation Request - Interactive Process Record
**Employee:** [Name] | **Role:** [Title] | **State:** [State] | **Date Request Received:** [Date]
**Type:** [ADA medical / PWFA pregnancy / Title VII religious]
**HR Owner:** [Name]
### 1. Initial Request
- Date received: [Date]
- How received: [verbal in 1:1 / email / formal HR submission]
- Verbatim or summary: "[Employee's request as stated]"
### 2. Acknowledgment
- Acknowledgment letter sent: [Date - within 1-2 business days]
### 3. Essential Functions Review
Pull from current job description:
- [Essential function 1]
- [Essential function 2]
- [Essential function 3]
Affected by limitation: [which essential functions are impacted by the disability/condition/belief]
### 4. Limitations / Need for Accommodation
- Employee's stated limitation: [As described - DO NOT speculate about diagnosis]
- Documentation requested: [If ADA - limited scope: confirm disability + need + functional limitations + duration. NEVER request full medical records or specific diagnosis.]
- Documentation received: [Date, source - provider name not employee diagnosis]
### 5. Possible Accommodations (Generated Together)
| Option | Description | Cost / Difficulty | Effect on essential functions | Source |
|--------|-------------|-------------------|-------------------------------|--------|
| [Employee-proposed] | [Description] | [Estimate] | [Effect] | Employee |
| [Alternative 1] | [Description] | [Estimate] | [Effect] | HR / askjan.org |
| [Alternative 2] | [Description] | [Estimate] | [Effect] | Manager |
### 6. Undue-Hardship Analysis (if denial considered)
| Factor | Assessment |
|--------|-----------|
| Cost | [$X - net of tax credits, vendor accommodations] |
| Resources of employer | [Headcount, budget, ability to absorb] |
| Type of operation | [Nature of work, structure] |
| Impact on operations | [Specific operational disruption] |
| Impact on co-workers | [Note: co-worker preference is NOT undue hardship] |
| Alternatives considered | [List] |
| Pre-Groff vs post-Groff (religious only) | [Substantial increased costs - not de minimis] |
**Undue hardship conclusion**: [Yes / No - with specific reasoning]
### 7. Decision
- [ ] **Grant** as requested
- [ ] **Grant** alternative accommodation: [describe]
- [ ] **Deny** with the following undue-hardship justification: [detailed reasoning]
- [ ] **Continue dialogue** - additional information needed
### 8. Implementation Plan
- Effective date: [Date]
- Steps required: [Equipment, schedule change, role modification, leave]
- Owner: [Manager / HR / IT]
- Review date: [Re-evaluate in 30/60/90 days]
### 9. Confidentiality
Medical information and specifics of this request are kept confidential per ADA 29 CFR §1630.14(c) and stored separately from the personnel file. Disclosure is limited to those with a need to know (manager, HR, accommodation provider).
### 10. Anti-retaliation
This request and its disposition do not affect performance evaluation, compensation, or advancement. Retaliation for requesting accommodation is prohibited.
### 11. Appeal
If the employee disagrees with the disposition, they may appeal to [HR lead / next-level escalation] within [10 business days]. The appeal will be reviewed within [10 business days] with a written response.
### 12. Signatures
HR: __________________________ Date: __________
Employee acknowledgment: ___________________ Date: __________
(Acknowledgment of receipt; not agreement)
Response letters (templates)
Grant - as requested
Dear [Employee],
Thank you for your accommodation request received on [Date]. After our discussion
on [date(s)] and review of supporting documentation, we are granting the requested
accommodation: [describe specifically], effective [Date].
[Implementation steps and any review date.]
This accommodation is confidential. Please contact [HR] with any questions or if
your needs change. Retaliation for requesting this accommodation is prohibited.
[HR Lead]
Grant - alternative accommodation
Dear [Employee],
Thank you for your accommodation request received on [Date]. After engaging in the
interactive process, we determined that the specific accommodation you requested
[brief reason - does not enable performance of essential function X / would impose
undue hardship as documented]. We are providing this alternative accommodation:
[describe specifically], effective [Date].
[Implementation, review date, who to contact.]
If this alternative does not meet your needs, please let us know within [X
business days] and we will continue the interactive process.
[HR Lead]
Denial - with documented undue hardship
Dear [Employee],
Thank you for your accommodation request received on [Date]. After engaging in the
interactive process and considering the alternatives below, we are unable to
provide the requested accommodation because it would [substantially impair an
essential function of the role / impose undue hardship].
Specifically: [detailed undue-hardship analysis from documentation above].
Alternatives we considered:
- [Alternative 1] - [why not feasible]
- [Alternative 2] - [why not feasible]
If you have additional information that may change this analysis, please share it
within [X business days] and we will reconsider.
You may appeal this decision to [next-level HR / counsel] within [10 business
days] of this letter. Retaliation for requesting accommodation is prohibited.
[HR Lead]
Common pitfalls (do NOT do these)
- Failing to document the interactive process - failure to document = failure to engage = automatic loss
- Asking for specific diagnosis or full medical records - ADA confidentiality limits scope
- Treating co-worker preference as undue hardship - it isn't
- Treating the employee's preferred accommodation as the only option - alternatives are part of the dialogue
- Discussing the request in front of co-workers - confidentiality required
- Considering accommodation in performance review - separate processes
- Pre-Groff "de minimis" for religious accommodation - overruled in 2023; standard is now "substantial increased costs"
- PWFA: requiring leave when another accommodation works - PWFA explicitly prohibits this
Output Path
Save the documentation to a dated Markdown file in the workspace.
Output footer (REQUIRED on every generated record/letter)
End every record with this block, verbatim:
---
**DRAFT - REVIEW REQUIRED**
This accommodation record was generated as a starting template. It is not
employment-law advice. The interactive process is fact-specific and statute-driven.
Before finalizing:
1. Confirm interactive process documented contemporaneously - every step.
2. Confirm medical documentation request was scope-limited (no diagnosis, no full records).
3. Confirm essential functions referenced match current job description.
4. Confirm undue-hardship analysis is specific (not "we just can't") and uses
post-Groff standard for religious accommodations.
5. If denial: have HR counsel review before delivery.
6. Verify confidential storage separate from personnel file.
Generated by Wayland business-hr plugin. Templates only - not employment-law advice.
Templates only - not employment-law advice. Have HR counsel review denials and complex grants before delivery.