ADA· 12 min read

The ADA Interactive Process, In Practice

What employers are actually required to do — and how to document a failure-to-accommodate claim while you still have access.

The 'interactive process' is the heart of an ADA accommodation case. It's also where most claims are won or lost — not at trial, but in the email thread between you and HR. This deep dive covers what the process must look like, what triggers it, and how to build a record that survives.

What triggers the duty

You don't have to invoke 'the ADA' or use the word 'accommodation.' Notifying your employer that you need an adjustment at work because of a medical condition is enough. Once that notice lands, the employer's duty to engage in an interactive dialogue begins, and the clock starts on whether they handled it in good faith.

Defining 'qualified individual'

The ADA protects qualified individuals — workers who can perform the essential functions of the job with or without reasonable accommodation. Identifying the essential functions accurately (and separating them from marginal duties) is the first analytic step in any accommodation analysis and often decides the case.

What 'reasonable' looks like in 2025

Remote work, modified schedules, ergonomic equipment, leave beyond FMLA, reassignment to a vacant position, schedule swaps, written instructions, quiet workspaces — all routinely held reasonable. The EEOC has signaled that blanket no-remote-work policies are not a defense if remote work is feasible for the role. Reassignment is the accommodation of last resort and must be considered before termination.

Undue hardship — a real defense, but a narrow one

Cost alone is rarely enough. Courts examine the employer's overall resources, the nature of the operation, the impact on co-workers, and whether the burden could be mitigated. Anecdotal hardship claims (a manager saying 'this would be hard') without analysis are routinely rejected.

Medical documentation: what an employer can ask

Employers can request reasonable medical documentation confirming the disability and the need for the requested accommodation. They cannot demand your full medical record. Ask your provider to write narrowly: the limitation, the functional impact, and the accommodation that addresses it.

The failure-to-engage claim

An employer who shuts down the dialogue, refuses to consider alternatives, or imposes its own preferred accommodation without discussion can be liable for failure to engage — even if the ultimate accommodation question is close. Build the record by sending each request and follow-up in writing.

Common employer mistakes that build your case

Skipping the interactive dialogue entirely; treating one accommodation request as a request for all foreseeable future accommodations; refusing to consider reassignment; pressuring the worker onto unpaid leave instead of trying an accommodation; or applying a uniform policy without an individualized analysis.

Key takeaways

Make every accommodation request in writing — email is sufficient.
Identify essential vs. marginal functions of your job early; this controls the analysis.
Track each interactive-process exchange with dates; gaps and non-responses become evidence.
Reassignment to a vacant role is required before termination if accommodation in the current role fails.
Medical documentation should be narrow — limitation, impact, accommodation. Nothing more.

Citations

29 C.F.R. § 1630.2(o)(3) (Interactive process) — EEOC regulations
U.S. Airways v. Barnett, 535 U.S. 391 (2002) — U.S. Supreme Court
EEOC Enforcement Guidance on Reasonable Accommodation and Undue Hardship — EEOC

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