ADA for Managers

Handling Requests for Medical Accommodation

The Americans with Disabilities Act (ADA) requires covered employers to provide effective reasonable accommodations for employees with disabilities.  An individual with a disability is defined by the ADA as a person who has a physical or mental impairment that limits one or more major life activities, a person who has a history or medical record of an impairment, or a person who is perceived by others as having an impairment.  To help determine effective accommodation employers must use an “interactive process,” by working together with employees who request accommodation to come up with solutions and determine what accommodation can be provided.

Recognizing an Accommodation Request for Managers – It’s important that a manager be able to recognize a request for medical accommodation.  An employee does not need to mention the ADA or use the wording “reasonable accommodation”.  For this reason, any time an employee indicates that they are having a problem in their job and the problem is related to a medical condition, the manager should consider whether the employee is making a request for accommodation under the ADA.  Here are some examples below:

  • An employee tells you they are having trouble getting to work or arriving at their scheduled start time because of medical treatments or illness associated with a medical condition.
  • An employee tells you they are unable to complete a particular work assignment or task (lifting, reaching, bending, standing, etc.) associated with their job due to a medical condition.
  • An employee shares with you that they are struggling with a mental health condition that is interfering with their ability to work or causing chronic absences.

Managers ResponsibilitiesA manager who believes they may have received a request for medical accommodation must contact Mary Cote in Human Resources (mcote@bowdoin.edu or by calling   725-3033) immediately.  Delays in processing an accommodation request can violate the ADA.  If you are not sure whether an employee is requesting accommodation err on the side of caution by contacting Mary Cote in Human Resources as soon as possible to provide notification of the potential request and for assistance in navigating next steps for communicating with your employee.

Human Resources will work through the interactive process with the employee by discussing the situation with the employee, gathering any needed medical information or recommendations from the employee and the employee’s doctor, explore with the department the options for accommodation and answer any questions you have about implementing the accommodations.  Managers may need to be open to new ideas and new ways of doing things and will need to work with Human Resources to brainstorm and consider what might work.  Accommodation is about doing things differently to help overcome a disability-related limitation.

Implementing and Monitoring the Accommodation – Once the accommodation has been determined it must be implemented as soon as possible.  If it’s not clear whether the accommodation will work for the employee or the employer, it might be possible to try out the accommodation or a trial period and will require the manager to monitor once in place and report to Human Resources any difficulties.  In some situations, the accommodation could stop being effective due to changes in the employee’s medical condition, changes in the workplace, the job itself, or the accommodation becomes an undue hardship for the department.  Managers should periodically check in with the employee, encourage ongoing communication and let employees know if there are any changes with their medical condition or problems with the accommodation to let them know so that Human Resources can work with the employee and the manager to see if it’s possible for something different to be provided.