Reasonable Accommodation Interactive Process: ADA Compliance Best Practices

The interactive process for reasonable accommodations represents one of the most consequential—and frequently mishandled—obligations under the Americans with Disabilities Act (ADA). Despite three decades since the ADA’s enactment, accommodation failures remain the leading source of disability discrimination claims, costing employers an average of $300,000 per lawsuit in settlements, legal fees, and operational disruption.

The legal standard is deceptively simple: employers must engage in a flexible, informal process with qualified individuals with disabilities to identify effective reasonable accommodations enabling them to perform essential job functions, unless doing so would impose undue hardship. Yet this straightforward principle spawns extraordinary complexity in practice— determining who qualifies as disabled, what constitutes essential functions, which accommodations are reasonable, and when hardship becomes undue requires nuanced analysis that many organizations struggle to execute consistently.