This page is general information, not legal or medical advice. It explains what official sources say, and it is not tailored to any individual situation.
Key takeaways
- The regulation calls it an informal, interactive process, not a single yes-or-no decision.
- What an employer may ask for is bounded by 29 C.F.R. 1630.14, and 29 C.F.R. 1630.13 makes a medical examination or disability-related inquiry outside those bounds unlawful.
- An employer may choose among accommodations that would be effective, and the EEOC states that an unnecessary delay can itself violate the ADA.
- A charge of discrimination has a filing window of 180 calendar days, extended to 300 calendar days where a state or local agency enforces a law prohibiting the same discrimination.
What the process is
The interactive process is the informal, good-faith exchange between an employee and an employer that works out an accommodation. The term comes from the regulation. Under 29 C.F.R. 1630.2(o)(3) (opens in a new tab), "[t]o determine the appropriate reasonable accommodation it may be necessary for the covered entity to initiate an informal, interactive process with the individual with a disability in need of the accommodation", and that process "should identify the precise limitations resulting from the disability and potential reasonable accommodations that could overcome those limitations". The EEOC's enforcement guidance calls a request for reasonable accommodation "the first step in an informal, interactive process between the individual and the employer". It is not a single yes-or-no decision, and both sides take part.
Neither the regulation nor the EEOC guidance requires a lawyer, a form, or a proposed solution at the outset. The guidance states that to request an accommodation a person "may use 'plain English' and need not mention the ADA or use the phrase 'reasonable accommodation'".
The narrowing inside that conversation, from a broad limitation to the one work task that is hard, then to the precise problem, and only then to a solution, is set out stage by stage on the research page covering how the right workplace accommodation is identified, with the EEOC guidance cited at each stage. The same page reports what accommodations cost: in the Job Accommodation Network's report Workplace Accommodations: Low Cost, High Impact, updated in September 2025, 61 percent of the employers that shared cost data said the accommodation their employee needed cost nothing, and among the employers that reported a one-time expense the median of those reported costs was 300 dollars.
Step 1: The request
A request can be made in ordinary, everyday words. The words "reasonable accommodation" are not required, and neither is a mention of the ADA. Under EEOC guidance, it is enough to let the employer know that an adjustment or change at work is needed for a reason related to a medical condition. The same guidance states that requests "do not need to be in writing" and that individuals "may request accommodations in conversation or may use any other mode of communication". This site carries a static reasonable accommodation request letter template with an official source for each legal point in it.
Step 2: Sharing information
In the next stage each side shares the information needed to find a workable change: the barrier and its effect on the work on one side, and what the job requires on the other. Where the disability or the need for an accommodation is not obvious, the EEOC guidance states that the employer "may ask the individual for reasonable documentation about his/her disability and functional limitations". The same guidance states that an employer "cannot ask for documentation that is unrelated to determining the existence of a disability and the necessity for an accommodation", and that in most situations it cannot request a person's complete medical records. The EEOC expects both sides to explore options together, and the exact accommodation does not have to be named at the outset.
Step 3: Choosing and adjusting
An accommodation can be tried and then adjusted, and a first idea that does not work does not end the process. The EEOC guidance states that an employer "may choose among reasonable accommodations as long as the chosen accommodation is effective", so the accommodation provided need not be the one that was asked for. Where more than one accommodation is effective, the same guidance states that "the preference of the individual with a disability should be given primary consideration", while "the employer providing the accommodation has the ultimate discretion to choose between effective accommodations".
Timing is also governed. The guidance states that an employer "should respond expeditiously to a request for reasonable accommodation" and that "Unnecessary delays can result in a violation of the ADA".
What an employer may and may not ask, stage by stage
Medical examinations and disability-related inquiries sit under two regulations that work as a pair. 29 C.F.R. 1630.13 (opens in a new tab) makes a medical examination or an inquiry into whether a person is an individual with a disability, or into the nature or severity of a disability, unlawful "[e]xcept as permitted by" the next section, and 29 C.F.R. 1630.14 (opens in a new tab) is that permitted list. The table below sets out each stage, what the permitted list allows at that stage, what falls outside it, and the subsection each line rests on.
| Stage | What an employer may ask for | What an employer may not ask for | Authority |
|---|---|---|---|
| Before a job offer, at application and interview | Inquiries into the ability of an applicant to perform job-related functions, and a request that the applicant describe or demonstrate how, with or without reasonable accommodation, the applicant will be able to perform those functions. | A medical examination of an applicant, or an inquiry into whether an applicant is an individual with a disability, or into the nature or severity of a disability. | 29 C.F.R. 1630.14(a) (opens in a new tab), permitting the inquiry. The prohibition is at 29 C.F.R. 1630.13(a) (opens in a new tab). |
| After a job offer and before the job starts | A medical examination or inquiry, and an offer conditioned on the result, if all entering employees in the same job category are subjected to the examination or inquiry regardless of disability. | An examination of some entering employees in a job category and not others. The results may not be used for any purpose inconsistent with the regulations, and criteria used to screen out an employee with a disability must be job-related and consistent with business necessity. | 29 C.F.R. 1630.14(b) (opens in a new tab), with (b)(2) on use of results and (b)(3) on exclusionary criteria. |
| At any point during employment | A medical examination or inquiry that is job-related and consistent with business necessity, and inquiries into the ability of an employee to perform job-related functions. | A required medical examination of an employee, or an inquiry into whether an employee is an individual with a disability, or into the nature or severity of a disability, outside what the permitted list allows. | 29 C.F.R. 1630.14(c) (opens in a new tab), permitting the inquiry. The prohibition is at 29 C.F.R. 1630.13(b) (opens in a new tab). |
| On a request, where the disability or the need is not obvious | Reasonable documentation about the disability and the functional limitations. | Documentation that is "unrelated to determining the existence of a disability and the necessity for an accommodation". On that basis the EEOC states that in most situations an employer cannot request a person's complete medical records. | 29 C.F.R. 1630.14(c) (opens in a new tab) sets the limit on the inquiry; the EEOC enforcement guidance (opens in a new tab) states what documentation may and may not be sought. |
| On a request, where the disability and the need are both obvious or already substantiated | No further documentation of the disability or of the need for the accommodation. | Documentation, where both the disability and the need for reasonable accommodation are obvious, or where the individual has already given the employer enough information to substantiate an ADA disability and the need for the accommodation requested. | The EEOC enforcement guidance (opens in a new tab), applying the limit at 29 C.F.R. 1630.14(c) (opens in a new tab). |
| Handling of the medical information once it has been collected | Telling supervisors and managers about necessary restrictions on work or duties and necessary accommodations, telling first aid and safety personnel where appropriate if the disability might require emergency treatment, and giving relevant information on request to government officials investigating compliance. | Keeping the information anywhere but on separate forms and in separate medical files, treated as a confidential medical record, or using it for any purpose inconsistent with the regulations. | 29 C.F.R. 1630.14(c)(1) and (c)(2) (opens in a new tab), and 1630.14(b)(1) for information from an entrance examination. |
If the request is denied
The regulations attach a condition to a denial. 29 C.F.R. 1630.9(a) (opens in a new tab) states that it is unlawful for a covered entity "not to make reasonable accommodation to the known physical or mental limitations of an otherwise qualified applicant or employee with a disability, unless such covered entity can demonstrate that the accommodation would impose an undue hardship on the operation of its business". Undue hardship is therefore something the employer has to establish, and 29 C.F.R. 1630.15(d) (opens in a new tab) lists it as a defense to a charge of not making reasonable accommodation.
The EEOC guidance adds a further step before a refusal is final: "If an employer determines that one particular reasonable accommodation will cause undue hardship, but a second type of reasonable accommodation will be effective and will not cause an undue hardship, then the employer must provide the second accommodation." A denial of one accommodation is not, on the face of the guidance, a denial of all of them.
Outside the workplace, the ADA is enforced through a charge of discrimination filed with the EEOC, and the filing windows for a charge are set by law.
| Step | Time limit | Authority |
|---|---|---|
| Filing a charge of discrimination with the EEOC | The EEOC states: "In general, you need to file a charge within 180 calendar days from the day the discrimination took place." | EEOC, Time Limits for Filing a Charge (opens in a new tab) |
| The extended window | The EEOC states: "The 180 calendar day filing deadline is extended to 300 calendar days if a state or local agency enforces a law that prohibits employment discrimination on the same basis." The extension turns on whether such a state or local agency enforces such a law, not on which office the charge is lodged with. The EEOC calls those agencies Fair Employment Practices Agencies and states that where an individual initially files with one that has a worksharing agreement with the EEOC, and the allegation is covered by a law enforced by the EEOC, the FEPA will dual file the charge with the EEOC. | EEOC, Time Limits for Filing a Charge (opens in a new tab); EEOC, Fair Employment Practices Agencies (FEPAs) and Dual Filing (opens in a new tab) |
| More than one discriminatory event | The EEOC states: "if more than one discriminatory event took place, the deadline usually applies to each event." Its example is a demotion followed by a discharge a year later, where a charge filed the day after the discharge leaves only the discharge claim timely. The EEOC states: "There is one exception to this general rule and that is if you are alleging ongoing harassment." | EEOC, Time Limits for Filing a Charge (opens in a new tab) |
| Ongoing harassment | The EEOC states: "In harassment cases, you must file your charge within 180 or 300 days of the last incident of harassment, although we will look at all incidents of harassment when investigating your charge, even if the earlier incidents happened more than 180/300 days earlier." | EEOC, Time Limits for Filing a Charge (opens in a new tab) |
| A charge before a federal lawsuit | A charge must be filed with the EEOC before a federal lawsuit alleging disability discrimination. The EEOC issues a Notice of Right to Sue when it closes its investigation, and will issue one earlier on request. | EEOC, Filing A Lawsuit (opens in a new tab) |
| Filing the lawsuit after a Notice of Right to Sue | The EEOC states: "Once you receive a Notice of Right to Sue, you must file your lawsuit within 90 days. This deadline is set by law." | EEOC, Filing A Lawsuit (opens in a new tab) |
| Asking for the notice before the investigation ends | Where more than 180 days have passed since the charge was filed, the EEOC states it is required by law to issue the notice on request. Where fewer than 180 days have passed, it issues the notice only if it will be unable to finish the investigation within 180 days. | EEOC, Filing A Lawsuit (opens in a new tab) |
Sources
Every statement above rests on one of these sources: the EEOC regulations implementing the ADA, the EEOC's enforcement guidance and filing-deadline pages, ADA.gov, and the Job Accommodation Network. Links open in a new tab.
- 29 C.F.R. 1630.14, Medical examinations and inquiries specifically permitted (opens in a new tab) Electronic Code of Federal Regulations, EEOC regulations implementing the ADA
- 29 C.F.R. 1630.13, Prohibited medical examinations and inquiries (opens in a new tab) Electronic Code of Federal Regulations, EEOC regulations implementing the ADA
- 29 C.F.R. 1630.2, Definitions (including (o)(3), the interactive process) (opens in a new tab) Electronic Code of Federal Regulations, EEOC regulations implementing the ADA
- 29 C.F.R. 1630.9, Not making reasonable accommodation (opens in a new tab) Electronic Code of Federal Regulations, EEOC regulations implementing the ADA
- 29 C.F.R. 1630.15, Defenses (opens in a new tab) Electronic Code of Federal Regulations, EEOC regulations implementing the ADA
- Enforcement Guidance on Reasonable Accommodation and Undue Hardship Under the ADA (opens in a new tab) U.S. Equal Employment Opportunity Commission
- Time Limits for Filing a Charge (opens in a new tab) U.S. Equal Employment Opportunity Commission
- Filing A Lawsuit (opens in a new tab) U.S. Equal Employment Opportunity Commission
- Fair Employment Practices Agencies (FEPAs) and Dual Filing (opens in a new tab) U.S. Equal Employment Opportunity Commission
- The Americans with Disabilities Act (opens in a new tab) U.S. Department of Justice, ADA.gov
- Accommodation and Compliance: the A to Z of disabilities and accommodations (opens in a new tab) Job Accommodation Network (JAN), funded by the U.S. Department of Labor