hr-accommodation-request

name	hr-accommodation-request
description	Document the ADA / PWFA / religious accommodation interactive process - request intake, undue-hardship analysis framework, response letter (grant / alternative / deny), and appeal process. Templates only - not employment-law advice.
slash_command	false
argument-hint	<accommodation type - medical, pregnancy, religious - and request>
attribution	{"lineage":"Wayland Business Suite (Original)"}
metadata	{"wayland":{"tags":["ada","accommodation","hr","people-ops","smb"]}}

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)

1. Type of accommodation requested: medical (ADA) / pregnancy or related (PWFA) / religious (Title VII)
2. Employee name, role, manager, state of employment, country
3. 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)
4. Specific accommodation requested by employee
5. Essential functions of the role (from job description) - drives whether accommodation is feasible
6. 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

1. Receive the request (no magic words required - "I'm having trouble [doing X] because of [Y]" is enough)
2. Acknowledge in writing within 1-2 business days
3. Discuss limitations and essential functions - what can/can't the employee do? Which essential functions are at issue?
4. Identify possible accommodations - together with the employee; consider EEOC's Job Accommodation Network (askjan.org)
5. Request supporting documentation if needed (limited scope - confirms disability and need; not full records)
6. Evaluate undue hardship - significant difficulty or expense, considering employer resources
7. Implement accommodation OR propose alternative OR deny with documented analysis
8. 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] |

: [Yes / No - with specific reasoning]



 [ ]  as requested
 [ ]  alternative accommodation: [describe]
 [ ]  with the following undue-hardship justification: [detailed reasoning]
 [ ]  - additional information needed



 Effective date: [Date]
 Steps required: [Equipment, schedule change, role modification, leave]
 Owner: [Manager / HR / IT]
 Review date: [Re-evaluate in 30/60/90 days]



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).



This request and its disposition do not affect performance evaluation, compensation, or advancement. Retaliation for requesting accommodation is prohibited.



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.



HR: __ Date: __
Employee acknowledgment: 
(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 using build_report_path("business-hr", instruction) when writing to file.

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.