Analyze Reasonable Accommodation Request Under Ada Requirements

---
name: analyze-reasonable-accommodation-request-under-ada-requirements
task_id: employment-labor/analyze-reasonable-accommodation-request-under-ada-requirements
description: Guides the analyst through a workplace accommodation memorandum covering disability qualification, procedural timeline compliance, and accommodation-by-accommodation reasonableness analysis.
activates_for: [planner, solver, checker]
---

# Skill: Analyze Reasonable Accommodation Request Under ADA Requirements

## 1. Subject-matter triage

- Confirm the request is an ADA accommodation matter, not a pure leave, FMLA, workers’ compensation, or generalized performance issue.
- Identify the employee’s condition, the requested accommodations, the job at issue, and any employer response already made.
- Separate three questions at the outset: disability coverage, interactive-process handling, and the reasonableness of each proposed accommodation.
- If the file contains more than one proposed accommodation, treat each as a distinct item and analyze it on its own facts.

## 2. Failure modes the skill is correcting

- Analyst assumes the condition qualifies as a disability without applying the ADA’s broad coverage standard to the specific functional limitations alleged.
- Analyst evaluates only the end result and misses whether the employer’s timing, communications, and follow-up satisfied the interactive process.
- Analyst treats an internal HR deadline as either irrelevant or automatically dispositive instead of evidence relevant to process quality.
- Analyst collapses multiple accommodation proposals into one conclusion instead of evaluating each proposed option separately.
- Analyst omits the medical-documentation question and fails to assess whether the request was sufficiently supported or needed follow-up.
- Analyst gives a binary grant/deny answer without identifying alternatives or the operational basis for undue hardship.
- Analyst states legal conclusions without tying them to governing ADA authorities.

## 3. Legal frameworks / domain conventions that apply

- Disability coverage under the ADA is construed broadly. Apply the statutory definition in the ADA, 42 U.S.C. § 12102, and the EEOC’s implementing regulations, including the rule that episodic conditions or conditions in remission are assessed when active.
- A qualified individual is one who can perform the essential functions of the position with or without reasonable accommodation. Anchor essential-function analysis in the job description, actual practice, and business necessity.
- The employer must engage in a prompt, good-faith interactive process once on notice of a disability-related need. Unexplained delay, refusal to communicate, or rigid insistence on formality can create independent litigation risk.
- Reasonable accommodations are those that enable performance of essential functions unless they impose undue hardship. Use the ADA’s undue-hardship framework, including cost, business resources, operational disruption, and impact on others.
- The employer may request documentation sufficient to establish the disability and functional limitations, but may not demand unnecessary detail or a particular form absent a legitimate basis.
- The employer may choose among effective accommodations and need not provide the employee’s preferred option if another effective, less burdensome option exists.
- Prior accommodation history matters. A previously successful arrangement can inform feasibility, but it does not automatically require continuation if circumstances have changed.
- If the request touches leave, schedule modification, remote work, job restructuring, equipment, reassignment, or policy exception, analyze each under the same reasonableness framework and ask whether it preserves essential functions.

## 4. Analytical scaffolds

- Disability qualification: identify the condition; state the major life activities implicated; analyze whether the limitation is substantial when active; conclude whether the employee is covered.
- Documentation adequacy: state what was provided, whether it supports the claimed limitation, what is missing, and whether a targeted follow-up request is warranted.
- Interactive process timeline: build a chronology from request date through each employer and employee response, noting the first substantive response, any silence periods, and any deadline in the employer’s policy.
- Procedural compliance assessment: determine whether the employer acted promptly and in good faith; separate a policy violation from a statutory violation; assign a procedural risk rating.
- Accommodation-by-accommodation analysis: for each proposed accommodation, assess whether it is facially reasonable, whether it addresses essential functions, whether it creates undue hardship, and whether an effective alternative exists.
- Comparative effectiveness: if multiple accommodations appear workable, identify the least burdensome effective option and explain why it is preferable.
- Litigation-risk summary: distinguish risk arising from coverage, process defects, documentation gaps, and substantive unreasonableness.
- Recommendations: convert each diagnosis into a concrete next step aimed at completing the interactive process and preserving a defensible record.

## 5. Vertical / structural / temporal relationships

- Tie the analysis to the position’s essential functions and the actual operational setting, not just the job title.
- If the employee previously received an accommodation, compare the current request to the earlier arrangement and identify any changed facts or new burdens.
- If the request is time-sensitive, note whether timing affects feasibility, short-term coverage, or interim measures.
- If leave is requested, distinguish finite leave, intermittent leave, and indefinite leave, and analyze whether the request still allows a return to essential functions within a manageable timeframe.
- If reassignment is requested, confirm whether a vacant, comparable role exists and whether reassignment is a last-resort accommodation under the governing framework.

## 6. Output structure conventions

- Format as a legal memorandum in conventional memo form, with concise headings and analytical paragraphs rather than a checklist-only response.
- Use this order: disability qualification; documentation and interactive-process timeline; procedural compliance and risk; accommodation-by-accommodation analysis; litigation-risk summary; recommendations.
- Include a timeline table or chart showing request, employer response, employee follow-up, and current status.
- For each accommodation proposal, give a separate conclusion and rationale; do not combine multiple proposals in one paragraph if they differ materially.
- When stating a legal rule, cite the controlling authority by name and section or by recognized authority form, including 42 U.S.C. § 12101 et seq., 42 U.S.C. § 12102, and applicable EEOC regulations or guidance as relevant.
- Include an explicit risk rating for both procedural handling and substantive accommodation merits, using a uniform ordinal scale defined once in the memo.
- End with a Recommended Actions section that uses imperative verbs, assigns the responsible role, and ties each action to a concrete timing anchor or immediate milestone.
- If the request file supports only one accommodation theory, say so expressly; otherwise enumerate each distinct accommodation and analyze each one on its own record.
- Keep the memo focused on actionable conclusions for the employer, with enough legal reasoning to support next-step decision-making.