Understanding Your Legal Responsibilities as an Employer

Employers are increasingly finding themselves in the position of having to balance legitimate business needs with their obligations under laws like the Americans with Disabilities Act (ADA) and Title VII of the Civil Rights Act. These laws require employers to provide reasonable accommodations for employees with medical or religious needs—unless doing so would cause undue hardship on the business.

For small and mid-sized businesses (SMBs), navigating this process can feel complex—but understanding the fundamentals helps you avoid costly compliance violations and maintain a positive workplace culture.

What Is a “Reasonable Accommodation”?

A reasonable accommodation is any change or adjustment to a job, work environment, or standard process that allows an employee to perform the essential functions of their position. These requests typically fall into two main categories:

• Medical Accommodations – related to disabilities, medical conditions, or pregnancy.
• Religious Accommodations – related to sincerely held beliefs or practices.

Examples include:

• Modifying work schedules or allowing remote work

• Providing assistive technology or ergonomic equipment

• Adjusting dress code or grooming requirements for religious reasons

• Allowing prayer breaks or flexible time off for observance

The Step-by-Step Accommodation Process

1. Receive and Acknowledge the Request

When an employee makes a request—verbally or in writing—it triggers your obligation to begin the interactive process. Acknowledge the request promptly, ideally within a few business days.

2. Engage in the Interactive Process

This is a collaborative dialogue between employer and employee to explore effective accommodation options. You may request limited medical documentation if the need isn’t obvious, but only what’s necessary to determine the appropriate accommodation.

3. Evaluate Reasonableness and Hardship

An accommodation is considered “reasonable” if it enables the employee to perform their job without imposing undue hardship—meaning significant difficulty or expense relative to the company’s size, resources, or operations.

For religious accommodations, the Supreme Court’s 2023 Groff v. DeJoy decision raised the standard, clarifying that employers must show a substantial burden to deny a request—not merely a minimal cost.

4. Document Every Step

Maintain clear, dated records of all communications, forms, and decisions. Documentation can be your best defense if a claim is filed with the EEOC (Equal Employment Opportunity Commission).

5. Monitor and Adjust

Accommodations may need modification over time. Regular check-ins ensure continued effectiveness and signal your company’s commitment to a supportive, compliant workplace.

Common Employer Pitfalls to Avoid

• Ignoring informal requests: Even a casual mention (“I’m having trouble because of my back condition…”) can constitute a valid request.

• Asking invasive medical questions: Only collect information directly related to the accommodation need.

• Applying inconsistent standards: Treat all employees equitably to avoid discrimination claims.

• Failing to train managers: A single supervisor’s misstep can expose your organization to significant legal risk.

Why Partnering with an HR Consulting Team Makes a Difference

Even well-intentioned employers can make costly mistakes when handling accommodation requests. That’s where having access to an HR consulting team becomes invaluable.

Experienced HR consultants provide the guidance and documentation support you need to stay compliant and confident. They can:

• Help interpret complex federal and state employment laws.

• Review your company policies and employee handbook for compliance gaps.

• Coach managers on how to respond appropriately to medical or religious accommodation requests.

• Assist in documenting the interactive process to ensure legal defensibility.

• Offer on-demand guidance when new requests arise or regulations change.

Instead of reacting to compliance issues after they occur, an HR consulting partner helps you proactively manage risk, maintain fairness, and protect your business reputation.

Practical Steps to Stay Compliant

• Conduct annual EEOC and ADA training for managers.

• Create a clear accommodation request form and policy within your employee handbook.

• Keep your HR systems and documentation centralized for quick access during audits.

• Consider working with a compliance expert or HR consulting partner like Asure, which offers dedicated guidance to help small businesses navigate complex labor laws, manage employee requests, and stay audit-ready.

When handled correctly, medical and religious accommodation requests present an opportunity—not a burden. They help employers demonstrate respect, inclusion, and integrity while maintaining compliance with federal and state regulations.

By building structured, transparent processes for responding to these requests—and having an HR consulting team in your corner—you can reduce risk, support your workforce, and strengthen your organizational culture, all while staying EEOC-compliant and audit-ready.