From Compliance Requirement to Practical Strategy
The Americans with Disabilities Act (ADA) is one of the most critical — and complex — laws HR professionals manage. But according to Tracie DeFreitas, Director of Training and Outreach at the Job Accommodation Network (JAN), the ADA’s interactive process doesn’t have to feel complicated.
“The best thing an employer can do,” DeFreitas explained, “is to stay communicative and proactive. Successful accommodations start with meaningful, compliant conversations with employees.”
That central theme ran through IEA’s recent webinar, Essential Strategies for Effective Interactive Processes, hosted with TELUS Health and JAN.
The presenters focused on practical tools and frameworks employers can use to move from uncertainty to confidence when handling accommodation requests.
1. Recognizing When the ADA Interactive Process Should Begin
Many employers make the same mistake: waiting for an employee to say, “I need an ADA accommodation.” But as DeFreitas noted, employees rarely use that exact phrase.
“An employee might say, ‘I’m having trouble concentrating because of my medication,’ or ‘I can’t lift as much as I used to.’ Those statements are enough to trigger the interactive process.”
The key is recognizing a nexus between the employee’s statement and a potential disability. Once that connection exists, the employer’s responsibility to act begins.
Practical Tip: Train managers to recognize potential requests even when employees don’t use legal terminology. A simple, empathetic response – “How can I help you be successful?” — can open the door to compliance and trust.
2. Using the Six-Step Accomodation Framework
DeFreitas outlined a straightforward, six-step approach for employers — a practical model JAN uses to simplify what can otherwise feel like a complex process:
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Recognize a potential accommodation request.
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Gather essential information (including medical documentation if necessary).
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Explore accommodation options collaboratively with the employee.
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Implement the chosen solution promptly.
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Monitor the effectiveness of the accommodation over time.
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Document every step of the process.
This structure turns the abstract idea of “the interactive process” into a repeatable, defensible workflow.
Practical Tip: Keep this framework visible in manager training materials or accommodation request forms. It helps ensure consistency and reinforces a culture of accountability.
3. Knowing What You Can Ask (and What You Shouldn’t)
A recurring theme in the webinar was the importance of documentation without overreach.
Kuzee reminded HR professionals that while employers may request medical information to understand limitations, they must keep the inquiry job-related and necessary.
“You’re not entitled to a diagnosis,” Kuzee explained. “You’re entitled to the information that helps you make an informed decision about accommodation.”
Practical Tip: When requesting medical information, frame questions around limitations and functional capacity, not medical history. This ensures compliance and avoids privacy violations.
4. Understanding the Cost of Accommodation – and Its Return
Cost is often cited as a barrier to ADA compliance, but the data tells a different story.
DeFreitas shared research from JAN showing that 61% of accommodations cost employers nothing, and the median one-time expense for those that do incur cost is only around $300.
“The real cost isn’t in the accommodation itself,” DeFreitas said. “It’s in the delay or the turnover when the process breaks down.”
Practical Tip: Build a small “accommodation reserve” in your HR budget. Most accommodations are inexpensive, and demonstrating readiness can expedite approval and reduce risk.
5. Turning Compliance into Collaboration
Kuzee emphasized that effective ADA management isn’t just about legal protection — it’s about culture.
Employers who view the interactive process as an opportunity to connect with employees see higher engagement and lower turnover.
“When employees feel heard and supported,” Kuzee said, “they’re more likely to stay, more likely to perform well, and far less likely to escalate to a claim.”
Practical Tip: Document outcomes not just for compliance but for continuous improvement. Tracking successful accommodations helps HR refine its process and share best practices across teams.
6. Building Confidence Through Knowledge
Both speakers agreed that training is the most powerful compliance tool of all.
Managers, HR professionals, and supervisors should understand not only the letter of the ADA, but also the intent behind it — to foster fair, effective workplaces.
That’s where structured education, such as IEA’s Certified Professional in Disability Management (CPDM) program, becomes essential.
The CPDM curriculum provides the framework HR leaders need to manage ADA, FMLA, and PWFA obligations with clarity and confidence — and to turn compliance into a strategic advantage.
Learn more about CPDM and start your path to certification:
👉 ieatraining.org/cpdm
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Additional Resources
Job Accommodation Network: https://askjan.org/
EEOC: Enforcement Guidance on Reasonable Accommodation and Undue Hardship Under ADA: https://www.eeoc.gov/laws/guidance/enforcement-guidance-reasonable-accommodation-and-undue-hardship-under-ada
EEOC: What You Should Know About the Pregnant Workers Fairness Act: https://www.eeoc.gov/wysk/what-you-should-know-about-pregnant-workers-fairness-act
