Module 3
Reasonable
Accommodation
MODULE GOALS:
 To understand the concept of reasonable accommodation, its
process, and the circumstances under which it is required
 To learn how to problem-solve situations where reasonable
accommodation might be necessary in the workplace
EQUIPMENT:
 PowerPoint Presentation (or alternate format)
 LCD Projector
 Computer / Laptop
 Flip Chart
 Flip Chart Markers
 Masking Tape
MATERIALS:
 Handout: EEOC Reasonable Accommodation Process (in 6, 12, and 18
point fonts.
 Quiz: Famous People with Disabilities
 Handout: Famous People with Disabilities
 Quiz: Facts and Figures
 Quiz: Crossword Puzzle
 Handout: Accommodation Worksheet (with and without scenarios)
 Handout: JAN Accommodation Solutions for Functional Limitations
TIME
45-60 minutes (time may vary)
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Review module before training and prepare necessary materials.
 Show PowerPoint:
Module 3
Reasonable
Accommodations
Module 3: Reasonable Accommodations
Before we begin, I’d like for you to review the following handout
about the EEOC’s recommendations for the reasonable
accommodation process.
Distribute handouts in 6 point font. Wait for “grumbles” in the group
and tell the group you have the same material in a larger font. Ask
for a show of hands for those who would like a larger font.
(Distribute 12 point font for those requesting). After distribution, tell
the participants you also have the handout in an even larger font.
Ask for a show of hands for those who would like an even larger
font. Then distribute the handout in 18 point font.
How many of you found a larger font easier to read?
This example shows how some people who are experiencing vision
problems might be accommodated when reading is required. Most
reading material is provided in 10-12 point fonts. The last handout
was in 18 point font, which is considered “large print,” and may be
a form of reasonable accommodation.
Many employers provide accommodations for their employees.
Can you think of some examples?
Prompt:
 flexible work schedules
 ergonomic office chairs
 PDAs
 desktop calendars
 changes of lighting
These are all accommodations that make doing the job a bit easier.
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Why do employers do this? So that employees can be more
productive and business can be more successful.
The Americans with Disabilities Act requires that employers provide
reasonable accommodation for qualified individuals with
disabilities. So although employers have been accommodating
their workers for many years, the law formalizes this process for
people who may need an accommodation to perform the essential
functions of their job. This module provides the definition and
examples of reasonable accommodation, as well as actual
scenarios where we will use a proven process to identify effective
accommodations.
 Show PowerPoint:
Module 3 Goals
• To understand the concept of
reasonable accommodation, its
process, and the circumstances
under which it is required
• To learn how to problem-solve
situations where reasonable
accommodation might be necessary
in the workplace
Module Goals:
 To understand the concept of reasonable accommodation,
its process, and the circumstances under which it is required
 To learn how to problem-solve situations where reasonable
accommodation might be necessary in the workplace
----- If you are using Module 3 as a stand alone section and have
not discussed the definition of disability materials from Module 2, it
would be helpful to introduce this concept before proceeding with
this section. Determining whether or not an individual is considered
to be an “individual with a disability” under the ADA is the first step
in the reasonable accommodation process. Although employers
may choose to provide accommodations for any employees, the
ADA only requires that employers provide reasonable
accommodations for employees who meet the statutory definition
of disability.
----- If you have already discussed the definition of disability in a
previous module, or choose not to discuss it in Module 3, please
skip to page 6 on this module.
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Let’s look at who is covered by Title I, the employment provisions
of the ADA.
 Show PowerPoint:
Definition of Disability
An individual with a disability is one
who:
 has
 has a record of, or
 is regarded as having
a physical or mental impairment that
substantially limits a major life activity.
Definition of Disability:
An individual with a disability is one who:
 has
 has a record of, or
 is regarded as having
a physical or mental impairment that substantially limits a major life
activity.
 Show PowerPoint:
Definition of Disability
Continued
An individual with a disability is one
who has a physical or mental
impairment that substantially limits a
major life activity.
Definition of Disability (continued) - An individual with a disability is
one who has a physical or mental impairment that substantially
limits a major life activity.
Emphasize: "Substantially limits" is a very high standard. Basically,
it means that the person must have a disability that really limits
their ability to perform a major life activity.
Can anyone tell me some major life activities?
Field responses from the audience. One method for soliciting
information would be to ask participants to list the physical or
mental tasks they needed to arrive at this training. You can
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compare the responses with the information.
 Show PowerPoint:
Major Life Activities
These are basic activities that the average person in the general
population can perform with little or no difficulty.
•
•
•
•
•
•
Caring for Oneself
Performing Manual Tasks
Walking
Seeing
Hearing
Speaking
•
•
•
•
•
•
•
Breathing
Concentrating
Learning
Working
Sitting
Standing
Lifting
Major Life Activities: These are basic activities that the average
person in the general population can perform with little or no
difficulty.
 Caring for Oneself
 Performing Manual Tasks
 Walking
 Seeing
 Hearing
 Speaking
 Breathing
 Concentrating
 Learning
 Working
 Sitting
 Standing
 Lifting
Let’s examine some disabilities that we are familiar with and the
major life activity that is substantially limited.
 Individuals who are deaf are substantially limited in their
ability to hear.
 Individuals who use wheelchairs are substantially limited in
their ability to walk.
 Individuals who have cerebral palsy may be substantially
limited in their ability to perform manual tasks.
The key is to look at each person individually. Not all cases are
clear-cut. There are some individuals with impairments that may or
may not be covered by the ADA. It all depends on how the
impairment affects the individual.
For example, what about individuals with asthma? Whether they
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are considered a person with a disability depends on how the
asthma affects their ability to perform major life activities. It is
important to remember that people with the same impairment may
function very differently, some may be substantially limited and
some may not.
----- If you chose to skip the definition of disability, please
resume here. Suggested language for the transition: Now that
you all already know the ADA’s definition of disability from our
previous workshop…
Let’s take a minute to look at our list of major life activities in a
slightly different way. Which of these activities might individuals
with hidden disabilities have substantial limitations in?
Elicit responses
Are individuals with hidden disabilities entitled to reasonable
accommodation under the ADA?
Elicit responses
The ADA protects all people with impairments whether hidden or
visible that meet the definition of disability. Simply put, a hidden
disability is exactly that – a disability that is not recognizable from
the outside. We may never know if some of our coworkers,
acquaintances, or friends have hidden disabilities, if they choose
not to tell us.
Did you know that these famous people all have disabilities?
Pass out Famous People Quiz and have participants complete it.
After everyone is finished, go over the answers with the group.
 Show PowerPoint:
Answers
to the
Quiz
A
B
C
D
E
F
7
4
8
6
10
5
G
H
I
J
K
2
11
9
3
1
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Answers to the Quiz: A-7, B-4, C-8, D-6, E-10, F-5, G-2, H-11, I-9,
J-3, K-1.
Was any of this information a surprise to you? Does this
information make you feel any differently about these people?
Why? Why not?
You may wish to distribute the supplementary handout about
famous people with disabilities now to review with the group. You
may also choose to distribute it at the end of the module to prevent
distractions during the training.
Depending on the needs of your audience, you may choose to
highlight the prevalence of different diseases and disabilities in
today’s society by distributing the Facts and Figures Quiz.
Suggested language to accompany this quiz: Just like celebrities,
many individuals have hidden disabilities. Please complete this
quiz to fully comprehend the prevalence of these disabilities in our
society.
Many celebrities, just like other people, have disabilities that we are
not aware of. Hidden or invisible disabilities may include emotional
or behavioral disorders, learning disabilities, chronic or episodic
illnesses, impairments of hearing, vision or speech, and the list
goes on. Of course, the ADA’s definition of disability includes
individuals with various impairments, who are limited in different
major life activities. What is important is that they have an
impairment which causes a substantial limitation.
We now know the ADA’s definition of who a “person with a
disability” is, and we know that it includes individuals with both
visible and hidden disabilities. The ADA only protects a qualified
person with a disability. Let’s look at the ADA’s definition of
qualified.
 Show PowerPoint:
Qualified Individual
with a Disability
A qualified individual with a disability means one
who satisfies the requisite skill, experience,
education, and other job-related requirements of
the position such individual holds or desires, and
who…
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Qualified Individual with a Disability:
A qualified person with a disability means one who satisfies the
requisite skill, experience, education, and other job-related
requirements of the position such individual holds or desires, and
who…
 Show PowerPoint:
With or without
reasonable
accommodation can
perform the essential
functions of such a
position.
With or without reasonable accommodation can perform the
essential functions of such a position.
Essential functions mean job tasks that are fundamental—not
marginal.
 Show PowerPoint:
What makes a job task
essential?
• If the position exists to perform the
function
• If there are a limited number of
employees among whom the task can be
distributed
• If the function is highly specialized
What makes a job task essential?
 If the position exists to perform the function
 If there are a limited number of employees among whom the
task can be distributed
 If the function is highly specialized
The employer has the right to determine the essential functions,
educational training requirements, and the performance standards
of the job, as long as standards and requirements are consistently
applied and are not established specifically to discriminate against
people with disabilities.
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 Show PowerPoint:
Evidence of Essential Functions
• Employer's judgment as to which
functions are essential
• Written job descriptions prepared
before advertising or interviewing
applicants
• Amount of time spent performing
the function
Evidence of Essential Functions:
 Employer's judgment as to which functions are essential
 Written job descriptions prepared before advertising or
interviewing applicants
 Amount of time spent performing the function
 Show PowerPoint:
Evidence of Essential Functions
Continued
• Consequences of not performing the function
• The terms of a collective bargaining
agreement
• Work experience of past incumbents on the
job
• Current work experience of incumbents in
similar jobs
Evidence of Essential Functions (continued):
 Consequences of not performing the function
 The terms of a collective bargaining agreement
 Work experience of past incumbents on the job
 Current work experience of incumbents in similar jobs
When the functions of a particular job are being performed by a
new employee, with or without a disability, barriers may exist that
prevent that person from performing the job effectively. These
barriers may, for example, include inexperience or may, in fact, be
related to disability. In the case of disability, the ADA requires
employers to consider whether a reasonable accommodation could
remove the barrier.
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 Show PowerPoint:
Accommodations are:
Any changes in the work
setting that enable qualified
workers to accomplish their
tasks.
Accommodations are: Any changes in the work setting that enable
qualified workers to accomplish their tasks.
 Show PowerPoint:
Scope of Reasonable
Accommodation:
• Modification to the job application
process
• Modification to the work environment or
the manner in which the position held is
customarily performed
• Modification that enables an employee
with a disability to enjoy equal benefits
and privileges of employment
Scope of Reasonable Accommodation:
 Modification to the job application process
 Modification to the work environment or the manner in which
the position held is customarily performed
 Modification that enables an employee with a disability to
enjoy equal benefits and privileges of employment
The term “reasonable” means plausible or feasible in this context.
The accommodation must be effective for the employer and
effective for the employee.
 Show PowerPoint:
Accommodations are
dependent upon:
• The specific requirements of the job
• The particular need(s) of the employee
or applicant
• The extent to which modifications or
aids are available without causing an
undue hardship on the employing
organization
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Accommodations are dependent upon:
 The specific requirements of the job
 The particular need(s) of the employee or applicant
 The extent to which modifications or aids are available
without causing an undue hardship on the employing
organization
Who is the first consultant or expert you should talk to about
providing an effective accommodation?
The person needing the accommodation!
When we start to think about possible reasonable
accommodations, we are often too focused on the medical aspect
of the disability. It is more important to focus on how a disability
affects an individual rather than the medical diagnosis. This is
especially significant when determining reasonable
accommodation for individuals with hidden disabilities.
When we think about how a hidden disability affects an individual,
we are thinking about the individual’s functional limitations. As a
large group, let’s work together to think of common functional areas
in which individuals with hidden disabilities may face limitations.
Using a flip chart, ask the audience to name functional limitations. If
they need prompting, you can name a hidden disability and ask the
audience what the functional limitation may be for an individual with
a certain disability.
If the audience finds this too difficult, you can use the PowerPoint
Slides to explain the concept of functional limitations.
 Show PowerPoint:
•
•
•
•
•
Possible Areas of
Functional Limitations
Reading
Writing
Mathematics
Organizational Skills, Memory
and Time Management
Managing the Physical
Environment
Possible Areas of Functional Limitations:
 Reading
 Writing
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


Mathematics
Organizational Skills, Memory and Time Management
Managing the Physical Environment
 Show PowerPoint:
Possible Areas of
Functional Limitations
Continued
• Working at Full Productivity
• Maintaining Stamina
• Working Effectively with
Supervisors
• Interacting with Coworkers
Possible Areas of Functional Limitations (continued):
 Working at Full Productivity
 Maintaining Stamina
 Working Effectively with Supervisors
 Interacting with Coworkers
 Show PowerPoint:
Possible Areas of
Functional Limitations
Continued
• Handling Stress and Emotions
• Concentrating on Work Details
• Completing Projects and Meeting
Deadlines
• Maintaining Tasks/Sequences
and Maintaining Daily Information
Possible Areas of Functional Limitations (continued):
 Handling Stress and Emotions
 Concentrating on Work Details
 Completing Projects and Meeting Deadlines
 Maintaining Tasks/Sequences and Maintaining Daily
Information
After we finish this workshop, I will distribute a handout with
possible accommodation solutions for each of these functional
limitations.
Here is a relatively simple way to categorize accommodations:
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 Show PowerPoint:
Categorizing Accommodations
• Physical Modifications
• Managerial Action
• Provision of Services
Categorizing Accommodations:
 Physical Modifications
 Managerial Action
 Provision of Services
For example, physical modifications can include:
 changes to facility
 changes to equipment
Managerial Action can include:
 providing a flexible schedule
 providing unpaid leave
 restructuring job tasks
Provision of Services can include:
 qualified interpreters
 qualified readers
 job coaches
There are as many different accommodations as there are
disabilities. Some examples include:
 Show PowerPoint:
Examples of Reasonable
Accommodation:
• Making existing facilities used by
employees readily accessible and usable
by individuals with disabilities
• Job restructuring
• Part-time or modified work schedules
Examples of Reasonable Accommodation:
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


Making existing facilities used by employees readily
accessible and usable by individuals with disabilities
Job restructuring
Part-time or modified work schedules
 Show PowerPoint:
Examples of Reasonable
Accommodation:
Continued
• Adjustment or modifications of
examinations, training materials, or policies
• Providing qualified readers or interpreters
• Reassignment to vacant positions
Examples of Reasonable Accommodation (continued):
 Adjustment or modifications of examinations, training
materials, or policies
 Providing qualified readers or interpreters
 Reassignment to vacant positions
Remember, a reasonable accommodation must work for both the
employer and the person with the disability. The best person to
identify the most effective accommodation may be the person with
the disability.
 Show PowerPoint:
The Job Accommodation
Network is:
An information and consultation service
providing individualized accommodation
solutions via a website and an 800 number.
JAN’s purpose is to make it possible for
employers and others to share information
about job accommodations.
The Job Accommodation Network is:
An information and consultation service providing individualized
accommodation solutions via a website and an 800 number. JAN’s
purpose is to make it possible for employers and others to share
information about job accommodations.
JAN conducted a survey of employers to examine the cost of
reasonable accommodations. The survey indicated the following:1
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 Show PowerPoint:
Average Cost of Job
Accommodations
–
–
–
–
–
–
–
20% of all accommodations suggested had no cost
51% cost between $1 and $500
11% cost between $501 and $1,000
3% cost between $1,001 and $1,500
3% cost between $1,501 and $2,000
8% cost between $2,001 and $5,000
4% cost more than $5,000
Source: Job Accommodation
Network Survey1
Average Cost of Job Accommodations
– 20% of all accommodations suggested had no cost
– 51% cost between $1 and $500
– 11% cost between $501 and $1,000
– 3% cost between $1,001 and $1,500
– 3% cost between $1,501 and $2,000
– 8% cost between $2,001 and $5,000
– 4% cost more than $5,000
(Source: Job Accommodation Network Survey)1
You may be surprised to learn that 82% of accommodations cost
under $1,000.
There is a four-step interactive process that the Equal Employment
Opportunity Commission recommends employers follow to
determine accommodations for employees. This is the same
information that we distributed earlier in font size 6, 10, and 12.
 Show PowerPoint:
Determining Reasonable
Accommodation
• Determine the essential functions of the job
• Consult with the employee to determine his or her
abilities and specific needs
• Identify potential accommodations in consultation
with the individual
• If two or more possible accommodations exist,
consider the preference of the individual, and then
select the method that best serves both the
individual and the business
Determining Reasonable Accommodation
 Determine the essential functions of the job
 Consult with the employee to determine his or her abilities
and specific needs
 Identify potential accommodations in consultation with the
individual
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
If two or more possible accommodations exist, consider the
preference of the individual, and then select the method that
best serves both the individual and the business
Emphasize that the most important steps are consulting with the
individual with the disability and keeping an open mind.
The ADA says that you are obligated to consider providing
accommodations only for a qualified person with a disability who
discloses the need for an accommodation.
Distribute crossword puzzle to group.
 Show PowerPoint:
CROSSWORD PUZZLE
1
2
2
3
4
3
4
Across:
1. Mosquitoes do it
2. Dogs do it
3. Horses do it
4. Children do it
Down:
1. Insects that sting
2. Organs of vision
3. Big brothers do it to
little sisters
4. Without effort
This PowerPoint slide shows a blank crossword puzzle with four
vertical columns intersecting four horizontal columns. It does not
look like a typical crossword puzzle; rather it looks like one big
square divided into 16 smaller squares. To fill in the puzzle, the
clues for the across squares are: (1) Mosquitoes do it, (2) Dogs do
it, (3) Horses do it, and (4) Children do it. The clues for the down
squares are: (1) Insects that sting, (2) Organs of vision, (3) Big
brothers do it to little sisters, and (4) Without effort.
Take a few minutes to complete this simple crossword puzzle.
After participants have spent 2-3 minutes on the crossword puzzle,
walk around room to see how they are doing. Some participants
may seem frustrated because a “logical” solution is not evident.
Has anyone completed the puzzle yet?
The answer should be “no.”
Who would like to review the correct answers?
Distribute answer sheet for the crossword puzzle and review.
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 Show PowerPoint:
CROSSWORD PUZZLE
1
2
3
4
B
I
T
E
B
I
T
E
B
I
T
E
B
I
T
E
2
3
4
Across:
1. Mosquitoes do it
2. Dogs do it
3. Horses do it
4. Children do it
Down:
1. Insects that sting
2. Organs of vision
3. Big brothers do it to
little sisters
4. Without effort
This PowerPoint slide shows the completed crossword puzzle. It
includes the same clues as a reminder. The clues for the across
squares are: (1) Mosquitoes do it, (2) Dogs do it, (3) Horses do it,
and (4) Children do it. The clues for the down squares are: (1)
Insects that sting, (2) Organs of vision, (3) Big brothers do it to little
sisters, and (4) Without effort. Each horizontal row spells out the
same word, “BITE.” To this effect, the first vertical row contains four
Bs, the second row contains four Is, the third four Ts, and the fourth
four Es.
First – how would you typically complete a crossword puzzle –
what do you already KNOW about crossword puzzles? Although
the solution to this crossword puzzle was not found in the “typical”
way, there was a solution. This puzzle illustrates one situation
which could not be solved using prior knowledge and experience.
Rather, you need to look at it in a new and different way.
After I told you the correct answers, many of you said, “Ah ha!”
Although the solution really was easy, it was not what immediately
came to mind. This exercise shows that the more experiences we
have, the greater our ability to think broadly, and expand our
knowledge and experience in order to create easy solutions.
Things are not always as difficult as we fear.
Activity: Identifying Accommodations
Now that you have practiced “thinking outside the box,” we will now
complete an activity that involves determining reasonable
accommodations based on different scenarios.
Divide participants into groups and distribute two or three
reasonable accommodation scenarios to each group.
Prior to the training, read the scenarios below and pick which ones
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you would like to use. Trainers can either pick one category, mix
and match from different categories, or complete them all. Base
this decision on the needs of your audience. They have been
categorized based on type of disability.
The handouts have one accommodation per page, so you can
decide the variety in quantity and disability-based variation each
group should discuss. The group can use the extra space on each
piece of paper to brainstorm different ideas.
There is also a PowerPoint slide for each of the accommodation
scenarios.
Direct each group to:
(1) Review the steps necessary to provide reasonable
accommodation;
(2) Identify the barrier(s) in the scenario and at least one
possible accommodation;
(3) Categorize each solution under the appropriate
heading (i.e., physical, managerial, services);
and
(4) Identify the resources possible to assist with
implementation of these accommodations.
As you work together, remember that there are multiple solutions.
Many accommodations fall under "managerial action." Remember
to focus on the individual’s functional limitations, not just their
disability.
Remind the groups to focus on a specific barrier, not disability. Do
not assume the disability is the real barrier. Stress the need for
creativity.
This activity will take approximately 20 minutes (or more,
depending on the size of your audience and how many scenarios
you choose to use). Remember to leave time to discuss the Undue
Hardship Section.
When the small groups have finished, bring the whole group
together again. Have each of the small groups present their
accommodation plan using flip chart paper. Put all the suggested
accommodations in the appropriate category.
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Deaf / Hard of Hearing
#1
Juanita is a 32-year-old Postal Worker who communicates
through handwritten notes, gestures and partial lip reading. She is
in line for a promotion to the position of Time and Attendance
Clerk. In the past, the person who was the Time and Attendance
Clerk answered the telephone as a back up to the regular
receptionist in addition to other duties. Juanita's supervisor is
concerned about her ability to do the job and is considering
denying Juanita this promotion because of his concerns.
Possible Solution: Reassignment of telephone duties.
#2
Saundra, who is applying for a position as a Data Process
Entry Clerk, requires a sign language interpreter for the interview.
The supervisor has some concerns that the company will need to
hire a full-time interpreter for the employee to successfully perform
her job duties.
Possible Solution: Provide the interpreter for the interview, analyze the job and
ask the applicant how he or she will perform the essential functions of the job.
Possible Solution: Provide an occasional interpreter for such activities as
trainings or staff meetings.
#3
Laverne works in a formal, corporate office. The office staff
communicates with each other through the use of an office
intercom. Laverne is hard of hearing and finds the intercom difficult
to use. She continually chooses not to use the office intercom to
talk to her supervisor, as requested. Instead, she frequently poses
questions to him in a loud boisterous voice that is an irritating
disruption for her co-workers and supervisor.
Possible Solution: Suggest that Laverne write her questions and then take them
to her supervisor at a pre-arranged time.
Possible Solution: Based on the level of Laverne’s hearing loss, a telephone
amplifier may allow her to use the office intercom effectively.
Mobility Impairments
#4
Roberto, who uses a wheelchair, has just been hired by an
accounting firm. His office is accessible but the conference room
where all the staff meetings and trainings are held is not
accessible.
Possible Solution: Hold meetings and trainings in another, accessible location.
Possible Solution: Depending on the size of the business and the costs involved,
make the conference room accessible.
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#5
Shirley uses a wheelchair and desires a job in the field of
video and film. Shirley has several years of experience, but the
only available position is entry-level labeling and packaging film
cartridges. She feels this position is beneath her capabilities.
Possible Solution: No accommodation required. She either chooses to accept
the position or she doesn't.
#6
Brian uses a wheelchair. His Mail/Messenger job also
includes major photocopying jobs. He is unable to reach the
selection button mounted on the rear of the photocopier.
Possible Solution: Construct a stick with a rubber-tip to push the button or
purchase a device that could be used for that purpose.
#7
Jonathan, a Chef, is a paraplegic and uses a wheelchair
needs to access several different areas in the restaurant kitchen.
His co-workers prefer to continue standing as they cook.
Possible Solution: The restaurant could install adjustable height workstations.
They could also purchase a stand-up wheelchair, allowing the chef to remain in
his wheelchair but work at standing height when necessary. (JAN solution)
Speech Disability
#8
Joe has a significant speech and articulation problem. His
speech is considered unintelligible at times; he stutters and has
many involuntary facial movements. Joe's supervisor is very patient
and understanding, but shares the concern of others about the
extra amount of time required of her and co-workers to understand
and direct Joe.
Possible Solution: Talk to Joe and ask for his suggestions, which might include
the purchasing of a communication board or having Joe write his responses.
Visual Impairment
#9
An employer is interested in hiring Adam as a Paralegal. As
a Paralegal, Adam would be responsible for conducting
background research on various legal issues. Adam would also
edit his supervising attorney’s cases, interview potential plaintiffs,
and draft legal briefs. Adam has had experience doing this type of
work in two previous positions. He is blind and the employer is
concerned about how he could perform these tasks.
Possible Solution: A screen reader might need to be purchased to enable Adam
to conduct all of his computer work. The potential employer should discuss with
Adam what types of programs have worked for him in the past and then adopt or
create a similar effective accommodation.
#10
Jeanette is a Radio Broadcast Announcer. She is blind and
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needs to read the Associated Press wire news which she receives
over the phone lines connected to a printer.
Possible Solution: The station could supply the announcer with a Braille printer,
which could be connected to the Associated Press wire. A switch would allow
any user to quickly move between the Braille and regular printer. (JAN solution)
Heat Sensitivity
#11
Maya has multiple sclerosis and is extremely sensitive to
heat. When she requests that the office thermostat be adjusted to
meet her needs, her colleagues explain that they will be very cold.
The company is unable to provide her with a private office.
Possible Solution: The individual could be provided with a cool vest that keeps
her body temperature down without affecting her colleague’s comfort. (JAN
solution)
Hidden Disabilities (Learning, Psychiatric)
#12 Mohammed has held his position as Manager of the
Communications Department for five years. His boss notices that
he has become withdrawn in meetings, his work is late and he
appears preoccupied while discussing business matters. When his
supervisor shares his concerns, Mohammed explains that his
doctor recently diagnosed Mohammed with depression.
Possible Solution: Ask Mohammed how you can work together to adjust his
workplace to accommodate him. Mohammad might need a flexible work
schedule or a job coach.
#13
Mark experiences a stress disorder and becomes easily
overwhelmed. His company recently received a large work order
and everyone is working under deadline to fill the order.
Possible Solution: First, talk with Mark and solicit accommodations ideas from
him. Then, consider dividing his responsibilities into smaller tasks that would be
easier to handle one at a time.
Possible Solution: Plan a schedule to prevent bottleneck of workflow and to allow
adequate breaks for Mark.
#14 Susie is applying for a job as a Stock Clerk. Part of the
application process involves taking a multiple-choice test. Susie
meets all of the qualifications for this job. However, she has a
learning disability and has difficulty taking written tests.
Possible Solution: Give an oral test or job try-out as an alternative.
#15 William has a variety of tasks to perform at the plant nursery
where he works. His duties consist of sweeping the floors, dusting
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the shelves, restocking, watering the plants and collecting and
restocking the carts from the parking lot. He often forgets to do
some of his tasks.
Possible Solution: Prepare a daily checklist of job duties and have William check
them off as he completes them.
Possible Solution: Pair William with a co-worker to act as a mentor.
#16
Bob has Attention-Deficit / Hyperactivity Disorder. He is
easily distracted on the job site and has a history of frequently
engaging in loud, inappropriate conversation. Bob's work area
faces a busy walkway into the office. Due to lack of office space
and other factors, Bob can not move to another cubicle.
Possible Solution: Re-arrange the way his desk faces, if possible.
Possible Solution: Partition off his work area.
Possible Solution: Instruct co-workers not to respond to inappropriate behavior
and to reinforce appropriate behavior.
#17 Tovah has mild mental retardation. She has the basic skills
necessary for the job of Administrative Assistant, likes the work and
shows potential. When she finishes one task, however, she tends
to stand in one place and look around, unsure of what to do next.
One of her co-workers has noticed this and will periodically give her
small assignments to keep her busy.
Possible Solution: Prepare a daily checklist of duties that Tovah can check off
after completing and which will act as a prompt to begin the next activity.
Possible Solution: Designate a co-worker as someone she can consult with
when her supervisor is not around to answer questions or provide instruction.
#18 Chen's job mandates a higher production rate than he is
currently achieving. He was hired with the understanding and
intention that his production rate would increase over a threemonth period. After several weeks, however, Chen is still
performing below the mandated production rate for the position,
and errors are increasing.
Before determining an accommodation, the supervisor must identify the reasons
for the decreased productivity and increased errors (e.g. skill issue,
communication issue, training issue, etc.)
Possible Solution: Provide re-training, as necessary.
Possible Solution: Set realistic production goals that can be achieved gradually.
If problems cannot be resolved, follow company procedures for termination.
Reasonable Accommodation
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#19 Jane has a learning disability, but her supervisor thinks that
she has the skills to succeed. Lately, however, Jane has had
problems with dressing inappropriately and making personal
telephone calls during work. Her supervisor has discussed these
problems with Jane and she made some improvements in her
dress, although she still wears inappropriate shoes. Jane also
continues making personal calls during work time. The supervisor
admits that they do not have a formal company policy, but insists
that Jane only use the phone during her breaks. Jane expresses
her confusion, as she sees her co-workers making and receiving
personal calls during work time.
Possible Solution: Prepare a formal company policy and hold all employees in
compliance.
Possible Solution: Address each inappropriate behavior (telephone usage,
dress, etc.) individually instead of together and devise a plan for achieving
performance standards.
#20 Given a specific mailing job duty that occurred only once a
week, Rayford has difficulty remembering all the steps involved
with the process. His supervisor is tired of having to repeat the
directions each week.
Possible Solution: Mark the mailing dates on a calendar and prepare written
directions.
Possible Solution: If the mailing tasks in this job are a marginal function, reassign task.
#21 A Job Coach had been on the job site with Connie for two
weeks, giving constant support to the supervisor and to Connie.
The entire office was supportive of Connie and responded well to
the Job Coach. It is now time for the Job Coach to reduce her time
from the job site and let the supervisor assume more of a support
role for Connie. The Job Coach senses panic from the supervisor
and receives several calls each day with complaints like "Connie
just walked into our boss's office and sat down at his desk."
Possible Solution: Decrease working time with Connie and increase training time
with the supervisor. Prepare a schedule for reducing the time the Job Coach will
spend at the job site.
#22 Sally, who has a developmental disability, works at a
warehouse. For two weeks, Sally’s Manager trained her and
directed her when to take a lunch break. At the end of the second
week, the Manager was transferred. On that same day, her new
manager did not direct her to take a break and so she worked six
hours without a lunch break. Sally is very concerned that she may
never be given an opportunity to take lunch breaks.
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Possible Solution: Provide an orientation and training for her new manager.
Possible Solution: Provider Sally with a watch/timer device.
Possible Solution: Designate a co-worker to act as a "buddy" telling Sally when it
is time for her to go on break.
#23 Rebecca, who has a spinal cord injury, loves her job, her coworkers and her supervisor. Recently, however, she has had
difficulty making it to work on time and has been missing days due
to problems with childcare.
Possible Solution: It appears that the problem is unrelated to disability and
specific to childcare. Rebecca’s employer does not have an obligation under the
ADA to accommodate her childcare needs. However, if other employees are
allowed consideration for childcare or other needs, Rebecca cannot be denied
equal consideration.
 Show PowerPoint:
Undue Hardship
Significant Difficulty or
Expense
Undue Hardship: Significant Difficulty or Expense
It is important to note in any discussion about reasonable
accommodation that an employer must provide the accommodation
unless it would pose an undue hardship. Undue hardship means
significant difficulty or expense. The concepts of reasonable
accommodation and undue hardship depend on the specifics of the
particular situation and personnel involved.
When determining whether a particular accommodation would pose
an undue hardship, the employer must base the decision on an
individualized assessment. The Equal Employment Opportunity
Commission (EEOC) states that the following factors must be
considered when determining undue hardship:
1. the nature and cost of the accommodation needed;
2. the overall financial resources of the facility making the
reasonable accommodation; the number of employees at this
facility; the effect on expenses and resources of the facility;
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3. the overall financial resources, size, number of employees, and
type and location of facilities of the employer (if the facility
involved in the reasonable accommodation is part of a larger
entity);
4. the type of operation of the employer, including the structure
and functions of the workforce, the geographic separateness,
and the administrative or fiscal relationship between the facility
involved in making the accommodation and the employer;
5. the impact of the accommodation on the operation of the facility.
The next slides list examples of accommodations that are not
considered to be reasonable.
 Show PowerPoint:
Examples of Accommodations
that are NOT REASONABLE
• Placing an applicant with a disability in a job for
which he/she did not specifically apply
• Placing an individual with a disability into a job if
doing so would create a direct threat to the health
or safety of the individual or others
• Maintaining the salary of an employee reassigned
from a higher-paying job to a lower-paying job, if
the employer does not do so for other employees
Examples of Accommodations that are NOT REASONABLE:
 Placing an applicant with a disability in a job for which he/she
did not specifically apply
 Placing an individual with a disability into a job if doing so
would create a direct threat to the health or safety of the
individual or others
 Maintaining the salary of an employee reassigned from a
higher-paying job to a lower-paying job, if the employer does
not do so for other employees
 Show PowerPoint:
Examples of Accommodations
that are NOT REASONABLE
Continued
• Eliminating essential functions of the job
• Lowering production standards
• Providing personal use items (e.g. prosthetic limb,
eyeglasses, hearing aids, wheelchair, hot pot or
refrigerator)
• Creating a job
• Promoting an employee
• Bumping another employee from his/her job
Reasonable Accommodation
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Examples of Accommodations that are NOT REASONABLE
(continued):
 Eliminating essential functions of the job
 Lowering production standards
 Providing personal use items (e.g. prosthetic limb,
eyeglasses, hearing aids, wheelchair, hot pot or refrigerator)
 Creating a job
 Promoting an employee
 Bumping another employee from his/her job
Undue hardship is an extremely high standard and this decision is
best left to management or the head of the company and should be
documented.
It is important to put the concept of reasonable accommodation in
perspective and remember that most employers are providing
accommodations for their workers all the time just by being “good”
employers. Since the ADA went into effect, we have seen that
providing reasonable accommodation is generally not difficult for
employers.
Most employers who engage in the interactive process find it to be
beneficial. When employers engage in this process, they often are
able to provide very effective reasonable accommodations for their
employees. Even if an employer eventually concludes that a
reasonable accommodation does not exist, all parties involved
typically feel confident that the decision was made in good faith
and without haste.
Employers should be aware that if the accommodations do not
enable the person to do the job, or if work is not performed
adequately, and all other avenues for providing accommodations
have been exhausted, the same disciplinary actions taken with any
employee should be enforced.
It is important to understand the intent of the law with regard to
reasonable accommodation so that when the issue does arise in
the workplace everyone will be well equipped to address it.
If you did not already do so, you should distribute the additional
handouts / quizzes for this Module. (Handout: Famous People with
Disabilities. Quiz: Facts and Figures, JAN: Example
Accommodation Solutions for Functional Limitations).
Reasonable Accommodation
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