Stephen Turner
Akash Kumar
Jordan Lee
Taylor Scott
HR manager meetings: running an accommodation conversation
HR managers run many sensitive conversations, and accommodation requests carry specific rules. Here is how to recognize a request, run the interactive process the EEOC describes, and keep notes confidential. This covers the US ADA only and is general information, not legal advice.
Why this meeting needs its own approach
Most HR meetings have a format you can pick. An accommodation conversation under the US Americans with Disabilities Act also has a legal backdrop, so a bad meeting can cost more than an awkward afternoon.
The EEOC calls it an informal, interactive process between the employer and the person. The ADA doesn't require a specific process, so check your own policy and your counsel first. Other federal or state laws may add requirements.
Recognize the request
Don't wait for formal wording. According to the EEOC guidance JAN summarizes, a person doesn't need legal terms or the word ADA. They can simply say they need a change because of a health condition.
So brief people managers: if someone mentions difficulty at work tied to a health condition, tell HR. The EEOC says employers should respond expeditiously, and its guidance gives an example where a supervisor's failure to act on a request caused a violation.
The process, step by step
JAN's sample process has six steps. It's an example, so adapt it to your policy.
| Step | What HR does |
|---|---|
| 1. Recognize the request | Notice it, even with no formal wording |
| 2. Begin the conversation | Discuss the difficulty, the nature of the disability as far as needed, the job's essential functions and possible changes |
| 3. Request information | Ask only for what you need. You can't ask for documentation when both the disability and the need are obvious, or the person has already given enough information |
| 4. Explore and choose | Weigh options together, and consider the person's preference |
| 5. Implement | Put it in place and tell only those who must know |
| 6. Monitor | Check that it works, and revisit it if things change |
Questions for the first conversation
These questions are our advice, not JAN's. They start from the work, and leave medical detail until it's needed.
- Which parts of the job are hard right now?
- What have you tried at work, and what helped?
- What change do you think would help?
- Who will need to know about the change, and what will we tell them?
- When should we check in on how this is working?
Keep the record confidential
EEOC guidance says employers must keep medical information collected in this process confidential. JAN says it must be stored separately from personnel files. The EEOC also says an employer may not tell coworkers that someone is receiving an accommodation.
Supervisors may need to know about restrictions and accommodations, so tell them only that. Record the request, the options discussed, the decision and the dates, and keep medical details out of general meeting notes and shared drives.
Your other meetings
Other HR meetings need their own care, and investigations, complaints and terminations can be as sensitive as this one. Use a structured format for routine meetings, so people get a similar experience.
Using Bridge in HR work
Our default advice is not to capture an accommodation conversation. Before the meeting, check Agent Auto-Join, Desktop App Auto-Record and hosted auto-recording in Preferences, since they can capture it anyway. A host can also turn off Record, Transcribe and Take notes in a hosted meeting.
If your policy allows capture, ask first, because recording consent rules can apply. Check that Recap Auto-Sharing is off, and tell the person how the notes will be stored.
Bridge suits the less sensitive meetings, such as policy briefings and manager training. They get notes, a transcript and action items.
Sharing notes by email invite sends each person an overview and lets them open the transcript. Adding a meeting to a space gives everyone in that space access. So keep sensitive meetings out of both unless each person needs to see them.