Run: ADA Interactive Process Documentation Policy

This policy establishes a consistent process for documenting the ADA interactive process and related reasonable accommodation decisions. The purpose is to ensure the organization maintains accurate, timely, and confidential records of accommodation requests, communications, meeting notes, options considered, decisions, implementation steps, and follow-up actions. This policy is intended to support compliance with the Americans with Disabilities Act (ADA), EEOC guidance on reasonable accommodation and the interactive process, and related recordkeeping obligations. Where accommodation-related timekeeping, pay, or hours worked are affected, records must also be maintained in a manner consistent with the Fair Labor Standards Act (FLSA).

This policy applies to all employees, applicants, managers, supervisors, HR staff, and any policy holder involved in receiving, evaluating, approving, implementing, or documenting accommodation requests. It applies to disability-related requests for accommodation, whether the request is made verbally or in writing, and whether the request is initiated by the employee, applicant, manager, or a third party acting on the individual's behalf. California employees: any disability-related medical information must be handled in accordance with applicable California privacy and employment laws, including the California Fair Employment and Housing Act (FEHA) and related confidentiality requirements. Other state or local laws providing greater protection will apply where applicable.

For purposes of this policy: - **Interactive process** means a timely, good-faith, individualized dialogue between the employer and the employee or applicant to identify limitations and potential accommodations. - **Reasonable accommodation** means a modification or adjustment that enables performance of essential functions or equal access, unless it creates undue hardship. - **Essential function** means a fundamental duty of the role. - **Undue hardship** means a significant difficulty or expense based on the employer's circumstances. - **Confidential medical information** means disability-related information, medical documentation, and related notes that must be stored and accessed separately from general personnel files. - **Policy holder** means the designated owner responsible for oversight, updates, and compliance monitoring.

The organization will engage in a good-faith interactive process when it becomes aware that an employee or applicant may need a reasonable accommodation due to a disability. The organization will document each material step of the process, including: 1. The date the request or need was identified. 2. The nature of the limitation or barrier, as described by the individual or supporting documentation. 3. The job-related essential function, application requirement, or workplace barrier at issue. 4. Accommodation options considered, including alternatives discussed and any trial accommodations. 5. The basis for any approval, denial, modification, or deferral. 6. Implementation responsibilities, target dates, and follow-up checkpoints. 7. Any changes to the accommodation over time. Documentation must be factual, objective, and limited to information necessary to support the accommodation process. Notes must not include unnecessary medical detail, stereotypes, or subjective judgments unrelated to the accommodation request.

### 1. Intake and opening the file - Record the date the request was received or the need was observed. - Open a confidential accommodation file separate from the personnel file. - Assign a case owner, typically HR or the policy holder. ### 2. Acknowledge and begin the interactive process - Acknowledge the request promptly. - Schedule a meeting or call to discuss the limitation, essential functions, and possible accommodations. - If medical documentation is needed, request only information that is job-related and consistent with business necessity. ### 3. Document each interaction For every meeting, call, or substantive email exchange, record: - Date, time, and participants - Summary of the limitation or barrier discussed - Essential function(s) or workplace issue involved - Accommodation ideas proposed by either party - Questions raised and responses provided - Any documents reviewed ### 4. Evaluate accommodation options Document each option considered, including: - Approved accommodation - Alternative accommodation offered - Temporary or trial accommodation - Accommodation denied, with the reason - Whether the option would remove the barrier or allow performance of essential functions - Whether the option would create undue hardship ### 5. Confirm the decision - Provide the final decision in writing when practicable. - State the accommodation approved, denied, or modified. - Identify the effective date, implementation owner, and any employee responsibilities. - If a request is denied, document the legitimate business reason and any alternative options considered. ### 6. Track implementation and follow-up - Record the date the accommodation was implemented. - Set follow-up checkpoints to confirm effectiveness. - Document any changes, extensions, failures, or renewed requests. - Close the file only after the accommodation is no longer active or the matter is otherwise resolved. ### 7. Retention and access controls - Store accommodation records securely with access limited to HR, legal, and others with a business need to know. - Retain records according to the organization’s retention schedule and applicable law.

- **Policy holder:** Maintains this policy, oversees compliance, and ensures records retention and access controls are followed. - **HR / People Operations:** Manages the interactive process, maintains documentation, coordinates with legal when needed, and ensures confidentiality. - **Managers / Supervisors:** Promptly refer accommodation requests to HR, participate in the process in good faith, and document operational impacts or proposed alternatives. - **Employees / Applicants:** Provide information needed to evaluate the request and participate in the interactive process in good faith. - **Legal / Compliance:** Advises on complex cases, denials, undue hardship analysis, litigation holds, and jurisdiction-specific requirements.

Failure to document the interactive process, disclose accommodation requests to unauthorized persons, or ignore follow-up obligations may result in corrective action, up to and including documented warning, performance improvement plan (PIP), or other discipline consistent with company policy and applicable law. Escalate immediately to HR and Legal when: - The request involves safety-sensitive essential functions - The accommodation may affect pay, hours, or timekeeping under the FLSA - There is disagreement about whether a function is essential - The request is denied or partially denied - The employee raises retaliation, discrimination, or harassment concerns under Title VII or the ADA - State or local law may impose additional obligations California employees: ensure any discipline or documentation related to accommodation handling is reviewed for compliance with FEHA and applicable California privacy requirements. New York employees: preserve records if a complaint may implicate whistleblower protections under NY Labor Law § 740. Washington employees: coordinate with paid sick leave rules where leave is part of the accommodation or related absence management. Illinois employees: confirm scheduling impacts are consistent with the One Day Rest in Seven Act where applicable.

This policy will be reviewed at least annually and updated as needed to reflect changes in the ADA, EEOC guidance, FLSA recordkeeping requirements, and applicable state or local laws. The policy holder is responsible for initiating revisions, obtaining legal review when necessary, and communicating material changes to affected roles.