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Accommodation disputes are decided on paper. An employer that handled a request reasonably but recorded nothing will struggle to prove it, because the question in a failure-to-accommodate claim is rarely just whether the outcome was fair. It is whether the employer engaged with the employee in good faith and promptly, and that can only be shown from records made at the time.
This article gives you the three documents that carry most of that load: an ADA accommodation request form, an outline for a medical inquiry letter that stays within what the ADA allows, and a decision record. It also covers what to log at each stage, what to leave out, and how the confidentiality rule shapes the file. The forms are samples to adapt, not official EEOC forms; have counsel review your versions.
If you need the legal framework first, read our ADA accommodations employer overview. This piece is part of the ADA and Accommodation Guide.
The Form Does Not Start the Process
Before the templates, one rule that the paperwork must never obscure. A request for accommodation does not have to be in writing, mention the ADA, or use the word "accommodation." EEOC’s enforcement guidance says an employer may ask the individual to fill out a form or may write a memo confirming the request, but it cannot ignore the initial request.
So the form confirms a request; it does not create one. Two consequences for your process:
- The date that matters is the date of the first conversation, not the date the form came back. Record it.
- If the employee never returns the form, you still have a request. Complete the form yourself from what you were told, note that you did so, and proceed.
Supervisors who handle these conversations informally and never report them are why many files begin months after the obligation did.
What to Record at Each Stage
| Stage | Record | Why it matters |
|---|---|---|
| Request | Date, who made it, to whom, how (in person, email, through a family member), what limitation and what change were described, in the person’s own words where possible | Fixes the start date and shows the request was recognized |
| Acknowledgment | Date you responded and what you said would happen next | EEOC says to respond expeditiously; unnecessary delay can itself be a violation |
| Medical information | What you asked for, why it was needed, when it was received | Shows the inquiry was limited and job-related |
| Interactive discussion | Each meeting or call: date, participants, options the employee proposed, options you proposed, the employee’s response | This is the core of the file |
| Analysis | Essential functions at issue, each option considered, whether it would be effective, reasons for and against | A rejected option with no recorded reason looks arbitrary |
| Decision | What was granted or denied, the reason, the start date, who was told what | Shows a reasoned, communicated decision |
| Follow-up | Review date, whether the accommodation is working, any changes | Accommodation is often iterative; a file that stops at implementation cannot show continued good faith |
Keep a single dated log for the whole case and file the documents below behind it. For the mechanics of the conversation itself, see the ADA interactive process guide.
Sample ADA Accommodation Request Form
The form should ask about limitations and the change requested. It should not ask for a diagnosis, medical history, or medication list. A question such as "What impairments do you have?" is the kind of broad disability-related inquiry EEOC’s guidance warns against.
Request for Workplace Accommodation (Sample)
You are not required to use this form. If you have already told your supervisor or HR that you need a change at work for a medical reason, your request has been received. This form helps us record it accurately. If you need help completing it, contact HR.
Section 1. Your information
Name: ____________________ Job title: ____________________ Department: ____________________ Supervisor: ____________________
Date you first asked for this change (if before today): ____________________ Whom you asked: ____________________
Section 2. What you are asking for
- What part of your job, the workplace, or a benefit or policy are you having difficulty with?
- How does your physical or mental condition make that difficult? (Describe the limitation. You do not need to state a diagnosis on this form.)
- What change or accommodation are you asking for? If you have more than one idea, list them all.
- When do you need it to start, and do you expect to need it temporarily or on an ongoing basis? If temporary, for about how long?
Section 3. Helping us respond
- Have you used an accommodation for this in a previous job or elsewhere that worked well? (Optional)
- Is there anything else you want us to know? (Optional)
Section 4. What happens next
HR will contact you within ______ business days to discuss your request. We may ask you for information from a health care provider if it is needed to understand your limitation and the accommodation. Medical information you provide is kept confidential in a file separate from your personnel file and is shared only as the law permits. You will not be retaliated against for making this request.
Employee signature: ____________________ Date: ____________________
Received by (HR): ____________________ Date received: ____________________
? Completed by HR on the employee’s behalf from an oral request made on ____________________ to ____________________
Notes on using it:
- Fill in a response time you can actually meet. The ADA sets no number of days; the standard is prompt.
- Because the completed form may describe a medical condition, file it with the confidential medical records, not in the personnel file.
- Do not make the form a gate. A policy that says requests "must" be submitted on the form invites a manager to ignore one that was not.
Medical Inquiry Letter Outline
When you may send one
During employment, a disability-related inquiry must be job-related and consistent with business necessity (29 CFR 1630.13(b) and 1630.14(c)). EEOC’s guidance on disability-related inquiries applies that to accommodation requests this way:
- You may ask for documentation when the disability or the need for accommodation is not obvious.
- You may not ask when both are obvious, or when the employee has already given you enough to substantiate the disability and the need.
- You may ask only for what is needed to establish that the person has an ADA disability and needs the accommodation. In most circumstances, that means you cannot ask for complete medical records.
- If the employee has more than one condition, ask only about the one behind the request.
EEOC describes sufficient documentation as information that describes the nature, severity, and duration of the impairment; the activity or activities it limits and the extent of the limitation; and why the requested accommodation is needed. Build the letter around those points and nothing else. More background is in medical information and inquiries under the ADA.
The outline
Letter to Health Care Provider (Sample Outline; Names Are Examples)
- Purpose and authority. "Jordan Ellis, a Customer Service Representative, has asked for a workplace accommodation and has authorized us to request the information below. A signed, limited release is enclosed."
- The job. Enclose the job description. List the essential functions relevant to the request and the working conditions that matter (schedule, physical demands, environment). State the accommodation the employee has asked for.
-
Questions (answer only as they relate to the condition for which accommodation is requested):
- Does the employee have a physical or mental impairment? Please describe its nature in general terms.
- What activities does the impairment limit (for example, walking, lifting, concentrating, sleeping, or the operation of a major bodily function), and to what extent?
- How long is the impairment or the limitation expected to last?
- Which of the listed job functions, if any, does the limitation affect, and how?
- Is the requested accommodation needed because of the limitation? Why?
- Are there other accommodations you would suggest that would allow the employee to perform these functions?
- If the need is temporary, when should it be reviewed?
- What not to send. "Please do not send medical records, test results, or information about conditions unrelated to this request."
- GINA notice. Include the safe harbor paragraph from 29 CFR 1635.8(b)(1)(i)(B), which begins: "The Genetic Information Nondiscrimination Act of 2008 (GINA) prohibits employers and other entities covered by GINA Title II from requesting or requiring genetic information of an individual or family member of the individual, except as specifically allowed by this law. To comply with this law, we are asking that you not provide any genetic information when responding to this request for medical information." Copy the full paragraph, including its definition of genetic information, from the regulation.
- Return instructions. Name the HR contact who will receive the response, give a confidential address or fax, and state a reasonable return date.
Rules for using the letter
- Get a limited release. EEOC’s guidance contemplates the individual signing a limited release so the employer can submit a list of specific questions to the provider. Do not contact a provider without the employee’s authorization.
- Explain gaps before escalating. If what comes back is insufficient, tell the employee why and give a chance to supply the missing information. EEOC also suggests considering a consultation with the employee’s doctor, with the employee’s consent, before going further.
- Employer-chosen examiner only as a later step. If the documentation remains insufficient, the ADA does not prevent requiring the employee to see an appropriate health professional of the employer’s choice. The exam must be limited to the disability and the functional limitations requiring accommodation, and the employer pays all costs.
- Check state law. Some states limit medical inquiries more tightly than the ADA. Confirm with counsel what a provider may be asked in each state where you have employees.
- Pregnancy-related requests are different. The Pregnant Workers Fairness Act has its own documentation rules; do not reuse this letter without checking them.
Accommodation Decision Record Template
The decision record is where an employer wins or loses a later dispute. It should show that you identified the essential functions, considered real options, and decided for a stated reason.
Accommodation Decision Record (Sample)
Case information
Employee: ____________________ Position: ____________________ Date of first request: ____________________ HR case owner: ____________________
1. Limitation and barrier
(Functional terms only; no diagnosis): __________________________________________________________________
2. Essential functions affected
(Cite the job description and date): __________________________________________________________________
3. Interactive process log
| Date | Participants | Summary of discussion |
|---|---|---|
4. Options considered
| Option | Proposed by | Would it be effective? | Cost or operational impact | Adopted? | Reason |
|---|---|---|---|---|---|
5. Decision
? Granted as requested ? Alternative accommodation offered ? Trial period through ____________________ ? Denied
6. If an alternative was offered
Why it is effective, and the employee’s response: _______________________________________________________
7. If denied, basis
Check one and attach the analysis:
- ? Documentation did not establish a disability or the need, after the employee was told what was missing and given time to provide it
- ? No accommodation would enable performance of the essential functions (list those considered, including reassignment to a vacant position)
- ? Undue hardship (attach the facts on cost, resources, and operational impact)
- ? Direct threat (attach the individualized assessment and the medical or objective evidence relied on)
8. Implementation
Start date: ____________________ Who is responsible: ____________________ What the supervisor was told (restrictions and accommodation only): ____________________
9. Communicated to employee
Date: ____________________ Method: ____________________ Copy of written confirmation attached: ?
10. Review
Review date: ____________________ Outcome of review: __________________________________________________
Decision maker: ____________________ Date: ____________________
Three points on completing it:
- Record the options you rejected. Files often show what was granted and omit what was considered. For each option, note whether it would have worked and why it was not adopted. Our articles on evaluating an effective accommodation and essential functions and job descriptions cover the analysis behind sections 2 and 4.
- A denial needs evidence, not a label. Undue hardship means significant difficulty or expense measured against specific factors in 29 CFR 1630.2(p); direct threat requires an individualized assessment under 29 CFR 1630.2(r). Writing the words on the form is not the analysis. See undue hardship explained and the direct threat standard.
- Confirm in writing. Tell the employee what was decided, when it starts, and whom to contact if it is not working.
Confidentiality and the Separate Medical File
Under 29 CFR 1630.14(c)(1), information about an employee’s medical condition or history obtained through an inquiry or exam must be "collected and maintained on separate forms and in separate medical files" and treated as a confidential medical record. EEOC’s guidance extends the same treatment to medical information an employee volunteers. This is a legal requirement, and a doctor’s note in the personnel file is one of the easiest violations for anyone reviewing your files to find.
The regulation allows three disclosures:
- Supervisors and managers may be told about necessary restrictions on the employee’s work or duties and necessary accommodations.
- First aid and safety personnel may be told, when appropriate, if the disability might require emergency treatment.
- Government officials investigating compliance must be given relevant information on request.
Coworkers are not on that list. EEOC’s position is that an employer may not tell other employees that a colleague is receiving an accommodation, since that usually discloses a disability.
In practice, the case splits into two places:
| File | Contents | Who has access |
|---|---|---|
| Confidential medical file (HR) | Request form, release, provider letter and response, any exam report, the decision record and log where they describe the condition | HR staff handling the case; others only as the three exceptions allow |
| Supervisor instruction | A short memo: the restriction or accommodation, start date, review date, and the reminder not to discuss it with the team | The supervisor and anyone who must implement it |
| Personnel file | Non-medical outcomes only where needed, such as a schedule change notice | Normal personnel file access |
The manager needs to know what to do, not why. More detail is in confidentiality of ADA accommodation requests.
What Not to Record
- Diagnoses or medical details in the personnel file, a ticketing system, or a shared calendar.
- Speculation about the employee’s condition or motives.
- Remarks about cost or inconvenience outside a documented hardship analysis.
- Side conversations in email or chat that bypass the case file. They are discoverable.
How Long to Keep Accommodation Records
EEOC’s recordkeeping rule requires employers to preserve personnel and employment records, expressly including requests for reasonable accommodation, for one year from the date the record was made or the personnel action involved, whichever is later. If the employee is involuntarily terminated, keep the records for one year from termination. Once a charge is filed, preserve all relevant records until final disposition (29 CFR 1602.14).
One year is the federal floor. Many employers keep accommodation files for the duration of employment plus several years because state laws and limitation periods can be longer. Set the period with counsel for your states. Our HR document retention schedule covers the other record types.
Where Training Fits
Forms make a good process repeatable; they do not supply the judgment that fills them in. The two-day Leave and Accommodation Management seminar covers medical inquiries, the interactive process, confidentiality, and notice and documentation where the ADA overlaps with FMLA, workers’ compensation, the PWFA, and state law, using scenarios and interactive exercises.
Frequently Asked Questions
Can an employer require an ADA accommodation request form?
An employer may ask the employee to complete a form, but it cannot refuse to act on an oral request or treat the request as not made until the form arrives. If the employee does not return the form, HR should record the request itself and continue.
What can an employer ask a doctor about an accommodation request?
Only what is needed to establish that the employee has an ADA disability and needs the accommodation: the nature, severity, and duration of the impairment, the activities it limits and to what extent, and why the accommodation is needed. Complete medical records and unrelated conditions are off limits in most circumstances.
Does accommodation paperwork go in the personnel file?
Not the medical parts. Medical information must be kept on separate forms in a separate, confidential medical file. Supervisors receive only the necessary restrictions and accommodations.
How long should accommodation request records be kept?
Federal rules require at least one year from the record or the personnel action, whichever is later, and until final disposition if a charge is filed. State law and counsel’s advice often call for longer.
Can a manager see the employee’s medical documentation?
Generally, no. A manager may be told about work restrictions and the accommodation to be made. The underlying medical documentation stays with HR in the confidential file.
The Bottom Line
A defensible accommodation file has a start date that matches the first conversation, a request form that asks about limitations instead of diagnoses, a medical inquiry no broader than EEOC allows, a decision record that shows the options weighed, written confirmation to the employee, a review date, and a wall between the medical information and everyone who does not need it.
Adapt the three templates above, add them to your ADA compliance checklist, and brief supervisors on reporting requests the day they hear them. For the rest of the cluster, go to the ADA and Accommodation Guide; for instructor-led practice on the harder cases, see the Leave and Accommodation Management seminar. This article is general education, not legal advice.
