9.5 Accommodation and Policy Exception Scenarios

Recognizing the Accommodation Trigger

Accommodation scenarios usually feature a manager who wants a quick yes or no. The most effective SHRM-CP response is more disciplined. The first skill tested is recognition: an employee does not have to say "ADA," "disability," or "reasonable accommodation" to trigger the employer's duty. When an employee connects a workplace barrier to a medical condition — "I'm having trouble doing this task because of my back," "I need a different schedule for treatment," "the lighting triggers my migraines" — HR should recognize a possible accommodation request and begin a good-faith interactive process.

Under the Americans with Disabilities Act (ADA), a reasonable accommodation is any change to the job or work environment that lets a qualified individual perform the essential functions of the position or enjoy equal employment opportunity. The ADA does not prescribe one rigid procedure, but the EEOC and the Job Accommodation Network (JAN) recommend a structured, flexible, collaborative dialogue built on communication.

Recognizing the trigger does not mean automatically granting the request exactly as worded. It means gathering enough information to consider effective, reasonable options through the process. The employer may choose among accommodations as long as the chosen one is effective, and where two options are equally effective it may pick the less costly or less burdensome one. The employer may also decline an accommodation that would cause undue hardship — significant difficulty or expense relative to the organization's size, resources, and structure — but that conclusion comes after the interactive process, not instead of it.

Running the Interactive Process

Work the scenario through these review questions and pick the option that follows them.

Two principles govern confidentiality. First, the employer may request reasonable documentation of the disability and need for accommodation when it is not obvious — but only what is job-relevant, kept in a confidential medical file separate from the personnel record. Second, the interactive process is ongoing: it does not end when an accommodation is put in place, and HR should revisit it if the arrangement stops working or the job changes.

A manager should receive only the work-related terms needed to implement the arrangement — modified schedule, lifting restriction, reassigned marginal duty, equipment — and should not receive the diagnosis or medical specifics. HR translates the approved accommodation into work terms and helps the manager apply it without resentment or unnecessary disclosure. A manager who insists on knowing "what's wrong with" the employee is asking for information HR should not provide, and the keyed answer reflects that boundary.

Policy Exceptions: Consistency Over Convenience

Policy-exception scenarios share the same discipline but a different driver. A manager may want to waive a rule for a top performer; an employee may ask for flexibility because of a serious personal circumstance (which is distinct from a disability accommodation, though the two can overlap). The most effective answer checks four things: does the policy itself permit exceptions; how were similar requests handled; what precedent does saying yes create; and who has the authority to approve it.

Avoid the two predictable wrong extremes:

• Automatic denial — refusing because the manager dislikes disruption, the request is informal, or "we don't make exceptions" — creates risk and damages trust, and for a medical-linked request it can be a failure of the interactive-process duty.
• Automatic approval — granting because the employee is a high performer or because it is easier — creates inconsistent treatment, operational problems, and unfairness to everyone who was told no.

The keyed answer usually starts with review, consultation, documentation, and communication of the decision through the correct channel — not a manager's first reaction becoming the organization's final decision.

Scenario checklist:

• Is the request about a work barrier linked to a medical condition (interactive process) or a policy flexibility (consistent exception review)?
• Is it being treated consistently with similar situations and precedent?
• Has HR involved the right internal resource (legal, senior HR, benefits) before deciding?
• Does the manager understand the work impact without receiving private details?
• Is there a follow-up plan if the arrangement stops working?

The winning SHRM-CP answer protects both the individual and the organization through structure: it treats the request as worth reviewing, controls information, and decides through the proper authority rather than convenience.