An employee mentions they’re struggling with a medical condition. A team member asks for flexibility after a doctor’s appointment. A high performer begins having attendance issues tied to a health concern. In most cases, the first person they talk to isn’t HR. It’s their supervisor.
What happens next can determine whether the organization begins a compliant accommodation process or creates unnecessary legal risk.
As accommodation requests continue to rise and disability-related claims remain a top enforcement priority for the Equal Employment Opportunity Commission (EEOC), organizations are realizing that ADA compliance is no longer just an HR responsibility. It is a manager responsibility.
The managers who know how to recognize potential accommodation situations, respond appropriately, and involve the right people can help protect employees, strengthen workplace culture, and reduce organizational risk. The managers who don’t may unintentionally create problems before HR ever has a chance to help.
Workplace accommodation requests have become more common as employers navigate evolving workforce needs and expectations. Changes in how, where, and when people work, combined with greater recognition of both visible and invisible disabilities, have expanded the range of situations that may require accommodation discussions.
One of the most significant drivers of this trend is the increased recognition of mental health conditions in the workplace. Anxiety, depression, PTSD, and other conditions that may not be visible to others are now among the most common reasons employees seek workplace accommodations.
At the same time, requests involving neurodivergent conditions such as ADHD, autism spectrum disorder, sensory processing differences, and other cognitive or neurological conditions are becoming more common across organizations of every size. As awareness grows, employers are increasingly navigating accommodation requests related to a broader range of workplace needs and experiences.
Many of today’s accommodation requests look different from the traditional accommodation conversations managers may expect. Instead of requests for modified workstations or physical adjustments, employees may seek support related to communication preferences, meeting formats, sensory environments, focus time, remote work arrangements, workplace flexibility, or other adjustments that help them perform their jobs effectively.
Remote and hybrid work arrangements have also created new accommodation considerations, while an aging workforce continues to increase the number of employees managing chronic illnesses and age-related disabilities. At the same time, employees are becoming more knowledgeable about their workplace rights and the protections available under the ADA.
These changes can create challenges for supervisors. Employees seeking accommodations often appear capable, productive, and successful in their roles. As a result, managers may mistakenly assume that because someone appears to be functioning well, an accommodation is unnecessary.
That assumption can create both compliance and employee relations risk. An employee who successfully manages a medical condition through treatment, coping strategies, or personal effort may still be entitled to a reasonable accommodation under the ADA. The question is not whether a condition is visible. The question is whether it affects the employee’s ability to perform their job without support or adjustment.
The accommodation playbook that worked a decade ago is no longer enough. Today’s supervisors are increasingly expected to navigate a broader range of workplace situations while balancing employee needs, operational requirements, and organizational policies. As a result, they are more likely than ever to encounter situations that may trigger accommodation obligations, making early recognition and appropriate response essential.
The rise in accommodation requests is happening at the same time disability discrimination enforcement remains a significant focus for the EEOC. The numbers tell the story:
More than 33,000 ADA-related charges were filed with the EEOC in FY2024, the highest number on record.
ADA claims were included in 43.2% of the EEOC's merits lawsuits filed in FY2024.
Through the first half of FY2025, 45% of EEOC enforcement lawsuits included ADA allegations, signaling continued focus on disability-related workplace issues.
For employers, these numbers highlight a simple reality: accommodation decisions continue to receive significant regulatory attention, making supervisor training and early issue recognition more important than ever.
In a statement marking the 35th anniversary of the Americans with Disabilities Act, EEOC Chair Andrea Lucas highlighted record-breaking charge volumes and emphasized the agency’s continued focus on disability-related enforcement. The EEOC’s Strategic Enforcement Plan identifies disability discrimination and accommodation obligations as a priority area through 2028.
At the same time, accommodation requests continue to increase. According to the 2026 State of Leave and Accommodations Report from AbsenceSoft, 56% of employers reported increased accommodation requests in 2025, marking the third consecutive year of growth. Among organizations experiencing increases, nearly three-quarters reported growth of 21% or more.
Together, these trends are increasing the likelihood that supervisors will encounter accommodation issues in everyday workplace conversations.
Many organizations think of the ADA interactive process as an HR function. While HR ultimately manages the process, accommodation requests rarely begin there.
Instead, they often start with an everyday conversation.
"I'm having trouble sitting for long periods because of my back."
"My medication is making mornings difficult."
"The office environment has been affecting my anxiety."
"My doctor recommended some changes to my schedule."
None of these statements use the word accommodation.
None reference the ADA.
Yet each may signal the need for further review.
Managers and supervisors are often the first people to hear these comments, making them the first line of defense in identifying potential accommodation situations.
The challenge is that many of them have never been trained to recognize them.
As accommodation requests become more varied and less obvious, the ability to recognize potential ADA issues early has become a critical management skill.
The most common ADA mistake is not recognizing that a request has been made.
Employees are not required to use legal language. They do not need to mention the ADA or formally request an accommodation. They simply need to communicate that a medical condition may be affecting their ability to perform their job.
Managers often want to help. Unfortunately, that desire to help can sometimes lead to questions they should not be asking.
Instead of focusing on medical diagnoses, managers should focus on workplace limitations and job-related needs.
The goal is not to determine whether someone has a disability. The goal is to recognize a potential issue and involve the appropriate internal resources.
In a recent EEOC case, a new manager cut off communication with an employee who had a disability and suspended them from their job. The jury awarded $5.2 million in damages. In another, an employer denied a PTSD accommodation for a service dog and withdrew a job offer — now an active EEOC lawsuit filed in March 2026.
Many workplace conflicts arise when managers rely solely on company policy without considering whether an accommodation discussion may be necessary.
Whether the issue involves attendance, scheduling, remote work, or performance expectations, accommodation obligations may require individualized consideration.
Policies matter. So does understanding when exceptions may need to be evaluated through the proper process.
An employer granted a dispatcher’s telework accommodation, watched her work successfully from home for nearly three years, then revoked it without engaging in the interactive process. The EEOC filed suit, and the resulting consent decree required $280,000 in relief plus updated policies and mandatory training.
Three process gaps made this avoidable: the employer pulled the accommodation from a group without individual assessment, relied on coworker complaints instead of conducting an undue hardship analysis, and never re-engaged the interactive process before making the change.
ADA compliance failures can result in regulatory investigations, litigation, settlement costs, and damage to employee trust.
But legal exposure is only part of the story.
When employees feel unsupported during health-related challenges, organizations often experience:
The organizations that manage accommodation situations effectively are not simply reducing risk. They are creating workplaces where employees feel supported and able to perform at their best.
Compliance training has a reputation problem, and in many cases it is deserved.
Most ADA training teaches the law. It explains what a reasonable accommodation is, reviews legal definitions, and outlines organizational responsibilities. What it often fails to do is prepare supervisors for the conversations where accommodation issues actually emerge.
An employee makes an unexpected comment during a one-on-one. A performance discussion reveals an underlying medical concern. A return-to-work conversation raises questions that a manager has never encountered before.
These are the moments that create risk.
Many ADA training programs focus on helping managers understand legal requirements. Effective training helps them recognize accommodation situations, navigate real conversations, and know what to do next.
The organizations that successfully navigate ADA obligations are not necessarily the ones with the largest legal departments. They are the ones whose frontline managers know how to recognize a potential accommodation request, understand what questions to ask and avoid, and involve the right people at the right time.
Supervisors do not need to become ADA experts. They need practical guidance for what to do next.
SHIFT’s Understanding the Americans with Disabilities Act (ADA) training course is designed specifically for supervisors and managers.
Rather than focusing solely on legal concepts, the course helps supervisors build practical skills for recognizing accommodation situations, responding appropriately, and involving the right people.
Through realistic workplace scenarios, learners practice:
The result is greater confidence, consistency, and compliance.
Most accommodation situations do not begin with a form.
They begin with a conversation.
The most effective organizations do not wait for accommodation issues to reach HR. They equip managers to recognize concerns early, respond appropriately, and connect employees with the right resources from the start.
Because when it comes to ADA compliance, the most important decision is often made before HR ever gets involved.
Want to help your supervisors recognize accommodation situations and respond with confidence?
Contact us to learn more about ADA training from SHIFT HR Compliance Training and see how behavior-focused learning can help strengthen compliance, consistency, and workplace culture.
No. Employees do not need to use specific legal language. Any communication that connects a health condition to a workplace challenge may warrant further review.
Supervisors should respond professionally, avoid making promises, and involve the appropriate HR or accommodation resources according to organizational procedures.
Supervisors should avoid asking for detailed medical information and instead focus on job-related limitations and workplace needs.
Managers are often the first people employees approach with accommodation concerns. Their response can significantly affect compliance, employee experience, and organizational risk.
Supervisors, managers, team leads, and anyone who may be responsible for responding to employee concerns related to health conditions, disabilities, or workplace accommodations.
ADA compliance often begins long before HR receives a request.
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