Full Answer Section

Reasonable Accommodation Expectations for Religion and Disability

Under U.S. law, employers have a legal obligation to provide reasonable accommodations for both religion and disability, though the specific legal standards differ.

Disability Accommodation: The Americans with Disabilities Act (ADA), as amended by the ADA Amendments Act (ADAAA), requires employers with 15 or more employees to provide reasonable accommodations to qualified individuals with disabilities. A “qualified individual with a disability” is a person who, with or without reasonable accommodation, can perform the essential functions of the job.

The obligation to accommodate is triggered when an employee or applicant informs the employer of their need for an accommodation. This request can be made orally or in writing and does not need to use the phrase “reasonable accommodation.” The employer is then expected to engage in an “interactive process” with the individual to identify a suitable and effective accommodation. Examples of accommodations can include:

• Making existing facilities accessible (e.g., installing ramps or modifying restrooms).
• Job restructuring or modifying work schedules.
• Acquiring or modifying equipment or devices (e.g., providing a screen reader for a visually impaired employee).
• Providing qualified readers or interpreters.
• Reassigning an employee to a vacant position.

The employer is not required to provide a specific accommodation if it would cause an “undue hardship.” Under the ADA, undue hardship is defined as an accommodation that would be “unduly costly, extensive, substantial, or disruptive” or would fundamentally alter the nature or operation of the business. The cost of an accommodation is a key factor, but employers must consider all resources available, including tax credits or outside funding. The “undue hardship” standard is a high bar, and employers must be prepared to demonstrate why an accommodation would pose a significant difficulty.

Religious Accommodation: Title VII of the Civil Rights Act of 1964 requires employers to reasonably accommodate the sincerely held religious beliefs, practices, or observances of their employees, unless doing so would cause an “undue hardship.” The definition of “religion” under Title VII is broad and includes not only traditional organized religions but also moral or ethical beliefs that are sincerely held with the strength of traditional religious views.

The accommodation process for religion is similar to that for disability: once an employee or applicant informs the employer of a conflict between their religion and a work requirement, the employer must engage in a good-faith effort to find an accommodation. Common types of religious accommodations include: