Understanding What Reasonable Really Means for Small Businesses

One of the biggest sources of anxiety for small business owners around ADA accommodation requests is the fear that “reasonable accommodation” means unlimited expense and endless flexibility. There’s this worry that you’ll be required to do things that larger companies with deeper pockets can easily absorb but that would genuinely harm your smaller operation.

The good news is the law already accounts for this. The ADA includes something called the undue hardship exemption, and it’s specifically designed to measure reasonableness against your particular business—your size, your resources, your operational realities. What might be perfectly reasonable for a tech giant with hundreds of employees and substantial budgets could absolutely constitute undue hardship for a startup with five people operating on thin margins. The law doesn’t expect you to be Amazon or Google. It expects you to be thoughtful within your actual constraints.

There’s another critical boundary here that provides clarity: the accommodation must enable the employee to perform the essential functions of their job. You’re not required to eliminate fundamental job duties or create an entirely new position. If you employ a delivery driver and they lose their ability to drive due to a medical condition, there’s no accommodation that makes it reasonable for them to continue in that role. You’re not expected to hire someone else to do their driving while keeping them on payroll in a job that no longer exists.

Your obligation is to determine whether the person can still do what the role fundamentally requires, and if so, what adjustments might help them do it effectively. This keeps the focus where it belongs—on enabling someone to succeed in their actual job, not on transforming the job into something completely different.

Even if your business has fewer than fifteen employees and technically isn’t covered by federal ADA requirements, pay attention to this guidance anyway. Many states have disability accommodation laws with lower employee thresholds. Beyond legal compliance, following these principles is simply good leadership. It builds trust with your team, prepares you for growth, and establishes practices that protect you from future claims as your business expands.

The Documentation and Confidentiality You Can’t Skip

Once you’ve worked through the interactive process and landed on an accommodation, your work isn’t finished. Now comes the part that many entrepreneurs overlook: documentation and confidentiality management.

You need to document everything. Write down what the employee requested. Note what you discussed during your conversations. Record what accommodation you agreed to and the reasoning behind your decision. If you explored alternatives that didn’t work, document why. This information needs to go into a file that’s completely separate from the employee’s regular personnel file because you’re dealing with medical information, and medical information has different confidentiality requirements than standard employment records.

Here’s where well-intentioned leaders often make serious mistakes. In an effort to build a transparent, open workplace culture, they announce to the team why certain accommodations are being made. They’ll say something like, “Jane is working from home on Tuesdays because of her migraines,” or “Mike got that new chair because he has back problems.” They think they’re being clear and fair by explaining the context.

This is a significant violation of privacy. Medical information is confidential, full stop. You cannot share it with other team members, regardless of your intentions. Even when those intentions are good—even when you’re trying to head off questions about fairness or special treatment—you cannot disclose someone’s private health information.

And make no mistake, your team will notice changes. They’ll wonder why one person got a standing desk when they didn’t, or why someone else gets to work different hours. They may feel it’s favoritism or that rules are being applied inconsistently. You still cannot explain the medical reasons to defend your decision.

What you can say is simple and sufficient: “We make individualized decisions to support everyone’s productivity here, just like I would do for you if you needed specific tools to succeed.” That’s your response. It acknowledges that accommodations exist without revealing private information. It reinforces that these decisions are available to anyone who needs them. And it shuts down the comparison conversation without violating confidentiality.

When it comes to sharing information with supervisors or team members who need to help implement the accommodation, share only what they absolutely need to know to do their part. If someone needs to know that a team member will be starting work an hour later, they don’t need to know it’s because of medication side effects. Give them the operational information they need and nothing more.

Remember that accommodations aren’t static. Check in periodically to see how things are working. Medical conditions evolve. Job responsibilities change. What worked six months ago might need adjustment now. Staying engaged with the process and updating your documentation as circumstances shift protects both your employee and your business over time.