An accommodation request is a conversation the law expects you to have.
Disability and religious accommodation rules reach hiring, scheduling, leave and benefit design. This guide explains the federal and Michigan duties, the interactive process and where benefits are affected.
The basics for employers.
A concise overview, not legal advice. Because the law moves, read the current statute or regulation yourself.
Disability Accommodation
The ADA obliges employers with 15 or more employees to accommodate a qualified individual up to the point of undue hardship, whereas Michigan’s disability rights act (PWDCRA) has no minimum headcount.
Religious Accommodation
Title VII obliges an employer to accommodate an employee’s religious practice unless that would impose substantial increased costs on the business. Michigan’s Elliott-Larsen Act likewise bars religious discrimination.
The Interactive Process
Discuss the request with the employee, look at the job’s essential functions, compare possible solutions and keep notes. Medical details stay confidential, outside the regular personnel file.
How a request plays out.
No special phrase is needed. A worker who says a health condition makes a task difficult, or that a schedule clashes with a religious observance, has opened the process. Send it to one trained person instead of leaving it with a line supervisor.
Ask for only the information needed. For a disability that is not obvious, an employer may request documentation from a health care provider describing the limitation and the need. It should not ask for a full medical history.
Rank the options by how well they fit: a revised schedule, adapted equipment, a move to a vacant role, or time away. Whether FMLA leave applies and whether leave works as an accommodation are two questions to track on separate lines.
Write down what was asked, what was considered and what was decided. A denial should explain why the request imposes an undue hardship or is not required, and offer alternatives where possible.
Where this shows up in your plan.
Leave and Plan Eligibility
Accommodation leave can interact with FMLA leave, short-term disability and the plan’s active-employee rules.
Wellness Programs
Employee wellness activities involving health questionnaires or medical testing have to be voluntary and respect ADA and GINA limits.
Reassignment and Reduced Hours
A move to a lower-hours position can change benefits eligibility and ACA measurement. Check the plan before agreeing.
Setting it up.
Name one person or a small team to receive accommodation requests and tell supervisors to forward them the same day.
Create a simple intake form and a standard response letter that offers a conversation, not a decision.
Keep medical records in a separate confidential file with limited access.
Review the handbook for a clear statement of how to ask for an accommodation.
Train supervisors on what to say when someone raises a religious or medical need.
Mistakes to avoid.
Denying a request because a supervisor assumed it would not work, without discussing alternatives.
Disclosing the reason for an accommodation to coworkers.
Treating every request as a leave request. Leave is one option among several.
Using the same policy for both disability and religion without noting the different hardship standards.
Other rules employers work with.
FMLA Rules for Michigan Employers
Eligibility, notices and benefits during leave.
Pregnancy and Lactation Accommodations: PWFA and PUMP
Accommodations tied to pregnancy.
Harassment and Discrimination Rules
Michigan and federal prohibitions.
Laws and Rules Referenced
ADA, 42 U.S.C. 12101 et seq. — Disability discrimination and reasonable accommodation.
ADA employment regulations, 29 CFR Part 1630 — Definitions, interactive process and undue hardship.
Religion under Title VII (definition), 42 U.S.C. 2000e(j) — Definition of religion and the duty to accommodate.
Michigan disability civil rights law, MCL 37.1101 et seq. — Michigan disability discrimination and accommodation.
Elliott-Larsen Act of Michigan, MCL 37.2101 et seq. — Michigan prohibition on discrimination including religion.
Quick answers.
What employers ask us most about accommodation, answered briefly and linked to the full guides.
Are small employers covered by the ADA?
ADA coverage begins at 15 employees; Michigan’s PWDCRA reaches employers with just one.
What is the interactive process?
A good-faith dialogue between employer and employee to pin down the limitation and the possible accommodations, recorded as it happens.
What is the standard for a religious accommodation?
The employer owes an accommodation unless it can show substantial increased costs in the context of how its business is run.
Can we ask for medical documentation?
When the disability or the need is not apparent, yes, limited to what shows the limitation and the accommodation needed.
Does accommodation leave count as FMLA leave?
It can overlap, but they are separate legal questions. An employee may be eligible for both, and each should be tracked.
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