Supporting Mental Health at Work: Understanding ADA Accommodations

As mental health awareness grows in the workplace, employers are increasingly seeking clarity on their responsibilities under the Americans with Disabilities Act (ADA). Passed in 1990, the ADA prohibits discrimination against qualified individuals with disabilities and requires employers with 15 or more employees to provide reasonable accommodations. These accommodations aren’t just about physical impairments—mental health conditions are equally protected. 

In this blog, we’ll explore what qualifies under the ADA, how employers can recognize and respond to accommodation requests, and the value of creating a supportive, inclusive environment. 

Who Does the ADA Protect? 

Under the ADA, a disability is defined as a physical or mental impairment that substantially limits one or more major life activities. Employers must not base employment decisions on someone’s disability or their need for accommodation. Instead, they’re required to: 

• Engage in the interactive process when an accommodation is requested. 
• Offer reasonable support unless it would create an undue hardship—i.e., significant difficulty or expense relative to the company’s size and resources. 

Even if an employee doesn’t explicitly say, "I’m requesting a reasonable accommodation," or disclose their exact condition, that doesn’t invalidate the request. It’s up to managers to recognize when someone may need help and respond appropriately. 

ADA vs. Family Medical Leave Act (FMLA): What’s the Difference? 

While both offer job-protected leave, the ADA and FMLA serve different purposes: 

Note: Both offer job protected leave, and both are unpaid. Employer can require that ADA leave and FMLA leave run concurrently. 

Why Mental Health Accommodations Matter 

Mental health conditions are common and, when unaddressed, they can impact attendance, productivity, and morale. Fortunately, reasonable accommodations help employees manage their health while continuing to contribute meaningfully to the workplace. 

Providing support for mental health: 

• Enhances employee wellbeing and job satisfaction. 
• Helps retain talented team members. 
• Boosts company performance through a more engaged workforce. 

Recognizing Accommodation Requests 

Mental Health Accommodations allow qualified employees with disabilities to perform essential job functions while maintaining physical and mental wellbeing. Accommodation requests don’t always come in the form of a formal letter. Here are common signs to watch for: 

• Direct Requests: The employee asks for help due to a medical condition. 
• Work Performance Issues: Declining attendance, frequent appointments, or challenges meeting expectations. 
• Changes in Work Needs: Requesting different hours, reduced workload, or special equipment. 
• Health-Related Leaves: Return from a medical event or request for a leave of absence. 
• Complaints or Concerns: Self-reported struggles or observations from team members. 

Each accommodation should be customized to the individual's needs, in collaboration with the employee and supported by medical documentation. Here are some common examples: 

• Flexible Work Arrangements: Remote work, flexible scheduling 
• Work Environment Adjustments: Quiet workspaces, noise-canceling headphones, modified supervision methods 
• Leave and Breaks: Sick leave for mental health reasons (full leave or intermittent leave); flexible use of vacation time; short, frequent breaks 

How to Navigate Reasonable Accommodation Process 

When a request arises, employers must initiate a confidential, good-faith dialogue with the employee. As noted, the ADA prohibits discrimination against individuals with disabilities. 

Here’s how to handle a request: 

• Review certification and supporting documentation for employee's medical condition 
• Medical certification can come from a physician, therapist, nurse, or other qualified provider 
• Discuss Accommodation Options: Work together to identify effective accommodations, such as schedule changes, modified duties, or leave. 
• Evaluate Reasonableness: Consider whether the accommodation enables the employee to perform essential job functions without creating undue hardship 
• Respond Appropriately: Approve the accommodation in writing, suggest alternatives if needed, or explain denials clearly and respectfully 
• Maintain documentation of the interactive process and outcome 

Additional Leave Requirements by State 

Some states and localities expand on federal leave laws with paid or protected leave. States like California, New York, Massachusetts, and others have specific laws requiring family or paid sick leave. Employers should stay informed of laws in their location or where remote workers are based. 

Determining Reasonableness  

A “reasonable” medical accommodation is any change or adjustment to a job or work environment that allows an employee with a disability or medical condition to perform the essential functions of their job without causing undue hardship to the employer. 

Whether a requested accommodation is reasonable will be determined on a case-by-case basis. The following factors can be considered when examining reasonableness. 

Effective in helping the employee do the essential job functions 

• Does not create significant disruption or cost 
• Is not indefinite or excessively burdensome 
• Employers are not required to provide the best accommodation—just a reasonable one 

A reasonable accommodation must be effective, necessary, and reasonable, and the employee must be able to perform the essential functions of the job either with or without an accommodation.  

Creating a Supportive, Compliant Workplace 

Mental health accommodations aren’t just a legal requirement—they’re a smart investment in your team’s success. Employers should: 

• Train managers to recognize signs of accommodation requests. 
• Use the interactive process to find effective solutions. 
• Maintain thorough documentation while respecting confidentiality. 
• By handling requests fairly and consistently, organizations can meet their legal obligations under the ADA while fostering a culture of trust and respect.

This article does not constitute legal advice and does not address state or local law.