Mental Health Provider’s Role in the ADA Reasonable Accommodation Process

Yesterday, the EEOC issued formal guidelines on the role of mental health providers in an employee’s request for reasonable accommodation at work. Of particular interest is the EEOC’s explanation that a condition may be a disability if it makes “activities more difficult, uncomfortable, or time-consuming” for the employee compared to others, and that “a condition does not have to result in a high degree of functional limitation to be ‘substantially limiting’ under the ADA.” The EEOC also clarifies that if an employee’s symptoms come and go “what matters is how limiting they would be when present.”

The guidelines also explain how a mental health provider can help an employee get a reasonable accommodation by providing the employee-client with documentation of their condition and its associated functional limitations together with an explanation of how a requested accommodation would help. The EEOC specifies that helpful documentation would include: the providers professional qualifications and nature and length of relationship with the employee; the employee’s diagnosis; the employee’s functional limitations in the absence of treatment; an explanation of how the employee’s condition makes changes at work necessary; and, suggested accommodations.  For more details, the guidelines can be found here:


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