Interactive Process

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Interactive Process

Reference Number: MTAS-1050
Reviewed Date: 09/04/2026

Overview
The interactive process is the ongoing conversation between the city and an employee or applicant about a possible reasonable accommodation. Running it well, and documenting it well, is the most important thing a city can do to comply with the ADA.

What the interactive process looks like
The process may include a series of conversations, meetings, and follow-up communication. It can also involve:

  • Consulting an ADA expert or peer employers about creative solutions
  • Observing the employee to identify physical or spatial changes that would help
  • Asking the employee for their ideas — often the individual has the best suggestions about the equipment or accommodation they need

Document every step
You do not want the case to come down to a "he said/she said" dispute in court. Document the interactive process in writing at each step.
Courts almost always look first at the interactive process to decide whether the employer acted in good faith. They want to see:

  • That the employer worked with the individual to identify barriers to applying for or performing the job
  • That the employer reviewed the individual's limitations to identify possible accommodations

The interactive process is the strongest tool an employer has to avoid liability for disability discrimination or failure to accommodate. Most problems in this area are avoidable by simply engaging in real dialogue with the individual.

Key sources

  • 29 CFR § 1630.2(o)(3) (interactive process guidance)
  • EEOC Enforcement Guidance on Reasonable Accommodation and Undue Hardship under the ADA

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