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Internal Accommodations Audit: Key Considerations for HR Leaders

TL;DR Conducting an internal accommodations audit is essential for ensuring compliance with the ADA, PWFA, and Title VII, and fostering an inclusive workplace. Download our comprehensive resource to guide you through the process and address key considerations to improve your accommodations procedures.

Team Disclo
September 13, 2024

As we approach the end of the fiscal year, HR leaders are focusing on ensuring their accommodation processes align with the Americans with Disabilities Act (ADA), the Pregnant Workers Fairness Act (PWFA), and Title VII of the Civil Rights Act. An internal accommodations audit is essential for identifying gaps, ensuring compliance, and safeguarding your organization from potential legal risks.

This article explores why performing an ADA compliance audit is critical for your business, highlighting key considerations in the audit process and touching on related laws like PWFA and Title VII. We’ll also show how an audit can drive inclusivity and efficiency across your company. 


Want to download the template to kickstart your internal accommodations audit now? 👇Scroll down to the end.


Why Conduct an ADA Accommodations Audit Now?

In today's regulatory environment, laws like the ADA, PWFA, and Title VII are crucial for ensuring equal opportunities in the workplace. However, many businesses fail to regularly audit compliance with these laws, which can lead to costly legal battles, loss of trust, and a negative workplace environment. Here’s why performing an internal accommodations audit should be a priority in 2024:

Legal Compliance with the ADA, PWFA, and Title VII

The ADA requires businesses to provide reasonable accommodations for employees with disabilities. Similarly, PWFA requires employers to provide accommodations for pregnant workers, and Title VII prohibits discrimination based on race, color, religion, sex, and national origin. Failing to comply with these regulations can expose your business to lawsuits, EEOC investigations, and significant financial penalties.

For example, under the PWFA, an employee who experiences pregnancy-related conditions must be provided with reasonable accommodations similar to those offered under the ADA. Conducting an accommodations audit will ensure your organization complies with these overlapping legal requirements.

Inclusivity and Employee Engagement

Conducting a thorough ADA audit and assessing your PWFA and Title VII compliance will enhance workplace inclusivity. Employees who feel supported and accommodated tend to be more engaged, productive, and loyal. A study by the Job Accommodation Network (JAN) found that providing accommodations often resulted in direct benefits for companies, including increased employee retention and productivity.

Addressing Workplace Accommodation Needs

With the increasing focus on disability inclusion, pregnancy accommodations, and the prevention of workplace discrimination, your business must ensure that all employees have access to the accommodations they need to succeed. Auditing your processes ensures that accommodations requests are handled consistently and fairly across the board.

Key Considerations for Your ADA Accommodations Audit

A successful ADA compliance audit goes beyond basic accessibility and must incorporate elements of PWFA and Title VII compliance. Let’s explore some key areas to consider when auditing your workplace accommodations processes. 


*Note: This list is not comprehensive. Download the template below to explore additional key considerations for your internal accommodations audit.

1. Assess Your Accommodation Request Process

The first step in an ADA compliance audit is evaluating how accommodation requests are handled. Are you addressing disability-related requests, pregnancy accommodations, and religious accommodations under Title VII in a consistent and efficient manner? Key areas to audit include:

  • Accommodation requests initiation: Are employees aware of how to request accommodations, and are those requests documented properly?
  • Case tracking and management: Is the status of each accommodation request properly tracked within HR systems, while ensuring that access to this information is limited to only those who need to know, such as HR personnel and case managers? Employees and managers should not have visibility into the full details of the request or medical information unless explicitly necessary for implementing the accommodation.
  • Medical verification and compliance: Is your process aligned with ADA standards, PWFA, and Title VII for validating the need for an accommodation?

Making sure your process is transparent and compliant with these laws will ensure a smooth and inclusive workplace accommodation experience.

2. Evaluate Your Compliance with PWFA and Title VII

The Pregnant Workers Fairness Act (PWFA), which took effect in 2023 and was finalized in 2024, extends protections to pregnant employees requiring reasonable accommodations, such as more frequent breaks, modified duties, or time off. Likewise, Title VII requires reasonable accommodations for employees facing religious conflicts or gender-related issues.


Your internal audit should include:

  • Are PWFA accommodations being handled with the same rigor and fairness as ADA accommodations?
  • Are managers trained to recognize requests that fall under Title VII, such as religious accommodations or accommodations for gender expression and identity?

Ensuring your compliance with both the ADA and PWFA avoids legal pitfalls and protects the rights of your employees.

3. Identify Bottlenecks and Resource Gaps

Your audit should identify critical bottlenecks to maintain efficiency and prevent delays in the accommodation process. Questions to consider:

  • How long does it take for requests to be processed and resolved?
  • Are there any resource gaps that delay the provision of accommodations?
  • Are legal consultations required frequently, adding unnecessary costs and time?

You'll improve compliance and employee satisfaction by identifying areas where your process could be streamlined—such as automating parts of your accommodations workflow or better utilizing HR resources.

4. Establish Clear Communication Between HR and Employees

The accommodation process must be transparent and accessible for all employees. During your audit, review how well employees understand the process and how effectively HR communicates about accommodations. Ask:

  • How easily can employees request accommodations under the ADA, PWFA, or Title VII?
  • After submitting a request, are employees regularly informed about their rights, timelines, and next steps?
  • Are managers trained to recognize when an employee might need accommodations? 


Improving communication channels and methods will create clear, accessible resources to ensure employees feel supported and protected. In addition, it will ensure that organizations operate compliantly and implement a system of record that protects both the employee and the organization. Not sure how to set up a system of record for accommodations? Contact Disclo for more information.

Ensuring Compliance with ADA, PWFA, and Title VII: The Time to Act is Now

As the fiscal year-end approaches, conducting a comprehensive audit of your workplace accommodations is critical for avoiding legal risks, ensuring compliance, and promoting an inclusive company culture. With overlapping and rapidly evolving requirements from the ADA, PWFA, and Title VII, your internal accommodations audit must be thorough and aligned with the latest legal standards.

Final Thoughts: Take Action Now

Don’t wait until it's too late. Conducting an internal accommodations audit now ensures you’re ready for the challenges and regulatory developments of 2025. This audit will help you identify gaps, reduce risks, and create a more inclusive, compliant workplace. By addressing accessibility issues and streamlining your accommodation process, you’ll be prepared to support your employees fully and avoid costly legal missteps.

Ready to get started? 

Get step-by-step guidance on evaluating your company’s internal accommodations processes with our template.

Fill out the form below to download the full Internal Accommodations Audit Template.

Curious to see how accommodations can support your employees?

Schedule a free demo today.
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