Open enrollment puts employees in a “benefits mindset.” That’s exactly when many realize they also need workplace accommodations — and they’ll ask for them. Under the ADA and PWFA, those requests are legal rights, not optional perks, and they can be made any time, not just during OE. For HR teams, that means your accommodations playbook should be live and ready before benefits emails start flying.
Bottom line: when employees are thinking about health and benefits, they’re more likely to initiate the (legally required) interactive process with HR — even in plain English and even if they don’t say “ADA.”
Mistake 1: Treating accommodations like benefits.
Accommodations are a legal obligation under ADA Title I, distinct from voluntary benefits, and they apply across the employment lifecycle—including access to benefits/privileges.
Mistake 2: Requiring a special form or “magic words.”
A verbal “I’m having trouble because of [condition]” is enough to trigger your process. Don’t wait for paperwork to begin engaging.
Mistake 3: Waiting until after OE to respond.
EEOC guidance is explicit: act expeditiously; unnecessary delays can violate the ADA.
Mistake 4: Pushing employees to use PTO/leave instead of discussing adjustments.
Leave can be a reasonable accommodation, but employers may offer another effective accommodation that keeps the employee working; you can’t ignore workable alternatives.
Mistake 5: Storing medical info with benefits files.
ADA requires medical information to be confidential and kept in separate medical files with limited access.
Need a workplace adjustment? If a health condition, pregnancy, or disability is making work harder, you can request a reasonable accommodation at any time. It’s separate from benefits enrollment, and your medical info stays confidential. [Link to your internal accommodations page/process.]
Open enrollment puts employees in a “benefits mindset.” That’s exactly when many realize they also need workplace accommodations — and they’ll ask for them. Under the ADA and PWFA, those requests are legal rights, not optional perks, and they can be made any time, not just during OE. For HR teams, that means your accommodations playbook should be live and ready before benefits emails start flying.
Bottom line: when employees are thinking about health and benefits, they’re more likely to initiate the (legally required) interactive process with HR — even in plain English and even if they don’t say “ADA.”
Mistake 1: Treating accommodations like benefits.
Accommodations are a legal obligation under ADA Title I, distinct from voluntary benefits, and they apply across the employment lifecycle—including access to benefits/privileges.
Mistake 2: Requiring a special form or “magic words.”
A verbal “I’m having trouble because of [condition]” is enough to trigger your process. Don’t wait for paperwork to begin engaging.
Mistake 3: Waiting until after OE to respond.
EEOC guidance is explicit: act expeditiously; unnecessary delays can violate the ADA.
Mistake 4: Pushing employees to use PTO/leave instead of discussing adjustments.
Leave can be a reasonable accommodation, but employers may offer another effective accommodation that keeps the employee working; you can’t ignore workable alternatives.
Mistake 5: Storing medical info with benefits files.
ADA requires medical information to be confidential and kept in separate medical files with limited access.
Need a workplace adjustment? If a health condition, pregnancy, or disability is making work harder, you can request a reasonable accommodation at any time. It’s separate from benefits enrollment, and your medical info stays confidential. [Link to your internal accommodations page/process.]
