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15
min read
Published on
February 18, 2026

When Bundling Accommodations With Your TPA Isn’t Working: Why “Standalone” Can Be the Most Practical Upgrade You Make

Updated on
February 18, 2026

Table of contents

A lot of HR and Leave leaders start in the same place: “We already have a TPA. Why not just bundle accommodations with them too?”

On paper, it makes sense. One vendor. One contract. One place for leave and job-related adjustments. In reality, accommodations are often the first workflow to break when you try to force-fit it into a leave-centric operating model—especially when your workforce is distributed, requests are getting more complex, and managers are increasingly the front door for disclosure.

Here’s the core idea: leave is a time-away decision; accommodations are a work-design decision. When those two are treated as the same workflow, you can end up with a process that is slow, inconsistent, risky, and deeply frustrating for employees and the people teams trying to do the right thing.

Keep reading to learn why standalone accommodations solutions can be the most effective path forward when bundling isn’t delivering—and what “good” looks like when you separate the function.

The real-world signs bundling isn’t working

If any of these sound familiar, you’re not alone:

1) Your accommodation process is “email + PDFs + heroics.” Even with a TPA in the mix, many organizations still run accommodations through inboxes, attachments, manager-side conversations, and undocumented calls. That’s not a process—it’s a memory test.

2) Cases stall because the workflow is built for leave, not iterative dialogue. The ADA interactive process (and parallel state requirements) is inherently iterative: explore limitations, consider options, document the reasoning, revisit as circumstances change. A leave-first workflow is optimized for eligibility + dates + certification. That mismatch creates friction.

3) Similar cases get different outcomes depending on who reviews them. Inconsistency isn’t just an operational problem; it becomes a compliance risk and a trust problem.

4) Managers are involved—but untrained and unsupported. Cornell’s ILR School notes that employees are at least 60% more likely to disclose a disability to their supervisor than to HR. If your accommodations “system” doesn’t meaningfully support managers (and capture what happens in those moments), the workflow is already leaking at the top.

5) You can’t confidently answer basic questions. “How many requests do we have?” “What’s our average time to resolution?” “Which sites or departments are most impacted?” “Are we consistently documenting undue hardship analyses?” If you can’t answer quickly, you’re operating without clear visibility.

Why TPAs struggle here (even great TPAs)

This isn’t a knock on TPAs. It’s about what they’re built to do. Most TPAs are optimized around:

  • Eligibility determinations (FMLA, STD, state leaves)
  • Certification collection and deadlines
  • Claims administration
  • High-volume, rules-based workflows

Accommodations are different:

  • They’re individualized by role, team, and environment
  • They require collaboration with managers and business leaders
  • They involve ongoing adjustments (not a single “approve/deny” moment)
  • They demand defensible documentation of reasoning (not just paperwork)

Even when a TPA offers “accommodations,” it’s often bolted onto a leave engine. The result can be a workflow that’s technically “covered,” but practically fragile.

The environment changed—and the old model is cracking

Three trends are converging:

1) Volume is rising

AbsenceSoft’s 2024 forecast report found 75% of employers said accommodation requests increased in the past year, and among those seeing increases, 74% reported handling 20%+ more requests than the prior year.

2) Complexity is rising

Mental health, remote work, pregnancy-related needs, religious accommodations, and chronic conditions often require nuance, back-and-forth, and strong documentation. You can’t “form letter” your way through that.

3) Risk is rising

The EEOC received 88,531 new charges of discrimination in FY 2024, a 9%+ increase over FY 2023. More charges don’t automatically mean “more employer wrongdoing,” but they do mean more scrutiny, more claims activity, and more reason to run high-integrity processes.

The myth that keeps companies stuck: “Accommodations are expensive anyway”

This belief drives two bad outcomes:

  1. Leaders avoid investing in infrastructure because they assume the accommodations themselves are cost-prohibitive, and
  2. HR teams are forced to ration time, attention, and consistency.

But the data consistently shows accommodations are often low-cost.

The U.S. Department of Labor highlighted research showing nearly half of accommodations can be implemented at no cost, and when there is a one-time cost, the median is $300.

JAN also summarizes employer-reported accommodation costs and emphasizes that many are low-cost while delivering meaningful retention/productivity benefits.

In other words: the expensive part is usually not the accommodation. It’s the administrative drag and the risk created by inconsistency.

What a “standalone accommodations” tool actually unlocks

A standalone accommodations solution is not just “another tool.” It’s a different operating model—one that treats accommodations as a core people system, not a sub-feature of leave.

1) A real interactive process engine (not an inbox)

Standalone systems are built around:

  • Capturing requests from employees (and managers) cleanly
  • Prompting for the right information at the right time
  • Tracking dialogue and decisions
  • Documenting alternative options considered
  • Managing timelines and follow-ups

That structure matters because it turns “good intentions” into repeatable practice.

2) Defensible documentation, without extra admin work

When something goes wrong, what protects you isn’t that you meant well. It’s that you can show you:

  • Engaged in the interactive process
  • Evaluated options
  • Communicated clearly
  • Made decisions consistently
  • Documented your rationale

Standalone solutions are designed to produce an audit trail as a byproduct of doing the work—not as a second job.

3) Better manager enablement (where disclosure actually happens)

If managers are where disclosure starts (and Cornell suggests it often is), your system has to support them with:

  • Guided intake
  • What to say / what not to say
  • Escalation paths
  • Documentation that doesn’t live in Slack texts and memory

A leave-centric model rarely solves that.

4) Clean separation of PHI, privacy, and “need-to-know”

One of the hidden risks in bundled, informal processes is PHI sprawl: medical documents forwarded around, stored in the wrong system, or shared too broadly. Standalone accommodations infrastructure tends to be intentionally designed to limit access and standardize what decision-makers see.

5) Analytics that actually help you run the program

This is where standalone really pays off. You can answer:

  • Request volume trends by month
  • Time-to-resolution
  • Common accommodation types
  • Hotspots by site/department/role
  • Outcomes and consistency indicators
  • Manager bottlenecks
  • Training gaps

If you’re trying to run a modern people function, this becomes operational intelligence, not a “nice to have.”

The “split brain” problem: why combining leave + accommodations can create worse outcomes

When accommodations are bundled into your leave operation, you can end up with two competing incentives:

  • Leave operations optimize for throughput, standardization, and closed cases
  • Accommodations require dialogue, flexibility, and individualized solutions

If your system is optimized for closure, it can unintentionally push toward premature decisions, especially for non-obvious needs (mental health, neurodiversity, chronic illness) where the best solution often emerges through iteration.

Standalone accommodations is, in many ways, the decision to prioritize correctness and defensibility over speed-throughput at all costs.

So when should you move to standalone?

Consider it when:

  • Your accommodation caseload is rising (and it probably is)
  • mental health/remote work complexity is creating inconsistency
  • You have multi-state or global footprint complexity
  • You’ve had escalation events: employee relations issues, legal threats, EEOC activity
  • Your managers are overwhelmed and improvising
  • You can’t produce reliable reporting quickly
  • Your team is spending too much time chasing paperwork rather than solving the work-design problem

A practical path forward (without blowing up your vendor ecosystem)

Standalone doesn’t have to mean “rip and replace everything.” A sane approach often looks like:

  1. Keep your TPA for leave administration
  2. Implement standalone accommodations as the system of record for accommodation requests and Interactive Process documentation
  3. Create clear handoffs where leave and accommodations intersect (e.g., return-to-work, restrictions, transitional duty, intermittent leave + job modifications)
  4. Train managers with lightweight, repeated enablement tied to the workflow—because that’s where disclosure starts

The outcome: your TPA can stay great at what it does, and your accommodations program becomes something you can actually run, measure, and defend.

The bottom line

If bundling accommodations with your TPA isn’t working (it’s OK if that’s the case), it’s rarely because your team isn’t trying hard enough. It’s because you’re asking a leave-optimized system to run a workflow that is fundamentally different.

Standalone accommodations solutions work when they turn accommodations into a:

  • Consistent process
  • Defensible record
  • Manageable program
  • Better experience for employees and managers

And when accommodations are increasingly high-volume , increasingly scrutinized , and often low-cost to implement in practice —the most expensive option is usually staying stuck in the broken middle.

If you’re ready to explore a standalone accommodations platform for your organization, let’s chat.

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When Bundling Accommodations With Your TPA Isn’t Working: Why “Standalone” Can Be the Most Practical Upgrade You Make

Learn why standalone accommodations solutions can be the most effective path forward when bundling isn’t delivering—and what “good” looks like when you separate the function.

Team Disclo
February 19, 2026

A lot of HR and Leave leaders start in the same place: “We already have a TPA. Why not just bundle accommodations with them too?”

On paper, it makes sense. One vendor. One contract. One place for leave and job-related adjustments. In reality, accommodations are often the first workflow to break when you try to force-fit it into a leave-centric operating model—especially when your workforce is distributed, requests are getting more complex, and managers are increasingly the front door for disclosure.

Here’s the core idea: leave is a time-away decision; accommodations are a work-design decision. When those two are treated as the same workflow, you can end up with a process that is slow, inconsistent, risky, and deeply frustrating for employees and the people teams trying to do the right thing.

Keep reading to learn why standalone accommodations solutions can be the most effective path forward when bundling isn’t delivering—and what “good” looks like when you separate the function.

The real-world signs bundling isn’t working

If any of these sound familiar, you’re not alone:

1) Your accommodation process is “email + PDFs + heroics.” Even with a TPA in the mix, many organizations still run accommodations through inboxes, attachments, manager-side conversations, and undocumented calls. That’s not a process—it’s a memory test.

2) Cases stall because the workflow is built for leave, not iterative dialogue. The ADA interactive process (and parallel state requirements) is inherently iterative: explore limitations, consider options, document the reasoning, revisit as circumstances change. A leave-first workflow is optimized for eligibility + dates + certification. That mismatch creates friction.

3) Similar cases get different outcomes depending on who reviews them. Inconsistency isn’t just an operational problem; it becomes a compliance risk and a trust problem.

4) Managers are involved—but untrained and unsupported. Cornell’s ILR School notes that employees are at least 60% more likely to disclose a disability to their supervisor than to HR. If your accommodations “system” doesn’t meaningfully support managers (and capture what happens in those moments), the workflow is already leaking at the top.

5) You can’t confidently answer basic questions. “How many requests do we have?” “What’s our average time to resolution?” “Which sites or departments are most impacted?” “Are we consistently documenting undue hardship analyses?” If you can’t answer quickly, you’re operating without clear visibility.

Why TPAs struggle here (even great TPAs)

This isn’t a knock on TPAs. It’s about what they’re built to do. Most TPAs are optimized around:

  • Eligibility determinations (FMLA, STD, state leaves)
  • Certification collection and deadlines
  • Claims administration
  • High-volume, rules-based workflows

Accommodations are different:

  • They’re individualized by role, team, and environment
  • They require collaboration with managers and business leaders
  • They involve ongoing adjustments (not a single “approve/deny” moment)
  • They demand defensible documentation of reasoning (not just paperwork)

Even when a TPA offers “accommodations,” it’s often bolted onto a leave engine. The result can be a workflow that’s technically “covered,” but practically fragile.

The environment changed—and the old model is cracking

Three trends are converging:

1) Volume is rising

AbsenceSoft’s 2024 forecast report found 75% of employers said accommodation requests increased in the past year, and among those seeing increases, 74% reported handling 20%+ more requests than the prior year.

2) Complexity is rising

Mental health, remote work, pregnancy-related needs, religious accommodations, and chronic conditions often require nuance, back-and-forth, and strong documentation. You can’t “form letter” your way through that.

3) Risk is rising

The EEOC received 88,531 new charges of discrimination in FY 2024, a 9%+ increase over FY 2023. More charges don’t automatically mean “more employer wrongdoing,” but they do mean more scrutiny, more claims activity, and more reason to run high-integrity processes.

The myth that keeps companies stuck: “Accommodations are expensive anyway”

This belief drives two bad outcomes:

  1. Leaders avoid investing in infrastructure because they assume the accommodations themselves are cost-prohibitive, and
  2. HR teams are forced to ration time, attention, and consistency.

But the data consistently shows accommodations are often low-cost.

The U.S. Department of Labor highlighted research showing nearly half of accommodations can be implemented at no cost, and when there is a one-time cost, the median is $300.

JAN also summarizes employer-reported accommodation costs and emphasizes that many are low-cost while delivering meaningful retention/productivity benefits.

In other words: the expensive part is usually not the accommodation. It’s the administrative drag and the risk created by inconsistency.

What a “standalone accommodations” tool actually unlocks

A standalone accommodations solution is not just “another tool.” It’s a different operating model—one that treats accommodations as a core people system, not a sub-feature of leave.

1) A real interactive process engine (not an inbox)

Standalone systems are built around:

  • Capturing requests from employees (and managers) cleanly
  • Prompting for the right information at the right time
  • Tracking dialogue and decisions
  • Documenting alternative options considered
  • Managing timelines and follow-ups

That structure matters because it turns “good intentions” into repeatable practice.

2) Defensible documentation, without extra admin work

When something goes wrong, what protects you isn’t that you meant well. It’s that you can show you:

  • Engaged in the interactive process
  • Evaluated options
  • Communicated clearly
  • Made decisions consistently
  • Documented your rationale

Standalone solutions are designed to produce an audit trail as a byproduct of doing the work—not as a second job.

3) Better manager enablement (where disclosure actually happens)

If managers are where disclosure starts (and Cornell suggests it often is), your system has to support them with:

  • Guided intake
  • What to say / what not to say
  • Escalation paths
  • Documentation that doesn’t live in Slack texts and memory

A leave-centric model rarely solves that.

4) Clean separation of PHI, privacy, and “need-to-know”

One of the hidden risks in bundled, informal processes is PHI sprawl: medical documents forwarded around, stored in the wrong system, or shared too broadly. Standalone accommodations infrastructure tends to be intentionally designed to limit access and standardize what decision-makers see.

5) Analytics that actually help you run the program

This is where standalone really pays off. You can answer:

  • Request volume trends by month
  • Time-to-resolution
  • Common accommodation types
  • Hotspots by site/department/role
  • Outcomes and consistency indicators
  • Manager bottlenecks
  • Training gaps

If you’re trying to run a modern people function, this becomes operational intelligence, not a “nice to have.”

The “split brain” problem: why combining leave + accommodations can create worse outcomes

When accommodations are bundled into your leave operation, you can end up with two competing incentives:

  • Leave operations optimize for throughput, standardization, and closed cases
  • Accommodations require dialogue, flexibility, and individualized solutions

If your system is optimized for closure, it can unintentionally push toward premature decisions, especially for non-obvious needs (mental health, neurodiversity, chronic illness) where the best solution often emerges through iteration.

Standalone accommodations is, in many ways, the decision to prioritize correctness and defensibility over speed-throughput at all costs.

So when should you move to standalone?

Consider it when:

  • Your accommodation caseload is rising (and it probably is)
  • mental health/remote work complexity is creating inconsistency
  • You have multi-state or global footprint complexity
  • You’ve had escalation events: employee relations issues, legal threats, EEOC activity
  • Your managers are overwhelmed and improvising
  • You can’t produce reliable reporting quickly
  • Your team is spending too much time chasing paperwork rather than solving the work-design problem

A practical path forward (without blowing up your vendor ecosystem)

Standalone doesn’t have to mean “rip and replace everything.” A sane approach often looks like:

  1. Keep your TPA for leave administration
  2. Implement standalone accommodations as the system of record for accommodation requests and Interactive Process documentation
  3. Create clear handoffs where leave and accommodations intersect (e.g., return-to-work, restrictions, transitional duty, intermittent leave + job modifications)
  4. Train managers with lightweight, repeated enablement tied to the workflow—because that’s where disclosure starts

The outcome: your TPA can stay great at what it does, and your accommodations program becomes something you can actually run, measure, and defend.

The bottom line

If bundling accommodations with your TPA isn’t working (it’s OK if that’s the case), it’s rarely because your team isn’t trying hard enough. It’s because you’re asking a leave-optimized system to run a workflow that is fundamentally different.

Standalone accommodations solutions work when they turn accommodations into a:

  • Consistent process
  • Defensible record
  • Manageable program
  • Better experience for employees and managers

And when accommodations are increasingly high-volume , increasingly scrutinized , and often low-cost to implement in practice —the most expensive option is usually staying stuck in the broken middle.

If you’re ready to explore a standalone accommodations platform for your organization, let’s chat.

Curious to see how accommodations can support your employees?

Schedule a free demo today.
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