A veteran forklift operator at a distribution center stops showing up for work.
After three days of silence, the company's policy is clear: no-call, no-show equals job abandonment. The termination is processed.
Two weeks later, a letter from an attorney arrives. The employee was hospitalized with a complication related to a known disability. The company never asked. The employee never told. The process never connected.
The company didn't make a bad decision. They made no decision at all. The conversation never happened.
Most employers believe that ADA compliance is about the final decision. Did you grant the accommodation? Did you deny it? Did you document the reason?
That's not what the law requires.
The EEOC's Enforcement Guidance is clear: the ADA requires an "informal, interactive process." The process itself — the conversation — is the compliance.
If you only document the final decision, you've documented the outcome. But you haven't proven the process. And the process is what the EEOC examines when a charge is filed.
The Signal Is Missed
Most ADA accommodations don't start with a formal request. They start with a signal. An employee mentions they're "struggling with the pace." A worker returns from a workers' comp injury with permanent restrictions. An unexplained absence from someone with a known medical condition.
If that signal isn't captured and routed into a structured dialogue, the loop stays open. The employee doesn't know they need to "request" an accommodation. They just know they're struggling.
The Handoff Between Departments Breaks
Safety knows about the injury. HR knows about the medical note. The supervisor knows the worker is struggling to keep up. These three people rarely talk to each other.
The EEOC secured nearly $700 million for victims of discrimination in FY 2024 — the highest in the agency's history. ADA claims made up 43.2% of all merits suits filed. Most of these cases don't involve a bad-faith denial. They involve a failure to communicate.
The "Job Abandonment" Trap
The scenario at the top of this article is one of the most common ADA failures. A company has a neutral attendance policy. An employee stops showing up. The company applies the policy. The employee sues, claiming the company should have known about their disability and engaged in the interactive process before terminating.
The EEOC has consistently held that employers must consider reasonable accommodation before terminating an employee with a known disability — even if the employee hasn't explicitly requested one.
Here's what a closed-loop ADA process looks like:
A worker returns from a back injury with a 15-pound lifting restriction. The restriction is entered into the system. The system flags the impacted essential functions. An interactive process is initiated automatically.
HR contacts the employee. They discuss what the job requires and what the employee can do. The system documents every step: the call, the offer, the response.
The supervisor is notified of the restriction — not the diagnosis — so they can adjust the work assignment safely.
The loop closes when the accommodation is implemented or when the good-faith dialogue reaches a documented conclusion.
The process isn't a file. It's a timeline.
ADA doesn't break at the final decision. It breaks during the conversation.
The conversation is a series of handoffs. The employee signals a need. The employer receives it. The employer responds. The employee responds back. Each step is a handoff. Each handoff is a place where the process can stall.
If the process stalls, the loop stays open. An open loop is where litigation lives.
InfraNet HR is not a document storage system. It's an event-driven platform that manages the interactive process from signal to resolution.
When a medical restriction is entered, InfraNet automatically initiates the ADA dialogue, tracks every step of the conversation, and ensures the handoff between HR, Safety, and the supervisor never breaks.
The system doesn't make the accommodation decision. It makes sure the conversation happens — and that it's documented.
The conversation is the compliance. Don't let it stall.
See how InfraNet HR manages the ADA interactive process from signal to closure.
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Post Summary:
Most ADA failures aren't about the final accommodation decision. They happen during the conversation — when the handoff between departments breaks, deadlines are missed, and the employee is left waiting. Here's where the real risk lives.
SEO Title: ADA Interactive Process Handoff Failures in Manufacturing | InfraNet HR