Reasonable Accommodation in Wellness
Employees with disabilities who cannot participate in a wellness program activity must be offered a reasonable alternative standard — an alternative way to earn the wellness incentive. The alternative must be reasonably designed to promote health, must not be overly burdensome, and must be available to all employees who request it.
The Interactive Process
When an employee requests a reasonable accommodation, the employer must engage in the interactive process — a good-faith dialogue to identify an appropriate accommodation. The employer cannot simply deny the request without engaging in the process. Document all steps in the interactive process.
Undue Hardship
Compliance Note
Employers are not required to provide accommodations that impose an undue hardship — significant difficulty or expense. Undue hardship is determined based on the employer's size, financial resources, and the nature of the accommodation. The undue hardship standard is high — most reasonable accommodations do not impose undue hardship. Document the undue hardship analysis if you deny an accommodation request.