Providing reasonable accommodation in recruitment and hiring: A guide for supervisors

Who Is Considered Qualified for a Job 

An applicant with a disability or pregnancy-related limitation is considered qualified if they: 

• Meet the employer’s basic job requirements, such as education, experience, skills, certifications, or licenses; and 

• Can perform the essential functions of the job—the fundamental duties of the position—with or without a reasonable accommodation. 

Employers are not required to provide reasonable accommodations that would cause undue hardship, meaning significant difficulty, disruption, or expense, or for disability related requests, posing a direct threat.  However, an employer may not refuse to hire an otherwise qualified applicant simply because a reasonable accommodation is needed. 

Reasonable Accommodations in the Hiring Process 

Employers must provide reasonable accommodations to ensure applicants with disabilities and pregnancy-related limitations have an equal opportunity to apply for and compete for jobs. This includes accommodations needed during: 

• Job applications 

• Interviews 

• Testing or assessments 

• Other parts of the recruitment and hiring process 

Examples of Reasonable Accommodations 

Examples may include, but are not limited to: 

• Providing application or interview materials in accessible formats (e.g., large print, or electronic formats) 

• Providing sign language interpreters or other communication supports 

• Conducting interviews in accessible locations 

• Adjusting interview procedures (e.g., providing questions in advance and/or in writing) 

• Adjusting interview schedules 

• Allowing remote interviews 

These examples are for informational purposes only. Reasonable accommodations are determined on a case-by-case basis. 

Applicants are encouraged to request accommodations as soon as they know they are needed, since employers usually need advance notice to arrange them. 

Limits on Employer Questions During Hiring Interview questions must focus on an applicant’s qualifications, education, skills, and ability to perform the job.  

Before a job offer is made, employers may not ask applicants, former employers, or others, questions that are likely to reveal: 

• A disability 

• A medical condition 

• Pregnancy or pregnancy-related limitations 

This restriction applies to verbal questions, written applications, interviews, and pre-employment testing. Employers also cannot require medical examinations before making a job offer.  

An employer may ask all applicants whether they need a reasonable accommodations for the hiring process itself, as long as the question is asked consistently of everyone. 

Question Examples Employers May Ask ​     ​ 

• What education, skills, and training do you have for this position?  

• What experience do you bring to this role? 

• What certifications or licenses do you hold? 

• Can you meet the physical requirements of the job? 

• How would you perform specific job tasks? (If asked, this must be asked of all applicants.) 

• What is your work history? Why did you leave your last position? 

• Can you meet the attendance and scheduling requirements of the job? 

• Are you able to perform the essential job functions with or without reasonable accommodation? 

• Can you perform all required job functions listed here, with or without reasonable accommodation? 

• • Employers should provide a detailed list of job functions. 

• • If an applicant indicates they can perform the functions with a reasonable accommodation, the employer may ask how the tasks would be performed and what reasonable accommodation is needed. 

Question Examples Employers May ​Not​ Ask ​     ​ 

• Do you have any medical conditions or disabilities that could affect your work? 

• Have you ever been treated for mental health issues? 

• Are you pregnant? 

• Will you need time off for childbirth or medical appointments? 

• Do you have childcare arrangements? 

• What medications do you take? 

• How did you become disabled? Why do you use a wheelchair? 

• How many sick days did you take at your last job? 

• Will you need medical leave? 

• Have you ever filed for workers’ compensation? 

• Is there any health reason you may not be able to perform this job? 

Limited Question Exception for Obvious or Voluntarily Disclosed Disabilities 

If a disability is obvious (for example, the applicant uses a wheelchair) or the applicant voluntarily discloses a condition, and it is reasonable to believe the condition may affect the performance of a specific job task, the employer may only ask: 

• Whether the applicant will need a reasonable accommodation to perform that task. 

    If the applicant says no, no further questions may be asked. 

    If the applicant says yes, the employer may ask about the type of reasonable accommodation needed, but  not  about the underlying condition. 

The employer may also ask the applicant to describe or demonstrate how they would perform the task, even if other applicants are not asked to do so. 

If a post-offer medical exam reveals a disability, an employer may not withdraw the job offer simply because of the disability. A job offer may only be withdrawn if the employer can demonstrate that: 

• The individual cannot perform the essential job functions, even with reasonable accommodation;  or 

• For disability-related requests, the individual would pose a direct threat. 

Divisions must consult the EDR Office before rescinding a job offer under these circumstances.