Are You Prepared for a Rise in Mental Health Accommodation Requests?

Mental health is the No. 1 reason for workplace accommodations, holding steady in that spot for the third year in a row, according to a new survey of 1,200 HR professionals by AbsenceSoft, an absence management software company. 

Research from the National Institute of Mental Health shows 1 in 5 U.S. adults will experience a mental illness this year, so it is likely some of those individuals will be members of your workforce.

This article addresses how you can support these employees during mental health challenges and shares leading practices to consider when handling these accommodation requests.

Behind the Rise

According to Deb Smolensky, the vitality and well-being solutions global practice leader at workforce advisory firm NFP, the rise in mental health accommodation requests reflects a fundamental shift in today’s workforce.

“Mental health challenges are no longer isolated — they’re part of everyday work life,” she said.

Smolensky noted the increase is driven by a convergence of forces: reduced stigma around mental health, greater self-awareness and the realities of modern work, where constant connectivity and sustained cognitive load can amplify burnout symptoms.

“Most mental health accommodations are far more doable — and impactful — than employers expect,” she said. “When requests are recognized early and met with curiosity and care, the process becomes collaborative and effective. The goal is simple: Help people do their best work by adjusting the environment or expectations — not changing the person.”

Leading Practices

With the increase in mental health accommodation requests, organizations should consider ways to assess their policies and processes to increase the likelihood that they are prepared to respond efficiently and compliantly. 

“Mistakes often occur because leadership does not understand they need to bring HR into the conversation to trigger the interactive process,” said Rocio Blanco Garcia, a shareholder at the Littler Mendelson employment law firm.

For instance, applying policies equally across the board is typically recommended in other settings, but Blanco Garcia explained the Americans with Disabilities Act (ADA) considers exceptions to policy and requirements when it is reasonable to accommodate an employee with one or more disabilities recognized under the ADA. The ADA defines a psychiatric disability as a physical or mental impairment that substantially limits one or more major life activities. When job applicants or employees have a mental health condition that meets this criteria, they have workplace rights under the ADA.

Employers also should avoid prematurely ending the interactive process, she said, noting, for example, an employer could open themselves up to liability if they stop working with an employee before offering a role change as a possible accommodation.

“Employers should remain flexible and look for creative ways to help their employees perform the essential functions of their roles,” Blanco Garcia said.

As you review mental health accommodation requests, James Paul, co-chair of the disability access practice group at the Ogletree Deakins law firm, shared the following considerations for employers:

• Quickly acknowledge receipt of the accommodation request and start the dialogue, which becomes the legally required interactive process.
• Provide an approved medical certification form that the mental health provider can complete, answering questions tailored to mental impairments rather than physical impairments.
• Consider unpaid leave as a reasonable accommodation even if the employee is ineligible for leave under your policies or has exhausted paid and/or unpaid leave time.
• Document the process, decisions, timing and implementation steps.
• Continue to enforce job-related, business-necessary conduct and performance standards and requirements, while considering prospective accommodations to enable future compliance (although you may have to retroactively forgive or unwind discipline later).
• Train supervisors on how to recognize accommodation requests, maintain confidentiality and route matters to HR promptly.
• Always start with the employee’s suggestions and requests but also consider external resources such as the Job Accommodation Network (JAN).

Employers also should avoid the following, Paul added:

• Do not use stereotypes or engage in speculation regarding what symptoms or problems the employee’s mental health condition might pose in the workplace.
• Never disclose an employee’s mental health condition(s) to coworkers or anyone other than the very few managers who have a legitimate need to know to facilitate the interactive process and implement an accommodation.
• Avoid requiring the employee to be “100% healed or symptom-free” or “having no restrictions” before returning them to work if they can still perform the essential job functions with or without reasonable accommodation.
• While you need not excuse past misconduct, also don’t ignore a request for accommodation that could provide an excuse or exemption from such conduct rules in the future.
• Be careful not to deny leave or flexible scheduling right out of the gate. Instead, evaluate whether leave, altered start times or intermittent time off might be a reasonable accommodation that does not impose an undue hardship on the operations.
• Avoid refusing to continue discussing alternatives with the employee just because the employee’s preferred accommodation isn’t feasible. You should be creative and identify and offer an effective alternative if one exists.
• Never allow retaliation against employees for requesting accommodations or asserting their rights under the ADA, even if their requests are ultimately rejected or unreasonable.

Examples of Accommodations

Under the ADA and other nondiscrimination laws, most employers must provide “reasonable accommodations” to qualified employees with disabilities. For employees with mental health conditions, these accommodations might include:

• Opportunities to work from home
• Flexible scheduling (e.g., different start times and break schedules)
• Flexible use of paid leave to cover mental health appointments
• Addition of room dividers to reduce noise or visual distractions
• Allowing music (with headset) to block out distractions
• Utilization of tape recorders for recording/reviewing meetings and training sessions
• Modification or removal of nonessential job duties or restructuring of the job to include only the essential job functions
• Adjusting management styles

“It is undeniable that the pandemic significantly changed work culture and what employees expect from their employers, including flexible schedules and remote work,” Littler Mendelson’s Blanco Garcia said. “With many companies pushing for a return to in-office work, we are also seeing an increase in requests for remote work accommodations to manage mental health conditions.”

Editor’s Note: Additional Content

For more information and resources related to this article, see the pages below, which offer quick access to all WorldatWork content on these topics:

• Employee Benefits
• Well-Being