Federal agencies face real operational demands. Federal employees faced with medical conditions want to contribute and thrive.

The interactive process is the bridge between those goals.

When agencies act promptly and in good faith to explore reasonable accommodations, they reduce risk, protect mission readiness, and help employees perform successfully. When the process is skipped or delayed, however, organizations can miss out on practical solutions and expose themselves to avoidable disputes.

What is a reasonable accommodation?

In simple terms, reasonable accommodations are any modification to an employee’s job that allows that employee to perform their essential job functions.

Agencies are not required to provide reasonable accommodation when doing so would present undue hardship. This determination must be made on a case-by-case basis.

What the interactive process is—and when it starts

The interactive process is a collaborative, individualized dialogue between an employer and an employee to identify and evaluate reasonable accommodations that enable the employee to perform essential job functions, absent undue hardship. It is triggered when the agency becomes aware—through any reliable means—that an employee may need accommodation due to medical conditions.

No special phrasing is required to start the conversation. Once an employer becomes aware that an employee may need accommodation because of medical condition, it has a duty to engage in an interactive process to identify and evaluate potential accommodations. An agency must provide reasonable accommodations for a qualified employee with a disability unless doing so imposes an undue hardship.

No “magic words” are required to trigger the accommodation process when management has notice that a medical condition is the employee’s ability to perform the job and assistance may be needed.

Why it matters

Engaging in the interactive process is not just a box to check. It is how agencies find effective, mission‑compatible solutions, and how employees receive a fair opportunity to meet performance expectations. Federal courts have recognized that bypassing this process can deprive both sides of the chance to identify workable accommodations. When a failure to engage in the interactive process results in the loss of an opportunity to identify effective accommodation, that failure may violate the Rehabilitation Act.

EEOC guidance emphasizes that both employer and employee must participate in good faith, share relevant information, and consider options rather than assume none exist. The EEOC has long held that both employer and employee must participate in good faith in the accommodation process and that an employer may not ignore known limitations or assume no accommodation is available.

Tully Rinckey can guide you through every step.

The interactive process works best when it is timely, structured, and well documented. Tully Rinckey helps federal agencies build compliant, mission‑aligned accommodation programs and represents employees seeking effective accommodations that enable them to perform and advance.

Whether you need to design a defensible process, navigate a complex medical restriction, or address a pending dispute, our team brings deep federal employment experience and a solutions‑first approach grounded in the principles recognized by federal courts and the EEOC. Employers and employees share responsibility to participate in good faith and explore workable accommodations rather than assume none exists.

Federal employment is subject to laws and regulations that differ significantly from those in the private sector; consulting with a federal employment lawyer can make all the difference. Tully Rinckey’s team of dedicated federal employment attorneys is available to assist you today. Please call 8885294543 to schedule a consultation, or schedule a consultation online.

Roger Locklear is a Senior Associate with extensive experience in reasonable accommodation and the interactive process. As former Agency Counsel for the Department of Defense and a Reasonable Accommodation Officer for the Department of the Navy, he advised on accommodation requests, Rehabilitation Act compliance, and complex federal employment matters. He now represents federal employees and advises agencies on workplace accommodation and employment law issues.