Employers across the United States are receiving accommodation requests from employees who currently have COVID-19 or who have recovered from COVID-19 but have long-term effects. As a result, JAN receives questions about whether COVID-19 is a disability under the Americans with Disabilities Act (ADA) and what accommodations might be provided.

COVID-19 as a disability under the ADA:  

It is possible that a person with COVID-19 or its long-term effects could meet the definition of disability under the ADA. Employers who receive requests for accommodations from employees with COVID-19 or its long-term effects can use the process laid out in the ADA to determine whether they are required to provide accommodations based on an employee’s current limitations. This determination should be made on a case-by-case basis. Employers can also consider providing temporary accommodations without determining whether an employee has a disability under the ADA until more is known.

For more information about COVID-19 as a disability, see What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws, section N.


Accommodations can vary depending on the specific limitations an employee has as well as the job duties and work environment, but the ideas below can serve as a starting point for exploring accommodation ideas. For more specific ideas, contact JAN.

Employees who currently have COVID-19 typically need leave or may ask to telework if they are able to continue working.

Employees who have recovered from COVID-19 may be able to safely return to the workplace, but may have long-term limitations such as shortness of breath with exertion, extreme fatigue, brain fog, insomnia, tachycardia, joint pain/body ache, and headaches.

Here are some accommodation ideas to explore for each of these limitations:

Shortness of breath or difficulty breathing

  • Provide an alternative mask
  • Allow removal of mask when appropriate
  • Reduce the physical demands of the job
  • Allow rest breaks
  • Reduce workplace triggers
  • Allow time for medical treatment such as use of a nebulizer or inhaler
  • Restructure the job to remove marginal job functions
  • Develop a plan of action to deal with sudden exacerbations
  • Allow telework
  • Allow leave for treatment

Tiredness or fatigue

Difficulty thinking or concentrating (sometimes called "brain fog")

  • Provide a quiet workspace
  • Allow use of noise cancellation or white noise
  • Provide uninterrupted work time
  • Provide memory aids such as flowcharts and checklists
  • Allow the use of apps for concentration, memory, and organization
  • Allow rest breaks
  • Restructure the job to remove marginal functions to allow focus on essential job duties
  • Allow telework

Depression or anxiety


Fast-beating or pounding heart (known as heart palpitations)

Joint or muscle pain


Additional accommodation ideas are available at JAN’s A-Z by Limitation or by contacting JAN for one-on-one consultation.