COVID-19

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 received 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.

Accommodations:

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 with exertion

  • Provide an alternative mask
  • Allow removal of mask when appropriate
  • Reduce physical exertion
  • Allow rest breaks
  • Reduce workplace triggers, if any
  • 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

Extreme fatigue

  • Allow rest breaks
  • Provide an ergonomic workstation
  • Allow a flexible schedule
  • Restructure the job to remove marginal job functions
  • Allow telework

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 check lists
  • 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

Insomnia

  • Allow rest breaks to take quick naps
  • Allow a flexible schedule
  • Keep the workstation temperature on the cool side
  • Allow cold drinks at the workstation
  • Allow telework

Tachycardia (fast heart rate)

  • Allow rest breaks
  • Control the workstation temperature
  • Provide an ergonomic workstation
  • Allow drinks at the workstation
  • Allow time off for treatment
  • Develop a plan of action to deal with sudden exacerbations
  • Allow telework

Joint pain/body aches

  • Allow rest breaks
  • Reduce the physical demands of the job
  • Provide an ergonomic workstation
  • Allow a flexible schedule
  • Restructure the job to remove marginal job functions
  • Allow telework

Headaches

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