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Accommodation and Compliance Series:
Employees with Intellectual or Cognitive Disabilities

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JAN’s Accommodation and Compliance Series is designed to help employers determine effective accommodations and comply with Title I of the Americans with Disabilities Act (ADA). Each publication in the series addresses a specific medical condition and provides information about the condition, ADA information, accommodation ideas, and resources for additional information.

The Accommodation and Compliance Series is a starting point in the accommodation process and may not address every situation. Accommodations should be made on a case by case basis, considering each employee’s individual limitations and accommodation needs. Employers are encouraged to contact JAN to discuss specific situations in more detail.

For information on assistive technology and other accommodation ideas, visit JAN's Searchable Online Accommodation Resource (SOAR) at http://AskJAN.org/soar.

Information about Intellectual or Cognitive Impairments

What are intellectual or cognitive impairments?

According to the American Association on Intellectual and Developmental Disabilities, an intellectual disability is a disability that involves significant limitations both in intellectual functioning and in adaptive behavior. Adaptive behaviors include many everyday social and practical skills such as interpersonal and communication skills, social problem solving and responsibility, the use of time and money, as well as daily personal care and safety. Limitations in individuals often coexist with strengths, and will vary from individual to individual. This disability originates before the age of 18 and encompasses a wide range of conditions, types, and levels. Intellectual disability is caused by factors that can be physical, genetic, and/or social.

According to the President's Committee for People with Intellectual Disabilities, an estimated seven to eight million Americans of all ages experience intellectual disability. Intellectual disabilities affect about one in ten families in the United States.

What causes intellectual or cognitive impairments?

Intellectual or cognitive impairments can start anytime before a child reaches the age of 18 years. Persons who have intellectual disabilities may have other impairments as well. Examples of coexisting conditions may include: cerebral palsy, seizure disorders, vision impairment, hearing loss, and attention-deficit/hyperactivity disorder (ADHD). Persons with severe intellectual disabilities are more likely to have additional limitations than persons with milder intellectual disabilities (EEOC, 2011).

Additional Helpful Terminology

Developmental disabilities that may also include an intellectual disability are briefly described below. Intellectual disabilities can also be caused by a head injury, stroke or illness. For some no cause is found. Intellectual disabilities will vary in degree and effect from person to person, just as individual capabilities vary considerably among people who do not have an intellectual disability. People should not make generalizations about the needs of persons with intellectual disabilities. In some instances an intellectual disability will not be obvious from a person's appearance, nor will it be accompanied by a physical disability. Persons with intellectual disabilities successfully perform a wide range of jobs, and can be dependable workers. (EEOC, 2011)

Autism: Individuals with disabilities on the autism spectrum may have complex developmental disabilities that typically appear during the first three years of life. These disabilities are the result of a neurological disorder that affects the normal functioning of the brain, impacting development in the areas of social interaction and communication skills. Both children and adults with disabilities on the autism spectrum typically show difficulties in verbal and non-verbal communication, social interactions, and play or leisure activities. http://www.autism-society.org

Cerebral Palsy is a condition, sometimes thought of as a group of disorders, that can involve brain and nervous system functions such as movement, learning, hearing, seeing, and thinking. Cerebral palsy is caused by injuries or abnormalities of the brain. Most of these problems occur as the baby grows in the womb, but they can happen at any time during the first two years of life, while the baby's brain is still developing. http://www.ncbi.nlm.nih.gov/guide/

Down Syndrome is a genetic disorder that causes lifelong intellectual disabilities, developmental delays and other complications. Down syndrome varies in severity, so developmental problems range from moderate to serious. Down syndrome is the most common genetic cause of severe intellectual disabilities in children. Individuals with Down syndrome have a higher incidence of heart defects, leukemia, sleep apnea, and dementia later in life. http://www.TheArc.org

Fetal Alcohol Syndrome is a condition that results from prenatal alcohol exposure. It is a cluster of mental and physical birth defects that include intellectual disabilities, growth deficits, central nervous system dysfunction, craniofacial abnormalities and behavioral instabilities. Fetal Alcohol Effect is a less severe set of the same symptoms. It is the only form of intellectual disability that can be totally prevented and eradicated. http://www.nofas.org

Fragile X Syndrome is a hereditary condition that can cause learning problems ranging from subtle learning disabilities and a normal IQ, to severe intellectual disabilities and autism. Individuals with Fragile X Syndrome may also have physical and behavioral disorders, and speech and language delays. http://www.fragilex.org/

Prader-Willi Syndrome (PWS) is the most common known genetic cause of life-threatening obesity in children. PWS typically causes low muscle tone, short stature if not treated with growth hormone, and a chronic feeling of hunger that, coupled with a metabolism that utilizes drastically fewer calories than normal, can lead to excessive eating and life-threatening obesity. PWS is also characterized by motor development delays along with some behavior problems and unique medical issues. Intellectual deficits can be present to varying degrees, but even higher functioning individuals will have learning difficulties. http://www.pwsausa.org

Intellectual Disabilities and the Americans with Disabilities Act

Are intellectual disabilities covered under the ADA?

The ADA does not contain a list of medical conditions that constitute disabilities. Instead, the ADA has a general definition of disability that each person must meet on a case by case basis (EEOC Regulations . . . , 2011). A person has a disability if he/she has a physical or mental impairment that substantially limits one or more major life activities, a record of such an impairment, or is regarded as having an impairment (EEOC Regulations . . . , 2011).

However, according to the Equal Employment Opportunity Commission (EEOC), the individualized assessment of virtually all people with an intellectual will result in a determination of disability under the ADA; given its inherent nature, an intellectual disability will almost always be found to substantially limit the major life activity of brain function (EEOC Regulations . . . , 2011).

Accommodating Employees with Intellectual or Cognitive Impairments

Note: People with intellectual or cognitive impairments may have some of the limitations discussed below, but seldom have all of them. Also, the degree of limitation will vary among individuals. Be aware that not all people with intellectual or cognitive impairments will need accommodations to perform their jobs and many others may only need a few accommodations. The following is only a sample of the possibilities available. Numerous other accommodation solutions may exist.

Questions to Consider:

  1. What limitations does the employee with intellectual or cognitive impairments experience?
  2. How do these limitations affect the employee and the employee’s job performance?
  3. What specific job tasks are problematic as a result of these limitations?
  4. What accommodations are available to reduce or eliminate these problems? Are all possible resources being used to determine possible accommodations?
  5. Can the employee provide information on possible accommodation solutions?
  6. Once accommodations are in place, can meetings take place to evaluate the effectiveness of the accommodations? Can meetings take place to determine whether additional accommodations are needed?
  7. Would human resources or personnel departments, supervisors, or coworkers benefit from education, training or disability awareness regarding intellectual or cognitive impairments? Can it be provided?

Accommodations for Limitations in Cognitive Abilities

Depending on cognitive abilities, people with Intellectual Disabilities may not be able to read information in the work environment.
  • Provide pictures, symbols, or diagrams instead of words
  • Read written information to employee
  • Provide written information on audiotape
  • Use voice output on computer
  • Use line guide to identify or highlight one line of text at a time
Depending on cognitive abilities, people with Intellectual Disabilities may not be able to write, spell, sign documents, or otherwise communicate through written word.
  • Provide templates or forms to prompt information requested
  • Allow verbal response instead of written response
  • Allow typed response instead of written response
  • Use voice input on computer
  • Use spell-check on computer
  • Use a scribe to write the employee’s response
  • Provide ample space on forms requiring written response
People with Intellectual Disabilities might have memory deficits due to auditory processing problems, cognitive inability to retain information, or congenital hearing impairment.
  • Use voice activated recorder to record verbal instructions
  • Provide written information
  • Provide checklists
  • Prompt employee with verbal cues (reminders)
  • Post written or pictorial instructions on frequently-used machines
Performing Calculations
Depending on cognitive abilities, people with Intellectual Disabilities may not be able to count, tally, measure, or track due to an inability to “do math” or perform calculations involving numbers.
  • Allow use of calculator
    • Large-display calculator
    • Talking calculator
  • Use counter or ticker
  • Make pre-counted or pre-measured poster or jig
  • Provide talking tape measure
  • Use liquid level indicators
  • Mark the measuring cup with a “fill to here” line
People with Intellectual Disabilities may be disorganized due to an inability to retain information and/or an inability to transfer or apply skills in different work environments.
  • Minimize clutter
  • Color-code items or resources
  • Provide A-B-C chart
  • Provide 1-2-3 chart
  • Divide large tasks into multiple smaller tasks
  • Avoid re-organization of workspace
  • Label items or resources
    • Use symbols instead of words
    • Use print labels instead of hand-written labels
Time Management/Performing or Completing Tasks
People with Intellectual Disabilities may have limitations in adaptive skills, such as self-initiating tasks.
  • Provide verbal prompts (reminders)
  • Provide written or symbolic reminders
  • Use alarm watch or beeper
  • Use jig for assembly to increase productivity
  • Arrange materials in order of use
  • Use task list with numbers or symbols
  • Avoid isolated workstations
  • Provide space for job coach
  • Provide additional training or retraining as needed

Accommodation for Limitations in Motor Abilities

Using Computer:
People with Intellectual Disabilities might have difficulty using the computer. This may be due to manual dexterity deficits, spasticity or rigidity, paralysis, or birth defects involving the fingers, hands, or arms.
  • Use key guard
  • Use alternative input devices
    • speech recognition
    • speech output
    • trackball
    • joystick
    • touchscreen
Using Telephone:
People with Intellectual Disabilities might have difficulty using the telephone. This may be due to manual dexterity deficits, spasticity or rigidity, paralysis, or birth defects involving the fingers, hands, or arms.
  • Use large-button phone
  • Use phone with universal symbols (fire, police, doctor)
  • Use phone with speed-dial, clearly labeled
  • Use receiver holder
  • Use headset
Accessing Workspace:
People with Intellectual Disabilities may have difficulty accessing the workspace. This may be due to muscle weakness or fatigue, an inability to stand for long periods of time, inability to walk long distances, inability to reach items, or an inability to carry/move heavy objects.
  • Place anti-fatigue mats at workstation
  • Use motorized scooter
  • Use stools at workstations
  • Move items within reach
  • Provide frequent rest breaks
Handling or Grasping Objects:
People with Intellectual Disabilities might have difficulty handling or grasping objects. This might be due to an inability to pinch or grip, inability to maintain a steady hand, muscle weakness, or joint pain.
  • Use ergonomic tools, handle build-ups, or other tool adaptations
  • Use orthopedic writing aids
  • Use grip aids
  • Use jig or brace

Accommodations for Limitations in Social Abilities

Emotional Support:
People with Intellectual Disabilities may have limitations in adaptive skills including communication, and understanding emotions and social cues
  • Give positive feedback
  • Use visual performance charts
  • Provide tangible rewards
  • Use co-workers as mentors
  • Use Employee Assistance Program (EAP)
  • Provide job coach
Interacting with Co-Workers:
People with Intellectual Disabilities may have limitations in adaptive skills and exhibiting appropriate social skills like communicating and cooperating with others and maintaining interpersonal relationships.
  • Provide sensitivity training (disability awareness) to all employees
  • Use role-play scenarios to demonstrate appropriate behavior in workplace
  • Use training videos to demonstrate appropriate behavior in workplace
  • Model appropriate social skills
    • Where to eat at work
    • When to eat at work
    • When to hug other co-workers
    • How to pay for coffee
    • What to do if you are mad
    • Who to ask for help
    • When to leave your workstation
Working Effectively with Supervisors:
People with Intellectual Disabilities may have limitations in adaptive skills in areas such as communication, interpersonal relationships, and problem-solving.
  • Communicate one-to-one with employee
  • Deal with problems as they arise
  • Keep job coach informed
  • Train supervisors on communication etiquette
  • Discuss disciplinary procedures
  • Monitor effectiveness of accommodations currently provided

Situations and Solutions

A production worker with intellectual or cognitive impairments and Cerebral Palsy had difficulty grasping a plastic bottle to accurately apply an adhesive label. JAN suggested making a wooden jig, which secured the bottle, thus allowing the employee to use both hands when applying the label.

A grocery stocker with intellectual or cognitive impairments could not remember to wear all parts of his uniform. JAN suggested taking a picture of the employee in full uniform and providing the picture to use as a reference when preparing for work.

A store clerk with intellectual or cognitive impairments had limited reading skills, making it difficult to return DVDs to the shelf. JAN suggested making picture labels for DVD cases that matched shelf display boxes. This allowed the employee to match pictures, not words, when returning DVDs to the shelf.


There are numerous products that can be used to accommodate people with limitations. JAN's Searchable Online Accommodation Resource (SOAR) at http://AskJAN.org/soar is designed to let users explore various accommodation options. Many product vendor lists are accessible through this system; however, upon request JAN provides these lists and many more that are not available on the Web site. Contact JAN directly if you have specific accommodation situations, are looking for products, need vendor information, or are seeking a referral.



EEOC Regulations To Implement the Equal Employment Provisions of the Americans With Disabilities Act, as Amended, 29 C.F.R. § 1630 (2011).

Equal Employment Opportunity Commission. Questions and Answers about Workers with Intellectual Disabilities in the workplace. Retrieved May 19, 2011, http://www.eeoc.gov/laws/types/intellectual_disabilities.cfm

EEOC Regulations To Implement the Equal Employment Provisions of the Americans With Disabilities Act, as Amended, 29 C.F.R. § 1630 (2011).

Updated 03/07/13


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