When promoting employee well-being in the workplace, it’s important for HR teams to know what their obligations are for specific mental illnesses and medical conditions. The Americans with Disabilities Act (ADA) entitles employees to reasonable accommodation for any “physical or mental impairment that substantially limits one or more major life activities.” But what are reasonable accommodations for PTSD?
Here’s what employers need to know about ADA accommodations for post-traumatic stress disorder, and how to comply with ADA confidentiality requirements.
What Is PTSD?
Post-traumatic stress disorder (PTSD) is a mental health condition that arises after a traumatic event, such as an assault, accident, abuse, or natural disaster. According to the National Institute of Mental Health, military veterans experience PTSD at a higher rate than civilians — 7% vs. 6% — but it can occur in anyone at any age.
Common symptoms of PTSD include:
- Flashbacks
- Panic attacks
- Difficulty sleeping
- Suicidal thoughts
Although fear is a normal response to a traumatic event, people with PTSD continue to feel fear and anxiety even after the danger has passed. Symptoms can be triggered by situations that remind them of the traumatic event, including words and objects.
To receive an official diagnosis, a person must experience PTSD symptoms for at least one month. Although symptoms can improve over time, especially with treatment, they can have a major impact on an employee’s job performance.
Employees with PTSD may also experience related conditions, such as depression or anxiety, which may also qualify them for accommodation under the ADA.
Who Is Eligible for PTSD Accommodations?
The Americans with Disabilities Act (ADA) applies to private employers with at least 15 employees, and to employees who have a qualifying disability. The Equal Employment Opportunity Commission (EEOC) specifically includes PTSD on the list of impairments that “should easily be concluded to be disabilities” that limit major life activities.
To qualify for an accommodation, the employee must be able to successfully perform the essential functions of their job — with or without the help of an accommodation — and the accommodation must not present an undue hardship to the employer.
Before providing a reasonable accommodation for PTSD or another qualifying disability, the employer can ask for medical documentation of the employee's condition and which job tasks it impacts. This documentation should be kept confidential and separate from other personnel files to protect the employee’s privacy.
6 Examples of Reasonable Accommodations for PTSD
Symptoms of PTSD can vary widely and impact everyone differently, so it’s important to discuss possible accommodations on a case-by-case basis. Here are some workplace accommodation ideas that may serve as reasonable accommodations for PTSD.
Flexible scheduling
One possible accommodation for PTSD is to provide flexible work hours. The employee could be allowed to set their own hours or even to work from home. If an employee has difficulty sleeping, they could be allowed to come in late or take frequent breaks.
Employers could also arrange for backup coverage, or someone who can take over their job duties if the employee needs to take time off at the last minute.
A leave of absence
A leave of absence could also be a reasonable accommodation for PTSD, especially if the employee needs time off for professional treatment. The employee could be placed on personal leave while receiving treatment, or moved to a part-time schedule.
The ADA doesn’t allow for indefinite leave, but it can kick in when other types of leave have been used up. For example, the Family and Medical Leave Act (FMLA) provides up to 12 weeks of leave for certain mental health conditions, and the ADA could be used to extend that leave period as a reasonable accommodation.
A support animal
Psychiatric service dogs can anticipate panic attacks and ensure that their owner gets the support they need. Emotional support animals have less training, but can provide reassurance and comfort to employees with PTSD.
If you already have a pet-friendly work environment, this can be an easy way to help an employee with PTSD feel at home. If not, this can still be a reasonable accommodation for PTSD, as long as it doesn’t pose an undue hardship to your business.
A separate workspace
Certain work environments can be especially triggering to employees with PTSD. Bright lights, loud noises, and other stimuli can bring back memories of a traumatic event and exacerbate PTSD symptoms. Or, they may feel uncomfortable in enclosed spaces or cluttered rooms without a clear route to an exit.
If an employee is having trouble concentrating in a shared workspace, offer a private space for them to work from or to take breaks when they feel anxious. White noise machines and noise-canceling headsets can be effective too.
Alternative instructions
Employees with PTSD may have trouble following verbal instructions, or they may be triggered by raised voices or unexpected interruptions. They may be uncomfortable in large group settings, and feel anxious participating in meetings.
Instead, provide them with alternatives, such as written instructions instead of verbal instructions, or a meeting transcript instead of mandatory meeting attendance.
Access to a support person
If an employee with PTSD experiences anxiety or panic attacks, they may need to reach out to their therapist or another support person in the middle of work-related tasks.
A reasonable accommodation for PTSD could be to let them keep their phone on them and call or text a support person throughout the work day, even if this is against your ordinary cell phone use policy.
Best Practices for ADA Accommodations
PTSD isn’t the only mental health condition to consider. Employees may also be eligible for accommodations for autism, anxiety, attention-deficit/hyperactivity disorder (ADHD), and other conditions. Be sure to consider each situation on a case-by-case basis and follow these best practices to comply with the ADA.
Follow the ADA interactive process
The ADA interactive process is a dialogue between the employer and employee that seeks to find a suitable accommodation for both parties. It starts when the employee discloses their medical condition, and continues even after the accommodation has been selected and implemented.
Follow this interactive process checklist to ensure you meet your obligations as an employer and find a reasonable accommodation for your workplace.
Respect employee privacy
Although employees will need to disclose their PTSD diagnosis in order to request an accommodation under the ADA, the details should be kept confidential. If someone in a supervisory capacity needs access to confidential information in order to provide the accommodation, this should only be shared on a need-to-know basis.
In some cases, an employee may choose to reveal their condition to their colleagues, but that decision is entirely up to them.
Consider alternatives
The ADA guarantees reasonable accommodations for PTSD, but that may not be an employee’s only option. According to the Department of Labor at DOL.gov, employees may be eligible for a leave of absence under FMLA for mental health if their condition requires inpatient care or ongoing treatment.
Some companies also offer an Employee Assistance Program (EAP), which provides counseling and other support to employees experiencing personal difficulties.
Streamline ADA Accommodations With Pulpstream
Providing reasonable accommodations for PTSD is a requirement under the ADA for businesses with more than 15 employees. Possible accommodations include a flexible schedule, a separate workspace, a leave of absence, or a support animal — but the most suitable accommodation will vary on a case-by-case basis.
Manage your leave of absence, return to work, and ADA processes all in one place with Pulpstream. Our cloud-based system makes it easy to determine eligibility, request and store documentation, track accommodations, and manage ADA leaves. Request a free demo today to see Pulpstream in action and learn more!
