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EEOC provides guidance on telework as a reasonable accommodation

May 2026 employment law letter
Authors: 

Catherine C. Buchanan, Whiteford, Taylor & Preston, L.L.P.

In February 2026, the Equal Employment Opportunity Commission (EEOC) issued guidance titled “Frequently Asked Questions from the Federal Sector about Telework Accommodations for Disabilities.” Although it’s targeted toward federal agencies, the guidance draws on standards also relevant to private employers covered under the Americans with Disabilities Act (ADA).

Alternative reasonable accommodations

The ADA entitles qualified employees with disabilities to reasonable accommodations to allow them to: 

  • Participate in the application process; 

  • Perform the essential functions of their job; and 

  • Enjoy equal benefits and privileges of their employment. 

An employer needs only to provide telework as an accommodation if it is effective in facilitating one of these purposes. If telework is only one of several reasonable and effective options, however, employers may choose to offer alternative accommodations.

Focusing on accommodations that allow employees to perform their essential job functions, the EEOC acknowledged that the possibility of symptom mitigation, by itself, doesn’t entitle an employee to telework as a reasonable accommodation. Employers must make individualized assessments for each employee to determine whether telework or an alternative accommodation is appropriate.

Reevaluating previously granted telework accommodations

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