Over the past year, I’ve worked through several client situations involving part-time or full-time telework requests as a reasonable accommodation under the Americans with Disabilities Act (ADA). These conversations are rarely simple. Employers want to support employees while also ensuring the essential functions of the role can still be performed effectively.
A recent 4th Circuit case, Jones v. Fairfax County School Board, provides an important reminder for employers navigating these requests: the key question is not whether remote work is preferred or temporarily helpful — it’s whether the employee can still perform all essential job functions while working remotely.
The Case at a Glance
In Jones v. Fairfax County School Board, a teacher requested temporary full-time telework following lung surgeries she believed were connected to mold and construction dust in her school building. Her role required regular in-person interaction with students and teachers, including classroom support and administering student testing on short notice.
The school district denied her request for full-time remote work, arguing she could not perform the essential functions of her position remotely. The court ultimately agreed.
One of the biggest takeaways from this case is that employers are not required to remove or redistribute essential job duties simply because an accommodation request is temporary. The court also reinforced that employees requesting accommodations must still be able to perform all essential functions of the role — not just most of them.
The decision also serves as a reminder that the ADA focuses on an employee’s present ability to perform the role, even when the employee is expected to recover in the future.
Why This Matters for Employers
Telework accommodations remain one of the most common and most misunderstood ADA issues employers face today.
Since the pandemic normalized remote work for many industries, employees often assume telework is automatically a reasonable accommodation option. But legally, the analysis is still highly position-specific.
In my own consulting work, I’ve seen employers struggle most when there is a disconnect between what the written job description says and what the role actually requires day to day. I’ve also seen situations where organizations approved temporary remote arrangements during emergencies, only to later face challenges explaining why permanent telework may not be feasible for the same position.
The real question becomes:
Can the employee effectively perform every essential function of the job while working remotely?
For some positions, the answer may absolutely be yes. For others — especially roles requiring in-person collaboration, customer interaction, supervision, physical presence, or hands-on tasks — the answer may be no.
The Importance of Clearly Defined Essential Functions
This case also highlights why accurate job descriptions matter.
One of the strongest defenses employers have in ADA accommodation cases is the ability to clearly articulate the essential functions of the role. Vague or outdated job descriptions can make these situations significantly harder to navigate.
Employers should periodically review positions and ask:
- What duties are truly essential?
- Which responsibilities require physical presence?
- Are there tasks that can reasonably be performed remotely?
- Are we applying standards consistently across employees?
Consistency matters. If one employee in a role has successfully worked remotely for an extended period, it may become more difficult to argue that in-person attendance is essential for others in the same position.
The Interactive Process Still Matters
Even when an employer ultimately denies a telework request, the interactive process remains critical.
Employers should:
- Engage in meaningful discussions with the employee
- Request appropriate medical documentation when needed
- Explore alternative accommodations
- Document conversations and decision-making carefully
- Avoid blanket assumptions or automatic denials
In the case above, the school district still worked with the employee by allowing limited remote participation in virtual faculty meetings, even though full-time telework was not feasible.
Practical Takeaways for Employers
When evaluating telework as a reasonable accommodation, employers should focus on:
- The actual essential functions of the role
- Whether those functions can realistically be performed remotely
- Operational impact on the organization
- Consistency with prior practices
- Documentation of the accommodation analysis
There is rarely a one-size-fits-all answer.
Some remote accommodation requests may be entirely reasonable. Others may create situations where essential functions simply cannot be performed effectively outside the workplace.
The key is approaching each request thoughtfully, consistently, and with a well-documented process.
Navigating ADA accommodations can quickly become complex, especially when balancing operational needs with employee support. Employers should ensure they are evaluating these requests carefully and consistently to reduce risk while maintaining a fair and compliant workplace.
Final Thought
Accommodation requests involving remote work are rarely black and white. Employers can support employees compassionately while still maintaining legitimate operational expectations and performance standards.
The goal is not to automatically approve or deny telework requests — it’s to evaluate each situation individually, understand the essential functions of the role, and engage in a thoughtful, well-documented process. When employers approach these conversations consistently and proactively, they are in a much stronger position to support employees while also protecting the organization.
If your organization is navigating accommodation requests, job description reviews, or the interactive process, CNY HR Now can help employers work through these situations thoughtfully, consistently, and with practical HR guidance tailored to their workplace.
Source: “4th Circuit Addresses Telework and Essential Job Functions Under ADA” by Jeffrey M. Cropp, published November 18, 2025.
Case referenced: Jones v. Fairfax County School Board.
This article is intended for informational purposes only and does not constitute legal advice. Employers should consult legal counsel regarding specific accommodation situations.