NYC Employers Should Prepare for New Accommodations Requirements | PN Lawyers

Employment Law Update: NYC Employers Should Prepare for New Accommodation Requirements

All New York City employers should prepare for a shift in handling employee accommodations.

Under a new amendment to the New york City Human Rights Law (NYCHRL) employers in New York City will soon be required to engage in “cooperative dialogue” with employees who are or may be entitled to reasonable accommodations. This is new amendment goes into effect on October 15, 2018. The NYCHRL applies to employers with 4 or more employees and requires they make reasonable accommodation for the following:

  • Victims of domestic violence
  • Pregnancy and related issues
  • Religious needs
  • Disability

They’re expanding this one step further to clarify the reasonable accommodation requirement by pushing for open conversations between employer and employee.

1. Now, what exactly does “cooperative dialogue” mean?

The amendment regards “cooperative dialogue” as a process in which the employer (covered entity) and the employee entitled to an accommodation, engage in good faith dialogue (click here to read more on “good faith process”), written or verbal concerning the individual’s current and requested accommodation needs.

Additionally, after the cooperative dialogue, the employer must provide their employee a written final decision outlining any granted or denied accommodations.  

2. What should you do as an employer?

You still have a few months to prepare. We suggest updating the rest of your management team on these new requirements, as well as updating your employee handbooks.

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