On October 15, 2018, the New York City Human Rights Law (CHRL) was amended to require employers to engage in a “cooperative dialogue” with individuals who may be entitled to a reasonable accommodation under the CHRL.
Whereas federal and state laws require an “interactive process” to determine a reasonable accommodation, the CHRL requires that employers go one step further – employers must engage in a good faith written or oral dialogue concerning:
- The person’s accommodation needs
- Potential accommodations that may address the person’s accommodation needs, including alternatives to a requested accommodation, and
- The difficulties that such potential accommodations may pose for the employer.