Everything quoted below is from the U.S. Equal Employment Opportunity Commission's Enforcement Guidance on Reasonable Accommodation and Undue Hardship Under the Americans with Disabilities Act (Notice 915.002, issued October 17, 2002), retrieved from eeoc.gov on September 16, 2026. It is enforcement guidance: the agency's published explanation of how it reads the statute, not the statute itself, and the page carries its own notice that it was issued before the 2008 amendments to the ADA broadened the definition of disability. Nothing here tells you whether a particular restructuring is required in a particular job, and nothing here promises an outcome. For free, confidential technical help on a specific accommodation the Job Accommodation Network at askjan.org is the call worth making first; for what you are legally obliged to do, an employment lawyer. Innovative Placements is a connector — we help people with disabilities find work in Western New York — and we are not lawyers.
Ask an employer what "reasonable accommodation" means and you will usually hear about equipment: a screen reader, a ramp, a different chair. Those are real. But one of the accommodations the Commission lists by name is not a purchase at all. It is a change to the job, and it has a rule attached that is short enough to memorise.
The Line, in the Agency's Words
“Job restructuring includes modifications such as: reallocating or redistributing marginal job functions that an employee is unable to perform because of a disability; and altering when and/or how a function, essential or marginal, is performed.”
“An employer never has to reallocate essential functions as a reasonable accommodation, but can do so if it wishes.”
Read the two together and the whole accommodation is visible. There are two kinds of function in any job. The marginal ones can be moved to somebody else, and the guidance treats moving them as a reasonable accommodation. The essential ones never have to be moved, and an employer that moves one anyway is doing something voluntary rather than something required. Either kind can be changed in when or how it is done without being moved at all.
That is the entire framework. Everything employers get wrong about it comes from collapsing the two kinds of function into one.
Wrong in Both Directions
The first mistake is refusing to move anything. "The job is the job" treats every task on the list as essential, which is almost never true; most jobs carry tasks that were added because somebody had to do them, not because they define the role. When an employee with a disability cannot do one of those, saying no on the grounds that the job cannot change is answering a question about essential functions with a fact about marginal ones.
The second mistake is moving an essential function, discovering that the job no longer works without it, and concluding that restructuring was the problem. It was not. The guidance never asked for that, and the failure was a sorting error made before anyone restructured anything: an essential function was treated as marginal, or nobody had ever decided which was which.
Not "can this task be done by someone else?" Almost any task can. The question is whether the task is one of the reasons the position exists. That is what makes a function essential, and it is a question about the job, not about the employee in front of you. If you cannot answer it from the job description, the job description is where the problem is, and the last section of this article is about that.
The Example the Agency Chose
The guidance illustrates the rule with a specific case, and the case is worth quoting in full because every part of it is doing work:
“A cleaning crew works in an office building. One member of the crew wears a prosthetic leg which enables him to walk very well, but climbing steps is painful and difficult. Although he can perform his essential functions without problems, he cannot perform the marginal function of sweeping the steps located throughout the building. The marginal functions of a second crew member include cleaning the small kitchen in the employee's lounge, which is something the first crew member can perform. The employer can switch the marginal functions performed by these two employees.”
Three things in that paragraph. The essential functions are untouched: the employee does them "without problems," and nothing in the example moves one. The function that moves is explicitly marginal. And the move is a swap, not a subtraction: the first crew member takes on the kitchen. The example is framed as the answer to a question the guidance poses directly, and answers in one word:
“If, as a reasonable accommodation, an employer restructures an employee's job to eliminate some marginal functions, may the employer require the employee to take on other marginal functions that s/he can perform? Yes. An employer may switch the marginal functions of two (or more) employees in order to restructure a job as a reasonable accommodation.”
So restructuring is not a lightening of the load. It is a rearrangement of the marginal work across the people who can do it, and the employee receiving the accommodation can be asked to carry marginal tasks they are able to perform in exchange. That answers the worry behind the first mistake — that accommodation means one person does less and everyone else absorbs it — with the agency's own words.
Altering When and How, Not Only Who
The second half of the definition gets less attention than the first and is often the more useful half. A function does not have to move to be restructured. It can stay exactly where it is and change in timing or method: “altering when and/or how a function, essential or marginal, is performed.”
That clause is the one that reaches essential functions. An employer never has to reallocate an essential function, but the guidance plainly contemplates changing when it happens or how it is done. A task done standing might be done seated; a task done first thing might be done after a treatment appointment; a task done in one block might be done in two. The function is still the employee's and still essential. What changed is the shape of it, and the site's stay-at-work playbook notes the practical edge of this: restructured essential functions can end up resembling light duty, which is a reason to write down what changed and why, so it stays an accommodation rather than drifting into a different job.
Part-Time, Full-Time, and the Word Nobody Quotes
One sentence in the same guidance answers a question employers ask quietly and rarely out loud: does any of this apply to somebody who has only just started?
“Reasonable accommodations must be provided to qualified employees regardless of whether they work part-time or full-time, or are considered ‘probationary.’”
The word "probationary" has never appeared on this site before today, and it should have. A probationary period is a real thing in many workplaces and a useful one, but in the agency's reading it is not a period during which accommodation is optional. A new hire in their first ninety days who cannot perform a marginal function because of a disability is, on this page, in the same position as a ten-year employee. Whether a particular request is reasonable is still a question about the request; the answer does not change because the employee is new.
The Skill Is the Job Description
Everything above depends on one thing being true before anyone needs an accommodation: that the job description already says, honestly, which functions are essential and which are marginal. If it does, restructuring is a short conversation with a visible line in it. If it does not, the conversation starts with an argument about the line, held under time pressure, by people who have just learned the words.
The site has an article on writing job descriptions whose first instruction is to separate essential functions from preferred qualifications, and this is the accommodation that instruction was for. Two habits make the line usable. Write the essential functions as outcomes rather than methods, so that "how" can change without the function changing. And keep the description current, because a marginal task that quietly became essential over three years is exactly the one that gets moved by mistake.
1. For each position, decide which functions are the reasons it exists. Those are essential.
2. Write them as outcomes. "Keeps the building's floors clean" survives a change of method; "sweeps the steps daily" does not.
3. List the marginal tasks too, and expect them to move.
4. Revisit both lists when the job changes, not when a request arrives.
What This Article Is Not
It is not about reassignment to a different position, which the guidance treats as its own accommodation with its own rules and which deserves its own article rather than a paragraph here. It is not a walkthrough of the interactive process or of undue hardship; the site has covered both many times, and choosing among effective accommodations is the place to start on the first and the cost-effective accommodations guide on the second. And it does not tell you that any particular restructuring is required of you, or that one will succeed. The guidance draws the line. Where a specific job falls on it is a question for the job description first, JAN second and counsel third.
Where to Take It
If the disability in question comes and goes, or is expected to progress, the line between essential and marginal has to be revisited more than once, and accommodating episodic and progressive disabilities covers how. If the employee is someone already on your payroll whose circumstances have changed, the stay-at-work playbook puts restructuring in its place among the other tools. And for the general question of what you owe, the Job Accommodation Network at askjan.org answers specific accommodation questions at no cost, which is the reason every employers article on this site sends you there before it sends you anywhere else.
Every quotation above is from the EEOC's Enforcement Guidance on Reasonable Accommodation and Undue Hardship Under the Americans with Disabilities Act, Notice 915.002, dated October 17, 2002, retrieved from eeoc.gov on September 16, 2026. The page carries the Commission's own notice that the document was issued before the ADA Amendments Act of 2008, which took effect January 1, 2009 and broadened the statutory definition of disability; the job-restructuring passages quoted here are about accommodation, not the definition, but the notice applies to the document as a whole. The agency revises its guidance. If this article ever disagrees with the current published text, trust the current text and tell us.