New Requirements For Memorializing The Interactive Process Under The NYCHRL: Engaging In A Cooperative Dialogue

This week, on Oct. 15, an amendment to the New York City Administrative Code went into effect requiring employers covered by the New York City Human Rights Law (NYCHRL) to engage in a good faith "cooperative dialogue" when evaluating employee requests for accommodations in the workplace, and to document the results of that dialogue in writing. Generally, all employers with four or more employees are covered by the NYCHRL, and all employees who work for such employers in New York City are entitled to the law's protections, whether full time or part time, interns, temporary workers, or otherwise.

Under the NYCHRL, employers must provide reasonable accommodations to employees requesting accommodations related to: