Employees with 

Sleep Disorders 

Accommodation and Compliance Series
Practical Solutions • Workplace Success 

2 

Preface 

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Updated 03/23/10.
Practical Solutions • Workplace Success 

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JAN’S ACCOMMODATION AND COMPLIANCE SERIES

Introduction

JAN’s Accommodation and Compliance Series is designed to help employers determine 

effective accommodations and comply with Title I of the Americans with Disabilities Act 

(ADA). Each publication in the series addresses a specific medical condition and 

provides information about the condition, ADA information, accommodation ideas, and 

resources for additional information. 

The Accommodation and Compliance Series is a starting point in the accommodation 

process and may not address every situation. Accommodations should be made on a 

case by case basis, considering each employee’s individual limitations and 

accommodation needs. Employers are encouraged to contact JAN to discuss specific 

situations in more detail. 

For information on assistive technology and other accommodation ideas, visit JAN's 

Searchable Online Accommodation Resource (SOAR) at http://askjan.org/soar. 

Information about Sleep Disorders 

How prevalent are sleep disorders? 

According to the National Institute of Neurological Disorders and Strokes, it is estimated 

that 40 million Americans are diagnosed with a chronic long-term sleep disorder each 

year, and 20 million Americans have occasional sleep problems (About Sleep 

Disorders, 2008). 

What are sleep disorders? 

Sleep disorders are neurological conditions that can affect sleep in a variety of ways. 

The International Classification of Sleep Disorders (ICSD) lists over 84 different types of 

sleep disorders that affect the body’s normal cycle of daytime wakefulness and night 

time sleep (About Sleep Disorders, 2008). 

Sleep disorders are often categorized into four types: (1) Primary Sleep Disorders, (2) 

Sleep Disorders Related to Another Mental Disorder, (3) Sleep Disorders Due to a 

General Medical Condition, and (4) Substance-Induced Sleep Disorders (American 

Psychiatric Association, 1994). Examples of Primary Sleep Disorders are: 

Primary Insomnia: The common complaint of primary insomnia is difficulty falling 

or staying asleep that is consistent for at least one month. Symptoms include 

decreased energy, lower concentration, and fatigue. Although symptoms are 

similar, primary insomnia should not be confused with insomnia related to a 

mental health impairment or another health condition. Insomnia, in general, often 

increases with age and affects women more (National Women’s Health 

Information Center, n.d.). 
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Narcolepsy: Narcolepsy’s primary characteristic is the occurrence of sleep 

attacks, which can occur at any time and during activity or conversation. 

Individuals with narcolepsy have abnormal sleep patterns and enter Rapid Eye 

Movement (REM) before going through their regular sleep sequence. Cataplexy 

(a weakness or paralysis of the muscles), sleep paralysis, and hallucinations are 

common symptoms of narcolepsy (Neurology Channel, 2005). 

Hypersomnia: Hypersomnia’s symptoms include excessive sleepiness for a 

minimum of one month. Excessive sleepiness is often characterized by 

extended sleep episodes or by daytime sleep episodes that occur daily. 

Individuals with hypersomnia often sleep 8 to 12 hours a night and have difficultly 

waking up (American Psychiatric Association, 1994). 

Restless Leg Syndrome (RLS): The primary complaint of individuals with RLS is 

that sensations in the legs, described as pins and needles, crawling, and tingling, 

occur during sleep. As a result of these sensations, there is an overwhelming 

urge to move the legs. People with RLS are often sleepy during the day due to 

lack of sleep. Between 5-10% of Americans have RLS; iron deficiencies and 

genetics may play a factor in the occurrence (Haran, 2005). 

Sleep Apnea: Over 12 million Americans have sleep apnea; it is more common 

in men over 40 years of age (National Institute of Health, 2003). There are two 

different types of sleep apnea: (1) central sleep apnea and (2) obstructive sleep 

apnea (OSA). Nine out of ten people with sleep apnea have OSA. The main 

characteristic of sleep apnea is that an individual stops breathing for 10-30 

seconds at a time while sleeping. As a result, the individual never completes a 

full sleep cycle and has significant daytime sleepiness. The most common 

treatment for sleep apnea is the nighttime use of a continuous positive airway 

pressure (CPAP) machine, which is a mask that is worn at night to force air into 

an individual’s airway. The CPAP keeps a person’s airway open while sleeping 

so the person can reach a deep sleep (American Psychiatric Association, 1994). 

Shift Work Type: Ten percent of all shift workers have been diagnosed with shiftwork type sleep disorder. Shift work type is a result of disruptions of sleep and 

wakefulness patterns due to irregular schedules. Rotating shift work is the most 

disruptive because sleep is never habitual. Serious health conditions can arise 

out of this, including peptic ulcer disease and heart disease (Basner, 2005). 

What causes sleep disorders? 

Many causes can be attributed to sleep disorders depending on the type. In many 

cases, sleep disorders can be a symptom of an underlying medical condition or a side 

effect of medications. Often times, a family pattern can be shown in conditions such as 

hypersomnia and narcolepsy (American Psychiatric Association, 1994). 
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How are sleep disorders treated?

Depending on the type of sleep disorder, life style changes, medications, and surgery 

can be options (American Psychiatric Association, 1994). 

Sleep Disorders and the Americans with Disabilities Act

Are sleep disorders disabilities under the ADA? 

The ADA does not contain a list of medical conditions that constitute disabilities. 

Instead, the ADA has a general definition of disability that each person must meet 

(EEOC, 1992). Therefore, some people with sleep disorders will have a disability under 

the ADA and some will not. 

A person has a disability if he/she has a physical or mental impairment that substantially 

limits one or more major life activities, a record of such an impairment, or is regarded as 

having such an impairment (EEOC, 1992). For more information about how to 

determine whether a person has a disability under the ADA, visit 

http://askjan.org/corner/vol02iss04.htm. 
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Accommodating Employees with Sleep Disorders 

(Note: People with sleep disorders may develop some of the limitations discussed 

below, but seldom develop all of them. Also, the degree of limitation will vary among 

individuals. Be aware that not all people with sleep disorders will need accommodations 

to perform their jobs and many others may only need a few accommodations. The 

following is only a sample of the possibilities available. Numerous other accommodation 

solutions may exist.) 

Questions to Consider: 

1. What limitations is the employee with a sleep disorder experiencing? 

2. How do these limitations affect the employee and the employee’s job performance? 

3. What specific job tasks are problematic as a result of these limitations? 

4. What accommodations are available to reduce or eliminate these problems? Are all 

possible resources being used to determine possible accommodations? 

5. Has the employee with the sleep disorder been consulted regarding possible 

accommodations? 

6. Once accommodations are in place, would it be useful to meet with the employee 

with a sleep disorder to evaluate the effectiveness of the accommodations and to 

determine whether additional accommodations are needed? 

7. Do supervisory personnel and employees need training regarding sleep disorders? 

Accommodation Ideas: 

Daytime Sleepiness: 

• Provide a device such as a Doze Alert or other alarms to keep the employee alert 

• Reschedule for longer or shorter, more frequent breaks 

• Provide a shift change for when the employee is most alert 

Maintaining Concentration: 

• Provide space enclosures or a private work area or office 

• Increase natural lighting or provide full spectrum lighting 

• Reduce clutter in the employee's work environment 

• Plan for uninterrupted work time 

• Divide large assignments into smaller tasks and steps 

• Restructure job to include only essential functions 

• Allow the employee to listen to music or white noise with a headset 
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Memory Deficits: 

• Post instructions with frequently used equipment 

• Allow the employee to tape record verbal instruction or meetings 

• Provide written checklists 

• Allow additional training time 

• Provide written as well as verbal instructions 

• Use notebooks, calendars, or sticky notes to record information for easy retrieval 

Attendance Issues: 

• Provide a flexible start time and/or end time

• Allow the employee to work from home

• Provide a part time work schedule

• Provide a shift change

Decreased Stamina: 

• Provide a flexible schedule 

• Allow longer or more frequent work breaks 

• Provide additional time to learn new responsibilities 

• Provide backup coverage for when the employee needs to take breaks 

• Restructure job to include only essential functions 

Situations and Solutions: 

A financial analyst with sleep apnea often fell asleep while working at her computer. 

The employer provided her with a small device called a Doze Alert that fits in her ear 

and sounds whenever her head starts to drop forward as she falls asleep. 

A customer service representative with hypersomnia had difficulty waking up for his 

morning schedule, which resulted in him being late for his shift. The employer 

accommodated him by moving him to the afternoon shift. 

A dispatcher with shift work sleep disorder worked rotating shifts that caused his sleep 

disorder to be exacerbated. The employer changed the rotating shift schedule for all 

employees to shifts that were assigned by seniority. 

A clerical employee with insomnia had a hard time maintaining concentration on the job 

and his stamina was often poor because of inadequate sleep. This employee was 

allowed frequent breaks to help improve his stamina. 

An accountant with restless leg syndrome was often 10-15 minutes late for work every 

day due to amount and quality of sleep. The employer provided this employee with a 

half an hour flexible start time. Depending on when the employee arrived, the time was 

made up either in a break or at the end of the day. 
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Products: 

There are numerous products that can be used to accommodate people with limitations. 

JAN's Searchable Online Accommodation Resource (SOAR) at http://askjan.org/soar is 

designed to let users explore various accommodation options. Many product vendor 

lists are accessible through this system; however, upon request JAN provides these 

lists and many more that are not available on the Web site. Contact JAN directly if you 

have specific accommodation situations, are looking for products, need vendor 

information, or are seeking a referral. 
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Resources 

Job Accommodation Network 

West Virginia University 

PO Box 6080 

Morgantown, WV 26506-6080 

Toll Free: (800)526-7234 

TTY: (877)781-9403 

Fax: (304)293-5407 

jan@askjan.org 

http://askjan.org 

The Job Accommodation Network (JAN) is a free consulting service that provides 

information about job accommodations, the Americans with Disabilities Act (ADA), and 

the employability of people with disabilities. 

Office of Disability Employment Policy 

200 Constitution Avenue, NW, Room S-1303 

Washington, DC 20210 

Toll Free: (866)633-7635 

TTY: (877)889-5627 

Fax: (202)693-7888 

http://www.dol.gov/odep/ 

The Office of Disability Employment Policy (ODEP) is an agency within the U.S. 

Department of Labor. ODEP provides national leadership to increase employment 

opportunities for adults and youth with disabilities while striving to eliminate barriers to 

employment. 

American Academy of Sleep Medicine 

1 Westbrook Corporate Center 

Suite 920 

Westchester, IL 60154 

Direct: (708)492-0930 

Fax: (708)492-0943 

http://www.aasmnet.org 

The American Academy of Sleep Medicine (AASM) is a professional medical 

association representing practitioners of sleep medicine and sleep research. 
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American Sleep Apnea Association 

1424 K Street NW 

Suite 302 

Washington, DC 20005 

Direct: (202)293-3650 

Fax: (202)293-3656 

http://www.sleepapnea.org 

The American Sleep Apnea Association is a non-profit organization that promotes 

education and awareness, the ASAA A.W.A.K.E. Network of voluntary mutual support 

groups, research, and continuous improvement of care. 

Narcolepsy Network 

79 Main Street 

North Kingstown, RI 02852 

Toll Free: (888)292-6522 

Direct: (401)667-2523 

Fax: (401)633-6567 

narnet@narcolepsynetwork.org 

http://www.narcolepsynetwork.org 

Narcolepsy Network is a national, non-profit organization incorporated in 1986. 

Members are people who have narcolepsy (or related sleep disorders), their families 

and friends, and professionals involved in treatment, research, and public education 

regarding narcolepsy. 

National Institute of Neurological Disorders and Stroke 

P.O. Box 5801 

Bethesda, MD 20824 

Toll Free: (800)352-9424 

Direct: (301)496-5751 

TTY: (301)468-5981 

http://www.ninds.nih.gov/ 

The NINDS, an agency of the U.S. Federal Government and a component of the 

National Institutes of Health and the U.S. Public Health Service, is a lead agency for the 

congressionally designated Decade of the Brain, and the leading supporter of 

biomedical research on disorders of the brain and nervous system. 
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National Sleep Foundation 

1522 K Street, NW, Suite 500 

Washington, DC 20005 

Direct: (202)347-3471 

Fax: (202)347-3472 

nsf@sleepfoundation.org 

http://www.sleepfoundation.org 

The National Sleep Foundation is a nonprofit organization that promotes public 

understanding of sleep and sleep disorders and supports sleep-related education, 

research, and advocacy to improve public health and safety. 

Restless Leg Syndrome Foundation 

1610 14th St NW Suite 300 

Rochester, MN 55902 

Direct: (507)287-6465 

Fax: (507)287-6312 

rlsfoundation@rls.org 

http://www.rls.org 

The Restless Leg Syndrome Foundation provides information on RLS-diagnosis, 

treatment, and support from others with the condition. 

Sleep Disorders Guide 

http://www.SleepDisordersGuide.com 

This Web site is designed to be a valuable tool for patients and members of the public 

who are seeking dependable information related to sleep, sleep disorders, treatments 

and services. Although the processes of sleep and its workings in the body are quite 

complex, the goal of this site is to present accurate, scientific information in a concise 

manner that is easy to understand. 
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References 

About Sleep Disorders. (2008). Types of sleep disorders, and how anxiety and diet may 

influence rest. Retrieved September 5, 2008, from http://www.about-sleepdisorders.com/articles/types-of-sleep-disorders/index.php 

American Psychiatric Association. (1994). Diagnostic and statistical manual of mental 

disorders (4th ed.). Washington, DC: Author. 

Basner, R.C. (2004). Shift-work sleep disorder – The glass is more than half 

Empty. The New England Journal or Medicine, 353(5). Retrieved November 11, 

2005, from http://content.nejm.org 

Equal Employment Opportunity Commission. (1992). A technical assistance manual on 

the employment provisions (title I) of the Americans with Disabilities Act. 

Retrieved September 5, 2008, from http://askjan.org/links/ADAtam1.html 

Haran, C. (2005). Iron works: A cause of restless leg syndrome. Retrieved November 

4, 2005, from http://www.abcnews.go.com 

National Institutes of Health. (2003). What is sleep apnea? Retrieved January 11, 2005, 

from http://www.nhlbi.nih.gov 

National Women’s Health Information Center. (n.d.) Frequently asked questions about 

insomnia. Retrieved December 12, 2005, from http://www.4women.gov 

Neurology Channel. (2005). Sleep Disorders. Retrieved January 4, 2006, from 

http://neurologychannel.com 
Practical Solutions • Workplace Success 

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This document was developed by the Job Accommodation Network, funded by a 

contract agreement from the U.S. Department of Labor, Office of Disability Employment 

Policy (DOL079RP20426). The opinions expressed herein do not necessarily reflect the 

position or policy of the U.S. Department of Labor. Nor does mention of trade names, 

commercial products, or organizations imply endorsement by the U.S. Department of 

Labor.