Employees with 

Brain Injuries 

Accommodation and Compliance Series 
Practical Solutions • Workplace Success 

2 

Preface 

The Job Accommodation Network (JAN) is a service of the Office of Disability 

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Updated 03/22/10.
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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 Traumatic Brain Injury (TBI) 

What is a TBI? 

According to TBI Recovery Center (2006), “TBI is any injury to the brain caused by 

trauma to the head. If there is trauma to the brain, but the skull is not broken, the TBI is 

known as a closed head injury. This could occur, for example, if a person in an 

automobile accident hits his head on the steering wheel, but does not have a skull 

fracture. If an object such as a bullet penetrates the skull and injures the brain, the TBI 

is known as a penetrating head injury.” There are several different types of TBI (TBI 

Recovery Center, 2006): 

Concussion: A concussion is the most minor and common type of TBI. A 

concussion is caused when the brain receives a somewhat minor trauma from an 

impact, such as a hit to the head by an object or person or from a sudden change 

in momentum, such as a fall. It may or may not result in a short loss of 

consciousness (not exceeding 20 minutes) and can be diagnosed by observing 

common symptoms such as headache, confusion, and vomiting. Difficulty with 

thinking skills (e.g., difficulty “thinking straight,” memory problems, poor 

judgment, poor attention span, a slowed thought processing speed) (Brain Injury 

Association of America, 2006a; TBI Recovery Center, 2006). 

Skull Fracture: A skull fracture occurs when the skull cracks or breaks. A 

depressed skull fracture occurs when pieces of broken skull press into the tissue 

of the brain. A penetrating skull fracture occurs when something pierces the skull 

and injures the brain (Brain Injury Association of America, 2006a; TBI Recovery 

Center, 2006).
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Contusion: A contusion is bruising or bleeding of the brain (Brain Injury 

Association of America, 2006a; TBI Recovery Center, 2006). 

Hematoma: A hematoma is a collection of blood inside the body (Brain Injury 

Association of America, 2006a; TBI Recovery Center, 2006). 

How prevalent are TBIs? 

The Brain Injury Association of America (2006a) estimates that every year about 1.4 

million Americans experience a traumatic brain injury. 

What are the causes of TBI? 

Half of all TBIs are due to accidents involving automobiles, motorcycles, bicycles, and 

pedestrians. Motor vehicle accidents are the major cause of TBI in people under age 

75. For those 75 and older, falls cause the majority of TBIs. Approximately twenty 

percent of TBIs are due to violence, such as gunshots and child abuse. About three 

percent are due to sports injuries. Alcohol use is associated with half of all TBIs (TBI 

Recovery Center, 2006).

Another type of brain injury is called Acquired brain Injury. This describes damage to the 

brain not associated with trauma to the head or skull and typically involves the entire 

brain. Common causes of acquired brain injury are loss of oxygen to the brain due to 

drowning, toxic exposure to carbon monoxide, as well as heart attack and stroke (Brain 

Injury Association of America, 2006b).

What are the signs and symptoms of TBI? 

There are various levels of TBI, including mild and moderate or severe TBI (TBI 

Recovery Center, 2006). 

 

Mild TBI: Symptoms of mild TBI include headache; confusion; lightheadedness; 

dizziness; blurred vision or tired eyes; ringing in the ears; bad taste in the mouth; 

fatigue; a change in sleep patterns; mood changes; and trouble with memory, 

concentration, attention, or thinking. The injury may or may not result in a brief 

period of unconsciousness. 

 

Moderate or Severe TBI: Symptoms of moderate to severe TBI may be similar to 

symptoms of mild TBI, but they may also include a headache that gets worse or 

does not go away, repeated vomiting or nausea, convulsions or seizures, inability 

to awaken from sleep, dilation of one or both pupils of the eyes, slurred speech, 

weakness or numbness in the arms or legs, loss of coordination, increased 

confusion, restlessness, or agitation. 

Most workplace difficulties are the result of cognitive functional limitations such 

as remembering, organizing, learning, and planning skills. (Hirsh et al., 1996). 
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TBIs and the Americans with Disabilities Act

Are TBIs 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 TBIs 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. 

Are employees (or applicants) with TBIs required to disclose their disability to 

their employers? 

No. Employees need only disclose their disability if/when they need an accommodation 

to perform the essential functions of the job. Applicants never have to disclose a 

disability on a job application, or in the job interview, unless they need an 

accommodation to assist them in the application or interview process (EEOC, 2000; 

EEOC, 1995). 

Can an employer ask an employee with TBI to submit to a medical examination? 

Yes, if the need for the medical examination is job-related and consistent with business 

necessity. Special note: pre-job offer medical examinations or inquiries are illegal under 

the ADA. People with brain injuries (or any disability) do not have to submit to a medical 

exam, or answer any medical questions until after they have been conditionally offered 

a job (EEOC, 2000; EEOC, 1995). 
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Accommodating Employees with TBIs 

(Note: People with TBIs 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 TBIs 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 TBI 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 a TBI been consulted regarding possible accommodations? 

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

with a TBI to evaluate the effectiveness of the accommodations and to determine 

whether additional accommodations are needed? 

7. Do supervisory personnel and employees need training regarding TBIs? 

Accommodation Ideas: 

Physical Limitations: 

• Install ramps, handrails, and provide handicap parking spaces

• Install lever style door handles

• Clear pathways of travel of any unnecessary equipment and furniture

Visual Problems: 

• Provide written information in large print

• Change fluorescent lights to high intensity, white lights

• Increase natural lighting

• Provide a glare guard for computer monitors

• Consult a vision specialist particularly with someone who has lost part of or all of 

their vision
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Maintaining Stamina During the Workday: 

• Permit flexible scheduling, allow longer or more frequent work breaks 

• Provide additional time to learn new responsibilities 

• Provide self-paced workload 

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

• Allow for time off for counseling 

• Allow for use of supportive employment and job coaches 

• Allow employee to work from home during part of the day 

• Provide for job sharing opportunities 

• Allow part-time work schedules 

Maintaining Concentration: 

• Reduce distractions in the work area 

• Provide space enclosures or a private office 

• Allow for use of white noise or environmental sound machines 

• Allow the employee to play soothing music using a cassette player and headset 

• 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 

Difficulty Staying Organized and Meeting Deadlines: 

• Make daily TO-DO lists and check items off as they are completed 

• Use several calendars to mark meetings and deadlines 

• Remind employee of important deadlines via memos or e-mail or weekly supervision 

• Use a watch or pager with timer capability 

• Use electronic organizers 

• Divide large assignments into smaller tasks and steps 

• Assign a mentor to assist employee in determining goals and provide daily guidance 

• Schedule weekly meetings with supervisor, manager, or mentor to determine if goals 

are being met 

Memory Deficits: 

 

• Allow the employee to tape record meetings 

• Provide type written minutes of each meeting 

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

• Provide written as well as verbal instructions 

• Allow additional training time 

• Provide written checklists and use color-coding to help identify items 

• Post instructions close to frequently used equipment 
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Problem Solving Deficits: 

• Provide picture diagrams of problem solving techniques, e.g., flow charts 

• Restructure the job to include only essential functions 

• Assign a supervisor, manager, or mentor when the employee has questions 

Working Effectively with Supervisors: 

• Provide positive praise and reinforcement 

• Provide written job instructions 

• Write clear expectations of responsibilities and the consequences of not meeting 

them 

• Allow for open communication with managers and supervisors 

• Establish written long term and short term goals 

• Develop strategies to deal with problems before they arise 

• Provide written work agreements 

• Develop a procedure to evaluate the effectiveness of the accommodation 

Difficulty Handling Stress and Emotions: 

• Provide praise and positive reinforcement 

• Refer to counseling and employee assistance programs 

• Allow telephone calls during work hours to doctors and others for needed support 

• Provide sensitivity training to coworkers 

• Allow the employee to take a break as a part of a stress management plan 

Attendance Issues: 

 

• Provide flexible leave for health problems 

• Provide a self-paced work load and flexible hours 

• Allow employee to work from home 

• Provide part-time work schedule 

Issues of Change: 

• Recognize that a change in the office environment or of supervisors may be difficult 

for a person with a brain injury 

• Maintain open channels of communication between the employee and the new and 

old supervisor in order to ensure an effective transition 

• Provide weekly or monthly meetings with the employee to discuss workplace issues 

and productions levels 
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Situations and Solutions: 

A police officer was returning to work following surgery for a brain aneurysm. He had 

partial paralysis to the left side and could no longer use both hands for word processing. 

Accommodation suggestions included: transferring the individual to a vacant position 

that involved computer research and providing a one-handed keyboard. 

A professional whose work required the use of a computer returned to work following a 

brain injury. As a result of his injury he was unable to read past the midline when 

reading from left to right. Accommodation suggestions included: changing the margin 

settings of his word processing program for 80 to 40 to limit right side reading or 

purchasing software that can split the computer screen left to right and black out the 

right side, redesigning his workstation to place equipment on the left, and providing task 

lighting. 

A therapist who had short-term memory deficits had difficulty writing case notes from 

counseling sessions. Accommodation suggestions included: allowing the therapist to 

tape record sessions and replay them before dictating notes, scheduling 15 minutes at 

the end of each session to write up hand written notes, and scheduling fewer counseling 

sessions per day. 

A laborer working in a noisy factory had difficulty concentrating on job tasks. 

Accommodation suggestions included: erecting sound absorbing barriers around his 

workstation, moving unnecessary equipment from the area to reduce traffic, and 

allowing the employee to wear a headset or ear plugs. 

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. 

Brain Injury Association of America 

1608 Spring Hill Road 

Suite 110 

Vienna, VA 22182 

Toll Free: (800)444-6443 

Direct: (703)761-0750 

Fax: (703)761-0755 

info@biausa.org 

http://www.biausa.org/ 

The Brain Injury Association creates a better future through brain injury prevention, 

research, education, and advocacy. 

National Dissemination Center for Children with Disabilities 

P.O. Box 1492 

Washington, DC 20013-1492 

Toll Free: (800)695-0285 
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TTY: (800)695-0285 

Fax: (202)884-8441 

nichcy@aed.org 

http://www.nichcy.org/index.html 

The National Dissemination Center for Children with Disabilities serves the nation as a 

central source of information on: disabilities in infants, toddlers, children, and youth; 

IDEA, which is the law authorizing special education; No Child Left Behind (as it relates 

to children with disabilities); and research-based information on effective educational 

practices. 

National Rehabilitation Information Center 

8201 Corporate Drive 

Suite 600 

Landover, MD 20785 

Toll Free: (800)346-2742 

Direct: (301)459-5900 

TTY: (301)459-5984 

naricinfo@heitechservices.com 

http://www.naric.com 

The National Rehabilitation Information Center is a library and information center 

focusing on disability and rehabilitation research. Specialists can provide quick 

information and referrals, customized database searching, and document delivery. 

National Resource Center for Traumatic Brain Injury 

Virginia Commonwealth University 

Department of Physical Medicine and Rehabilitation 

Richmond, VA 23298-0542 

jhmarwit@vcu.edu 

http://www.neuro.pmr.vcu.edu/ 

The National Resource Center for Traumatic Brain Injury provides relevant, practical 

information for professionals, persons with brain injury, and family members. 

Ohio Valley Center for Brain Injury Prevention and Rehabilitation 

Department of Physical Medicine and Rehabilitation 

The Ohio State University 

480 W. 9th Avenue, 1166 Dodd Hall 

Columbus, OH 43210 

Direct: (614)293-3802 

Fax: (614)293-8886 

http://www.ohiovalley.org 
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The Ohio Valley Center for Head Injury Prevention and Rehabilitation provides 

education and develops programs to improve the quality of life of persons who 

experience traumatic brain injury. 

Perspectives Network, Inc. 

P. O. Box 121012 

Melbourne, FL 32912-1012 

Direct: (770)844-6898 

Fax: (770)844-6898 

tpn@tbi.org 

http://www.tbi.org 

Positive communication between persons with brain injury, family members/ 

caregivers/friends of persons with brain injury, community members, and those many 

professionals who treat persons with brain injury in order to create positive changes and 

enhance public awareness and knowledge of acquired/traumatic brain injury. 

Society for Neuroscience 

1121 14th Street, NW 

Suite 1010 

Washington, DC 20005 

Direct: (202)462-4000 

Fax: (202)462-4941 

info@sfn.org 

http://www.sfn.org 

The Society for Neuroscience promotes the exchange of information among 

researchers. 
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References 

Brain Injury Association of America. (2006a). What is brain injury? Retrieved February 

9, 2006, from http://www.biausa.org/Pages/what_is_brain_injury.html 

Brain Injury Association of America. (2006b). Causes of brain injury. Retrieved 

September 4, 2008, from 

http://www.biausa.org/Pages/causes_of_brain_injury.html 

Equal Employment Opportunity Commission. (2000). Enforcement guidance on 

disability-related inquiries and medical examinations of employees under the 

Americans with Disabilities Act. Retrieved September 4, 2008, from 

http://www.eeoc.gov/policy/docs/guidance-inquiries.html 

Equal Employment Opportunity Commission. (1995). Pre-employment disability-related 

questions and medical examinations. Retrieved September 4, 2008, from 

http://www.eeoc.gov/policy/docs/preemp.html 

Hirsh, A., Duckworth, K., Hendricks, D.J., & Dowler, D. (1996). Accommodating 

workers with traumatic brain injury: Issues related to TBI and ADA. Journal of 

Vocational Rehabilitation, 7, 217-226. 

TBI Recovery Center, (2006). What is a traumatic brain injury? Retrieved September 4, 

2008, from http://www.tbirecoverycenter.org/whatis.htm 
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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.