Employees with Diabetes

Accommodation and Compliance Series
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Preface

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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 Diabetes

What is diabetes?

Diabetes is a disease in which blood glucose levels are above normal. Most of the food 

we eat is turned into glucose, or sugar, for our bodies to use for energy. The pancreas, 

an organ that lies near the stomach, makes a hormone called insulin to help glucose get 

into the cells of our bodies. When you have diabetes, your body either doesn't make 

enough insulin or can't use its own insulin as well as it should. This causes sugar to 

build up in your blood (CDC, 2007).

Diabetes can cause serious health complications including heart disease, blindness, 

kidney failure, and lower-extremity amputations. Diabetes is the sixth leading cause of 

death in the United States (CDC, 2007).

What types of diabetes are there?

Type 1 diabetes was previously called insulin-dependent diabetes mellitus (IDDM) or 

juvenile-onset diabetes. Type 1 diabetes develops when the body's immune system 

destroys pancreatic beta cells, the only cells in the body that make the hormone insulin 

that regulates blood glucose. This form of diabetes usually strikes children and young 

adults, although disease onset can occur at any age. Type 1 diabetes may account for 

5% to 10% of all diagnosed cases of diabetes. Risk factors for type 1 diabetes may 

include autoimmune, genetic, and environmental factors (CDC, 2007).

Type 2 diabetes was previously called non-insulin-dependent diabetes mellitus (NIDDM) 

or adult-onset diabetes. Type 2 diabetes may account for about 90% to 95% of all 

diagnosed cases of diabetes. It usually begins as insulin resistance, a disorder in which 

the cells do not use insulin properly. As the need for insulin rises, the pancreas 
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gradually loses its ability to produce insulin. Type 2 diabetes is associated with older 

age, obesity, family history of diabetes, history of gestational diabetes, impaired glucose 

metabolism, physical inactivity, and race/ethnicity. African Americans, Hispanic/Latino 

Americans, American Indians, and some Asian Americans and Native Hawaiians or 

Other Pacific Islanders are at particularly high risk for type 2 diabetes. Type 2 diabetes 

is increasingly being diagnosed in children and adolescents (CDC, 2007).

Gestational diabetes is a form of glucose intolerance that is diagnosed in some women 

during pregnancy. Gestational diabetes occurs more frequently among African 

Americans, Hispanic/Latino Americans, and American Indians. It is also more common 

among obese women and women with a family history of diabetes. During pregnancy, 

gestational diabetes requires treatment to normalize maternal blood glucose levels to 

avoid complications in the infant. After pregnancy, 5% to 10% of women with gestational 

diabetes are found to have type 2 diabetes. Women who have had gestational diabetes 

have a 20% to 50% chance of developing diabetes in the next 5-10 years (CDC, 2007).

Other specific types of diabetes result from specific genetic conditions (such as 

maturity-onset diabetes of youth), surgery, drugs, malnutrition, infections, and other 

illnesses. Such types of diabetes may account for 1% to 5% of all diagnosed cases of 

diabetes (CDC, 2007).

How is diabetes treated?

It is important to get good medical care if you are a person with diabetes. The American 

Diabetes Association provides standards of medical care for people with diabetes (see 

Resources). 

Healthy eating, physical activity, and insulin injections are the basic therapies for type 1 

diabetes. The amount of insulin taken must be balanced with food intake and daily 

activities. Blood glucose levels must be closely monitored through frequent blood 

glucose testing (CDC, 2007).

Healthy eating, physical activity, and blood glucose testing are the basic therapies for 

type 2 diabetes. In addition, many people with type 2 diabetes require oral medication, 

insulin, or both to control their blood glucose levels (CDC, 2007).

People with diabetes must take responsibility for their day-to-day care, and keep blood 

glucose levels from going too low or too high. People with diabetes should see a health 

care provider who will monitor their diabetes control and help them learn to manage 

their diabetes. In addition, people with diabetes may see endocrinologists, who may 

specialize in diabetes care; ophthalmologists for eye examinations; podiatrists for 

routine foot care; and dietitians and diabetes educators who teach the skills needed for 

daily diabetes management (CDC, 2007).
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Diabetes and the Americans with Disabilities Act

Is diabetes a disability 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 diabetes 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.

Where can employers get additional information about diabetes and the ADA?

The Equal Employment Opportunity Commission (EEOC) has a publication called 

"Questions and Answers about Diabetes in the Workplace and the Americans with 

Disabilities Act (ADA)” available on-line at http://www.eeoc.gov/facts/diabetes.html.
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Accommodating Employees with Diabetes

(Note: People with diabetes 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 diabetes 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 diabetes 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 diabetes been consulted regarding possible 

accommodations?

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

with diabetes to evaluate the effectiveness of the accommodations and to determine 

whether additional accommodations are needed?

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

Accommodation Ideas:

Hypo/Hyperglycemia:

• Allow for storage of medications, such as insulin and/or food

• Provide an area to test blood sugar levels 

• Provide an area to administer medications (insulin)

• Provide appropriate containers for needles/syringe disposal

• Provide a rest area for reorientation after hypo/hyperglycemic episode

• Allow frequent breaks for food as needed

Neuropathy (Nerve damage):

• Modify job tasks requiring fine finger dexterity

• Provide protective clothing and equipment

• Eliminate or reduce the need to use sharp objects
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Fatigue or Weakness: 

• Allow frequent rest breaks

• Reduce or eliminate strenuous activities

• Provide anti-fatigue mats or padded carpeting

• Provide a rest area with cot

• Allow flexibility to sit or stand

• Allow job sharing

• Shorten work day and extend work week

Vision Impairment:

(Not an inclusive listing of accommodation ideas, see Accommodation Ideas for 

Individuals with Vision Impairments for further information at 

http://askjan.org/media/Sight.html)

• If the individual benefits from magnification, consider external 

magnification devices or computer screen magnification software

• If the individual does not benefit from magnification, consider Braille, 

tactile graphics, or assistive technology (e.g., screen reading software)

• Provide a tape recorder

• Provide a reader

• Allow flexible schedule to use public transportation to and from work

• Allow use of service animal for assistance with vision and/or mobility

Kidney Disease:

• Provide easy access to restroom facilities

• Allow a flexible schedule or time off for treatment (dialysis)

Cognitive Limitations: 

• Provide written job instructions and prioritize assignments

• Increase job structure

• Use of day planner or electronic organizer

• Provide flexible work hours

• Minimize distractions

Psychological Limitations:

• Reduce stress

• Allow time off for counseling or therapy
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Other Considerations:

• Provide area to brush teeth to prevent periodontal gum disease

• Evaluate safety hazards

• Avoid temperature extremes to help deal with poor circulation

• Educate coworkers on emergency situation procedures and identification 

of symptoms of hypoglycemia or hyperglycemia

Situations and Solutions:

A nurse with insulin-dependent diabetes and hypoglycemia was having problems 

regulating her condition (specifically, eating regularly while at work). Her schedule was 

altered by eliminating the evening rotation until her blood glucose levels could be 

controlled on a consistent basis. The employer reported this as a very effective 

accommodation. Cost of accommodation: none.

A data entry clerk with diabetes was having problems with vision. Her employer 

installed additional lighting in the file room and purchased a glare filter for her computer 

monitor to reduce eyestrain. Approximate cost: $30.

An employee in a manufacturing plant had difficulty working through an 8-hour shift 

without a break (typically employees work straight through). Accommodation 

suggestions: flexible schedule where a break can be provided if employee makes up the 

time by coming in 15 minutes early and staying 15 minutes later.

A cafeteria worker with diabetes had difficulty standing in one place for long periods of 

time. Accommodation suggestions: use anti-fatigue mats, sit/stand/lean stool, and 

frequent rest breaks.

An investigator was having problems balancing between reading text and his computer 

screen due to diabetic retinopathy. Accommodations suggestions: use task lighting; 

glare filter for computer monitor; and Closed Circuit Television with split screen to view 

text and computer monitor at same time.

A production assembly line worker had symptoms of frequent urination and neuropathy 

in his legs. The employee could not leave his work area except during scheduled 

breaks. Accommodation suggestions: use anti-fatigue mat, sit/stand/lean stool, and an 

in-house paging system to notify the supervisor that a replacement is needed while the 

employee takes a restroom break.

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 
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lists are accessible through this system; however, JAN provides these lists and many 

more that are not available on the Web site upon request. Contact JAN directly if you 

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

information, or are seeking a referral.

Terminology:

Blood Glucose: Blood glucose is the main sugar that the body makes from the food we 

eat. Glucose is carried through the bloodstream to provide energy to cells. The cells 

cannot use glucose without insulin.

Insulin: Insulin is a hormone that helps the body use blood glucose for energy. When 

people with diabetes cannot make enough insulin, they may need to inject it as a 

prescribed medication.

 

Hypoglycemia: Hypoglycemia is a condition that occurs when blood glucose levels are 

too low. The person can become cranky, tired, sweaty, hungry, confused, and shaky 

and is some instances can lose consciousness or experience a seizure. Eating sugar 

may treat this, for example soda, lifesavers, or glucose tablets. 

Hyperglycemia: Hyperglycemia occurs when blood sugar is too high. Insufficient 

insulin, overeating, inactivity, illness, stress, or a combination of these factors may 

cause this. Symptoms include extreme thirst, frequent urination, fatigue, blurred vision, 

vomiting, and weight loss.

Neuropathy: Neuropathy is a disease of the nervous system that may affect the organs, 

feet, and/or hands.

Diabetic Nephropathy: Diabetic Nephropathy, or kidney disease, occurs when there is 

damage to the kidney.
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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)633-7365

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 Association of Diabetes Educators

200 W. Madison Street

Suite 800

Chicago, IL 60606

Toll Free: (800)338-3633

aade@aadenet.org

http://www.diabeteseducator.org

The AADE is a multi-disciplinary professional membership organization dedicated to 

advancing the practice of diabetes self-management training and care as integral 

components of health care for persons with diabetes and lifestyle management for the 

prevention of diabetes. 

American Diabetes Association

1701 North Beauregard Street

Alexandria, VA 22311

Toll Free: (800)342-2383
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AskADA@diabetes.org

http://www.diabetes.org/ 

The American Diabetes Association is the nation's leading nonprofit health organization 

providing diabetes research, information and advocacy.

American Dietetic Association

National Center for Nutrition and Dietetics

120 South Riverside Plaza

Suite 2000

Chicago, IL 60606-6995

Toll Free: (800)877-1600

http://www.eatright.org 

ADA members are the most valued source of food and nutrition services. 

American Heart Association

7272 Greenville Avenue

Dallas, TX 75231

Toll Free: (800)242-8721

http://www.americanheart.org

The American Heart Association is dedicated to providing education and information on 

fighting heart disease and stroke.

Diabetes Exercise & Sports Association

8001 Montcastle Dr.

Nashville, TN 37221

Toll Free: (800)898-4322

Fax: (615)673-2077

desa@diabetes-exercise.org

http://www.diabetes-exercise.org 

Diabetes Exercise & Sports Association (DESA) exists to enhance the quality of life for 

people with diabetes through exercise and physical fitness. 

Indian Health Service

Division of Diabetes Treatment and Prevention 

National Diabetes Program

5300 Homestead Road, NE

Albuquerque, NM 87110

Direct: (505)248-4182

diabetesprogram@ihs.gov

http://www.ihs.gov/MedicalPrograms/Diabetes/ 
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The mission of the Indian Health Service (I H S) National Diabetes Program is to 

develop, document, and sustain a public health effort to prevent and control diabetes in 

American Indian and Alaska Native peoples. 

Juvenile Diabetes Research Foundation International

120 Wall Street

New York, NY 10005-4001

Toll Free: (800)533-CURE

Direct: (212)785-9500

info@jdrf.org

http://www.jdf.org 

Mission is to find a cure for diabetes and its complications through the support of 

research.

National Diabetes Information Clearinghouse (NDIC)

Building 31. Rm 9A06

31 Center Drive, MSC 2560

Bethesda, MD 20892-2560

Direct: (301)496-3583

http://www.niddk.nih.gov

An information and referral service of the National Institute of Diabetes and Digestive 

and Kidney Diseases. The clearinghouse responds to written inquiries develops and 

distributes publications about diabetes and maintains a database of patient and 

professional education materials.

National Eye Institute

National Eye Institute Information Office

31 Center Drive MSC 2510

Bethesda, MD 20892-2510

Direct: (301)496-5248

2020@nei.nih.gov

http://www.nei.nih.gov 

The National Eye Institute (NEI) was established by Congress in 1968 to protect and 

prolong the vision of the American people.

National Institute of Diabetes & Digestive & Kidney Diseases

Office of Communications & Public Liaison

Building 31, Room 9A06

31 Center Drive, MSC 2560

Bethesda, MD 20892-2560

http://www.niddk.nih.gov
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The National Institute of Diabetes and Digestive and Kidney Diseases conducts and 

supports research on many of the most serious diseases affecting public health. The 

Institute supports much of the clinical research on the diseases of internal medicine and 

related subspecialty fields as well as many basic science disciplines. 

National Kidney Foundation

30 East 33rd St., Suite 1100

New York, NY 10016

Toll Free: (800)622-9010

http://www.kidney.org

The National Kidney Foundation, Inc., a major voluntary health organization, seeks to 

prevent kidney and urinary tract diseases, improve the health and well-being of 

individuals and families affected by these diseases, and increase the availability of all 

organs for transplantation. 

Veterans Health Administration

Program Chief, Diabetes 

Veterans Health Affairs

810 Vermont Avenue NW

Washington, DC 20420

Direct: (202)273-5400

http://www1.va.gov/diabetes/index.cfm

The mission of the Veterans Healthcare System is to serve the needs of America's 

veterans by providing primary care, specialized care, and related medical and social 

support services.
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References

Centers for Disease Control and Prevention. (2007). Basics about diabetes. Retrieved 

September 5, 2008, from http://www.cdc.gov/diabetes/faq/basics.htm 

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.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.