Intellectual or Cognitive 

Impairments 

Accommodation and Compliance Series
Practical Solutions • Workplace Success 

2 

Preface 

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

Employment Policy of the U.S. Department of Labor. JAN makes documents available 

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contact JAN. 

Updated 05/19/11. 
Practical Solutions • Workplace Success 

3 

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 Intellectual or Cognitive Impairments 

What are intellectual or cognitive impairments? 

According to the American Association on Intellectual and Developmental Disabilities, 

an intellectual disability is a disability that involves significant limitations both in 

intellectual functioning and in adaptive behavior. Adaptive behaviors include many 

everyday social and practical skills such as interpersonal and communication skills, 

social problem solving and responsibility, the use of time and money, as well as daily 

personal care and safety. Limitations in individuals often coexist with strengths, and will 

vary from individual to individual. This disability originates before the age of 18 and 

encompasses a wide range of conditions, types, and levels. Intellectual disability is 

caused by factors that can be physical, genetic, and/or social. http://www.aaidd.org/ 

According to the President's Committee for People with Intellectual Disabilities, an 

estimated seven to eight million Americans of all ages experience intellectual disability. 

Intellectual disabilities affect about one in ten families in the United States. 

http://www.acf.hhs.gov/programs/pcpid/ 

What causes intellectual or cognitive impairments? 

Intellectual or cognitive impairments can start anytime before a child reaches the age of 

18 years. Persons who have intellectual disabilities may have other impairments as 

well. Examples of coexisting conditions may include: cerebral palsy, seizure disorders, 

vision impairment, hearing loss, and attention-deficit/hyperactivity disorder (ADHD). 

Persons with severe intellectual disabilities are more likely to have additional limitations 

than persons with milder intellectual disabilities (EEOC, 2011). 
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Intellectual or cognitive impairments can start anytime before a child reaches the age of 

18 years. Persons who have intellectual disabilities may have other impairments as 

well. Examples of coexisting conditions may include: cerebral palsy, seizure disorders, 

vision impairment, hearing loss, and attention-deficit/hyperactivity disorder (ADHD). 

Persons with severe intellectual disabilities are more likely to have additional limitations 

than persons with milder intellectual disabilities (EEOC, 2011). 

Additional Helpful Terminology 

Developmental disabilities that may also include an intellectual disability are briefly 

described below. Intellectual disabilities can also be caused by a head injury, stroke or 

illness. For some no cause is found. Intellectual disabilities will vary in degree and effect 

from person to person, just as individual capabilities vary considerably among people 

who do not have an intellectual disability. People should not make generalizations about 

the needs of persons with intellectual disabilities. In some instances an intellectual 

disability will not be obvious from a person's appearance, nor will it be accompanied by 

a physical disability. Persons with intellectual disabilities successfully perform a wide 

range of jobs, and can be dependable workers. (EEOC, 2011) 

Autism: Individuals with disabilities on the autism spectrum may have complex 

developmental disabilities that typically appear during the first three years of life. These 

disabilities are the result of a neurological disorder that affects the normal functioning of 

the brain, impacting development in the areas of social interaction and communication 

skills. Both children and adults with disabilities on the autism spectrum typically show 

difficulties in verbal and non-verbal communication, social interactions, and play or 

leisure activities. http://www.autism-society.org 

Cerebral Palsy is a condition, sometimes thought of as a group of disorders, that can 

involve brain and nervous system functions such as movement, learning, hearing, 

seeing, and thinking. Cerebral palsy is caused by injuries or abnormalities of the brain. 

Most of these problems occur as the baby grows in the womb, but they can happen at 

any time during the first two years of life, while the baby's brain is still developing. 

http://www.ncbi.nlm.nih.gov/guide/ 

Down Syndrome is a genetic disorder that causes lifelong intellectual disabilities, 

developmental delays and other complications. Down syndrome varies in severity, so 

developmental problems range from moderate to serious. Down syndrome is the most 

common genetic cause of severe intellectual disabilities in children. Individuals with 

Down syndrome have a higher incidence of heart defects, leukemia, sleep apnea, and 

dementia later in life. http://www.TheArc.org 

Fetal Alcohol Syndrome is a condition that results from prenatal alcohol exposure. It is a 

cluster of mental and physical birth defects that include intellectual disabilities, growth 

deficits, central nervous system dysfunction, craniofacial abnormalities and behavioral 

instabilities. Fetal Alcohol Effect is a less severe set of the same symptoms. It is the 

only form of intellectual disability that can be totally prevented and eradicated. 

http://www.nofas.org 

Fragile X Syndrome is a hereditary condition that can cause learning problems ranging 

from subtle learning disabilities and a normal IQ, to severe intellectual disabilities and 
Practical Solutions • Workplace Success 

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autism. Individuals with Fragile X Syndrome may also have physical and behavioral 

disorders, and speech and language delays. http://nfxf.org 

Prader-Willi Syndrome (PWS) is the most common known genetic cause of lifethreatening obesity in children. PWS typically causes low muscle tone, short stature if 

not treated with growth hormone, and a chronic feeling of hunger that, coupled with a 

metabolism that utilizes drastically fewer calories than normal, can lead to excessive 

eating and life-threatening obesity. PWS is also characterized by motor development 

delays along with some behavior problems and unique medical issues. Intellectual 

deficits can be present to varying degrees, but even higher functioning individuals will 

have learning difficulties. http://www.pwsausa.org 
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Intellectual Disabilities and the Americans with Disabilities Act

Are Intellectual Disabilities covered 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 on a 

case by case basis (EEOC Regulations . . . , 2011). 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 Regulations . . . , 2011). 

However, according to the Equal Employment Opportunity Commission (EEOC), the 

individualized assessment of virtually all people with an intellectual disability will result in 

a determination of disability under the ADA; given its inherent nature, an intellectual 

disability will almost always be found to substantially limit the major life activity of brain 

function (EEOC Regulations . . . , 2011).
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Accommodating Employees with Intellectual or Cognitive 

Impairments 

Note: People with intellectual or cognitive impairments may have some of the limitations 

discussed below, but seldom have all of them. Also, the degree of limitation will vary 

among individuals. Be aware that not all people with intellectual or cognitive 

impairments 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 does the employee with intellectual or cognitive impairments 

experience? 

2. How do these limitations affect 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 accommodations? 

5. Can the employee provide information on possible accommodation solutions? 

6. Once accommodations are in place, can meetings take place to evaluate the 

effectiveness of the accommodations? Can meetings take place to determine 

whether additional accommodations are needed? 

7. Would human resources or personnel departments, supervisors, or coworkers benefit 

from education, training or disability awareness regarding intellectual or cognitive 

impairments? Can it be provided? 
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Accommodation Ideas for Limitations in Cognitive Abilities 

Reading: Depending on cognitive abilities, people with Intellectual Disabilities may not 

be able to read information in the work environment. 

 Provide pictures, symbols, or diagrams instead of words 

 Read written information to employee 

 Provide written information on audiotape 

 Use voice output on computer 

 Use line guide to identify or hi-light one line of text at a time 

Writing: Depending on cognitive abilities, people with Intellectual Disabilities may not 

be able to write, spell, sign documents, or otherwise communicate through written word. 

 Provide templates or forms to prompt information requested 

 Allow verbal response instead of written response 

 Allow typed response instead of written response 

 Use voice input on computer 

 Use spell-check on computer 

 Use a scribe to write the employee’s response 

 Provide ample space on forms requiring written response 

Memory: People with Intellectual Disabilities might have memory deficits due to 

auditory processing problems, cognitive inability to retain information, or congenital 

hearing impairment. 

 Use voice activated recorder to record verbal instructions 

 Provide written information 

 Provide checklists

 Prompt employee with verbal cues (reminders) 

 Post written or pictorial instructions on frequently-used machines 

Performing Calculations: Depending on cognitive abilities, people with Intellectual 

Disabilities may not be able to count, tally, measure, or track due to an inability to “do 

math” or perform calculations involving numbers. 

 Allow use of calculator 

 Large-display calculator 

 Talking calculator 

 Use counter or ticker 

 Make pre-counted or pre-measured poster or jig 

 Provide talking tape measure 

 Use liquid level indicators 

 Mark the measuring cup with a “fill to here” line 
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Organization: People with Intellectual Disabilities may be disorganized due to an 

inability to retain information and/or an inability to transfer or apply skills in different work 

environments. 

 Minimize clutter 

 Color-code items or resources 

 Provide A-B-C chart 

 Provide 1-2-3 chart 

 Divide large tasks into multiple smaller tasks 

 Avoid re-organization of workspace 

 Label items or resources 

 Use symbols instead of words 

 Use print labels instead of hand-written labels 

 

Time Management/Performing or Completing Tasks: People with Intellectual 

Disabilities may have limitations in adaptive skills, such as self-initiating tasks. 

 Provide verbal prompts (reminders)

 Provide written or symbolic reminders

 Use alarm watch or beeper

 Use jig for assembly to increase productivity 

 Arrange materials in order of use 

 Use task list with numbers or symbols 

 Avoid isolated workstations 

 Provide space for job coach 

 Provide additional training or retraining as needed 

Accommodations for Limitations in Motor Abilities 

Using Computer: People with Intellectual Disabilities might have difficulty using the 

computer. This may be due to manual dexterity deficits, spasticity or rigidity, paralysis, 

or birth defects involving the fingers, hands, or arms. 

 Use key guard 

 Use alternative input devices 

 speech recognition 

 speech output 

 trackball 

 joystick 

 touchscreen 
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Using Telephone: People with Intellectual Disabilities might have difficulty using the 

telephone. This may be due to manual dexterity deficits, spasticity or rigidity, paralysis, 

or birth defects involving the fingers, hands, or arms.

 Use large-button phone 

 Use phone with universal symbols (fire, police, doctor) 

 Use phone with speed-dial, clearly labeled 

 Use receiver holder 

 Use headset 

Accessing Workspace: People with Intellectual Disabilities may have difficulty 

accessing the workspace. This may be due to muscle weakness or fatigue, an inability 

to stand for long periods of time, inability to walk long distances, inability to reach items, 

or an inability to carry/move heavy objects.

 Place anti-fatigue mats at workstation 

 Use motorized scooter 

 Use stools at workstations 

 Move items within reach 

 Provide frequent rest breaks 

Handling or Grasping Objects: People with Intellectual Disabilities might have 

difficulty handling or grasping objects. This might be due to an inability to pinch or grip, 

inability to maintain a steady hand, muscle weakness, or joint pain. 

 Use ergonomic tools, handle build-ups, or other tool adaptations 

 Use orthopedic writing aids 

 Use grip aids 

 Use jig or brace 

Accommodations for Limitations in Social Abilities 

Emotional Support: People with Intellectual Disabilities may need more or different 

emotional support in the workplace. 

 

 Give positive feedback 

 Use visual performance charts 

 Provide tangible rewards 

 Use co-workers as mentors 

 Use Employee Assistance Program (EAP) 

 Provide job coach 
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Interacting with Co-Workers: People with Intellectual Disabilities may have limitations 

in adaptive skills, such exhibiting appropriate social skills. 

 Provide sensitivity training (disability awareness) to all employees 

 Use role-play scenarios to demonstrate appropriate behavior in workplace 

 Use training videos to demonstrate appropriate behavior in workplace 

 Model appropriate social skills 

 Where to eat at work 

 When to eat at work 

 When to hug other co-workers 

 How to pay for coffee 

 What to do if you are mad 

 Who to ask for help 

 When to leave your workstation 

Working Effectively with Supervisors: People with Intellectual Disabilities may have 

limitations in adaptive skills, such as communicating with others and exhibiting 

appropriate social skills. 

 Communicate one-to-one with employee 

 Deal with problems as they arise 

 Keep job coach informed

 Train supervisors on communication etiquette

 Discuss disciplinary procedures

 Monitor effectiveness of accommodations currently provided

Situations and Solutions:

A production worker with intellectual or cognitive impairments and Cerebral Palsy had 

difficulty grasping a plastic bottle to accurately apply an adhesive label. JAN suggested 

making a wooden jig, which secured the bottle, thus allowing the employee to use both 

hands when applying the label. 

A grocery stocker with intellectual or cognitive impairments could not remember to wear 

all parts of his uniform. JAN suggested taking a picture of the employee in full uniform 

and providing the picture to use as a reference when preparing for work. 

A store clerk with intellectual or cognitive impairments had limited reading skills, making 

it difficult to return DVDs to the shelf. JAN suggested making picture labels for DVD 

cases that matched shelf display boxes. This allowed the employee to match pictures, 

not words, when returning DVDs to the shelf. 
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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. 
Practical Solutions • Workplace Success 

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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. 

President's Committee for People with Intellectual Disabilities 

Administration for Children and Families 

Aerospace Center, Suite 701 

370 L’Enfant Promenade, SW 

Washington, DC 20447 

Direct: (202)619-0634 

Fax: (202)205-9519 

satwater@acf.hhs.gov 

http://www.acf.hhs.gov/programs/pcpid 

Acts in an advisory capacity to the President and the Secretary of Health and Human 

Services on matters relating to programs and services for persons with mental 

retardation. 
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ARC of the United States 

1010 Wayne Ave. 

Suite 650 

Silver Springs, MD 20910 

Direct: (301)565-3842 

Fax: (301)565-3843 

info@thearc.org 

http://thearc.org 

Provides easy access to facts, contacts, and news updates that will help you learn more 

about its constituents and advocacy. 

ASPEN of America, Inc. 

2020 Pennsylvania Aven, N.W. 

Box 771 

Washington, DC 20006 

Toll Free: (866)4AS-PRGR 

Direct: (904)745-6741 

http://www.asperger.org 

Committed to providing the most up-to-date and comprehensive information on 

Asperger Syndrome and related conditions. 

American Association for Intellectual and Developmental Disabilities 

formerly the American Association For Mental Retardation 

444 North Capitol Street, NW 

Suite 846 

Washington, DC 20001-1512 

Toll Free: (800)424-3688 

Direct: (202)387-1968 

Fax: (202)387-2193 

http://www.aaidd.org 

Promotes progressive policies, sound research, effective practices, and universal 

human rights for people with intellectual disabilities. 

Association for Persons in Supported Employment 

1627 Monument Avenue 

Richmond, VA 23220 

Direct: (804)278-9187 

Fax: (804)278-9377 

apse@apse.org 

http://www.apse.org 

Created to improve and expand integrated employment opportunities and services for 

persons with severe disabilities, including mental disabilities. 
Practical Solutions • Workplace Success 

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Austistic Self Advocacy Network, The 

1660 L St. NW 

Suite 301 

Washington, DC 20036 

info@autisticadvocacy.org 

http://www.autisticadvocacy.org 

The Autistic Self Advocacy Network seeks to advance the principles of the disability 

rights movement with regard to autism. ASAN believes that the goal of autism advocacy 

should be a world in which Autistic people enjoy the same access, rights, and 

opportunities as all other citizens. 

Autism Society of America 

7910 Woodmont Avenue 

Suite 300 

Bethesda, MD 20814-3067 

Toll Free: (800)3AU-TISM 

Phone: (301)657-0881 

info@autism-society.org 

http://www.autism-society.org 

Promotes lifelong access and opportunities for persons within the autism spectrum and 

their families to be fully included, participating members of their communities through 

advocacy, public awareness, education, and research related to autism. 

National Association of Councils on Developmental Disabilities 

225 Reinekers Ln. Suite 650-B 

Alexandria, VA 22314 

Direct: (703)739-4400 

Fax: (703)739-6030 

info@nacdd.org 

http://www.nacdd.org/ 

Strives to provide support & assistance to member Councils in order to promote a 

consumer and family centered system of services and supports for those with 

Developmental Disability(s). 

National Down Syndrome Society 

666 Broadway 

New York, NY 10012 

Toll Free: (800)221-4602 

Fax: (212)979-2873 

info@ndss.org 

http://www.ndss.org 
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The NDSS' goal is to ensure that all people with Down syndrome have the opportunity 

to achieve their full potential in community life. 

National Organization on Fetal Alcohol Syndrome 

900 17th Street NW 

Suite 910 

Washington, DC 20006 

Toll Free: (800)666-6327 

Direct: (202)785-4585 

Fax: (202)466-6456 

http://www.nofas.org/ 

Dedicated to eliminating birth defects caused by alcohol consumption during pregnancy, 

and improving the quality of life for those individuals and families affected. 

U.S. Department of Education: Office of Civil Rights 

Customer Service Team 

400 Maryland Avenue, SW 

Washington, DC 20202-1100 

Toll Free: (800)421-3481 

TTY: (877)521-2172 

Fax: (202)245-6480 

OCR@ed.gov 

http://www.ed.gov/about/offices/list/ocr/index.html?src=mr 

Ensures equal access to education and to promote educational excellence throughout 

the nation through vigorous enforcement of civil rights. 

United Cerebral Palsy 

1660 L Street, NW, Suite 700 

Washington, DC 20036 

Toll Free: (800)872-5827 

Direct: (202)776-0406 

TTY: (800)872-5827 

Fax: (202)776-0414 

info@ucp.org 

http://www.ucp.org 

United Cerebral Palsy's mission is to advance the independence, productivity, and full 

citizenship of people with cerebral palsy and other disabilities through its commitment to 

the principles of independence, inclusion, and self-determination. 
Practical Solutions • Workplace Success 

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References 

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

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

Retrieved September 4, 2008, from http://askjan.org/links/ADAtam1.html 

Equal Employment Opportunity Commission. Questions and Answers about Workers 

with Intellectual Disabilities in the workplace. Retrieved August 4, 2008, from 

http://www.eeoc.gov/facts/intellectual_disabilities.html 

EEOC Regulations To Implement the Equal Employment Provisions of the Americans 

With Disabilities Act, as Amended, 29 C.F.R. § 1630 (2011). 
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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.