Q4 is in full swing, and Team Cocoon is busy building new functionality to take even more off your team’s plate. Keep reading to learn more about how you can leverage two top-requested features, email visibility and employee SSO, as well as several smaller but impactful updates. Because managing leave should not be the spookiest thing you encounter this October.
Full context in a couple clicks: introducing email visibility in Cocoon
You can now see all notices and emails we send to each employee right in your Cocoon Dashboard. Your Leave Log will include the details (time stamp, attachments, subject line, anyone cc’d) and full text of any compliance notice or email employees receive throughout their leave. We already took this communication work off your plate, and now we’re showing our work to make sure you’re always in the loop. This level of real-time visibility is one of the many benefits of a tech-powered leave solution, and we’re excited to see this top-requested feature out in the wild. Check out the experience below.
SO long email and password, welcome SSO for employees
Why should Admins have all the fun? Our new SSO login option for employees gives your team an even more seamless experience the moment they interact with Cocoon. This new functionality also means employees don’t need a work email to use Cocoon—critical to expanding access to employees a wider range of job functions. Our SSO feature leverages OpenID Connect (OIDC), a secure protocol that verifies user identities, and works for most companies regardless of SSO provider.
Small wins, big impact
Some launches are flashier than others, but smaller improvements stack up over time to make a real impact to the overall experience for both People teams and employees. Our team is always hard at work to make incremental changes based on our community’s needs. Here are a few recent small but mighty updates that are now live:
Dayforce HRIS integration: Dayforce users can instantly sync their census data with Cocoon and leave manual uploads behind. Implementation takes about 15 minutes—get started on your Settings page.
Contact screen updates: Based on feedback, we updated the “Contact us” design to make it crystal clear to employees how to get the support they need at any time. Check it out below, and remember that employees can always request a call if they’d prefer to speak with one of our CLMS-certified leave specialists.

Guidance for CA EDD Certification for Continued Benefits: Things with the EDD aren’t always super straightforward, so we’re stepping in to help employees in California who may need to complete a Certification for Continued Benefits form. If applicable, CA employees will now see a specific task in their Dashboard, along with detailed Help Center articles on how to complete the required forms to ensure they get their benefits without hassle or delay.

Stay tuned: big things are coming to expand leave access to employees who need it
First up: we’re hard at work on building a brand new experience for intermittent medical and caregiver leaves in Cocoon. This functionality will help expand access to critically-needed leave time for many employees, all while making a complex process less confusing, less time consuming, and less prone to human error. Keep your eyes peeled for a launch announcement in the coming weeks.
And last but in no way least….support for hourly employees is coming! Our mission to empower every working person to take care of what matters most is certainly not limited to those with standard Mon-Fri, 9am-5pm schedules. Our team is busy building to expand Cocoon’s product support to those with fixed (i.e. doesn’t change week over week) hourly schedules by the end of the year. Building the future of leave is a long road, and we’re excited to approach this milestone of expanding access to a reliable, seamless leave experience for this employee population.
We’ve said it once (or many times) and will say it again: here at Cocoon, we’re committed to keeping you fully in the loop along the journey toward transforming leave. Have feedback or thoughts on anything above? Feel free to share them directly with our Product Marketer, Libby Buttenwieser, at product-feedback@cocoon.com.
Anyone who’s ever managed leave knows that people take leave in many different ways—and it’s often not in a single, continuous period. This is known as intermittent leave, a type of leave employers struggle to administer because of the complexity and special FMLA rules that apply. Navigating complexity is our middle name, so we’ve put together this guide to help you understand those rules and feel more empowered to manage these important leave cases.
💡Pro tip: Get guidance on employee eligibility rules and what types of conditions apply for FMLA with our FMLA compliance checklist here.
What is FMLA intermittent leave?
A lot of leave cases are lumped into the intermittent leave category but there are some significant nuances that are important to call out. The TL;DR is that intermittent FMLA leave is any FMLA leave taken in separate blocks of time due to a single qualifying reason (this is governed by 29 CFR 825.202(a)). They can pose unique challenges for employers because the intermittent absence, regardless of duration, is legally protected regardless of the operational hardship it may pose. Employers often separate intermittent leave into three categories:
- Planned intermittent leave. This usually involves planned medical treatments or caregiver obligations. Employees can schedule the time off and work with their employers to address operational needs arising from the absences. This type of intermittent leave is fairly common.
- Unplanned intermittent leave. This type of intermittent leave often varies in duration, and arises when an employee’s or their family member’s medical condition flares up and they are unable to work as planned. This is where challenges arise, as the name suggests, the absence is unplanned.
- Reduced leave schedules. This is when an employee takes FMLA leave and works fewer hours than usual, but in a consistent, predictable schedule that will continue for an agreed upon duration. Here, an employee may move from full-time to part-time for a period, but they are still treated as a full-time employee for health care benefits and potentially other benefit programs.
For example, an employee will return to work following surgery for a limited, and gradually increasing work schedule (e.g., 20 hours for the first month following surgery, 30 hours the second month, 35 hours the fourth month, and then back full time).
For simplicity, we’ll refer to it as intermittent leave from here on out, but the advice can apply for all three types described above.
Reasons for intermittent leave
Not all FMLA leave can be taken intermittently, so it’s crucial for employers to understand which reasons for leave do qualify. Employees can take intermittent leave for their own medical condition or to care for a qualifying family member—these two reasons must be “medically necessary,” which is documented with a serious health condition form.
Some example reasons for leave:
- Chronic health condition flare-ups (IBS, arthritis)
- Mental health episodes (depression, anxiety attack)
- Ongoing conditions that require medical treatment 2+ times a year (squamous cell removal, cancer treatment follow-up care)
- Attending medical appointments for an ongoing condition (physical therapy, blood transfusion)
Intermittent leave obligations, nuances, and rights
Regardless of whether someone is taking a continuous, intermittent, or reduced schedule FMLA leave, many components and requirements are the same. However, there are a few nuances particular to intermittent leave. Here’s a simplified breakdown:
Obligations regardless of leave type
- Leave-takers must be eligible for FMLA:
- The employee must work for a covered employer.
- The employee must work at a worksite with at least 50 employees within 75 miles.
- The employee has worked for their employer for at least 12 months (and have logged 1,250 work hours during the 12 months immediately preceding their leave start date).
- Employees can take a maximum of 12 workweeks of FMLA leave in a 12-month period (except for military caregiver leave).
- Medical and caregiver leaves generally should provide medical certifications from a healthcare provider to demonstrate the need for it.
- Foreseeable leave should be requested at least 30 days in advance when possible, and ASAP for emergencies or sudden changes.
- Employers need to clearly communicate how employees can request FMLA leave (e.g., requesting leave in Cocoon).
Nuances particular to intermittent leave
- Employers have the right to request additional supporting medical documentation at certain intervals after an intermittent medical or caregiver leave starts. For example, if an employee’s doctor initially estimated six weeks for recovery, but after that time they request one day a week for physical therapy for two months, their employer could request this documentation from the healthcare provider at the end of the first six weeks, and again after the two months of physical therapy.
- Under FMLA, employees are not permitted to take intermittent leave for child bonding unless they clear it with their employer. There are also state leave laws where intermittent leave may be permitted for some or all qualifying leave types.
- Employees should make a reasonable effort to schedule treatments so as to not unduly disrupt employer’s operations.
Employees have the right to:
- Take intermittent leave (when medically necessary) in the smallest duration an employer accounts for in its payroll system (e.g. 15 minutes).
- Arrive or depart early or late to work when medically necessary due to a qualifying serious health condition.
- Have their job restored regardless of the hardship their intermittent absence caused to the business or other employees.
- Use their accrued paid time off (PTO) during periods of completely unpaid FMLA leave.
Employers have the right to:
- Require employees take FMLA intermittent leave in minimum increments, as long as that increment isn’t greater than one hour and the employee is not required to work.
- Request additional supporting medical documentation from an employee and their healthcare provider, like for:some text
- Planned medical treatment/appointment dates and times.
- Estimates of the frequency and duration of anticipated absences due to flare-ups of a condition.
- Recommended leave schedules, clarifying the specific schedule an employee could work, and the duration the employee would need to work on that schedule.
- Recertification if original documentation varies substantially from actual leave usage and needs, or they suspect there may be potential fraud or misuse of leave rights
- Require employees to request an intermittent leave like they would any other leave, and that when possible, they should call in an absence in a certain time frame before a scheduled shift.
Additional intermittent leave FAQs
Intermittent leave intersects and diverges with things like continuous leave and PTO, which can prompt some of these FAQs.
Can employers allow employees to use paid time off (PTO) instead of FMLA-qualifying intermittent leave?
No. Under the FMLA, once an employer knows that a request for PTO is for an FMLA-qualifying event, an employer must designate the absence as FMLA-qualifying. From there the employee can elect to use PTO to cover any unpaid portion of the leave. Ultimately, this is for the employee’s benefit to be protected by the FMLA and to avoid disciplinary actions if their employer perceives “absenteeism” versus a legally-protected absence.
Can employees use our company’s paid medical leave instead of FMLA/state leave laws for intermittent leave?
No. Again, if employers know an employee is absent for an FMLA-qualifying reason, they must designate that absence as FMLA-qualifying. Most employers run company medical leaves concurrently with FMLA or other statutory leaves to minimize the period of time an employee is away from work, but employers could run their own medical leave policy after FMLA is exhausted (aka “stacking”).
Also, employers should ensure that their company leaves are truly overlapping with FMLA leaves. Employers need to verify what conditions and situations their company’s leave policies do and do not address. For example, an employer’s leave policy might cover leave for family members that are not covered under FMLA (e.g., domestic partners, grandparents, and grandchildren). If employers feel unsure about any of this, we recommend going in-depth with our FMLA and parental leave checklists. Even if there’s already a policy in place, these checklists offer questions and considerations for situations employers might face with intermittent leave to help plan ahead.
Can you retroactively designate past intermittent leaves as FMLA?
It depends. Employers can retroactively designate FMLA leave if they send designations within the time frame required by law—which is within five business days of receiving all of the supporting documentation that they require to determine if the leave was FMLA-qualifying. If an employer takes longer than five days, they can still retroactively designate the absences as FMLA-qualifying, just as long as this doesn’t unfairly prejudice and impact the employee.
For example, if an employee was expecting to save their FMLA for the birth of their child, but it was retroactively designated towards a caregiver leave, they could argue that they would have pursued other options to care for their family member had they known about the designation.
Another example: if an employee was absent intermittently for 10 days in September, but an employer only received a complete and sufficient medical certification supporting the need for intermittent leave on September 30th, they could retroactively designate all of the September absences as FMLA-qualifying.
The bottom line
Navigating the complexities of intermittent leave is crucial for both employers and employees. By understanding its nuances and leveraging tools like Cocoon, organizations can ensure compliance while providing the flexibility that employees need during challenging times. A well-managed intermittent leave not only supports the health and well-being of employees but also maintains the smooth operation of the business. With the right approach and resources, intermittent leave can be a win-win situation, fostering a supportive workplace culture.
Even the most seasoned managers have lots of questions and doubts when a direct report takes leave—especially if it’s everybody’s first time. Yet, with over 10,000 leaves taken with Cocoon, we know first hand what it takes to plan a leave well, the questions people tend to have, and the factors that can best improve the employee experience. With Cocoon doing the heavy lifting on compliance, claims, and payroll, People Ops teams and managers can focus their time and attention on supporting an employee through a leave. Here we offer tons of tips, dos and don’ts, and even some templates to help you in the process.
Dos and don’ts upon finding out about an employee’s leave
People usually take leave as a result of a major life event. How you show up in that first conversation is important to get right. Here are some dos and don’ts to set the right tone.
Dos:
- Lead with empathy. Ask how they’re feeling, what their immediate needs and questions are—and truly listen to their answers.
- Keep your emotions in check. Make the leave-taker the protagonist, be steady and supportive for them.
- Show you’re willing to help. A leave-taker might not know what to say or do, and you might not either. Emphasize that you’re willing to learn and help them navigate.
- Lean into privacy and policy. Assume confidentiality with everything they tell you. Refer back to your organization’s leave policies so you understand what’s in scope and tap an HR partner to help you navigate policies in practice.
Don’ts
- Don’t jump in with solutions and advice. You don’t have all the information and answers. At this stage, it’s more important to listen and show your willingness to help them figure it out.
- Don’t make assumptions. Things that seem “happy” or “sad” can be fraught with all kinds of other emotions. Other details about their personal life and factors like race, class, and gender can impact a leave experience in ways you might not fully understand.
- Don’t make comparisons. Your own leave experience may or may not have anything to do with theirs. Your own experience helping another employee through their leave may or may not apply.
How to help a teammate prepare for a leave of absence
Once the wheels are in motion for an employee’s leave, it’s time to proactively plan with them around timelines, workloads, communication preferences, etc. For someone going on parental leave, you likely have a bigger window of time to hash out these details, whereas a medical, caregiver, and other leaves may come on suddenly—do your best to be proactive and to anticipate the unexpected while being reasonable with the time and resources you have.
💡Pro tip: download our leave transition plan worksheet so you can map out a leave plan together in a 1:1. It has a list of questions to work through, with space for your answers.
- Make a leave plan and timeline. Our leave options explorer tool is a great way to not only visualize timelines, but to play around with different scenarios to see how policies or pay change along the way. Write down your answers in the planning worksheet.
- Make sure they feel comfortable and confident using Cocoon. This may sound like a shameless plug, but the biggest questions leave-takers have tend to be around pay and filing claims—and Cocoon is precisely the place where they can file and receive this information accurately, with more help on topics that most managers and even People Ops leads aren’t experts on.
- Talk about pay and benefits. Though Cocoon has you covered here, it’s still important to discuss. Will any benefits be on hold while they’re out (e.g., stock vesting)? Tap HR, Accounting, and Legal teammates to make sure you’re giving accurate information.
- Document responsibilities, processes, and current work. Get an idea of their day-to-day and recurring tasks. Understand where projects they’re part of stand. Have them record tutorials to walk colleagues through tools or processes they may be unfamiliar with.
- Pass along logins and contacts. What tools do they use that you may need to access or pause the licenses for? Who do they regularly communicate with that you need the contact information of?
- Re-balance team workloads. Figure out who can cover what, what you may have to outsource, and what might need to go on hold. Have this discussion in a team meeting for visibility. Nobody wants to feel like they suddenly got work dumped on them or that they were overlooked.
- Discuss communication preferences. Generally, you shouldn’t contact someone on leave, but it’s important to set boundaries about how and when they might want to be contacted, and for what reasons.
Dos and don’ts while your employee is out on leave
By this stage, the plan you made has shifted into reality. While things don’t always go according to plan… these dos and don’ts keep you going steady on what you can control.
DON’T reach out… DO keep a one-pager of key updates
Though it might feel off to not check in, respect a leave-taker’s time away. Communications from a coworker might make them feel stressed or obligated to respond. Unless they have explicitly contacted you or asked to be contacted, a better way to handle this is by keeping track of team, project, and company updates as they happen and presenting them upon their return.
💡Pro tip: If you have a regular 1:1 with the leave-taker, instead of canceling it, use that time to work on the updates so you don’t get behind.
DON’T expect them to do work… DO start preparing for their return to work
Except for staying on top of timely claims paperwork (which Cocoon helps with), a leave-taker shouldn’t have anything on their to-do list. Instead, focus on planning for their return from leave. Understand what accommodations your company offers (e.g., schedule modifications) and start to think about handoffs and workload re-balancing. Get your key updates one-pager ready, and refer back to the list of their responsibilities and project work to understand how handoffs could work.
How to support a colleague after they return from leave
Whether a leave-taker is ready to return to work or hesitant to, this transition will be a big shift for everyone, especially the leave-taker. Let them set the pace, while being an effective ally to help them set and achieve the boundaries and accommodations they need. Here are some tips for a smooth return:
- Welcome them back. Make sure the team is aware of the leave-taker’s return date so they feel acknowledged and welcomed—but avoid making it a big spectacle or putting them on the spot.
- Have an open, real conversation. Find a good time to sit down for a private one-on-one to ask them how things went, how they’re doing and feeling, what they need. Don’t get into work duties and what they missed—focus on their experience and listening.
- Set ramp-up expectations. A leave-taker might need to set a particular schedule around their hours, or days they work from home vs. in-office. Communication norms should also be set (e.g., video off, no Slacks after 4pm). Loop in an HR partner to discuss additional accommodations, and explore them in Cocoon.
- Present the “things you missed” one-pager. Set aside time to go through your list of updates together, and also let them dive in by themselves. Answer any questions they may have.
- Re-balance workloads. Once a leave-taker is caught up, you can work as a team to determine what will be handed off, when, and how—ensuring the scope and pace of handoffs makes sense.
- Encourage community and support. Invite them to relevant Employee Resource Groups, Slack channels, or even informal communities within your organization so they can connect with others who can relate to their situation.
Taking leave is a transformative experience that comes with highs and lows, and there’s no single way to prepare for an employee’s leave because each situation is different. Yet in leading with empathy, having a supportive mentality, and getting organized with Cocoon, you will be in as good of a place as you can be to support a leave-taker. Cocoon is dedicated to helping you do just that by offering the technology that keeps up with the legal and financial requirements, as well as giving tips to help you navigate the emotional side. Doing so is an important part of being a great manager, with lasting impacts that can resonate through a leave-taker’s career and personal life.
Though ADA and PWFA leave accommodation requests can be processed in Cocoon, that’s only part of the puzzle for employees and employers to navigate as there are also non-leave accommodations (think modified work schedules, installing a ramp or modifying a workspace, and more). What counts as a reasonable non-leave accommodation will differ across industries, companies, and employees based on jobs, departments, timing, and other operational circumstances. What doesn’t change is the need for People Ops and HR teams to have a fair and consistent way to evaluate these requests. That’s why we’ve created an ADA non-leave reasonable accommodations guide and checklist, defining common terms, answering FAQs, and giving you the foundation for your own internal evaluation process when an accommodation request arises. For ADA leave accommodations, check out our webinar and recap blog.
When and why must employers consider reasonable accommodations?
Not everyone can perform the full extent of their job’s duties for a multitude of reasons. But when this is the case due to a disability recognized by the Americans with Disabilities Act (ADA) or a pregnancy-related condition under the Pregnant Workers Fairness Act (PWFA), businesses with more than 15 employees are legally required to consider and provide reasonable accommodations for qualified employees, unless doing so poses an undue hardship. Some state and local laws have even lower thresholds (e.g., they apply to employers with at least three employees and sometimes as low as just one employee). In other words: you don’t want to get this wrong because it likely applies to you.
Though this may entail making some changes or getting creative on the employer’s end, by supporting and enabling these employees to work with reasonable accommodations rather than excluding them, more employment opportunities exist and businesses experience less interruptions—ultimately benefiting workers and employers in the long run. The key is to find a reasonable solution for both parties.
What is a reasonable accommodation?
Under the Americans with Disabilities Act, a reasonable accommodation is “a modification or adjustment to a job, the work environment, or the hiring process. These modifications enable an individual with a disability to have an equal opportunity to get a job, successfully perform their job tasks, and enjoy the benefits and privileges of employment to the same extent as people without disabilities.” Though there isn’t an official list of what a reasonable accommodation would be (each case is unique), below we offer an extensive list of examples based on regulations and guidance the Equal Employment Opportunity Commission (EEOC) has provided under the ADA and PWFA.
The EEOC takes the position that any accommodation is reasonable unless it poses undue hardship for the employer.
Reasonable accommodations examples
Modifying facilities and equipment
- Changing the workspace layout (could be as simple as moving desks, avoiding stairs)
- Installing a ramp or modifying a restroom
- Implementing accessible or assistive materials, technologies, etc. (e.g., screen readers, teleconferencing with live captioning, materials in Braille or large print, sign language interpreters, accessible software platforms)
- Implementing or modifying equipment and uniforms (including equipment that assists with lifting or carrying)
- Providing seating or allowing for standing, to work without increased pain or risk to health (e.g., providing a sit/stand desk)
- Providing a reserved parking space
Modified work conditions, schedule, or location
- Part-time or modified work schedules (e.g., scheduling around medical appointments)
- Telework, remote work, or change of work site
- Policies allowing service animals at the facilities
- Permitting the use of paid leave (whether accrued, as part of a short-term disability program, or any other employer benefit) or providing unpaid leave
- Lactation, pumping, and breastfeeding accommodations including: some text
- Breaks and space for lactation near the workstation (as required under the PUMP Act).
- The pumping area is a regularly cleaned facility with electricity, seating, private, and not a bathroom. It should be in reasonable proximity to a sink, running water, and a refrigerator for storing milk.
- The ability to nurse during work hours (if the child is in close proximity.)
Changing the scope of the job
- Job restructuring
- Taking on a temporary role they are able to perform
- Reassignment to a vacant position
- (PWFA only) Temporary suspension of essential job function(s) until the pregnant worker is able to perform them again.
The hiring process
- Make the application process accessible by following Web Content Accessibility Guidelines (WCAG) standards.
- Offer various application and interview formats (video conferencing with captions, phone interviews with sign language interpreters).
- Make each candidate feel safe and comfortable to request accommodations.
Providing equal privileges of employment to all
- Offer inclusive benefits (e.g., commuter benefits that support wheelchair-accessible transit; gym or fitness course stipends are applicable, ensure all employees can fully participate in company offsites, etc.).
- Offer accessible trainings and workshops even if they are optional (e.g., translate materials into Braille, provide an interpreter).
The Equal Employment Opportunity Commission (EEOC)—who enforces the ADA and Pregnant Workers Fairness Act (PWFA)—takes the position that any accommodation is reasonable unless it poses undue hardship for the employer. For more technical resources and examples of reasonable accommodations, we recommend checking out the Job Accommodation Network (JAN)—a very comprehensive resource that’s even cited in the ADA.
What is undue hardship?
An undue hardship is a significant difficulty or expense, meaning an accommodation is extremely difficult to provide, given a company’s resources. Keep in mind that proving economic hardship requires employers to readily demonstrate their financial situation and potentially disclose their financials and internal policies in litigation or court should it get to that point. In determining whether an accommodation would impose an undue hardship, employers can consider:
- The nature and net cost of the accommodation, the effect on expenses and resources
- The number of employees, the number, type, and location of its facilities
- The type of operations conducted and functions of the workforce
- The impact upon the operation of the facility, other employees’ ability to perform their duties, and the ability to conduct business
For example, after exhausting all paid and unpaid leave due to a spinal injury, a bus driver requested an additional six weeks of unpaid leave to recover from a surgery related to the injury. Their employer denied the accommodation on the basis that they could not leave the role vacant as it would negatively affect commuters on that route; hiring and training a new employee to cover only six weeks was not realistic; and asking other employees to cover the work would be too costly in overtime. The employer won the case.
ADA reasonable accommodation checklist
💡 Pro tip: See how Cocoon helps you carry out this process compliantly by following along in our interactive demo here.
Step 1: Recognize the request
There are no magic words or special processes required under the law—an employee may simply say they need something to help them work because of a medical or pregnancy-related condition. Here are examples for pregnancy alone:
- An employee mentions that their morning sickness is making it hard to get to work at their scheduled starting time.
- An employee who gave birth 3 months ago requests an hour a week to attend treatments to help with a back problem that began during pregnancy.
- An employee goes to HR because they are concerned that continuing to lift heavy boxes will harm their pregnancy.
- An employee hasn’t filled out an accommodation form, but explains to her manager that her more frequent bathroom breaks are the result of her pregnancy.
- An employee tells a supervisor that she needs time off to recover from childbirth.
The request can be very informal, which is why it’s important to train managers to recognize when a request is on the table and the obligations that may ensue.
Step 2: Begin the interactive process
The initial request triggers the “interactive process,” which is a documented series of communications that explore or brainstorm accommodations. This documented process is critical for compliance. If any legal disputes arise, the interactive process will be examined closely to determine liability. Having reasonable accommodations policies, forms, and processes (and implementing them in a leave management system like Cocoon that can streamline the process for both employees and employers) helps operationalize and document the process. It also helps employees understand what their rights are and help them follow a process they are unfamiliar with.
In some places like California, failure to engage in the interactive process is illegal, even if there is no reasonable accommodation.
Step 3: Explore reasonable accommodation ideas, gather information
Start off by asking an employee themselves to suggest accommodations. If you need the employee to provide more information or documentation, you can also request that to help you understand the extent of their condition and solicit their healthcare provider for suggestions.
Meanwhile, start documenting things like the essential job functions and responsibilities of the employee’s role, a list of prior accommodations provided for the employee or others. Explain that the accommodation should help the employee successfully perform their essential job functions.
Step 4: Give your initial assessment and obtain additional feedback
Your response might be a simple yes or entail negotiating, making a compromise, or exploring an interim solution. At the end of the day, employers should give primary consideration to the accommodation desired by an employee (or recommended by their healthcare provider). Many times, the accommodations are affordable and reasonable. Focusing on accommodations that make continued work possible can prevent the need for leave or the employee leaving the workforce altogether. If you are denying the request, you should be prepared to demonstrate undue hardship.
Step 5: Implement the accommodation
If you are able to make the reasonable accommodation and have completed your discussions with the employee, now you’re ready to implement it. Depending on the type of accommodation, this could mean purchasing new equipment, construction on or modification of a facility, or announcing schedule changes to the team. At this stage, you also need to work out how you will communicate with other employees who have a business need to know about the accommodation (while complying with confidentiality obligations) so they know how it might impact them or their work, or other changes that might be coming. Discuss this directly with the employee requesting an accommodation to ensure they understand the efforts you are taking to protect their privacy while also not springing a surprise on other employees who have a business need to be aware of the accommodation.
The bottom line
This guide to reasonable non-leave accommodations for ADA and PWFA is just a start. When businesses and employees can reasonably explore, request, and provide reasonable accommodations, they strike the balance of support and empowerment, keeping businesses running, and employees employed—a win, win for all.
Hello and welcome to Q3! It might be summertime, but Team Cocoon shows no signs of slowing down on evolving our product to better serve the needs of our community. This month’s updates bring more automation to help Admins save time on day-to-day leave management, and improve two key experiences in Cocoon based directly on employee feedback. Let’s dive in.
Easily manage your top to-do’s with our revamped Admin Dashboard
The Cocoon Admin Dashboard got a glow-up this month with the introduction of our new Tasks page. Nobody likes that feeling of “did I forget something really important?” or “I remember seeing an email reminder about something but now I have no idea what it was.” Our Admin Tasks page saves you the time and stress over staying on top of your leave management to-do’s by surfacing all of your tasks in one central place.
At login, Admins will now see a clear list of all high-priority tasks they need to action on: reviewing accommodation or personal leave requests, uploading new census files, or executing repayments to employees. You can filter by status, date, or category, with categories like “Blocking employee” to help you prioritize. And don’t worry—our good ol’ Leaves view is just a click away using our nifty new sidebar nav. Check out the walkthrough below for a preview.
Workday x Cocoon: a LOA match made in heaven
You asked, we listened (and built the thing). Our two-way integration with Workday is here! Our newest API integration instantly syncs employees’ leave status and dates to Workday in real-time, giving Workday users the full picture of employee leave right in their HRIS. No more painstaking and error-prone manual work to input leave dates in Workday or update them any time an employee changes their plan—which, spoiler alert, happens a lot. Pair this with our integration to automatically sync census information from Workday to Cocoon and save yourself hours per week to do literally anything else.
Uploading paperwork, simplified
Next up: we’ve made it even easier for employees to upload their medical and claim forms to their “Your tasks” Dashboard in Cocoon. We heard from employees that the previous experience of uploading one big PDF with all forms including (serious health condition, private disability claim, and state claim in some cases) made the next steps a little ambiguous.
Our new experience breaks out the upload tasks for each unique document type and gives employees clearer guidance to avoid any confusion. And—we now give employees specific instructions and FAQs on how to complete each document type. A small step for the “Your tasks” Dashboard, but a big stride for clarity and ease throughout the leave journey.

Honorable mention: more granular leaves reporting
Last but not least, we’d be remiss not to mention that we’ve added three new columns to the Leaves report based on your feedback. When you download the report from the Leaves tab on your Admin Dashboard, it will now include columns to help you report in more detail about the state of your team’s leave:
- Employee ID
- Remote ID
- Employee Payroll ID
A few extra columns on a report might not sound like much, but we get pretty excited about anything that saves our partners time or hassle on manual leave management work.

From automating admin workflows to take more off People teams’ plates to consistently iterating on the employee experience, our team remains committed to hearing your feedback and pushing the boundaries of what technology-powered leave can look like. Stay tuned for more Cocoon release notes like this one as we head into the second half of 2024.
What is the Americans with Disability Act (ADA)?
The Americans with Disabilities Act (ADA) is a federal law that passed in 1990 that prohibits discrimination against individuals with disabilities in many aspects of society—including employment, transportation, public accommodations, communications, and access to state and local government programs and services. To make it even more complex, most states and many municipalities have their own laws that are closely modeled after the ADA.
If you don’t feel like reading the full text of the law, we can give you the SparkNotes: it’s illegal for covered entities (i.e. employers) to discriminate against qualified individuals with disabilities.
Still unclear? Understandable, so let’s break it down:
Covered entities under the ADA
The ADA applies to companies with 15 or more employees and prohibits discrimination in all aspects of employment, including hiring, firing, pay, job assignments, promotions, layoffs, training, fringe benefits, and other terms and conditions of employment.
Defining disability
The ADA protects employees and job seekers with disabilities. The ADA defines a person with a disability as someone who:
- Has a physical or mental impairment that substantially limits one or more major life activities,
- Has a record of such an impairment (like cancer in remission), or
- Is perceived by others as having such an impairment (this could be severe burns or the loss of a limb)
Official ADA regulations do not list all disabilities—there are a wide variety and not all disabilities are visible. Here are some additional examples from the U.S. Department of Justice, Civil Rights Division (this is not an exhaustive list!):
- Cancer
- Diabetes
- Post-traumatic stress disorder
- HIV
- Autism
- Cerebral palsy
- Deafness or hearing loss
- Blindness or low vision
- Epilepsy
- Mobility disabilities such as those requiring the use of a wheelchair, walker, or cane
- Intellectual disabilities
- Major depressive disorder
- Traumatic brain injury
Qualified individuals
To be protected under the ADA, an employee or job seeker with a disability must also be qualified to perform the “essential functions of the job” with or without reasonable accommodations that do not pose undue hardship on the employer.
Essential job functions:
These are often (unhelpfully) defined as the basic job duties. This phrase exists to ensure that anyone with a disability will not be deemed unqualified because of their inability to perform marginal job functions. If there is a written job description, that’s usually a good place to start to determine essential job functions.
With or without reasonable accommodation:
This can sometimes trip people up, but it just means that employees should be able to perform essential job duties on their own or with the help of a reasonable accommodation.
Undue hardship
The agency that enforces the ADA, the Equal Employment Opportunity Commission (EEOC), defines “undue hardship” as something that is significantly difficult or expensive. It focuses on the resources and circumstances of the specific employer related to the specific accommodation requested.
ADA requests from employees and ADA discrimination
ADA discrimination can manifest in a number of ways, but two common methods are:
- Treating qualified employees or job seekers with disabilities differently based on their disabilities in the terms and conditions of employment
- Failing to provide reasonable accommodations to otherwise qualified individuals with disabilities (unless doing so poses an undue hardship)
Assessing ADA requests requires an individualized, case-by-case assessment. To do this, employers must engage in an interactive dialogue with employees (and their health care providers, if necessary).
The interactive process
We have a whole guide to the interactive process here, along with a click-through demo so you can see exactly how this process works in Cocoon. But to summarize, employers must:
- Recognize the request from the employee
- Begin the interactive process
- Explore reasonable accommodation ideas and gather information (in partnership with the employee)
- Give an initial assessment
- Implement the accommodation
At Cocoon, we think of accommodations in two categories: leave accommodations, and non-leave accommodations. We’ll get into leave accommodations here, but check out our non-leave accommodation checklist for more information on that route.
Leave as an ADA accommodation
A reasonable accommodation can include modifying existing leave policies and providing leave even when it’s not covered by existing policies or state/federal leave laws (EEOC). But there is no rule that says an employer must always provide leave as an accommodation. It depends on the facts in each situation (hence the case-by-case assessment). How much time does the employee need? Is the leave sought for a definite or indefinite duration? Will the leave time be continuous or intermittent? Has the employee already taken leave? The list goes on… and on and on. To add another layer of complexity for employers, they must integrate ADA with the federal Family and Medical Leave Act (FMLA), which was passed three years after the ADA in 1993, plus state family and medical leave laws.
The FMLA covers employers with 50 or more employees and provides medical leave rights to employees who meet certain eligibility criteria such as tenure (12 months) and work hours (1,250 hours in the 12-month period immediately preceding leave). Because employers must provide leave under both the FMLA and ADA, the challenge is knowing when and how to do so. For example, if an employee can take FMLA leave, they don’t need ADA leave as a reasonable accommodation. But if employees need medical leave and they are not eligible for—or have exhausted—FMLA leave, the ADA suddenly becomes front and center, and employers must consider providing unpaid, job-protected leave as an ADA reasonable accommodation (if providing the leave doesn’t cause undue hardship).
Where to learn more about employer responsibilities under the ADA
Hopefully after reading this quick primer on the ADA, you have a better understanding of what it is and who is eligible. For a deeper dive into the topic, we recommend the following resources:
- US Dept of Justice, Civil Rights Division: Introduction to the Americans with Disabilities Act
- US Dept of Labor: Americans with Disabilities Act Overview
- Job Accommodation Network (JAN): Employers’ Practical Guide to Reasonable Accommodation under the ADA
Build a more inclusive workplace, stress less about compliance
Cocoon’s mission is to empower every working person to focus on the important things in life when it matters most—this is absolutely inclusive of workers with disabilities who have every right to the same opportunities as everyone else. Disability discrimination laws are not getting any easier to administer, and they aren’t going away. Workers deserve these rights, and People teams deserve solutions that help them streamline the process. We’re excited to usher in a new era of more inclusion and accessibility for Cocoon, especially as we continue to expand on this functionality.
We have bad news and we have good news. The bad news—employers have to stay up to date with yet another leave law that recently went into effect. The good news—we’re here to help you understand it. The Pregnant Workers Fairness Act (PWFA) has been in the works for a long time. It was signed into law in December of 2022, became effective in June of 2023, final regulations were released in April of 2024 and it finally went into effect on June 18, 2024.
tl;dr: What is the Pregnant Worker’s Fairness Act?
The PWFA requires that all employers with 15 or more employees provide reasonable accommodations for a qualified applicant’s or employee’s known limitations related to, affected by, or arising out of pregnancy, childbirth, or related medical conditions unless the accommodation will cause the employer “undue hardship.”
There’s a lot to unpack there, so keep reading for a deep dive into the PWFA ↓
“Qualified employees” under the PWFA and how it differs from the Americans with Disabilities Act (ADA)
As with most leave laws, employers must make decisions on a case-by-case basis and evaluate:
- The impact on an employee’s ability to perform their essential job functions with or without reasonable accommodations and
- If they are unable to do so, whether or not leave is a reasonable accommodation
In general, the definition of “qualified” under the PWFA is a bit different and actually more protective of employees than under the ADA. Like the ADA, an employee is qualified if they can perform the essential functions of the job with or without reasonable accommodation that does not pose an undue hardship. “With or without” reasonable accommodation just means that employees can perform essential job duties on their own or with the help of a reasonable accommodation. Under the PWFA, “essential functions” of a position are… the fundamental duties of the job (vague, we know, but you’ll have to take that up with Congress).
Unlike the ADA, an employee is also qualified if they cannot perform the essential function of the job and if these three things are true:
- The inability to perform the essential functions is “temporary”
- The employee can perform the functions “in the near future”
- The employee’s inability to perform the essential functions can be reasonably accommodated

Reasonable accommodations under the PWFA
A “reasonable accommodation” is a broad concept—it’s any change in the work environment or the way things are usually done at work. We like to think of accommodations as two categories: leave accommodations (time away from work), and then everything else. The PWFA is very clear that employers should focus mostly on the second category (everything else) and leave accommodations should be the last resort.
Examples of non-leave accommodations:
- Additional, longer, or more flexible breaks to drink water, eat, rest, or use the restroom
- Changes to a work schedule, such as having shorter hours, part-time work, or a later start time
- Remote work
- Temporary reassignment or modified work duties
This list is not exhaustive—there are many other reasonable accommodations that may make sense based on an employee’s situation. The accommodation process is dynamic, so an employee may need different accommodations at different times during pregnancy or after childbirth. Check out our non-leave accommodation checklist and see how Cocoon handles accommodation requests in an interactive demo for more details.
When employers might need to consider leave accommodations
Employers will usually need to consider leave as a reasonable accommodation if employees need time away from work to go to healthcare appointments or recover from childbirth or other medical conditions related to pregnancy and childbirth.

We recommend the following order of operations to kick off discussions with the employee:
- Determine whether or not any leave is available under the FMLA or state leave laws
- Confirm whether or not leave is available under your company leave policies
- If an employee has no leave available under laws or company policies, consider whether leave should be provided as a reasonable accommodation under the PWFA or ADA
How the PWFA interacts with FMLA and state leave laws
The PWFA runs concurrently with other leave laws and does not override any federal, state, or local laws. This means if there are overlapping legal obligations under multiple laws at the same time, employers must provide the most generous legal protection available to the employee.
If the employee qualifies for FMLA
If a pregnant employee qualifies for FMLA, the employer still must provide a reasonable accommodation under PWFA that would eliminate or reduce the pregnant employee’s need to take FMLA leave due to pregnancy-related limitations.
If there is no reasonable accommodation
On the other hand, if there is no reasonable accommodation that will enable the pregnant employee to continue working in lieu of leave, the pregnant employee can still take FMLA leave if available.
If the employee has exhausted FMLA and/or company leave policies
If FMLA is exhausted or unavailable, the pregnant employee may still be entitled to leave as a PWFA reasonable accommodation even if the employer does not offer leave as an employee benefit or the employee is not eligible for leave under the employer’s leave policy. Here are some (not all) of the situations where leave as a reasonable accommodation under the PWFA may be available:
- Prenatal appointments
- Recovery from childbirth
- Medical appointments
Where to learn more about the PWFA
The EEOC published a comprehensive summary of PWFA for employers that dives even deeper into the regulations: What You Should Know About the Pregnant Workers Fairness Act.
We’ve just scratched the surface here but it’s clear there’s a lot for employers to keep track of with PWFA, on top of managing run of the mill parental leaves. Chat with our team to see how you can seamlessly manage PWFA leave accommodations in Cocoon.
Challenge: A manual, in-house leave management process became unmanageable as ActiveCampaign rapidly expanded, causing administrative burdens for People Ops and a negative employee experience.
Solution: Implementing Cocoon's leave management platform streamlined the process, reducing administrative tasks and providing an intuitive, user-friendly experience for employees and managers.
Results:
- Significant reduction in time spent on leave admin work.
- Employees are empowered to plan their leave and understand pay, eligibility, and paperwork.
- Integrations and evolving software enhancements for continuous automation and scaling.
- Conversations about leave are more transparent and productive.
- Trusted partnership frees up time for strategic efforts like planning for open enrollment and global benefits expansion.
Keep reading for the whole story ↓
Meet Sarah Robillard, Senior Benefit Analyst @ ActiveCampaign
Though Sarah Robillard is just shy of rounding out her first year at ActiveCampaign—an intelligent marketing automation platform—it’s been a fast-paced year for her as a Senior Benefits Analyst. ActiveCampaign has grown to over 500 employees across the US alone, while also rapidly expanding their global operations—most recently in Krakow, Poland. To keep up with growth, Sarah and her team are always looking for ways to innovate and automate where they can. That way, they can focus on improving the employee experience and education around the full offering of benefits and total rewards. But before they had Cocoon, their in-house manual process for managing more leaves in more places was stopping them in their tracks.
ActiveCampaign’s in-house leave management becomes more complicated
“Before we had Cocoon, we actually administered leaves of absence entirely in-house,” explains Sarah. “And if you’re in the benefits space, you know how big of an undertaking that is.” With a small team tackling such a big endeavor for a rapidly-growing company, things became unmanageable. “On the People Ops side, we had colleagues tackling the day-to-day details of leave who really needed to be focused on larger, more strategic priorities. For employees, it wasn’t a great experience. There were a lot of confusing back and forth exchanges over FMLA paperwork. There was no straightforward way to plan, navigate, or get the right insights into managing a leave of absence.”
Why ActiveCampaign chose Cocoon for leave management
“Because we were used to handling leave administration from start to finish, even a small reduction in that would be a win for People Ops, so we really prioritized something that would offer a great experience for our employees, with an easy interface,” Sarah says. “One of our values is ‘Creating Wow’ and during the Cocoon demos, the team could really feel that. Sure, there are some ‘heavy hitters’ in the leave of absence vendor market, but Cocoon’s size and newness allow them to provide high-touch, excellent support for leave takers, and offer a fresh approach to managing leaves that bigger names simply aren’t. Onboarding Cocoon was the most seamless process I’ve seen with a leave management vendor.”
“It’s not just about having Cocoon, it’s about really trusting Cocoon, its software and processes, to take care of our employees and give them more ownership over their leave. We’re still involved in the process, but in a much more meaningful way. Overall, the experience with Cocoon has been overwhelmingly positive across the business.”
The biggest benefits of using Cocoon
In their first six months with Cocoon, ActiveCampaign managed 20 leaves. “Every single leave taker has said it was so straightforward and intuitive. They love the support from Cocoon’s team, as well as their support guides that explain things like managing pay and what’s next,” Sarah says, smiling. “For managers, they love getting reminders about employee dates and plans so they can prepare accordingly.”
“For us on the internal Benefits team, there’s been a significant reduction in the administrative burden related to leave management. Cocoon can automatically calculate and display certain information that we simply couldn’t. It’s a relief to know that pay and entitlements are correct in the portal, and we don’t have to manually update that anywhere, because Cocoon also integrates with Workday.”
“We also used to spend a lot of time explaining how leave pay and eligibility requirements worked. These can be difficult and confusing conversations, but with the way Cocoon visualizes and explains the information to leave takers, we get these questions far less, and the conversations that we do have are much more productive. They don’t feel like HR is just telling them something—they can interact with the information these decisions are based on.”
Why ActiveCampaign plans on sticking with Cocoon to manage leaves
While a smooth implementation is important, experiencing true ROI requires active, ongoing partnership—and that’s exactly what ActiveCampaign has with Cocoon. Sarah raves that, “Cocoon is committed to meeting our evolving needs, with a responsive approach showing they listen to feedback, make continuous enhancements, and update us about it.”
For example, “this might seem small,” Sarah laughs, “but we had a fitness for duty form for anyone taking a leave over a certain number of days. Cocoon didn’t yet have a feature to manage it. I sat down with our account manager to see if there was a way we could add it, only to find out that this feature was already in development, based on feedback from other customers, too! A few weeks later, Cocoon launched it and showed us how it worked.”
This trust and responsiveness is key for ActiveCampaign during the busy push leading up to open enrollment and renewals. “It’s not just about having Cocoon, it’s about really trusting Cocoon, its software and processes, to take care of our employees and give them more ownership over their leave. We’re still involved in the process, but in a much more meaningful way. Overall, the experience with Cocoon has been overwhelmingly positive across the business.”
About ActiveCampaign
ActiveCampaign helps small teams power big businesses with the must-have platform for intelligent marketing automation. Customers from over 170 countries depend on ActiveCampaign’s mix of pre-built automations and integrations (including Facebook, Google, WordPress, Salesforce, Shopify, and Square) to power personalized marketing, transactional emails, and one-to-one CRM interactions throughout the customer lifecycle. Learn more and start your free trial at ActiveCampaign.com.
Our momentum shows no signs of slowing down in Q2 2024 as we release more updates that take work off the plates of People teams and leave-takers alike. We’re particularly excited about these recent launches because they represent several top requests we’ve gotten from partners and our broader community over the past year. First up: hot off the heels of ADA accommodation leaves, our long-awaited product experience to support personal leaves is here—further empowering leaders everywhere to create more compassionate workplaces.
Keep reading for details about personal leaves, revamped Pay Dashboards, our new seamless fitness for duty process, and even more granular Admin visibility into denied leaves and FMLA balances.
Beyond FMLA: Introducing personal leaves in Cocoon
Today, we're thrilled to announce that Cocoon is expanding beyond FMLA and ADA-covered leave types with our new product experience for planning and managing personal leaves. Many companies offer personal leave (or they take it a step further with compassionate leave) policies to encourage employees to take time away from work for a reason that doesn’t fit into “traditional'' leave types, whether it be bereavement, caregiving for someone that doesn't fall under FMLA’s caregiver definition, or any number of other reasons.
Employees can now easily request a personal leave and track their progress right in Cocoon. We streamline communications and collect information from employees so that Admins can review each leave request, and track it alongside all others in one place. We talk a lot about how Cocoon differs from the traditional rep-based leave solution, and this launch is no different: we believe no one knows your employees and policy nuances like you do, so we give you control over the highly subjective and sensitive approval decision, while automating the little pieces of the puzzle to take as much off your plate as possible.
Fitness for duty form collection, simplified
Facilitating medical leaves is notoriously complex (that’s why we had a whole webinar on the topic), so we’re using software to take even more off your plate. Our new product experience makes collecting fitness for duty (FFD) forms easy:
Step 1: Cocoon automatically reminds employees to complete their certifications
Step 2: Employees upload the forms right in Cocoon
Step 3: Admins stay looped in every step of the way, automatically
No more juggling clunky PDF attachments or missing key information.
Track time balances and denied leaves with a couple clicks
At Cocoon, we’re all about giving People teams easy access to leave details that help them support employees quickly and with confidence. This time we’re adding visibility into leave balances and denied leaves because employees often want to know how much leave time they have left at any given moment. On the Eligibility details tab, you can now view each employee’s latest balances for FMLA and any applicable state laws to give them immediate answers. You can see:
- Total days
- Used days
- Remaining days

Cocoon Admins can also now view any planned medical leaves that were denied for missing or incomplete serious health condition forms right in their Dashboards. Medical leaves are not just complicated to administer—they are complicated for employees to navigate, too. This latest update will ensure you have full context to help employees get the right documentation to take the time they need to recover.
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Meet your new leave pay education hub
Last quarter we told you about our new in-depth Pay Trackers for both employees and Cocoon Admins. Today, we’re excited to share even more updates to our Pay Dashboards with the addition of new tooltips, explainers, and extensive resource libraries (with videos like this one) to help answer the most common pay questions—before they come up. Admins and employees can navigate to their dedicated resource libraries right in their Dashboards.
From giving more peace of mind around pay to to expanding the traditional meaning of a reason for leave, our team is laser-focused on building solutions that truly make life with leave easier. Stay tuned for more Cocoon release notes like this one as the year continues!
We’re thrilled to announce that ADP, a global leader in human capital management, has named Cocoon as a strategic partner in leave management. ADP continues to lead the evolution of the workplace with the employee experience at the center. Back in October, ADP announced an investment in Cocoon through their new investment arm, ADP Ventures. Today marks another big stride toward shaping the future of work with Cocoon available to ADP customers right on ADP Marketplace.
“Cocoon empowers our mid-market clients with the tools they need to navigate the complexities of leave and absence management with ease and confidence.”
Leading the way for leave innovation
ADP Ventures is committed to shaping a future where work is more enriching for People teams and their employees alike. Sound familiar? That’s because the best partnerships are built on a shared vision.
Cocoon is building the future of work by re-imagining leave with software that automates some of the most complex parts of the leave puzzle for People teams, all while giving employees a modern, seamless experience through user-friendly tools and always-on support. Our partnership with ADP sets the stage not only to bring those tools to many more mid-market ADP customers, but also to work with the expert ADP Ventures team as we evolve our solution with more powerful automation, new leave types, and beyond.
“ADP is committed to the future of the HCM [human capital management] industry…ADP Ventures invests in technology that enhances the human experience in ways that empower businesses to grow and their employees to succeed at work and life, says Usman Khan, SVP of ADP Ventures. “Cocoon empowers our mid-market clients with the tools they need to navigate the complexities of leave and absence management with ease and confidence.”

An easy choice for growing companies to navigate leave
Cocoon is now available on the ADP Marketplace, making it quick and easy for ADP customers to implement Cocoon and log in via SSO with their ADP credentials. And, our API integration with ADP Workforce Now® automatically syncs census data to Cocoon in real-time to ensure your employee information is always accurate, up-to-date, and secure. This saves People teams hours each month otherwise spent creating and manually uploading census files to a leave provider—one major benefit of this partnership, and of a software-powered leave platform like Cocoon. Existing mutual customers can immediately take advantage of the integration, too, via the Cocoon Data Connector for ADP Workforce Now®.
As workplaces become increasingly distributed, the future of work will require digital-first solutions that empower People teams to deliver premium employee experiences without operational complexity. Today's announcement marks a huge step in that direction. As Mahima, my co-founder and CEO of Cocoon, shared: "We couldn't be prouder to partner with ADP, one of the most trusted names in HR and people technology. Their employee-centric approach perfectly aligns with our vision of using technology to simplify leave for People leaders and expand access for individuals.”
ADP customers can learn more or schedule a demo through ADP Marketplace today. We hope you’ll join us in ushering in this new chapter for workplaces everywhere—onwards!
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