Editorial disclosure: AirCaps manufactures smart captioning glasses used by deaf and hard-of-hearing professionals across enterprise, healthcare, legal, and academic settings. This guide explains the ADA accommodation process generally and references our product alongside the broader landscape. Accommodation rules vary by employer, state, and circumstance — confirm specifics with your HR team, an EEOC counselor, or a disability rights attorney before filing.

How Do You Request Captioning Glasses as an ADA Workplace Accommodation?

You request captioning glasses as a reasonable accommodation by submitting a written request to your employer's HR or accessibility coordinator, attaching medical documentation of your hearing loss, and engaging in the ADA's required "interactive process." 61% of workplace accommodations cost employers $0 to implement, and the ones that do cost something carry a one-time median price of $300 (Job Accommodation Network, 2025). At $599, captioning glasses fall within the typical accommodation budget — and the math gets easier when you compare a one-time hardware purchase to ongoing CART or interpreter services that run $100 to $290 per hour (Karasch Captioning, 2024).

The ADA's Title I provisions cover roughly 666,000 U.S. businesses with 15 or more employees, including most knowledge-work employers (ADA National Network, 2024). If your employer falls in that group, they're legally required to consider your accommodation request — and the Job Accommodation Network's research shows 66% of employers rate the accommodations they implement as "very effective" or "extremely effective" (JAN, 2025). This guide walks through the request process step by step: what to write, what to attach, how the interactive process works, and what to do if the answer is no.

Key Takeaways

• 61% of workplace accommodations cost employers $0; the remaining 33% carry a one-time median cost of $300 — captioning glasses at $599 fit within the typical range (JAN, 2025)
• The ADA covers employers with 15+ employees, reaching roughly 86 million U.S. workers across 666,000 businesses (ADA National Network, 2024)
• 43.2% of EEOC merits suits filed in fiscal year 2024 contained ADA claims, and the agency filed 16 hearing-impairment cases across 2023-2024 — accommodation refusals are actively enforced (EEOC Office of General Counsel, 2024)
• At a $150/hour CART rate, a $599 captioning glasses purchase pays for itself after roughly 4 hours of comparable service (Karasch Captioning, 2024)
• Deaf adult employment hit a record 57.7% in 2024, but the gap to hearing peers still sits above 15 percentage points — meeting accessibility is the single biggest driver (National Deaf Center, 2024)

Table of Contents

• Does the ADA Actually Cover Captioning Glasses?
• What Does a Reasonable Accommodation Request Look Like?
• How Much Will Your Employer Actually Pay?
• Step-by-Step: The Interactive Process
• What Documents Should You Include?
• How to Write the Accommodation Request Letter
• What If Your Employer Says No?
• Captioning Glasses vs. CART, ASL, and Other Accommodations
• Frequently Asked Questions

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Does the ADA Actually Cover Captioning Glasses?

Yes — captioning glasses qualify as auxiliary aids and services under the ADA when they enable an employee with hearing loss to perform essential job functions or participate in the workplace on equal terms with hearing peers. The Equal Employment Opportunity Commission's published guidance specifically identifies "real-time captioning" and "assistive listening devices" as recognized accommodations for hearing-impaired employees (EEOC Hearing Disabilities Guidance, 2024). Captioning glasses sit at the intersection of both categories — they show real-time text in your field of view while functioning as a wearable assistive device.

The ADA's reasonable accommodation requirement applies to employers with 15 or more employees, which covers about 86 million U.S. workers across roughly 666,000 businesses (ADA National Network, 2024). If your employer is in that group, they have a legal obligation to engage with your request — not necessarily to grant it, but to participate meaningfully in what the EEOC calls the "interactive process." A flat refusal without dialogue is itself an ADA violation.

The legal landscape supports employees who pursue these claims. 43.2% of EEOC merits suits filed in fiscal year 2024 contained ADA claims, and the agency filed 42 disability-related lawsuits — nearly 40% more than in fiscal year 2022 (EEOC Office of General Counsel, 2024). Among those, 16 cases over 2023 and 2024 specifically involved hearing-impaired employees. That doesn't mean every denial leads to a lawsuit, but it does mean enforcement is real and HR teams know it.

There's a practical wrinkle worth knowing. The ADA doesn't require employers to provide the specific device the employee requests — it requires an effective accommodation. If your employer offers a different solution that genuinely works (a CART service, an FM system, or a real-time captioning app), that may satisfy the law. Your job is to make a clear case that captioning glasses are the most effective solution for your specific work pattern: hybrid meetings, hallway conversations, multi-speaker rooms, and the kinds of unscheduled interactions where booking a CART writer in advance isn't realistic.

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What Does a Reasonable Accommodation Request Look Like?

A reasonable accommodation request is a written communication to your employer stating that you have a disability and need a specific change to perform your job. The EEOC's guidance is intentionally informal — there's no required form, no magic words, and no specific format. You don't even have to use the phrase "reasonable accommodation" or "ADA" (EEOC Reasonable Accommodation Guidance, 2024). What you do need is enough information for your employer to recognize that you're requesting workplace support tied to a medical condition.

A strong request includes four pieces: a statement that you have a disability, a description of how that disability affects your work, the specific accommodation you're proposing, and an offer to engage in the interactive process. You don't need to share your full medical history or even disclose the specific diagnosis — federal law lets you keep that private unless your employer has a genuine reason to ask for more. A simple "I have a documented hearing impairment that affects my participation in meetings and group conversations" is enough to trigger the employer's legal obligations.

Citation Capsule: The EEOC's published guidance establishes that reasonable accommodation requests don't require specific forms, magic words, or even the term "ADA" — what matters is that the employee clearly conveys the existence of a medical condition and the need for workplace support (EEOC, 2024). At that point, the employer's legal obligation to engage in the interactive process begins.

Who do you send it to? In most companies, the right destination is your HR business partner or a designated accessibility coordinator. Smaller companies may not have a dedicated role — in that case, your direct manager or the senior-most HR contact works. Send the request by email so you have a written record, and ask for written acknowledgment when the request is received. The paper trail matters if the situation later escalates.

One subtle point: you don't have to disclose your hearing loss to your manager or peers if you don't want to. The ADA gives you the right to confidential medical information, and your employer's HR team is legally required to keep your diagnosis private. You can have captioning glasses approved as an accommodation, wear them at work, and never explain why to your coworkers if you'd prefer the privacy. The AirCaps captioning glasses are designed for exactly this — under 2% light leakage means others can't see your captions, and the binocular display works behind any prescription lens.

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How Much Will Your Employer Actually Pay?

Less than HR teams typically assume. The Job Accommodation Network's longitudinal employer survey — 1,425 respondents across 2019 through 2024 — found that 61% of accommodations cost employers nothing to implement. Of the remaining accommodations that did have a cost, 33% carried a one-time median price of $300, while only 6% involved an ongoing annual median cost of $2,400 (JAN, 2025). At $599, AirCaps falls in the upper-third of typical one-time accommodation costs — well within what HR teams routinely approve without escalation.

The comparison that wins approvals is the alternative cost. Industry pricing puts onsite CART captioning at $160 to $290 per hour, remote CART at $175 to $230 per hour, and onsite ASL interpretation at $100 to $220 per hour with a standard 2-hour minimum (Karasch Captioning, 2024). A single all-day offsite with eight billable hours runs $1,500 to $3,000 before travel reimbursement. At a conservative $150 per hour blended rate, a $599 captioning glasses purchase pays for itself after roughly 4 hours of comparable CART service — meaning the return on investment lands inside the first week for any employee in regular meetings.

Accommodation	Cost Structure	Annualized Cost (Daily Use)	Coverage Range
Onsite CART captioner	$160-$290 per hour	$120,000+ (full-time)	Scheduled meetings only
Remote CART (video)	$175-$230 per hour	$95,000+ (full-time)	Video meetings, lectures
Onsite ASL interpreter	$100-$220 per hour, 2-hour minimum	$80,000+ (full-time)	Formal events, medical, legal
FM system / hearing loop	$1,000-$5,000 install	$1,000-$5,000 one-time	Fixed location only
Auto-captioning meeting apps	$0-$30 per month	$0-$360	Video meetings only, no in-person
Captioning glasses (AirCaps)	$599 hardware + optional $20/month	$599-$839	In-person, hybrid, hallway, on-the-go

The hidden value of a one-time hardware purchase is administrative simplicity. CART and interpreter services require ongoing scheduling, vendor contracts, advance booking, and approval cycles. A captioning glasses purchase is a single procurement line, a single device, and zero ongoing operational overhead. For HR teams trying to keep their accommodation processes lightweight, the simplicity itself is a selling point.

There's a separate question of whether your employer's insurance, health benefits, or HSA/FSA programs can offset the cost further. Many employers run flexible spending accounts that cover assistive devices — we cover the mechanics in our HSA and FSA guide for smart glasses. For our broader breakdown of insurance, Medicare, and benefits coverage, see our captioning glasses insurance guide.

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Step-by-Step: The Interactive Process

The ADA requires employers to engage in what the EEOC calls "the interactive process" — a good-faith back-and-forth dialogue about your accommodation request. The process isn't optional. Skipping it or going through the motions without genuine consideration is itself a form of ADA violation. Here's how it typically unfolds, step by step.

Step 1: Submit your written request to HR or the accessibility coordinator. Include a statement of your medical condition, a description of the workplace impact, the accommodation you're requesting (captioning glasses), and an offer to discuss alternatives. Keep your tone collaborative — this is a problem-solving conversation, not an adversarial filing.

Step 2: Provide medical documentation if requested. Your employer can ask for verification that you have a disability and that the accommodation is medically appropriate, but they cannot ask for your full medical records or unrelated diagnoses. A Letter of Medical Necessity from your audiologist, ENT, or primary care physician is the standard document. It should state your diagnosis (in general terms — "documented hearing impairment" is enough), the workplace impact, and the recommended accommodation.

Step 3: Participate in the interactive process meeting. Most employers will schedule a conversation with HR, your manager, and sometimes an outside accessibility consultant. The conversation should cover your essential job functions, the specific limitations your hearing loss creates, the proposed accommodation, and any alternatives the employer wants to explore. Bring documentation, but keep the tone solution-focused.

Step 4: Receive the employer's decision in writing. Federal law doesn't set a strict deadline, but the EEOC expects responses to be timely — typically within 30 days for straightforward requests. The decision should be one of three options: approved as requested, approved with modification (a different but effective accommodation), or denied with a specific reason.

Step 5: Implement and review. If approved, the employer purchases or reimburses the device, you start using it, and the team checks in periodically to confirm it's working. If problems arise — the device doesn't work as expected, the job changes, or new barriers emerge — the interactive process can reopen. Accommodations are living arrangements, not one-time transactions.

Throughout the process, document everything. Save emails, take notes during meetings, and keep copies of every document you submit. If the situation escalates to an EEOC charge or lawsuit, the paper trail is your strongest evidence. The 16 hearing-impairment cases the EEOC filed in 2023 and 2024 typically turned on documentation gaps and procedural failures rather than disputes about whether the accommodation itself was reasonable.

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What Documents Should You Include?

Five documents make the strongest accommodation request package. You don't need every one for every employer, but the more complete your initial submission, the faster the approval typically moves.

The Letter of Medical Necessity is the foundation. Written by your audiologist, ENT, or primary care physician, it confirms your diagnosis and recommends captioning glasses as a medically appropriate accommodation. The ideal LMN includes your diagnosis (with the relevant ICD-10 code, typically H90 for sensorineural hearing loss), a description of how the condition affects communication, the recommended device, and the provider's credentials and signature. Most providers will write this during a standard appointment at no additional cost.

A recent audiogram supports the LMN with measurable data. It shows your pure-tone air conduction thresholds, speech reception thresholds, and word recognition scores — particularly useful when accompanied by speech-in-noise testing that documents the exact problem captioning glasses solve. Reviewers who don't know much about hearing loss find the audiogram persuasive because it converts your experience into numbers and graphs.

Document	Where to Get It	What It Proves
Letter of Medical Necessity	Audiologist, ENT, or PCP	Device is medically required for diagnosed condition
Recent Audiogram	Audiologist (hearing test results)	Severity and pattern of hearing loss
Job Description and Essential Functions	Your HR file or current job posting	The communication-heavy duties the accommodation supports
Product Specifications	Manufacturer (AirCaps spec sheet)	Technical capabilities and intended workplace use
JAN Accommodation Guidance	askjan.org topic pages	Federally-funded recommendation of captioning technology

The product specification sheet matters more than people expect. HR reviewers often have no working knowledge of captioning glasses, and they need a clear technical description to evaluate the request. Include the AirCaps specs: 4-microphone beamforming for noise rejection, 97% caption accuracy, 300ms latency, binocular MicroLED display with a 30-degree field of view, 49g weight, FCC and CE certifications, and HSA/FSA eligibility. Pulling these specs directly from manufacturer documentation positions the device as a serious assistive product rather than a consumer gadget.

Reference the Job Accommodation Network's published guidance in your submission. JAN is funded by the U.S. Department of Labor and publishes detailed accommodation recommendations by disability type. Their hearing loss accommodation guidance specifically endorses speech-to-text and captioning technology, which makes the federal-government endorsement available to any HR team that doubts whether the request fits ADA norms. Citing JAN's guidance is one of the highest-leverage moves in an accommodation submission.

Finally, a copy of your job description with essential functions highlighted helps connect the accommodation to your work. If you spend 60% of your time in meetings, that 60% needs accessible communication. If you do customer-facing presentations, the captioning supports your ability to handle Q&A. The connection between the accommodation and the job is what makes the request "reasonable" under the ADA — without that link, employers can argue the device isn't required for the role.

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How to Write the Accommodation Request Letter

The accommodation request letter doesn't need to be long. A clear, well-structured one-page email beats a three-page filing every time. Use the template below as a starting point and adapt the language to your situation.

Subject line: Reasonable Accommodation Request — [Your Name]

Opening paragraph: State your purpose plainly. "I am writing to request a reasonable accommodation under the Americans with Disabilities Act. I have a documented hearing impairment that limits my ability to fully participate in meetings, group conversations, and other communication-intensive aspects of my role."

Middle paragraphs: Describe the specific job impact and the requested accommodation. "In my current role as [job title], I attend an average of [X] meetings per week, many of which involve multiple speakers, fast-paced discussion, or hybrid in-person and remote participants. My hearing loss creates a meaningful barrier in these settings. I am requesting captioning glasses — specifically AirCaps, a $599 wearable device that displays real-time captions in my field of view — as the most effective accommodation for this work pattern."

Cost and ROI paragraph: Address the business case directly. "AirCaps captioning glasses cost $599 as a one-time purchase, which falls within the typical workplace accommodation range — the Job Accommodation Network reports a one-time median cost of $300 for accommodations that have any cost, with 61% costing the employer nothing. Compared to CART captioning services at $160 to $290 per hour, the device pays back in roughly 4 hours of comparable use. I have attached a Letter of Medical Necessity from my audiologist, a recent audiogram, the AirCaps product specification sheet, and JAN's hearing loss accommodation guidance."

Closing paragraph: Invite the interactive process. "I am happy to discuss alternative accommodations if you believe a different solution would be more effective, and I welcome the opportunity to participate in the interactive process. Please let me know what additional information you need and when we can schedule a conversation. I am available [your availability]."

A few tone notes. Keep the language professional but warm — you're asking for support, not threatening litigation. Avoid words like "demand" or "require" in the early stages; the law uses "request" and so should you. Reference the ADA explicitly once, in the opening paragraph, so the legal context is clear without belaboring it. If your relationship with HR is good, you can lean toward conversational; if your employer has a track record of denying accommodations, lean toward formal and complete documentation from the start.

Send the letter by email and keep the read receipt. Ask for written acknowledgment within five business days. If you don't hear back, follow up in writing — silence is not an acceptable response under the ADA, and federal courts have consistently treated employer non-response as evidence of bad-faith engagement.

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What If Your Employer Says No?

The first denial usually isn't really a denial — it's a request for more information or a counter-offer. Read the denial carefully and identify which of the three common patterns applies: outright refusal, alternative-accommodation proposal, or "we need more documentation" delay. Each pattern has a different response strategy.

Pattern 1: The employer proposes a different accommodation. This is the most common outcome — your employer may suggest a CART service, an FM system, an iPhone captioning app, or moving you to a quieter workspace. The ADA permits this as long as the alternative is genuinely effective. Your job is to evaluate the alternative honestly. If it works for your job pattern, accept it. If it doesn't — say, CART that requires advance booking when most of your meetings are impromptu — explain specifically why the proposed alternative fails and re-propose captioning glasses with the gap clearly defined.

Pattern 2: The employer asks for more documentation. This often means the medical documentation didn't establish a clear connection between your condition and the workplace impact. Respond with a stronger Letter of Medical Necessity that explicitly addresses the job functions, an audiogram with speech-in-noise testing if you don't have one, and references to JAN's hearing loss accommodation guidance. Documentation requests are usually not bad-faith — HR teams want defensible paperwork in case the request is audited.

Pattern 3: The employer denies the request outright on "undue hardship" grounds. "Undue hardship" is the only legal exception to ADA accommodations, but it's a high bar. The EEOC defines undue hardship as significant difficulty or expense — not minor inconvenience. A $599 one-time purchase almost never qualifies, but employers occasionally cite undue hardship for accommodations they don't want to provide. If you receive an undue hardship denial, request the specific financial or operational evidence the employer relied on, and consider escalating.

Escalation has three steps. First, request an internal appeal through your HR department or accessibility office. Most companies have a formal review process — use it. Second, file a charge of discrimination with the Equal Employment Opportunity Commission within 180 days of the denial. EEOC charges are free, you don't need a lawyer, and the agency will investigate. The EEOC's enforcement record matters here — 43.2% of merits suits filed in fiscal year 2024 contained ADA claims, and disability cases consistently make up one of the agency's top enforcement categories (EEOC, 2024).

Third, consult a disability rights attorney. The National Association of the Deaf, the Disability Rights Education and Defense Fund, and your state's Protection and Advocacy agency all maintain referral networks. Many disability attorneys take ADA cases on a contingency basis — meaning you don't pay unless you win. The legal community treats accommodation denials as serious cases, and a well-documented denial often resolves at the demand letter stage without going to court.

One realistic note: most accommodation requests don't reach this level of conflict. The vast majority of HR teams approve reasonable requests once they understand the cost, the technology, and the legal context. The escalation path exists because some employers do refuse — but the average reader of this guide will probably never need to use it.

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Captioning Glasses vs. CART, ASL, and Other Accommodations

The honest comparison: captioning glasses don't replace every hearing accommodation, and they're not always the right choice. The best accommodation for your situation depends on your specific work pattern, your communication preferences, and the kinds of meetings you actually attend. Here's how to think about the trade-offs.

CART (Communication Access Realtime Translation) remains the gold standard for formal events — board meetings, court proceedings, conferences, and any setting where verbatim accuracy is legally or professionally critical. A human captioner reaches near-perfect accuracy and handles specialized vocabulary, proper names, and acronyms better than any current AI system. The downside is cost and scheduling — CART writers book days in advance and charge $100 to $290 per hour. For employees who can plan around scheduled events, CART is excellent. For employees whose work depends on unscheduled hallway conversations, it's not workable as a daily solution.

ASL interpretation is the right accommodation for ASL-fluent deaf professionals, particularly in settings where conceptual nuance, two-way conversation, and cultural fluency matter. ASL interpreters can also relay tone, emotion, and context that text-based captioning misses. The downsides parallel CART — interpreters book in advance, cost $100 to $220 per hour, and require two-hour minimums. ASL is also irrelevant for hard-of-hearing employees who don't sign, which is a large share of the deaf and hard-of-hearing professional population.

Auto-captioning meeting apps (Otter, Google Meet captions, Zoom live transcripts) work well for video meetings but break down in person. They require a laptop or phone, they typically don't filter background noise, and they force the user to look at a screen instead of the speaker. For employees whose meetings are 100% remote, they're often sufficient. For hybrid or in-person work, they leave a major gap.

FM systems and hearing loops amplify sound directly to a hearing aid or cochlear implant. They work brilliantly for fixed locations with installed infrastructure — many universities, theaters, and large conference rooms have them. The limitations are portability (you can't bring a hearing loop to a coffee meeting) and applicability (they help only if you wear compatible hearing aids).

Captioning glasses fill the gap that other accommodations leave open: ambient, in-person, multi-speaker, unscheduled conversations. Our AirCaps captioning glasses deliver 97% accuracy at 300ms latency through 4-microphone beamforming, identify up to 15 different speakers in real time, and support 60+ languages with automatic detection — useful for multilingual workplace settings and international business calls. The AirCaps meeting intelligence layer adds automated summaries, action item extraction, and searchable conversation history that complement the live captions. None of these features replace CART for a formal board meeting, but they cover the 80% of communication that happens outside scheduled formal events.

The optimal accommodation stack for most deaf and hard-of-hearing professionals is layered: captioning glasses for daily ambient use, CART for high-stakes formal events, and auto-captioning apps as a backup for routine video meetings. You don't have to pick one — and the ADA's interactive process is the right venue to negotiate a stack that actually fits your work.

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Frequently Asked Questions

Can my employer refuse to pay for captioning glasses if they cost too much?

Only if the cost would create "undue hardship" — a high legal standard requiring significant difficulty or expense. At $599, captioning glasses fall within the typical workplace accommodation range, with 61% of accommodations costing $0 and the rest carrying a median cost of $300 (JAN, 2025). For most U.S. employers covered by ADA Title I, $599 doesn't meet the undue hardship threshold — particularly when compared to ongoing CART or interpreter costs.

Do I have to disclose my specific diagnosis to HR?

No. The ADA gives you the right to confidentiality around your specific medical condition. You need to confirm that you have a disability and that the accommodation is medically appropriate, but you don't have to disclose the underlying diagnosis to your manager, your peers, or anyone other than the HR or accessibility coordinator who reviews your request. Federal law requires HR teams to keep medical information confidential.

What if I work remotely — does the ADA still apply?

Yes. The ADA applies to remote workers the same way it applies to in-person workers, and the Bureau of Labor Statistics reports that 25% of disabled workers worked from home in some capacity in 2024 (BLS, 2024). Remote work often actually strengthens the case for captioning glasses, which work equally well in video meetings, hybrid setups, and in-person sessions — unlike CART or interpreter services that require scheduled bookings.

How long does the accommodation request process take?

The EEOC expects employers to respond promptly, but federal law doesn't set a strict deadline. Most straightforward requests resolve within 30 days. Requests that involve documentation gaps, alternative accommodation proposals, or formal interactive process meetings can take 60 to 90 days. If your employer is taking longer than 90 days without a substantive response, you can file an EEOC charge or request an internal escalation.

Can I use my HSA or FSA if my employer denies the accommodation?

Yes. HSA and FSA accounts let you pay for captioning glasses with pre-tax dollars regardless of whether your employer formally accommodates the device. IRS Publication 502 lists hearing aids and assistive communication equipment as qualified medical expenses, and AirCaps is HSA/FSA eligible. We cover the mechanics in our HSA and FSA guide for smart glasses.

Does my employer have to provide my exact device of choice?

Not necessarily. The ADA requires an "effective" accommodation, not necessarily your preferred one. If your employer offers a different solution that genuinely works for your job pattern, that may satisfy the law. Your strongest case for the specific device you want is to demonstrate why alternatives don't work — typically through documentation of the unscheduled, multi-speaker, ambient communication settings that other accommodations can't cover.

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Start Your Accommodation Request Today

Here's the practical sequence: schedule an audiologist or ENT appointment to update your audiogram and obtain a Letter of Medical Necessity, gather the AirCaps product specification sheet and the JAN hearing loss accommodation guidance, draft a one-page request letter using the template above, and send it to your HR business partner or accessibility coordinator by email. Most requests resolve within 30 days, and HR teams overwhelmingly approve well-documented accommodation submissions for devices in the $599 range.

AirCaps captioning glasses weigh 49 grams, deliver 97% caption accuracy at 300ms latency through 4-microphone beamforming, and display real-time captions on a binocular MicroLED waveguide with under 2% light leakage — invisible to colleagues across the table. The device supports 60+ languages with automatic detection, identifies up to 15 speakers, and works with any prescription from minus 16 to plus 16 diopters via interchangeable lens holders. Every specification supports the medical-device classification that makes ADA accommodation requests defensible.

The ADA exists because workplace accessibility is a civil right, not a favor. The interactive process is your legal entitlement, not a special accommodation your employer is doing you. Most HR teams know this — and the ones that don't usually figure it out when they see the documentation. Ask in their language, attach the right paperwork, and the approval typically follows.

Explore AirCaps captioning glasses to see the full spec sheet and reviews from 5,000+ customers, or visit the AirCaps shop to purchase using your HSA/FSA debit card. For real-time translation use cases, see AirCaps translation glasses. For professional meeting intelligence, see AirCaps meeting intelligence.