Compliance issues rarely make headlines until something goes wrong.
Most organizations assume their policies are sound and their intentions are good, which is often true. But when a single accommodation request turns into a federal lawsuit, it becomes clear how quickly even routine HR decisions can carry legal, operational, and reputational risk.
That’s exactly what’s playing out right now with the Society for Human Resource Management (SHRM), which is responding to a lawsuit alleging violations of the Americans with Disabilities Act and the Virginia Human Rights Act. The case centers on a job candidate who requested to bring a trained medical service dog to work to help manage Type 1 diabetes. According to the complaint, the offer was later rescinded. SHRM has denied wrongdoing and stated that it proposed multiple alternative accommodations to support the candidate.
While the case is still in the allegations phase, it highlights something every employer should pay attention to: accommodation decisions are rarely simple, and how you handle them matters just as much as what you decide.
Why this case matters beyond one organization
It would be easy to view this situation as a one-off dispute, but the reality is broader. Nearly every employer will face accommodation requests at some point, whether related to medical conditions, mobility challenges, mental health needs, or assistive technologies.
These requests don’t just affect legal compliance. They affect hiring timelines, workplace logistics, employee morale, and company culture. When handled well, they demonstrate fairness and inclusion. When handled poorly, they can escalate into formal complaints or lawsuits.
That’s why ADA compliance isn’t simply a legal checkbox. It’s a core part of risk management and good workforce leadership.
Understanding what the ADA actually requires
The Americans with Disabilities Act is designed to protect qualified individuals with disabilities from discrimination in the workplace. Under the law, employers must provide reasonable accommodations that allow an employee or candidate to perform the essential functions of their job, unless doing so would create an undue hardship for the business.
Reasonable accommodations can take many forms. They might include modified schedules, additional breaks, adjustments to job duties, specialized equipment, or assistive technology. In some cases, they may involve physical changes to the workplace or flexibility in how tasks are completed.
What the law does not require is automatically granting every requested solution. Instead, it requires employers to engage in what’s known as the interactive process, a collaborative, good-faith discussion aimed at identifying an effective and practical accommodation.
Guidance from the U.S. Equal Employment Opportunity Commission makes it clear that the process is just as important as the outcome. Employers must evaluate each request individually, consider options thoughtfully, and document how decisions are made.
The challenge employers often face
On paper, the concept of reasonable accommodation sounds straightforward. In practice, it’s often nuanced.
Employers must balance employee needs with operational realities. A requested solution may not be feasible due to safety concerns, cost, space limitations, or the impact on essential job functions. In those situations, the question becomes whether there’s an alternative that still meets the employee’s needs without creating undue hardship.
That’s where many organizations struggle.
If an employer denies a specific request without exploring alternatives or fails to communicate clearly, it can appear dismissive or discriminatory, even when the intention is simply to find a workable solution. On the other hand, automatically approving everything without evaluating business impact can create operational challenges and inconsistencies.
The goal isn’t to say yes to everything. The goal is to demonstrate a thoughtful, documented, and good-faith effort to find a reasonable path forward.
Why documentation and dialogue matter so much
One of the biggest lessons from cases like this is that compliance isn’t just about the final answer. It’s about how you get there.
Employers should take time to clearly define the essential functions of the role, understand the employee’s limitations, and discuss potential solutions together. Each option should be evaluated based on effectiveness and feasibility, with consideration given to cost, available resources, and operational impact. Once a solution is agreed upon, it should be implemented promptly and documented thoroughly.
When this process is followed carefully, employers not only reduce legal risk but also build trust with employees. Even if the original request isn’t possible, offering alternatives and explaining the reasoning shows respect and transparency.
That proactive communication often makes the difference between collaboration and conflict.
Accommodation requests start earlier than many think
Another important reminder for employers is that ADA responsibilities don’t begin after someone is hired. They often begin during the application and interview stages.
Qualified candidates may request accommodations for interviews, assessments, or onboarding activities. Employers generally cannot ask disability-related questions before a job offer, but they must still be prepared to provide reasonable support when needed. Having a clear, consistent process in place helps avoid confusion and ensures fair treatment from the very beginning.
In today’s hiring environment, where employer reputation matters more than ever, how you handle these moments can shape how candidates view your organization.
Taking a proactive approach to compliance
The most successful organizations don’t wait for a complaint or lawsuit to review their practices. They build accommodation planning into their overall HR and compliance strategy.
That means training managers on the interactive process, keeping job descriptions up to date with clearly defined essential functions, and establishing consistent documentation procedures. It also means creating a culture where employees feel comfortable raising requests without fear of stigma or retaliation.
When policies, communication, and training are aligned, accommodation conversations become routine and manageable instead of stressful and reactive.
At C2, we work with employers every day to navigate complex workplace regulations, including ADA compliance and accommodation management. Our focus is helping organizations put clear processes in place before issues arise, so requests are handled consistently, fairly, and with confidence.
From HR guidance and documentation support to policy development and manager training, we help reduce compliance risk while protecting both your employees and your operations. Because when it comes to disability accommodations, preparation is far more effective than damage control.
Lawsuits may grab attention, but they also offer an opportunity to learn. Employers who treat accommodation requests as collaborative conversations, not legal hurdles, are far better positioned to build inclusive workplaces and avoid unnecessary risk.
Additional resources
- ADA National Network – Reasonable Accommodations in the Workplace: https://adata.org/factsheet/reasonable-accommodations-workplace
- U.S. Equal Employment Opportunity Commission – Reasonable Accommodation Guidance: https://www.eeoc.gov/disability-discrimination-and-reasonable-accommodations