The accommodation path

This is a different road — don't blend the two

The business case says "this tool creates risk and cost for the organization." The accommodation request says "a medical condition makes this mandated tool or process difficult for me, and I need a modification." These run on different rules, go to different people, and should never share a memo. Mixing them weakens both: the business case starts to look personal, and the accommodation request starts to look like policy opposition dressed in medical language.

Take this road when the issue genuinely runs through a health condition. Common real-world examples: an anxiety disorder or OCD aggravated by AI tools that score, monitor, or unpredictably rewrite one's work; PTSD triggered by ambient recording or surveillance features; ADHD or autism where a person's carefully built compensatory workflow is the thing that makes them effective, and a mandated tool dismantles it; conditions where unpredictable, frequently changing processes themselves are the limitation. That last one isn't novel — the EEOC's longstanding accommodation guidance includes the example of an employee whose psychiatric disability made changes to routine difficult, and treats adjustments to how the work is structured as classic reasonable accommodations.

The legal frame

Under Title I of the Americans with Disabilities Act, employers with 15 or more employees must provide reasonable accommodations to qualified employees with disabilities, unless doing so would impose an undue hardship. Mental health conditions are covered when they substantially limit a major life activity — and since the 2008 ADA Amendments Act, that standard is interpreted broadly. Conditions like major depression, anxiety disorders, PTSD, OCD, bipolar disorder, ADHD, and autism spectrum conditions can all qualify; the question is functional limitation, not diagnosis label. A condition that is episodic or managed by treatment is assessed in its unmitigated, active state.

State law often reaches further. California's FEHA, for example, applies to employers with five or more employees and uses a lower "limits" threshold rather than the ADA's "substantially limits." Federal employees and employees of federal contractors are covered by the Rehabilitation Act, which applies the same standards. If you work somewhere small, check your state before assuming you're outside the ADA's headcount.

How a request actually works

No magic words are required. Under the EEOC's framework, telling your employer that a medical condition makes it difficult to use a tool or participate in a process is a request for reasonable accommodation — you don't have to say "ADA" or "reasonable accommodation," and the EEOC applied exactly this principle to algorithmic tools in its (since-removed but legally unchanged) AI guidance. That said, putting it in writing, to HR rather than only your manager, with the right structure, protects you and speeds things up.

The interactive process follows. Once you've requested, the employer must engage in a good-faith back-and-forth to identify an effective accommodation. They may request documentation if the disability and need aren't obvious — which is normal, not a rebuff.

Documentation is narrower than people fear. The employer is entitled to confirmation from an appropriate professional (psychiatrist, psychologist, licensed therapist, or physician) that a condition exists, what its functional limitations are, and how the requested accommodation addresses them. They are not entitled to your full mental health records or therapy notes. A focused one-page provider letter usually does it; the EEOC publishes a fact sheet specifically for mental health providers writing these.

The employer chooses among effective options. You propose; they may counter with a different accommodation, and that's lawful as long as the alternative is effective. Expect "use the tool with monitoring disabled" or "a colleague runs that step" as counteroffers to a full exemption, and decide in advance which alternatives would actually work for you.

The two limits. An employer can deny an accommodation that imposes undue hardship (significant difficulty or expense, judged against the employer's resources) or one that eliminates an essential function of the job. This is where AI mandates get interesting: in most jobs today, using a particular AI tool is a method, not an essential function — the essential function is the underlying work (drafting the document, resolving the ticket, analyzing the data). An accommodation that achieves the same output by different means is squarely the kind of change the ADA contemplates. If a role is genuinely built around the tool, the analysis is harder, and reassignment to a vacant position can become the accommodation of last resort.

Retaliation is separately illegal. Requesting an accommodation in good faith is protected activity even if the request is ultimately denied.

What an accommodation can look like

Requests succeed more often when they're specific and graduated. Depending on the limitation, workable asks include: exemption from a specific tool with an agreed alternative method for the same deliverable; routing the AI-dependent step through a colleague while you absorb an equivalent task; disabling monitoring, scoring, or recording features for your account where the tool allows it; written processes and advance notice of workflow changes instead of rolling changes; a longer transition period with training structured to your needs; or modified interim metrics while an alternative workflow is established. Leading with a menu rather than a single demand signals good faith and gives the interactive process room to work.

The request letter

Send to HR (copy your manager if relations are good), keep it factual, and resist the urge to argue the tool's merits — that's the other road.

TO: [HR / People Operations]
CC: [Manager, optional]
FROM: [Name]
RE: Request for reasonable accommodation

I am writing to request a reasonable accommodation under the ADA
[and [state law], if applicable].

I have a medical condition that makes it difficult for me to
[use [tool] / work under [specific feature: AI monitoring/scoring,
ambient recording, etc.] / adapt to the new [tool] workflow] as
currently required. Specifically, the condition affects
[concentration / stress response / ability to manage changes in
routine / other functional limitation — no diagnosis needed here].

I remain fully able to perform the essential functions of my role,
and I'd like to discuss accommodations that let me keep delivering
the same work. Options that I believe would be effective include:

1. [Exemption from [tool] for [tasks], producing the same
   deliverables by [alternative method]]
2. [Disabling [monitoring/recording/scoring feature] for my account]
3. [Written procedures and advance notice for workflow changes]

I'm glad to provide documentation from my [provider type] confirming
the condition and these functional limitations, and to meet to
discuss this or any alternative accommodation that would be
effective. Could we schedule the interactive-process conversation
within the next [two weeks]?

Thank you,
[Name, date]

For the provider letter, point your clinician to the EEOC's fact sheet for mental health providers. The letter should confirm a condition exists, describe the functional limitations in workplace terms (not therapy detail), connect the limitation to the specific barrier (the mandated tool or feature), and state that the requested accommodations would address it. One page. It should not include diagnosis history, treatment notes, or anything beyond what's needed.

Honest expectations

Accommodation requests specifically about generative-AI mandates are new territory; there's little case law on this exact pattern yet, and outcomes will turn on the specifics of the role, the limitation, and the alternatives available. What's not new is the framework — changes in supervisory methods, modifications to how work is done, and adjustments for conditions affected by process changes are textbook accommodations with decades of practice behind them. Expect a counteroffer rather than a clean exemption. Keep every exchange in writing. If the process stalls or turns hostile, deadlines matter: an EEOC charge generally must be filed within 180 days of the discriminatory act, extended to 300 days in states with their own fair-employment agency, and state deadlines vary. At that point, or before, a consultation with an employment attorney is worth far more than anything on this page. The Job Accommodation Network (JAN, at askjan.org), a free service of the U.S. Department of Labor, provides confidential one-on-one guidance on accommodation requests and is the single best starting resource.

EEOC: The Mental Health Provider's Role in a Client's Request for Reasonable Accommodation
EEOC: Enforcement Guidance on Reasonable Accommodation and Undue Hardship
Cooley: Federal Laws Still Apply Despite AI Guidance Removal (2025)
National Law Review: status of the removed EEOC AI guidance (2026)
Job Accommodation Network (JAN)