AI-Proof Your ADA Accommodation Process in Hiring

A rescinded job offer can turn into a lawsuit faster than most HR teams can schedule a follow-up call.

This week’s headline is a sharp reminder: a lawsuit alleges SHRM withdrew an offer after a candidate requested to bring a trained service dog to the office as a reasonable accommodation related to Type 1 diabetes. The legal merits will be decided in court, but the operational lesson for every employer is already clear: accommodation requests are high-stakes, high-variance, and easy to mishandle when your process depends on memory, inbox threads, and inconsistent judgment.

I’ve found that many organizations treat accommodations like an “exception workflow” instead of what they actually are: a core compliance and inclusion workflow that intersects directly with recruiting, onboarding, facilities, security, and management. If you’re building an “AI in Human Resources & Workforce Management” roadmap for 2026, accommodations should be on it—because AI can reduce process risk when it’s used to standardize documentation, prompt the right questions, and prevent premature decisions.

What the service dog lawsuit teaches HR about process risk

The central risk isn’t the accommodation itself—it’s breaking the interactive process. Most ADA failures don’t come from a dramatic “no.” They come from a messy middle: inconsistent requests for documentation, unclear rationale, dropped follow-ups, and decisions made before the facts are fully understood.

In the lawsuit, the candidate alleged she needed a trained service dog to detect and alert her before blood glucose levels rise or fall to dangerous levels due to Type 1 diabetes. According to the complaint, she had experienced severe hypoglycemia episodes around 10 times per year prior to having the dog, and only one incident after being paired with the dog.

The filing also alleges the employer initially requested more information, then denied the request on the grounds that she could perform essential job duties without the dog, suggested a glucose monitoring system instead, and later withdrew the job offer without further engagement.

Here’s the uncomfortable part: even HR teams with strong intentions can end up in the same pattern when they lack a consistent internal playbook.

The “reasonable accommodation” decision is rarely a single decision

A good accommodation outcome usually requires several linked decisions:

• What information is actually needed to evaluate the request?
• Which job functions are truly “essential,” and how do we know?
• What alternatives exist, and who has authority to assess feasibility?
• What’s the timeline, and how do we keep the candidate informed?
• What’s the rationale, documented in plain language, for every step?

If your answers live across email, Slack, and tribal knowledge, you’re relying on luck.

Where HR teams usually get accommodations wrong (and why it happens)

Accommodation breakdowns are usually system failures, not “bad people” failures. And the system failures repeat.

1) Treating medical accommodations like a negotiation

The interactive process isn’t a contest where HR tries to “win” by finding a cheaper or simpler alternative. It’s a structured conversation to find a workable accommodation without undue hardship.

When HR pushes a single preferred alternative (“Just use a monitoring device”), candidates can reasonably feel dismissed—especially if they’ve already tried the alternative.

2) Over-indexing on “can you do the job without it?”

A common misunderstanding is that if someone can technically perform essential duties without an accommodation, the request can be denied. In practice, the question is whether an accommodation is needed to enable equal employment opportunity and safe, sustainable performance.

This is where service animals often trigger confusion. A service dog isn’t “nice to have.” For some employees, it’s a safety support that prevents medical emergencies.

3) Ending the process too early

The lawsuit’s most instructive allegation is the abrupt end of engagement. Even if you ultimately deny a specific accommodation, your risk increases when you:

• stop communicating,
• fail to explore alternatives credibly,
• fail to document your reasoning,
• or make a sudden employment decision (like pulling an offer) tied to the request.

4) Letting too many people “weigh in” informally

Facilities, security, managers, and coworkers all have opinions—some valid, some not. When their feedback comes in as side-comments, HR can unintentionally adopt bias (“Dogs don’t belong here”) instead of focusing on lawful criteria.

This matters because service animal requests are emotionally charged. AI can’t fix emotions, but it can force structure.

How AI can support compliant, consistent accommodation decisions

AI’s best role in accommodation management is process control: standardize, document, and prompt—not decide. If your AI tool is making approval/denial decisions, you’re building a new liability.

Used correctly, AI can reduce risk in four practical ways.

1) AI as an “interactive process co-pilot” (prompting the right steps)

An accommodation request has predictable milestones. AI can act like a checklist that doesn’t forget.

Examples of what AI can do well:

• Detect accommodation-related language in emails or ATS notes (e.g., “service dog,” “medical,” “reasonable accommodation”) and trigger the formal workflow.
• Generate a timeline of required next steps (intake, clarification, evaluation, decision, implementation).
• Draft candidate communications that are neutral, respectful, and consistent.

The value here is simple: fewer dropped handoffs, fewer undocumented calls, fewer “we’ll get back to you” moments that stretch for weeks.

2) AI to produce documentation that holds up under scrutiny

When disputes escalate, the quality of documentation often decides how painful the process gets.

AI can help by:

• Summarizing the request and all interactions in a structured case file.
• Producing a decision memo template that forces HR to record:
  • the essential job functions considered,
  • the options evaluated,
  • the rationale for acceptance/denial,
  • and any undue hardship factors.

A strong stance: If you can’t explain your decision without referencing personal opinions, you’re not ready to decide. AI can push teams toward evidence-based reasoning.

3) AI to standardize “essential functions” and reduce manager drift

One of the sneakiest compliance problems is when job descriptions don’t match reality.

AI can help HR teams:

• Compare job postings, job descriptions, performance plans, and real work artifacts to flag inconsistencies.
• Highlight where “essential” functions appear subjective or overbroad.

This prevents the common mistake of redefining the job after an accommodation request appears.

4) AI to spot risk patterns early (before legal does)

Most HR leaders don’t want AI because it’s trendy. They want it because they’re tired of surprises.

AI can flag patterns like:

• repeated denials for a specific accommodation type,
• long cycle times for accommodation decisions,
• managers with unusually high “pushback” rates,
• rescinded offers occurring shortly after accommodation requests.

These are the types of signals you want in Q1 2026—before a claim arrives in Q3.

A practical AI-enabled workflow for accommodation requests (hiring edition)

A workable model is: human decision-making, AI-assisted consistency. Here’s a hiring-focused approach many teams can implement without rebuilding everything.

Step 1: Standardize intake in recruiting systems

• Add an accommodation intake form connected to your ATS or candidate portal.
• Allow multiple submission methods (portal, email, recruiter entry) but route everything into one case record.

AI assist:

• Auto-classify the request type (e.g., interview accommodation vs. workplace accommodation vs. onboarding).
• Suggest the correct internal owner and SLA based on role/location.

Step 2: Run a structured “essential functions” review

• Pull the job description.
• Confirm with the hiring manager what’s truly essential (and why).
• Document evidence, not opinions.

AI assist:

• Provide a guided template and highlight inconsistencies across documents.

Step 3: Conduct interactive process conversations—then document them

• Ask only for information you need.
• Keep communication timely and respectful.
• Provide options when feasible.

AI assist:

• Draft follow-up questions that avoid intrusive or irrelevant medical probing.
• Summarize meeting notes into the case file.

Step 4: Evaluate options and decide with a defensible rationale

• Assess feasibility, cost, safety, and operational impact.
• Document undue hardship considerations clearly.

AI assist:

• Generate a decision memo draft that forces completeness.

Step 5: Implement, monitor, and revisit

Accommodations aren’t always “set it and forget it.”

AI assist:

• Schedule check-ins and reminders.
• Track effectiveness notes over time.

Guardrails: how to use AI without creating a new compliance problem

If you’re bringing AI into HR compliance, your governance needs to be stricter than your recruiting chatbot rules. Accommodations involve disability-related information and high legal exposure.

Here are non-negotiable guardrails:

• Don’t automate final decisions. Use AI for drafts, prompts, summaries, and consistency checks.
• Role-based access controls. Limit who can see accommodation details; log every access.
• Data minimization by design. Store only what you need; separate medical documentation from general recruiting files where possible.
• Bias and error testing. If AI suggests next steps, test whether it treats similar requests consistently across roles/locations.
• Human review on all outbound communications. Tone matters, and AI can sound cold or overly certain.

One blunt line I use internally: “AI should make us more careful, not more confident.”

People also ask: service dogs, accommodations, and hiring

Can an employer deny a service dog accommodation because other tools exist?

An employer can explore alternatives, but denying a request requires a defensible rationale and a real interactive process. “Use a different tool” isn’t automatically reasonable if it doesn’t address the person’s limitation or safety need.

Should recruiters handle accommodation requests?

Recruiters should route them, not judge them. The fastest way to create risk is letting a busy recruiting team make ad hoc calls on medical-related requests.

Does AI reduce discrimination risk in hiring?

It reduces risk when it standardizes process and documentation, and increases risk when it replaces judgment without accountability. The tool is neutral; implementation rarely is.

What to do next (before the next request hits your inbox)

The timing here matters. It’s mid-December, headcount plans are getting finalized, and Q1 hiring ramps are being scoped. If your accommodation process is still “email HR and we’ll figure it out,” you’re heading into 2026 with avoidable exposure.

Start with a realistic goal: make your accommodation process consistent enough that two different HRBPs would handle the same request the same way. Then add AI where it reduces variance—intake, prompts, documentation, and analytics.

If your team is exploring AI in Human Resources & Workforce Management, this is one of the most practical places to apply it because the success criteria are clear: faster cycle times, better documentation, fewer escalations, and decisions that are easier to defend.

What would change in your organization if every accommodation request generated a clean case file, a clear timeline, and a documented rationale—before anyone felt the need to call legal?