Estimated reading time: 20 minutes

Key Takeaways

• The ADA protects many workers in recovery from illegal drugs and most workers with alcohol use disorder, but not those currently engaging in illegal drug use; protection turns on individualized, job‑focused analysis and documentation backed by the interactive process.

• Reasonable addiction accommodation at work can include flexible or modified schedules, rehab leave, temporary job restructuring, remote work, or reassignment to a vacant role when appropriate and not an undue hardship.

• Employers must request only limited medical information about functional limitations, keep medical records confidential, and make decisions based on objective evidence, not stereotypes or rumors.

• Workplace safety matters: employers may address impairment and apply the “direct threat” standard based on individualized assessment, while still exploring accommodations that reduce risk.

• If disciplined or terminated because of disability bias, workers can use internal procedures and file a charge with the Equal Employment Opportunity Commission (EEOC) to pursue remedies.

Table of Contents

• When substance use disorders are covered by the ADA, what accommodations employers must provide, and how to handle discipline and rehabilitation leave

• Introduction

• Quick summary

• Understanding addiction as a disability under the ADA

• Who is protected (recovery vs current use)

• Alcoholism vs illegal drug use

• Types of addiction accommodations at work

• Rehab leave and leave-related obligations

• Flexible schedules, job restructuring, reassignment, remote work

• Treatment-related accommodations and the interactive process

• Employer responsibilities and legal obligations

• The interactive process — step by step

• Undue hardship and direct threat analyses

• Confidentiality and recordkeeping

• Protections when facing discipline or termination

• When firing may violate the ADA

• Disciplinary best practices and last chance agreements

• Legal recourse (EEOC)

• Best practices for employers

• Practical checklists for implementation

• Resources and further reading

• Conclusion

• FAQ

When substance use disorders are covered by the ADA, what accommodations employers must provide, and how to handle discipline and rehabilitation leave

Rehab leave employer obligations fit within a larger framework of disability rights and safety. This guide explains when substance use disorders are covered by the ADA, how the interactive process works, and how to balance workplace safety with recovery support and consistent performance standards.

Introduction

Addiction accommodation at work refers to reasonable, individualized changes to job duties, schedules, or leave that employers provide so employees with substance use disorders can perform essential job functions and seek treatment.

Why this matters: organizations increasingly recognize addiction as a medical issue, not a moral failing. The stakes are high for both employers and employees—balancing safety, staffing, and productivity while supporting recovery can reduce turnover and legal risk. Clarity about rights and responsibilities helps people get help and keep working.

The Americans with Disabilities Act (ADA) protects qualified individuals with disabilities — including many people with alcohol use disorder and those in recovery from illegal drug addiction — by requiring reasonable accommodations unless doing so would cause undue hardship. This understanding is reflected in practical employer guidance about the interactive process and confidentiality duties, which emphasize individualized analysis and documentation grounded in objective evidence rather than assumptions or stigma, as summarized in Nextep’s overview of ADA rights and addiction and reinforced by peer‑reviewed analysis in NCBI/PMC’s discussion of ADA coverage.

In this article, we cover employer obligations, what accommodations can look like (including rehab leave), how to handle impairment and discipline, and where to find resources if rights are violated. We’ll use plain language examples, cite trusted sources, and provide practical checklists for HR and workers.

Quick summary

• Who is protected: People in recovery or in supervised rehab and no longer using illegal drugs, and those mistakenly regarded as using; current illegal drug use is not protected. See Safe Project’s ADA substance use guide and NCBI/PMC.

• Alcoholism is treated differently: Alcohol use disorder is generally a disability requiring individualized analysis; policies must focus on performance and safety, not status. See NCBI/PMC and SHRM’s employer guidance.

• Accommodations examples: flexible schedules, leave (including rehab leave), part‑time transitions, temporary job restructuring, remote work, and reassignment when appropriate. See Safe Project’s examples.

• Interactive process: respond promptly, request only necessary medical information, explore options, document decisions, and maintain confidentiality. See Nextep.

• Remedies: If you face discrimination or are fired, you can file with the EEOC for fired for addiction protections and other ADA violations.

Understanding addiction as a disability under the ADA

Under the ADA, a disability is a physical or mental impairment that substantially limits one or more major life activities (e.g., working, learning, caring for oneself). Substance use disorders may meet this test when they substantially limit major life activities or when the person is in recovery and qualifies as a ‘qualified individual with a disability.’ Detailed analyses of these standards, including how they apply to substance use, appear in peer‑reviewed ADA and addiction research.

“Substantially limits” is practical and fact‑specific. Major life activities include working, concentrating, interacting with others, and driving. Addiction can impair attendance, focus, mood regulation, and safety—limitations that may require support to perform essential duties. Employer‑facing guidance highlights that protection depends on functional limits and job requirements, not labels, as discussed in Nextep’s ADA/addiction explainer.

Example: An employee in outpatient treatment for opioid use disorder who misses occasional hours for counseling but otherwise performs the essential duties may be a “qualified individual” who needs a reasonable schedule change to attend treatment. That is a straightforward example of substance use accommodation ADA principles applied to real work.

Who is protected (recovery vs current use)

• Not protected for that use: Individuals currently engaging in the illegal use of drugs are not protected by the ADA for that illegal use. Employers can enforce conduct and safety policies, including discipline for on‑duty impairment, as summarized by Nextep.

• Protected: People who have successfully completed a supervised rehab program and are no longer using illegal drugs, are currently participating in a supervised program and are no longer using, or who are mistakenly regarded as using drugs illegally. See Safe Project’s ADA substance use guidance and NCBI/PMC.

Protection depends on being “qualified,” meaning able to perform essential functions with or without accommodation. Employers should analyze essential duties carefully and document decisions to ensure consistency with ADA rules—best practices echoed in our broader ADA reasonable accommodations guidance for employees and HR.

Alcoholism vs illegal drug use

Alcohol use disorder (alcoholism) is generally recognized as a disability and requires individualized analysis even if the individual is currently using alcohol. Employers may still enforce performance, attendance, and safety rules but must avoid decisions based on stereotypes. See NCBI/PMC’s summary of ADA case law and SHRM’s HR compliance guidance.

By contrast, illegal drug use receives ADA protection when a worker is in recovery under the standards noted above or is erroneously regarded as using. That distinction is critical when assessing employer duty accommodate addiction and clarifying alcoholism accommodation job considerations.

Types of addiction accommodations at work

A reasonable accommodation is any change to the work environment or job that enables a qualified employee with a disability to perform the essential functions of the job, unless the change would cause undue hardship. Both practical HR guidance and legal analysis emphasize the interactive process to tailor solutions, as outlined by Nextep and in NCBI/PMC’s ADA overview.

Below are common accommodations for addiction accommodation at work, with tips on when each is appropriate and what documentation is typically necessary. Employers should request only what is needed to understand functional limitations and duration, not a diagnosis, and keep all medical information confidential.

Rehab leave and leave-related obligations

Definition: Rehab leave includes paid or unpaid time off to attend inpatient or intensive outpatient treatment. Rehab leave employer obligations require engaging in the interactive process, considering leave as a reasonable accommodation, and coordinating policies with other laws. Leave may run concurrently with the Family and Medical Leave Act (FMLA) if eligible; in some cases, the ADA can require additional leave beyond FMLA, unless it would be an undue hardship. These points appear in both NCBI/PMC’s ADA analysis and employer‑facing summaries like Nextep.

Practical steps:

• Define the expected duration, check-ins, and return‑to‑work requirements (e.g., fitness‑for‑duty note limited to functional ability, not diagnosis).

• Coordinate ADA and FMLA; if FMLA applies, designate appropriately and document interactions in the accommodation file. For related guidance on job protection during medical leave, see our overview on FMLA rights and the risk of being fired while on FMLA.

• Plan a transition back to work—consider a brief part‑time or modified schedule to support recovery while maintaining essential duties.

• Set review windows (e.g., every 30–45 days) to reassess needs without over‑collecting medical details, consistent with ADA limits on inquiries.

Example phrasing a manager might use during the interactive process: “We can provide a leave of X weeks for an approved treatment program; let’s document the start/end dates and what we need for return‑to‑work clearance.” That sentence is a conversational example, not a template; HR should adapt language to policy and legal advice.

Flexible schedules, job restructuring, reassignment, remote work

Alternative or flexible schedules: Allow later starts, shift swaps, or protected hours for counseling or recovery meetings. This is especially useful for outpatient treatment, support groups, or medication management. Employers may request limited verification of the treatment schedule (not the diagnosis) to plan coverage, consistent with ADA medical inquiry rules discussed by Nextep. Example: “Allowing an employee to start 90 minutes late two days per week to attend outpatient treatment can be a reasonable accommodation.”

Part‑time or modified schedules: After rehab leave, a phased return (e.g., 50% for two weeks, 75% for two weeks, then full time) can stabilize performance while meeting essential duties. Document milestones and performance expectations so both sides understand the plan. For additional structure ideas, see our broader guide to ADA reasonable accommodations.

Job restructuring: Temporarily remove non‑essential tasks that conflict with treatment timing or recovery limits while keeping essential functions intact. Managers should identify essential vs. nonessential functions, define the temporary duration, set metrics, and revisit at set intervals. This aligns with employer duty accommodate addiction while safeguarding core operations.

Reassignment: If an employee cannot perform essential functions even with accommodation, reassignment to a vacant position for which the employee is qualified may be required. Document which positions were considered, why a specific role fits, and the start date. This option is generally considered after exploring other accommodations and remains subject to undue hardship limits summarized in NCBI/PMC.

Remote work or telecommuting: For non‑safety‑sensitive roles, remote or hybrid work can reduce treatment barriers and support stability. Consider equipment, cybersecurity, supervision, and performance management needs. Remote work may be temporary during recovery or a longer accommodation if it enables essential function performance without undue hardship.

Unpaid leave beyond statutory entitlements: If FMLA is unavailable or exhausted, the ADA may still require additional unpaid leave for a finite period if it is reasonable and not an undue hardship. Employers should check FMLA eligibility and coordinate leave policies with ADA obligations. Practical leave coordination tips are also covered in related posts on paid sick leave coordination and disability rights in workplace disability discrimination.

Treatment-related accommodations and the interactive process

A clear, good‑faith process builds trust and reduces errors. A common flow, consistent with substance use accommodation ADA guidance from Nextep:

1. Employee requests an accommodation (verbal or written).

2. Employer responds promptly to acknowledge the request and begins the interactive process.

3. Employer requests limited medical documentation about functional limitations and expected duration if needed to evaluate the request; do not ask for more than necessary and avoid fishing for diagnosis details.

4. Employer and employee explore reasonable options (e.g., leave, flexible schedule, temporary job restructuring, reassignment, remote work) and evaluate undue hardship.

5. Employer issues a written decision, implements the chosen accommodation, and documents milestones and any appeals or adjustments.

To manage risks around drug testing during or after treatment, ensure policies are job‑related and consistent, especially in safety‑sensitive roles. For a deeper dive on policy and rights, see our drug testing at work rights guide.

Employer responsibilities and legal obligations

Core ADA duties include engaging in a good‑faith interactive process, providing reasonable accommodations unless they cause undue hardship, maintaining safety, and safeguarding confidentiality. HR should use standardized procedures and train managers to spot when the process is triggered, consistent with practical guidance in Nextep’s ADA overview and legal analysis in NCBI/PMC.

The interactive process — step by step

Step 1 — Acknowledge quickly: Confirm receipt of the accommodation request in writing, ideally within three business days, and outline the next steps. A short acknowledgment shows respect and preserves timelines for accommodation review, a pillar of employer duty accommodate addiction.

Step 2 — Request only necessary documentation: Employers may ask for medical information that explains functional limitations and the need for accommodation but should avoid broad requests for diagnosis or entire records. Keep the purpose “job‑related and consistent with business necessity,” as summarized in NCBI/PMC’s ADA discussion. If the employee is in supervised treatment, a simple schedule verification may suffice.

Step 3 — Propose and evaluate options: Consider leave (including rehab leave), flexible or part‑time schedules, temporary job restructuring, remote work, or reassignment. Evaluate each against essential functions, staffing, costs, and safety. Documentation should reflect alternatives considered and the rationale for the chosen solution, echoing process tips in Nextep.

Step 4 — Conclude with a written decision: Provide a decision letter that identifies the accommodation, duration, checkpoints, and how to request adjustments. If declining, include a documented undue hardship analysis and encourage the employee to raise new options or updated medical information.

As you implement, align your practices with broader ADA guidance in our explainer on when to contact a disability discrimination lawyer if accommodation is denied.

Undue hardship and direct threat analyses

Undue hardship: The ADA does not require accommodations that cause significant difficulty or expense relative to the employer’s size, resources, and operations. This is a high bar that must be applied carefully and consistently, with documentation of cost estimates, alternatives considered, and why less burdensome options would fail. See NCBI/PMC on the legal standard and examples.

Examples might include: a 24/7 operation where no viable reassignment exists despite a thorough search; or extraordinarily costly restructuring that would critically impair business function. Most accommodations (schedule adjustments, finite leave, non‑essential duty reallocation) are often modest if planned early.

Direct threat: Employers can act when an employee poses a significant risk of substantial harm to self or others that cannot be mitigated by reasonable accommodation. The assessment must be individualized, based on reasonable medical judgment and current objective evidence—not stereotypes, speculation, or rumor—consistent with Nextep’s safety guidance. Document the factors considered, accommodations explored to reduce risk, and the reasons a residual risk remains unacceptable.

Checklist for an individualized safety assessment:

• Describe the specific risk and the essential duties affected.

• Identify objective evidence (e.g., contemporaneous observations, reliable test results) supporting impairment or risk.

• List accommodations considered (schedule changes, leave, reassignment) and whether they reduce risk sufficiently.

• Record the final determination and review date, noting that changes in treatment or performance may alter the risk picture.

Confidentiality and recordkeeping

Medical information must be kept separate from personnel files and shared only on a need‑to‑know basis. Access should be limited, tracked, and secured. These confidentiality rules are emphasized in practical employer guidance such as Nextep’s overview and align with broader privacy principles covered in our guide to employee medical privacy rights at work.

Recommended practice:

• Store accommodation and medical documents in a secure HR file, separate from performance records.

• Limit disclosures to those who must implement the accommodation (e.g., schedule change) without revealing diagnoses.

• Maintain a disclosure log noting who accessed what information, why, and when.

Sample policy language (for internal policy drafting): “All medical information obtained during the accommodation process will be kept confidential in a separate file, disclosed only to personnel with a demonstrated need to know to implement accommodations or ensure safety, and retained in accordance with our records policy and applicable law.”

Protections when facing discipline or termination

The law balances non‑discrimination with performance and safety. Employers cannot terminate someone because of disability status, history, or for requesting an accommodation. They may, however, enforce legitimate performance and conduct rules, including addressing on‑duty impairment or safety violations. These principles are summarized in Nextep’s ADA/addiction guidance and expanded in training materials like BBI Syracuse’s ADA & Addiction paper.

When firing may violate the ADA

Prohibited: Firing someone solely for being in recovery, because they requested an accommodation, or based on disability history if they can perform essential functions with accommodation. Employers should not base decisions on stigma or assumptions. See Nextep.

Permitted: Firing may be lawful when an employee is actively using illegal drugs; is impaired at work creating a direct threat that cannot be mitigated; or fails to meet essential performance standards despite reasonable accommodations and documented counseling/warnings. Consistent application of conduct rules is key, as reflected in Nextep’s guidance.

If you believe you were terminated because of your disability rather than performance, review our primer on how to prove disability discrimination and consider your fired for addiction protections under the ADA.

Disciplinary best practices and last chance agreements

Stepwise discipline that separates performance documentation from the accommodation process limits risk and preserves fairness. BBI’s training materials suggest progressive discipline and careful tailoring of any “last chance” agreements to performance and safety, not status, in line with ADA rules (BBI Syracuse ADA & Addiction).

Manager roadmap:

• Investigate and document incidents objectively (dates, witnesses, facts). Keep a separate accommodation file to avoid commingling records.

• When addiction is disclosed or suspected, engage in the interactive process and explore reasonable accommodations before considering termination for performance issues.

• Use progressive discipline where appropriate: incident → counseling → written warning → “last chance” agreement with clear performance and safety conditions → termination if violations continue.

• Ensure any testing or monitoring is job‑related and consistent with policy—especially in safety‑sensitive roles—and apply standards consistently.

Purpose of last chance agreements: They allow continued employment contingent on compliance with performance and safety conditions (and, when appropriate, verified treatment participation), while respecting confidentiality. Key clauses often address: finite duration, job‑related compliance terms, consequences of violation, and privacy safeguards. BBI’s resource provides examples and legal cautions (BBI Syracuse).

Legal recourse (EEOC)

If you believe discrimination occurred, you can use internal grievance procedures and also file a charge with the Equal Employment Opportunity Commission (EEOC). Remedies can include reinstatement, back pay, compensatory damages, and injunctive relief. While outcomes vary case‑by‑case, acting promptly preserves deadlines. For a step‑by‑step overview, see our guide on how to file an EEOC complaint and our resource on building strong workplace discrimination claims.

Best practices for employers

Practical policies and training reduce legal risk, support recovery, and maintain safety. A clear framework helps managers respond consistently and compassionately to accommodation requests while meeting business needs.

Written policy checklist:

• ADA and non‑discrimination statement that addresses substance use disorders and alcoholism accommodation job considerations.

• Procedures for requesting accommodations (who to contact, how to request, expected timelines for each step of the interactive process).

• Confidentiality protections and recordkeeping requirements—separate medical files, access limits, and disclosure logs.

• Rehab leave policy with ADA/FMLA coordination and review windows; ensure it aligns with rehab leave employer obligations.

• Performance management and discipline procedures for employees with disabilities, including guidance on “last chance” agreements.

• Employee Assistance Program (EAP) and external resources list, made easy to access and confidential.

• Anti‑retaliation clause covering disclosures, accommodation requests, and participation in treatment.

Manager training program outline:

• ADA basics applied to substance use and recovery, including substance use accommodation ADA standards and direct threat.

• How to recognize potential impairment versus misconduct, when to pause discipline to initiate the interactive process, and how to document both streams.

• Confidentiality and limited medical inquiries; practical scripts for asking about functional limits rather than diagnoses.

• Return‑to‑work conversations, phased schedules, and reassignment processes.

• Annual refreshers plus onboarding training for new managers; content guidance reflected in Nextep’s interactive process tips and BBI’s ADA & addiction training resource.

Create a supportive workplace culture:

• Publicize EAP access and make referrals easy, confidential, and stigma‑free.

• Offer recovery‑friendly benefits (coverage for substance use treatment, flexible time for therapy) and include them in benefit communications.

• Recognize recovery milestones privately and with consent; avoid singling out employees publicly.

• Use return‑to‑work supports such as peer mentors, phased returns, and flexible shifts that reinforce accommodation success.

Monitoring and metrics:

• Track the number of accommodation requests, average time to decision, outcomes, return‑to‑work rates, EAP utilization, and ADA‑related complaints.

• Conduct quarterly reviews of decision files to check for consistency, proper undue hardship documentation, and confidentiality compliance.

• Compare outcomes across departments to identify training needs and policy gaps related to employer duty accommodate addiction and substance use accommodation ADA compliance.

For broader policy alignment across your organization, see related guidance on legal compliance in workplace policies and how to build workplace discrimination policy frameworks that integrate ADA duties.

Practical checklists for implementation

Use these concise, printable checklists to standardize reviews on addiction accommodation at work. Keep all documentation in confidential HR files and restrict access on a need‑to‑know basis.

Accommodation intake checklist (for HR/managers):

• Receive request (verbal or written); acknowledge within three business days.

• Identify essential job functions and current performance concerns, if any.

• Request only necessary medical information (functional limits, expected duration) consistent with ADA standards.

• Confirm if FMLA applies; coordinate ADA and FMLA leaves and designate appropriately.

• Brainstorm options: flexible schedule, finite leave, job restructuring, remote work, reassignment.

• Evaluate feasibility and undue hardship factors; document alternatives considered.

• Issue written decision with duration, milestones, and review dates.

• Schedule follow‑ups (e.g., 30/60/90‑day checks); adjust as needed.

Confidentiality and privacy checklist:

• Store medical and accommodation records separately from personnel files.

• Limit access; maintain a disclosure log (who, what, why, date).

• Train managers not to request or share diagnosis details; communicate only what is necessary to implement accommodations.

• Review data retention timelines and secure disposal practices.

Rehab leave coordination checklist:

• Confirm eligibility and duration; define start/end and expected return‑to‑work date.

• Coordinate with FMLA if applicable; advise on benefit continuation and how to request extensions.

• Plan a phased return if medically indicated; set performance expectations for each phase.

• Set review points to reassess accommodations and gather updated, limited medical information if needed.

Safety and direct threat assessment checklist:

• Gather objective evidence of risk (observations, test results, incident reports).

• Identify essential functions affected and potential harm.

• Evaluate accommodations to reduce risk; document why any cannot sufficiently mitigate risk.

• Record decision and next review; revisit if treatment or job conditions change.

Discipline and last chance oversight checklist:

• Document performance issues objectively; keep separate from medical/accommodation files.

• Engage in the interactive process if addiction is disclosed or suspected; explore accommodations before considering termination.

• Apply testing/monitoring consistently and only if job‑related and policy‑based.

• If using a last chance agreement, define clear performance/safety conditions, finite duration, and confidentiality protections, consistent with BBI’s guidance.

If you need a refresher on ADA concepts before using these checklists, review our disability discrimination workplace rights guide for foundational definitions and examples.

Resources and further reading

• Nextep — Balancing Addiction and ADA Rights (interactive process, confidentiality, practical employer steps)

• NCBI/PMC — ADA, Addiction, and Employment (peer‑reviewed legal and clinical context; undue hardship and alcoholism analysis)

• Safe Project — ADA Accommodations for Substance Use (who is protected; example accommodations)

• SHRM — Treatment, Drug/Alcohol Issues, and ADA Coverage (employer‑facing HR compliance guidance)

• BBI Syracuse — ADA & Addiction Training Resource (discipline and last chance agreements)

• EEOC — Disability Discrimination Resources (how to file charges and enforcement overview)

Conclusion

Employers must treat addiction and recovery as a medical issue subject to ADA protections: engage in the interactive process, provide reasonable accommodations (including rehab leave where appropriate), and carefully document decisions while maintaining safety and confidentiality. Employees should know their rights and, if necessary, use internal complaint procedures or file with the EEOC. Aligning policies to rehab leave employer obligations and training managers on employer duty accommodate addiction will reduce risk and keep skilled people working.

As you apply this guidance, remember that facts are unique. Consult legal counsel for complex cases, especially when safety, testing, or overlapping state laws are involved. For additional background on accommodations and discrimination claims, explore our resources on ADA reasonable accommodations, disability discrimination workplace rights, and the EEOC processes in filing a complaint with the EEOC.

Need practical help deciding whether to request leave, restructure a role, or propose a phased return? Ground your plan in objective evidence, focus on essential functions, and rely on the interactive process to tailor solutions.

Need help now? Get a free and instant case evaluation by US Employment Lawyers. See if your case qualifies within 30-seconds at https://usemploymentlawyers.com.

FAQ

Is addiction considered a disability under the ADA?

It can be. Many people with alcohol use disorder and those in recovery from illegal drug use qualify as disabled when their condition substantially limits major life activities or when they meet recovery criteria; current illegal drug use is not protected. See NCBI/PMC’s analysis and Safe Project’s ADA resource.

Can my employer fire me for being addicted to drugs?

Employers may discipline current illegal drug use or on‑duty impairment, but they cannot fire you solely because you are in recovery or request accommodation if you can perform essential duties with reasonable support. See Nextep’s ADA/addiction guidance for fired for addiction protections.

What is rehab leave and must employers give it?

Rehab leave is time off for inpatient or intensive outpatient treatment. Employers must consider leave as a reasonable accommodation through the interactive process; FMLA may run concurrently, and the ADA can require additional leave unless it’s an undue hardship. See NCBI/PMC and Nextep.

Does alcoholism get special protection at work?

Alcoholism is generally recognized as a disability that warrants individualized analysis, even when current use is involved; employers can still enforce neutral performance and safety rules. See NCBI/PMC and SHRM.

How do I request an accommodation for addiction?

Tell HR or your manager that you need a work adjustment due to a medical condition, describe the functional limitations, and suggest options like a schedule change or rehab leave. Expect limited medical documentation requests and a collaborative interactive process (see Nextep).

What should I do if I think my employer discriminated against me?

Use internal complaint procedures, document everything, and consider filing a charge with the EEOC. You can also review our guides to filing an EEOC complaint and disability discrimination workplace rights.

Can employers require drug testing?

Yes, when job‑related and consistent with business necessity, especially in safety‑sensitive roles; policies must be applied consistently and with confidentiality. For nuances around discipline and monitoring, see BBI’s ADA & Addiction paper and our comprehensive drug testing at work rights guide.

What counts as an undue hardship?

An accommodation that causes significant difficulty or expense relative to the employer’s size, resources, and operations; it is a high standard that must be well‑documented with alternatives considered. See NCBI/PMC’s undue hardship overview.