How One Accommodation Failure Led to a $270,000 Outcome

PepsiCo recently learned a costly lesson—one that many organizations are still at risk of repeating. See EEOC Press Release

After hiring a blind employee into a customer-facing role, the organization was presented with a request that should have been routine: a reasonable accommodation that would allow the employee to access company systems and perform the essential functions of the job.

The request was neither unusual nor unreasonable.

And yet, instead of identifying a solution, the organization concluded it could not accommodate the request—and made the decision to terminate the employee.

That decision ultimately resulted in a $270,000 settlement, along with federal oversight and mandated changes to internal systems, policies, and training practices.

A Breakdown in Process—Not Possibility

At its core, this situation was not driven by a lack of technology or resources.

It was the result of a breakdown in leadership capability and process.

The organization was presented with an opportunity to engage in the interactive process, explore solutions, and leverage available support. In fact, external resources were offered to assist in identifying accommodations.

Yet the response remained the same: we can’t do it.

This is where organizations become exposed—not because accommodations are inherently difficult, but because leaders are not equipped to navigate them effectively.

The Pattern Organizations Continue to Repeat

Across industries, similar missteps continue to surface.

Organizations treat accommodations as exceptions rather than standard business practice.

·         Leaders make decisions without fully engaging in the interactive process.

·         Technology limitations are cited without exploring alternative solutions.

·         And available expertise—both internal and external—is often underutilized or ignored.

These are not isolated errors. They are indicators of a broader issue: a lack of confidence and clarity at the leadership level when managing employee relations in real time.

Beyond Legal Risk: The Operational Impact

While legal exposure is significant, the operational consequences are equally important.

When accommodation requests are mishandled, organizations begin to see erosion in trust. Employees lose confidence in leadership’s ability to support them. Managers become hesitant to engage in complex situations. Over time, compliance becomes reactive rather than embedded into daily leadership behavior.

The result is not just increased legal risk—but a weakened organizational culture where issues escalate instead of being effectively managed.

What Effective Organizations Do Differently

Organizations that successfully navigate accommodation challenges take a fundamentally different approach. They focus on building capability before issues arise.

·         They treat the interactive process as a structured and essential part of leadership—not an administrative burden.

·         They invest in accessibility within their systems and processes proactively, rather than reacting under pressure.

·         They ensure that leaders—not just HR—are trained to handle accommodation conversations with clarity and confidence.

·         And they leverage external expertise when needed, recognizing that specialized knowledge is often critical to identifying effective solutions.

Three Actions Employers Should Take Now

Situations like this are preventable—but only if organizations act intentionally.

1. First, operationalize the interactive process. Accommodation requests should never be handled informally or inconsistently. Leaders must be trained to engage in structured, solution-oriented conversations—exploring options, documenting decisions, and avoiding premature conclusions.

2. Second, assess your systems for accessibility gaps. If your technology cannot support employees with disabilities, that is not an employee limitation—it is an organizational risk. Conduct proactive audits of your systems and partner with experts to identify solutions before issues arise.

3. Third, build leadership capability—not just compliance knowledge. Policies alone do not prevent risk. Your leaders are the ones making real-time decisions. If they lack clarity or confidence, they will default to avoidance or incorrect decisions. Equip them with the tools, frameworks, and support needed to navigate these situations effectively.

Conclusion

Situations like this serve as a clear reminder: accommodation failures are not simply compliance issues—they are leadership issues.

And organizations that fail to recognize that distinction will continue to face preventable risk.

The question is not whether accommodation requests will arise.

They will.

The question is whether your leaders are equipped to respond in a way that protects both the organization and the people within it.