EEOC Reaches $15 Million, Three Year Deal Over COVID 19 Vaccine Accommodation Claims

March 25, 2006

What's New

The EEOC entered into a three year, $15 million conciliation agreement with a global technology company to resolve class allegations that the company denied religious and disability accommodation requests tied to its COVID 19 vaccination policy and terminated employees who declined vaccination. The company resolved the matter without admitting liability. The agreement also requires the company to update its EEO policies, provide annual training on religious and disability discrimination, and report accommodation data to the EEOC.

What It Means

As one of the EEOC’s largest conciliation resolutions to date, this matter signals continued agency focus on how employers evaluate vaccine related accommodation requests under Title VII and the ADA. It highlights the legal and financial risk when employers do not conduct individualized assessments, document the interactive process, or substantiate an undue hardship determination. The multi year policy, training, and reporting requirements also reflect the EEOC’s emphasis on consistent, well documented accommodation decision making.

What You Should Do

Employers should review their religion, disability, and pregnancy-related accommodation polices and practices. In particular:

Use a consistent intake and interactive-process workflow, and document individualized assessments.
Train HR and managers on accommodation triage, confidentiality, and escalation to support timely, consistent decisions.
Avoid blanket undue-hardship denials; tie each determination to the specific request and document the rationale and supporting facts.
Periodically audit outcomes for consistency and risk, and remediate gaps.

Employers seeking an in-depth review should consider our course Navigating the Reasonable Accommodation Process.

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