The California Civil Rights Department (CRD) recently announced a $300,000 settlement with the University of California San Francisco (UCSF) over allegations that the university failed to properly respond to an employee’s request for a remote work accommodation related to a disability. Beyond the financial settlement, the case serves as an important reminder that employers should regularly review accommodation procedures, manager training, and workplace policies to reduce compliance risk. 

The Facts 

In 2022, the CRD received a complaint alleging that UCSF failed in multiple instances to adequately engage with an employee seeking exceptions to workplace policies because of a disability limiting certain physical activities. According to the complaint, the employee was involuntarily placed on medical leave, denied meaningful opportunities to discussu  alternatives to working in the office despite providing a doctor’s note supporting the request, and required to continue driving into the office in pain for an extended period after seeking an accommodation. The employee also alleged they could have continued performing their regular duties remotely, particularly because the department was already working remotely at the time. 

As part of the settlement, UCSF will: 

• Hire an external consultant to conduct a thorough assessment of the university’s policies and practices for disability-related accommodations for employees. 

• Implement recommendations made by the consultant, as appropriate and in consultation with CRD, to ensure compliance with state protections for workers with disabilities. 

• Train supervisors, managers, and staff who provide disability services on state requirements regarding reasonable accommodations, as well as protections against disability discrimination. 

• Provide direct notice to certain UCSF medical center employees on their right to be free from discrimination and retaliation, including information on how to request an accommodation. 

• Pay $300,000 in compensation to cover relief for the employee and legal costs. 

What Does It Mean for Employers? 

The case highlights a common compliance issue: applying workplace policies too rigidly without fully evaluating whether reasonable exceptions may be required under California disability laws. 

California law requires employers to engage in a timely, good-faith interactive process to explore reasonable accommodations before denying requests tied to a disability. According to the California Code of Regulations, reasonable accommodations specifically include modified schedules, remote work arrangements, reassignment of duties, leave, changes to work locations, or assistive devices, provided they do not create an undue hardship for the employer. 

California also broadly defines disability protections, covering conditions that limit major life activities, including physical, mental, social, and work-related activities. Employers should ensure supervisors understand that accommodation requests often require individualized assessments rather than automatic reliance on existing workplace policies. 

To reduce legal and compliance risk, employers should ensure accommodation requests are evaluated individually rather than through rigid application of workplace policies. Consider these best practices: 

• Review accommodation policies to ensure flexibility for individualized assessments. 
• Train supervisors and HR personnel on the importance of engaging in the interactive process and documenting accommodation discussions. 
• Consider whether remote work or modified work arrangements may qualify as reasonable accommodations based on the employee’s job duties and operational needs. 
• Avoid retaliatory actions or automatically placing employees on leave before fully exploring accommodation options and, when appropriate, seeking legal counsel. 
• Regularly audit accommodation procedures to ensure compliance with California disability laws.

California employers covered by the state’s pay data reporting requirements are reminded that annual pay data reports to the California Civil Rights Department (CRD) were due May 13, 2026. Employers that have not yet submitted their reports should act quickly to complete their filings. 

California law requires private employers with 100 or more payroll employees, including employers with labor contractor employees, to annually submit pay, demographic, and workforce data to the CRD. Reports are submitted through the CRD’s online Pay Data Portal and include workforce demographic information, pay bands, hours worked, and median and mean hourly rates by race, ethnicity, and sex. 

For those that have not yet filed, immediate action is important. Failure to submit required reports may expose employers to mandatory civil penalties for noncompliance. Employers who fail to report could face penalties of $100 per employee for initial failure to file and $200 per employee for any subsequent failure to file. 

SB 464 also introduced several important compliance updates that employers should prepare for moving forward. Effective January 1, 2026, demographic information collected for pay data reporting purposes must be stored separately from employee personnel records. Beginning in 2027, employers will transition from the current 10 EEO-1 job categories to 23 Standard Occupational Classification (SOC) categories for reporting purposes. 

In addition, the CRD’s current reporting cycle includes expanded reporting fields such as exemption status, employment type, and weeks worked during the reporting year. 

If your organization has not yet filed, consider taking these important next steps: 

1. Submit overdue reports immediately. Employers that missed the May 13 deadline should complete filings through the CRD Pay Data Portal as soon as possible. 
2. Review internal data collection practices. Confirm payroll, HR, and labor contractor data are accurate and complete. 
3. Separate demographic reporting data from personnel files. Ensure that internal procedures are SB 464 compliant by collecting and storing demographic information used for pay data reporting separately from employee personnel records. 
4. Prepare for expanded reporting categories. Begin evaluating how employees will be classified under the upcoming SOC job category structure, which becomes effective in 2027. 
5. Coordinate with labor contractors and payroll providers. Ensure reporting systems and vendor partnerships support current and future compliance obligations.