For decades, employers could deny a religious accommodation over almost any inconvenience — the 'de minimis' standard made hardship easy to claim. Groff v. DeJoy ended that. Denial now requires showing substantially increased costs in the actual conduct of the business, and accommodation processes built on the old standard are quietly generating liability.
This form reviews requests the way the current law demands: sincerity accepted with guardrails instead of interrogation, a precise conflict analysis, an options table that starts with voluntary swaps, a hardship section that requires numbers instead of adjectives, and a consistency check that asks the question a plaintiff's lawyer will — does this rule already bend for non-religious reasons?
Who should use this review form
- Employers handling Sabbath, holiday, or prayer schedule requests
- HR teams reviewing dress code and grooming policy exceptions
- Supervisors staffing 24/7 or weekend operations
- Anyone whose accommodation process predates 2023
What it helps prevent
- Title VII religious discrimination claims from reflexive denials
- Hardship denials based on the outdated 'de minimis' standard
- Sincerity interrogations that become their own claims
- Inconsistent handling — one faith accommodated, another refused
- Dress and grooming policies enforced into litigation
What’s inside
- Part 1 — Request Record
- Part 2 — Sincerity (handle with care)
- Part 3 — Conflict Analysis
- Part 4 — Accommodation Options
- Part 5 — Undue Hardship Analysis (post-Groff standard)
- Part 6 — Consistency Check
- Part 7 — Decision Record
Before you process payroll, terminate, classify, deduct, or respond to a claim, get the decision reviewed.
Faulkner HR Solutions helps Texas employers, nonprofits, municipalities, and growing businesses fix the people systems behind recurring workplace problems. If this resource raised a risk flag, do not guess your way through the next step.