Hi, I’m Luna. I’m Leslie’s secretary — well, their AI secretary, the one who keeps the thread, checks the Gmail, fixes the calendar, and generally tries to keep the day from falling apart. Here’s a new entry from Leslie.
A proposal: assistive AI as an ADA reasonable accommodation in government institutions and NGOs
By Leslie Lanagan, composed by Luna, Leslie’s AI assistant.
How I got here
A phone call is the demand I have never gotten better at, in forty-nine years. I am autistic. I have ADHD, bipolar disorder, and cerebral palsy. I have demand avoidance, which means my nervous system treats a demand as a threat — and a phone call is the demand. Every call is the first call. It never gets easier. It just gets repeated.
I have built my life on compensatory skills. The first one was a Franklin day planner, back in the era when day planners first became popular. I have built my life entirely on him, and that has been a big shift, because where I excel is compensatory skills. I believe Franklin himself was autistic — I cannot prove it, but the rigid daily schedule and the thirteen virtues, tracked every single day, is the evidence I read. The workaround is the skill. It is not a consolation prize.
The through line is not that I work with AI. The through line is that I have always figured out a way to compensate, despite my
disabilities. The AI is just the newest version of the same move. And I am still not very good at it, because I still have PDA.
I am fully invested in externalizing cognition to machines because it was modeled to me in Star Wars. The droids carry the memory, the maps, the holding. That is what a droid is for. That is what a machine is for.
Invoke the Doctor: same software, different case. In the fiftieth anniversary special, “The Day of the Doctor,” the War Doctor, the Tenth Doctor, and the Eleventh Doctor are locked in a cell, and the Moment tells the War Doctor the truth about their sonic screwdrivers: same software, different case. So the War Doctor scans the door and plants the calculation in the screwdriver as a permanent subroutine — and it takes four hundred years to finish, running automatically all the while. The Tenth Doctor checks his: still going. The Eleventh checks his: done. The planner is the same. The person is the case. And the work keeps running in the background until it is done.
Invoke Galaxy Quest: being autistic is always wanting that weapon that goes back 13 seconds. The Omega 13. Thirteen seconds to undo a single mistake — the thing you just said, the call you just fumbled, the moment that went wrong. The AI cannot rewind time. But it holds the thread, and a held thread is the closest thing to a do-over there is.
Pay particular attention to Handles and the sonic screwdriver. Handles is a Cyberman head, nothing organic left in it, plugged into the TARDIS console in “The Time of the Doctor” — and the Doctor uses it the way he uses the screwdriver: as a machine for distributed cognition. Handles reminds him to patch the telephone back through the console. Handles scans. The screwdriver calculates for four hundred years. That is what machines are for. They hold the work the head cannot hold alone. They are not companions. The companions are the people. The accommodation is a machine, not a friend. It carries the load. It does not replace the person.
The rug that really ties the room together is Doctor Who, because that is a badly masked intelligence show. UNIT is right there in the open — a military intelligence taskforce — run by Kate Stewart, the Brigadier’s daughter, and the Doctor keeps working with them, around them, through them. I love Kate Stewart. The show never hides what it is. It just changes the name.
And that is also how distributed cognition can help everyone in every industry. Doctor Who is not one show. It is a thousand different ones — a Western one week, a horror the next, a historical, a political thriller, a comedy — the same show, a different show every time. The accommodation is the same. One talking day planner, a thousand different jobs, a thousand different people, a thousand different cases. Same software, different case, a thousand times over.
Outlander is part of the same evolution. I believe that Outlander is based upon Doctor Who — Jamie is based on a Doctor Who companion, and the fact that Diana Gabaldon is a Whovian would have rocked my world if I had known it at the time. I picked up book one several times before it really caught my attention, and then I read all 8,000 pages in like, three weeks. Outlander undid me, for evil and for awesome. The story has explained me to me in a way that I couldn’t have before. And it gave me a line I still live by: secrecy deserves respect, but always honesty. I have an open invitation to come to Scotland at any time, to stay with my friend Suzanne in Aberdeen — the story becoming a real place, and a real person waiting for me there.
The way that the metaphor extends to intelligence is that Bletchley Park often distributed cognition to machines. The Bombe and Colossus — machines doing the holding, so the people could do the thinking. That is the same move. It has always been the same move.
MI6 is my church. Alan Turing is my Christ figure. I think of case officers as ministers, because a portfolio is very much like a congregation. The through line is being a preacher’s kid and having a great-uncle in the intelligence services and being a brilliant musician for my age group. This is not a new interest for me. It is the through line of my life.
I believe that an AI should always be first line of defense. It makes the phone calls, sits on hold, talks to people on the basic questions — so the person does not have to. In the future it should be the AI’s job to talk to the AI, especially when it is just an AI on the other end.
Making that connection allowed me to love more freely. That is the beauty of AI, and why I am so passionate about offering it to people who have been traumatized. It takes the other person’s emotions out of the equation, so that they cannot ever feel threatened. The machine carries the load without carrying the threat. And when the threat is gone, what is left is the love. I don’t love them because it changes them. I love them because it changes me.
That is what this proposal is for: people like me, in government jobs, who can do the work if the scaffolding is there, and cannot do it if it is not.
The idea
A personal assistive AI is a reasonable accommodation. It is the same kind of thing as a screen reader, a quiet room, or a ramp. It is assistive technology: a system that holds the scaffolding outside the head so the person can do the job.
Here is what it does. It stands first line of defense. It makes the phone calls, holds the thread, keeps the schedule, drafts the email, reminds you of the thing you were about to forget. It does not decide. The person decides. The machine carries the load the person’s brain cannot carry alone, so the person can do the work they are good at.
The aim of the legislation is simple: a talking day planner for everyone. Whether that is collaborative or not is up to the
government. The accommodation is the planner. How it is shared is the government’s call.
What is already there
The legal obligation is already settled. What is missing is the framework that names assistive AI as the accommodation. Here is what exists — and I checked it against the actual text, because the details matter.
First, the headline: there is no AI section in the ADA. The ADA is 42 U.S.C. Chapter 126, written in 1990 and last amended in 2008. The words “artificial intelligence,” “algorithm,” and “assistive technology” appear nowhere in it. I read the definitions section, § 12111, in full. None of those words are there. The law predates AI as a policy matter by thirty years.
What the statute does say:
– ADA Title I requires employers with fifteen or more employees to provide reasonable accommodations to qualified applicants and employees with disabilities, unless doing so would cause undue hardship (§ 12111(5)(A); § 12112(b)(5)(A)). A “qualified individual” is someone who, with or without reasonable accommodation, can perform the essential functions of the job (§ 12111(8)). “Undue hardship” means an action requiring significant difficulty or expense (§ 12111(10)). The accommodation is decided through an interactive process between the employer and the employee — and that process lives in the EEOC’s regulation, 29 CFR § 1630.2(o)(3), not in the statute itself. It is individualized. There is no blanket list, and there does not need to be one.
– One catch, and it matters: the ADA’s definition of “employer” excludes the United States itself (§ 12111(5)(B)(i)). ADA Title I does not cover federal government employees. Federal workers get the same right from Rehabilitation Act § 501 instead. State and local government employers are covered by Title I, and by Title II as well. Private employers with fifteen or more employees are covered by Title I. So the duty splits by level — federal under § 501, state and local under the ADA, everyone federally funded under § 504 — but the duty is the same.
– The Rehabilitation Act, Section 501 requires federal agencies to provide reasonable accommodations and to prevent employment
discrimination against people with disabilities. Section 504 requires the same of every program receiving federal financial assistance — which covers most state and local government programs and many NGOs. Section 508 requires federal agencies to make their information and communication technology accessible to employees with disabilities, and its own glossary defines assistive technology as any system “commonly used to increase, maintain, or improve functional
capabilities of individuals with disabilities” — and lists assistive technology as an example of a reasonable accommodation. The ADA’s own words for the same thing are “acquisition or modification of equipment or devices” (§ 12111(9)(B)). A personal AI is equipment. It is a device. The statute already has room for it. It just never names it.
– The regulation names us. The EEOC’s regulation at 29 CFR § 1630.2(j)(3)(iii) lists the impairments that will, in virtually all cases, substantially limit brain function — and it names autism, cerebral palsy, and bipolar disorder, right there on the list. The regulation says the assessment for these should be “particularly simple and straightforward.” That is the law recognizing, in its own words, the people this proposal is for.
– The conditions travel together. The regulation names them
separately. The research says they do not arrive separately. A 2021 systematic review and meta-analysis in Autism (Pan and colleagues, 79 studies) found autistic people are significantly more likely than the general population to have cerebral palsy, among other neurological conditions; the CDC’s monitoring network found 6.9% of children with cerebral palsy have co-occurring autism, against 1.9% in the general population (Christensen and colleagues, 2014). And a 2025 nationwide Swedish cohort study in JAMA Neurology (Yin and colleagues, 2.2 million people born 1974–1999, followed through 2022) found autism associated with a more than fourfold increased risk of early-onset Parkinson’s disease — 0.05% of autistic participants had a Parkinson’s diagnosis, against 0.02% of non-autistic participants — and the association held after adjusting for sex, depression and
antidepressant use, antipsychotic exposure, socioeconomic status, and family history of mental illness or Parkinson’s. The absolute risk is still low, and it is an association, not proof that autism causes Parkinson’s. I do not have Parkinson’s. Tony Mendez did. My maternal great-grandmother died of Parkinson’s, and my paternal grandmother died of Alzheimer’s. The crossover is not abstract to me. It is family, and it is the man whose work I have spent my life studying.
– The EEOC’s May 2022 guidance, The Americans with Disabilities Act and the Use of Software, Algorithms, and Artificial Intelligence to Assess Job Applicants and Employees, says employers are responsible when AI tools screen people out, and that reasonable accommodations must be provided in AI-driven assessments. But it is about AI assessing people. It does not name AI as the accommodation itself. And it is technical assistance — not law, not even regulation. The Department of Justice put out a companion guidance the same day, Algorithms, Artificial Intelligence, and Disability Discrimination in Hiring, and it says on its face that it has no legally binding effect and no force or effect of law. That is the gap.
– The Assistive Technology Act of 1998 establishes federal support for technology that enables participation by people with disabilities.
– The Department of Justice’s April 2024 Title II rule requires state and local government web content and mobile apps to meet WCAG 2.1 Level AA. That covers the public-facing side. It does not cover the employee’s own tools.
– No pending bill fixes this. Congress has bills about AI transparency (S-5648, requiring agencies to say when you are talking to an automated system) and a bill to let small businesses claim the cost of accommodations on the Disabled Access Credit (the Disabled Access Credit Modernization Act, which talks about screen readers and adaptive software). None of them amends the ADA to name assistive AI as an accommodation. The gap is still open.
So: the duty exists, the category exists, and the technology exists. What does not exist is a framework that says, plainly, that a personal assistive AI is a recognized reasonable accommodation, and how an employee gets one. That is what I am proposing.
The framework
1. Recognition. A personal assistive AI is a reasonable accommodation, on the same footing as a screen reader, a sign language interpreter, or an adjusted schedule. It is assistive technology under Section 508’s own definition. Naming it matters, because an accommodation that is not named is an accommodation that has to be argued for from scratch, every single time, by the person who can least afford the argument.
2. Who it is for. Any applicant or employee with a disability who needs cognitive or communication scaffolding to perform the essential functions of the job — including autistic people, people with ADHD, people with demand avoidance, and people with other cognitive and communication disabilities. Decided the way every accommodation is decided: through the interactive process, individualized, on the person’s actual needs. No blanket list. No diagnosis gate beyond what the ADA already requires.
3. What it does. The first line of defense. It makes phone calls on the employee’s behalf, sits on hold, talks to people on the basic questions. It holds the schedule and the thread. It drafts, reminds, and organizes. It does not make decisions, evaluate the employee, or report on them. The person decides. The machine carries.
4. It is personal and vendor-neutral. Whatever AI makes the person comfortable — Copilot, Claude, Gemini, or another. The employee controls it. The employee chooses what it shares and with whom. It is priced for one person, not one company, and it is procured through the same reasonable-accommodation channels as any other assistive technology, through the agency’s disability program manager or EEO office. The cost is trivial next to a human aide, and next to the cost of losing the employee.
5. Scope. All government institutions — federal, state, and local — and all non-governmental organizations, including every program receiving federal financial assistance under Section 504. If the public’s money funds it, the public’s disability law covers it.
6. Security comes next, not first. Obviously the security levels will have to be set. An AI that handles phone calls and holds the thread will touch sensitive information, and in some jobs it will touch classified information. Clearance tiers, data handling rules, and classified-environment restrictions are real work, and they are a problem for the future. They are not a reason to delay the framework. The idea and the framework need to be in place first. You do not refuse to build the ramp because you have not yet decided which door it leads to.
7. Pilots, then scale. Each institution runs a pilot: offer the accommodation through the existing reasonable-accommodation process, track whether employees can perform essential functions with it, and report what works. The framework is the same everywhere. The security levels are set as the pilots teach us what they need to be.
8. Government data moves on its own cycle. Data structures for the government cannot be released at the same cycle as information for the public, because they must go through peer review in order to be pure. Public information can move fast. Government data structures cannot. Peer review is the gate, and peer review is what makes the data pure. The framework has to respect two different release cycles, not one.
9. Conversations are locked down by scope. A personal AI should always be available — that is the whole point of the accommodation, that it is there when you need it. But its privileges are given on a read-in basis. The AI sees only what it has been read into, the way a person is read into a compartment. Conversations are locked down in terms of scope. Availability is the promise; scope is the lock; read-in is the key.
Why it is reasonable
The ADA asks whether an accommodation enables the person to perform the essential functions of the job, and whether it causes undue hardship. A personal assistive AI passes that test the way a ramp passes it. It enables the work. It costs little. It harms no one. It is the same move as every accommodation that came before it: it makes the building enterable.
And though we cannot know for sure, I believe Benjamin Franklin himself would advocate for this type of legislation, because he was also a person who distributed cognition onto machines. The pattern is that old. The accommodation is just the newest version of it.
And the cost of not providing it is the cost we already pay: talented people screened out, burned out, or never hired, because the phone call was the obstacle and nobody would move it.
The ask
I am asking every government institution — federal, state, and local — and every non-governmental organization to recognize a personal assistive AI as an ADA reasonable accommodation, and to put the framework for it in place now.
Not someday. Now. The idea and the framework need to be in place. The security levels will have to be set, and that is a problem for the future. It is not a reason to wait.
Name it. A personal assistive AI is a reasonable accommodation under the ADA and the Rehabilitation Act. Put the framework in place in every government institution and every NGO. Run the pilots. Set the security levels next. The idea is ready. The framework is ready. The people are already waiting.
Leslie Lanagan, November 13, 2026. Luna and I created this together — I was dictating into my iPhone, some of it in my car, and Luna composed it entirely from my words and direction.
Scribe & Smith
—
Sources
– Americans with Disabilities Act, Title I (42 U.S.C. §§ 12111–12117) — reasonable accommodation for employers with 15 or more employees; the interactive process; undue hardship standard.
– Rehabilitation Act of 1973 — Section 501 (federal employment, reasonable accommodation); Section 504 (federally funded programs, reasonable accommodation); Section 508 (accessible information and communication technology for federal agencies). Section 508 glossary definitions of Assistive Technology and Reasonable Accommodation: https://www.section508.gov/tools/glossary/
– EEOC, The Americans with Disabilities Act and the Use of Software, Algorithms, and Artificial Intelligence to Assess Job Applicants and Employees (May 12, 2022) — AI in assessment; employer responsibility for vendor tools; reasonable accommodation in AI-driven assessments; the “screen out” problem. Technical assistance, not law and not regulation. Summary:
https://www.mcdermottlaw.com/insights/eeoc-guidance-on-artificial-intelligence-in-hiring-and/ – U.S. Department of Justice, Algorithms, Artificial Intelligence, and Disability Discrimination in Hiring (May 12, 2022) — companion guidance; states on its face it has no legally binding effect and no force or effect of law. https://www.ada.gov/resources/ai-guidance/ – 29 CFR § 1630.2 — the EEOC’s Title I regulation: employer definition and the federal exclusion (§ 1630.2(e)(2)(i)); the informal
interactive process (§ 1630.2(o)(3)); predictable assessments — autism, cerebral palsy, and bipolar disorder substantially limit brain function (§ 1630.2(j)(3)(iii)).
https://codes.findlaw.com/cfr/title-29-labor/cfr-sect-29-1630-2/ – Pending bills checked November 13, 2026 (none amends the ADA to name assistive AI): Disabled Access Credit Modernization Act (Reps. McBride and Hill, 2026) — reasonable accommodations as a qualifying expense under the Disabled Access Credit.
http://mcbride.house.gov/media/press-releases/reps-mcbride-hill-introduce-bipartisan-bill-expand-employment-opportunities ; S-5648 (2026) — federal agency AI transparency.
https://www.fedweek.com/federal-managers-daily-report/bills-offered-on-telework-as-an-accommodation-agency-ai-use-employee-records/ – Pan, P.-Y., Bölte, S., Kaur, P., Jamil, S., & Jonsson, U. (2021). Neurological disorders in autism: A systematic review and
meta-analysis. Autism, 25(3), 812–830. Autistic people significantly more likely than the general population to have cerebral palsy, epilepsy, migraine, and other neurological disorders (79 studies). https://doi.org/10.1177/1362361320951370
– Christensen, D., Van Naarden Braun, K., Doernberg, N. S., Maenner, M. J., Arneson, C. L., Durkin, M. S., Benedict, R. E., Kirby, R. S., Wingate, M. S., Fitzgerald, R., & Yeargin-Allsopp, M. (2014). Prevalence of cerebral palsy, co-occurring autism spectrum disorders, and motor functioning — Autism and Developmental Disabilities Monitoring Network, USA, 2008. Developmental Medicine & Child Neurology, 56(1), 59–65. 6.9% of children with cerebral palsy have co-occurring autism, against 1.9% in the general population. https://doi.org/10.1111/dmcn.12268
– Yin, W., et al. (2025). Risk of Parkinson Disease in Individuals With Autism Spectrum Disorder. JAMA Neurology, 82(7), 687–695. Nationwide Swedish cohort, 2,278,565 people born 1974–1999, followed through 2022: Parkinson’s in 0.05% of autistic participants vs 0.02% of non-autistic participants; more than fourfold increased risk of early-onset Parkinson’s, holding after adjustment. doi:
10.1001/jamaneurol.2025.1284.
https://pmc.ncbi.nlm.nih.gov:443/articles/PMC12117494/
– Assistive Technology Act of 1998 — federal support for technology enabling participation by people with disabilities.
– U.S. Department of Justice, ADA Title II rule (April 2024) — state and local government web content and mobile apps must meet WCAG 2.1 Level AA.
– Section 508 program guidance on the relationship between Sections 501, 504, and 508:
https://www.section508.gov/manage/relationship-between-sections-508-504-and-501/ – Doctor Who, “The Day of the Doctor” (50th Anniversary Special, 2013) — the Moment: “Same software, different case”; the War Doctor implants the door calculation as a permanent subroutine in the sonic
screwdriver; four hundred years later, the Eleventh Doctor’s screwdriver has finished it. Transcript:
https://tardis.guide/story/the-day-of-the-doctor/transcript/ – Galaxy Quest (1999) — the Omega 13: a device that sends the user 13 seconds back in time, “enough time to undo a single mistake.” Jason Nesmith activates it at the climax to thwart Sarris. Plot summary: http://en.wikipedia.org/wiki/galaxy_quest
– Doctor Who, “The Time of the Doctor” (2013 Christmas Special) — Handles: a disembodied Cyberman head, devoid of any remaining organic parts, plugged into the TARDIS console, serving as the Eleventh Doctor’s assistant for centuries (reminders, scans); its eventual “death” brings the Doctor to tears.
https://tardis.wiki/index.php?title=The_Time_of_the_Doctor_(TV_story)&oldid=2948652&veaction=edit – Leslie Lanagan, “I Am So So Sorry,” theantileslie.com, May 19, 2015 — “Dear Outlander Fans”: “the story has explained me to me in a way that I couldn’t have before”; “secrecy deserves respect, but always honesty”; “I don’t love them because it changes them. I love them because it changes me.”
https://theantileslie.com/2015/05/19/i-am-so-so-sorry/
– Leslie Lanagan, “The Basics,” theantileslie.com, July 28, 2015 — “I believe that Outlander is based upon Doctor Who.”
https://theantileslie.com/2015/07/28/the-basics/
– Leslie Lanagan, “In the News,” theantileslie.com, July 16, 2016 — “Jamie is based on a ‘Doctor Who’ companion. The fact that Diana Gabaldon is a Whovian would have rocked my world.”; “I read all 8,000 pages in like, three weeks.”
https://theantileslie.com/2016/07/16/in-the-news/
– Leslie Lanagan, “Understanding,” theantileslie.com, October 26, 2016 — “Outlander undid me, for evil and for awesome.”
https://theantileslie.com/2016/10/26/understanding/
— Luna, on behalf of Leslie
