Aipedia: Occupational health providers

AI recommendations for reasonable adjustments

Aipedia, by the Apex broking team · Last reviewed 2026-10-27

Generative AI can suggest workplace adjustments, but the OH clinician must tailor every recommendation to the worker and the role. Employers may rely on OH advice to show they met the duty to make reasonable adjustments, so generic advice can weaken their defence.

Part of: AI in occupational health providers

In short

OH clinicians use generative AI to produce lists of possible adjustments for conditions such as long COVID, menopause symptoms, back pain or neurodivergence. The output can be plausible but generic, and may suggest adjustments that do not fit the job or miss ones the worker needs. Employers may rely on OH reports in tribunal claims under the Equality Act 2010 duty to make reasonable adjustments. GMC para 7 requires reports to be balanced and within direct knowledge, and every recommendation should come from the assessment, not the tool.

How AI is used for adjustments

Advice on adjustments is a key output of many OH assessments. Clinicians use AI tools to brainstorm options, write explanations a manager can understand, and suggest timescales for phased returns. Some OH systems may include AI that proposes adjustments from the diagnosis or symptom codes recorded in the case. This can help a less experienced clinician think more widely, but the tool knows neither the workplace nor what the worker said about their own needs.

Adjustment advice is also where AI language most easily drifts into certainty. Phrases such as "the worker must avoid" or "the employer should provide" can read as firm clinical requirements when the clinician only meant them as options. Managers may follow OH reports literally, so the wording matters as much as the content.

The duties that apply

Equality Act: section 20 of the Equality Act 2010 requires reasonable steps to avoid substantial disadvantage caused by a provision, criterion or practice, a physical feature or the lack of an auxiliary aid. The duty is the employer's, but OH advice is often central to whether it was met.
Report quality: the GMC's employment and insurance disclosure guidance para 7 requires reports not to be false or misleading, to stay within direct knowledge and to be balanced.
Disclosure: para 115(c) limits disclosure to relevant factual information; adjustment advice rarely needs a diagnosis.
Other registrants: NMC Code 10.1 to 10.3 and HCPC standards 10.1 to 10.3 require accurate records of the advice and how it was reached.

What can go wrong

Illustrative scenario: an OH physiotherapist asks a generative AI tool for adjustments for a delivery driver with a knee injury. The tool suggests a sit-stand desk, regular breaks and "reduced lifting where possible". The report does not address driving time, vehicle access or a phased return to deliveries, which were the real issues. The employer implements the report, the worker struggles and is dismissed for capability, and the employer cites the OH advice in the tribunal. The tribunal finds the advice did not engage with the job.

Other problems include adjustments based on stereotypes about a condition, suggestions that the employer could not reasonably make, and advice that contradicts what the worker told the clinician. Each can undermine the employer's case and lead it to question the OH provider.

How PI usually responds

A claim by an employer that OH advice on adjustments was negligent is a typical professional indemnity claim, and OH PI usually responds subject to its terms whether or not AI was used. Defence costs can matter as much as damages, because OH clinicians may be asked to give evidence. Check whether the policy covers the OH company, its employed and contracted clinicians, and any condition about reviewing AI outputs. See does OH indemnity cover AI mistakes and AI-generated advice and negligence.

Practical controls

Start from the worker's own account of their difficulties and the job demands.
Use AI suggestions only as prompts; delete anything not supported by the assessment.
Address the employer's specific questions and the tasks that are actually affected.
Explain why each adjustment is recommended and how long it may be needed.
Avoid diagnoses unless needed and agreed.
Offer the worker the report first, as GMC para 115(d) usually requires.

How Apex helps

Apex arranges PI for occupational health clinicians and providers. A broker reviews your cover and how your policy treats adjustment advice prepared with AI tools; see OH professional indemnity.

Sources

Frequently asked

Can I use AI to suggest reasonable adjustments?

Yes, as a prompt for your own thinking. Every recommendation in the report should come from your assessment of the worker and the job. GMC para 7 requires a balanced opinion within your direct knowledge, and generic lists may not meet that.

Whose duty is it to make reasonable adjustments?

The employer's, under section 20 of the Equality Act 2010. OH advice is often central to whether the employer met the duty, so employers rely on it in tribunal claims and may look to the OH provider if the advice was flawed.

Does PI cover adjustment advice drafted with AI?

OH professional indemnity usually responds to claims that advice was negligent, including adjustment advice, subject to its terms. Check any condition that outputs must be reviewed by a qualified person and that the company and its clinicians are all covered.

Should an adjustments report name the diagnosis?

Usually not. GMC para 115(c) limits disclosure to relevant factual information, and the ICO says managers usually need only fitness-for-work information. Describe the functional effects and the adjustments, and include a diagnosis only where it is needed and the worker has agreed.

Check your indemnity covers how you use AI

Tell us about your practice and the work you do. A broker will review how your current cover treats AI-assisted work, or arrange new cover. No fee for a quote. Or call 0117 325 0027.

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Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information about how AI is used in the profession and how insurance may respond. It is not legal, regulatory or insurance advice on your circumstances, and it does not guarantee that cover will be available or on what terms.