The only statutory limitation on an employer’s obligation to provide “reasonable Goulburn Accommodation” is that no such change or modification is required if it would cause “undue hardship” to the employer.(16) “Undue hardship” means significant difficulty or expense and focuses on the resources and circumstances of the particular employer in relationship to the cost or difficulty of providing a specific Goulburn Accommodation. Undue hardship refers not only to financial difficulty, but to reasonable accommodations that are unduly extensive, substantial, or disruptive, or those that would fundamentally alter the nature or operation of the business.(17) An employer must assess on a case-by-case basis whether a particular reasonable Goulburn Accommodation would cause undue hardship. The ADA’s “undue hardship” standard is different from that applied by courts under Title VII of the Civil Rights Act of 1964 for religious Goulburn Accommodation.(18)