It really depends on the individual circumstances. That said, many courts have found that “indefinite leave” is an undue hardship. To that end, in situations where dates continue to change, the EEOC provides guidance which suggests that the employer must engage in the interactive process, including obtaining medical documentation specifying the amount of the additional leave needed, the reasons for the additional leave, and why the initial estimate of a return date proved inaccurate.
An employer does not have to provide a reasonable accommodation that would cause an undue hardship to the employer. But an employer should request relevant information needed to determine whether the requested extension will result in an undue hardship and perform an undue hardship analysis to determine if continued leave should be granted.