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In 9.2 there is a configuration option available to create actions in the work queue table that open custom dialogs. I have attached that documentation, which is partially done in the Application Configuration (MAF) tool, and then linked to the Actions application of Manage.
However, I believe your idea is a simple enhancement to just require a "Comment" dialog for all actions. There would be no other available actions the user can take other than enter a comment as to why they performed the action. We could enable this dialog as a toggle on the work queue in the work queue builder.