Medical verification is not always required to approve an accommodation request or for an employee to receive an accommodation.
Under the Americans with Disabilities Act and other applicable reasonable accommodation/adjustment laws and regulations, employers may request medical documentation only when it is necessary to evaluate the request.
Start with the interactive process
Before requesting medical documentation, employers should first engage in the interactive process with the employee.
This includes:
Understanding the employee’s needs
Clarifying job-related challenges
Exploring potential accommodation options
In many cases, this conversation provides enough information to move forward without additional documentation.
When is medical verification appropriate?
Medical verification may be appropriate if:
The condition or need for accommodation is not obvious
Additional information is needed to understand functional limitations
The employer cannot determine an effective accommodation based on the information available
When is it not needed?
Medical documentation is often not necessary when:
The condition and need for accommodation are already known
The limitation is obvious
The requested accommodation is straightforward and low risk
Important considerations
Medical verification should not be the first step in the process
Requests for documentation should be limited to what is necessary
The focus should remain on identifying effective, reasonable accommodations
Key takeaway
Medical verification is a supporting tool — not a default requirement.
Employers should prioritize a good-faith interactive process and request documentation only when needed to move the request forward.
Tools in Disclo that support the interactive process
Disclo provides tools to help facilitate the interactive process before turning to medical verification:
Request Clarifications
Ask the employee targeted, job-related questions to better understand their needs and limitationsPropose Changes
Suggest alternative accommodations or adjustments to collaboratively identify an effective solution