In our experience at JAN, there is often confusion about medical documentation under the ADA: what employers may ask for, when they may ask, and whether the ADA Amendments Act changed the rules. Employees and medical professionals also have questions about how much information is needed to support an accommodation request. Most of these issues arise when an employee requests an accommodation.
The general rule is straightforward: when a disability or the need for an accommodation is not obvious, an employer may request documentation that substantiates that an employee has an ADA-covered disability and needs the reasonable accommodation requested, but the employer should not request unrelated medical information.
To determine whether an employee has a disability for accommodation purposes, an employer may ask whether the employee has (or had) an impairment, whether the impairment affects (or affected) a major life activity, and whether the impairment substantially limits (or limited) that activity.
The ADA Amendments Act lowered the threshold for showing that a condition is substantially limiting, so in many cases the documentation needed to establish a disability will be less extensive than in the past.
An employer may also verify that the specific accommodation is needed and ask questions about how the employee's limitations cause the workplace problem so the employer can identify effective accommodations. Requests should be limited to information relevant to the accommodation request.
Related resources
- Guidance on how to determine whether a person has a disability for accommodation purposes.
- Information about appropriate medical inquiries and sample documentation forms for accommodation requests.
- Practical guidance for medical professionals on providing sufficient documentation to support a patient's request.
For additional context about medical documentation and insurance issues, see Understanding Medical Documentation and Health Insurance. You may also find Understanding Medical Documentation and Insurance Options helpful when considering how documentation and coverage interact.
When deciding what to request or provide, focus on what is needed to evaluate the disability and the requested accommodation — and stop there. If you have questions about coverage or need help locating an appropriate plan, consider contacting an agent by using the link to talk to an agent.
Frequently Asked Questions
What medical information can an employer request when an employee asks for an accommodation?
An employer may request documentation that verifies an ADA disability and explains why the requested accommodation is needed, but should limit inquiries to information directly related to the accommodation.
Has the ADA Amendments Act changed documentation requirements?
The ADA Amendments Act lowered the threshold for showing a substantial limitation, so less documentation is often required to establish a disability, but the accommodation verification rules remain the same.
How much must an employee disclose about their condition?
An employee should provide enough information to establish the disability and the need for the requested accommodation, but is not required to disclose unrelated medical details.
What should medical professionals include in documentation to support an accommodation request?
Useful documentation typically identifies the impairment, describes how it limits major life activities or work tasks, and explains how the recommended accommodation will address those limitations.
Can an employer request past medical records or unrelated diagnoses?
No—employers should not request unrelated medical records; requests must be limited to information necessary to evaluate the disability and the accommodation need.