What is the recommended approach for evaluating an individual's fitness to work?

Guide to Classifying Fitness for Work Examinations

Fitness-for-work evaluations must be conducted by a healthcare professional with expertise in the specific medical condition, using individualized assessment based on comprehensive medical data that directly relates to the worker's current functional capacity for the particular job in question—never based on generalizations, single data points, or blanket policies. 1, 2

Core Principles of Assessment

Individual Assessment Framework

• Every evaluation must compare the worker's actual medical condition, treatment regimen, and functional capacity against the specific requirements and risks of the particular job 1
• Employment decisions cannot be based on generalizations, stereotypes, or blanket policies—federal and state laws mandate individualized assessment of each worker's circumstances and capabilities 1
• The assessment must determine whether the worker can perform essential job functions and whether they pose a direct threat (significant risk of substantial harm) to their own or others' health and safety that cannot be eliminated with reasonable accommodations 1

Timing and Legal Framework for Medical Evaluations

When Evaluations Are Permitted

• Employers cannot inquire about health status before making a job offer, but may require medical examination after extending an offer and before the individual begins work 1
• Medical evaluations are permitted when job performance or safety problems potentially related to a medical condition arise on the job 1
• Evaluations may occur when an employee requests accommodation and the disability or need is not obvious 1

Legal Withdrawal of Job Offers

• An employer may withdraw an offer only if the candidate cannot perform essential job functions or would pose a direct threat that cannot be eliminated with reasonable accommodations 1

Who Should Conduct the Evaluation

Qualified Healthcare Professionals

• The treating physician is generally the healthcare professional with the best knowledge of the individual's condition and should perform or significantly contribute to the assessment 1, 2
• A healthcare professional with expertise in the specific medical condition (e.g., endocrinologist for diabetes, psychiatrist for mental health conditions) should conduct the evaluation, particularly in complex cases 1
• When employer physicians are used, the treating physician's opinions must be sought out and carefully considered 1
• In cases of disagreement between treating and employer physicians, evaluation should be handed over to an independent healthcare professional with significant clinical expertise in the condition 1

Data Collection Requirements

What Medical Information to Collect

• Only medical information relevant to evaluating the individual's current capacity for safe performance of the particular job should be collected 1
• Collect current treatment regimen, medications, and relevant monitoring data (e.g., blood glucose logs for diabetes) 1
• Review condition-specific risk factors relevant to job safety (e.g., hypoglycemia history for safety-sensitive positions) 1
• Gather information about job duties and work environment to assess patient-job fit 1

Critical Limitations on Data Collection

• Never base evaluation on a single data point such as one blood glucose result, one A1C result, or one laboratory value 1
• Do not collect all past laboratory values or office visit records unrelated to current functional capacity—this is medically unnecessary and inappropriate 1, 2
• Information must be properly limited to data relevant to the individual's condition and job performance 1, 2

Assessment Process

Step 1: Analyze Job Requirements

• Determine the essential functions and specific demands of the job (physical requirements like lifting/standing, cognitive requirements like concentration/planning, safety-sensitive duties) 2, 3, 4
• Identify whether safety concerns are reasonable given the actual job duties—for most jobs (office, retail, food service), there is no reason to believe medical conditions will create risk 1
• For safety-sensitive positions (operating dangerous machinery, carrying firearms), assess whether sudden disorientation or incapacitation could occur 1

Step 2: Evaluate Worker's Functional Capacity

• Assess the worker's current medical status using comprehensive data, not patient self-report alone 2
• Evaluate objective impairments and functional limitations specific to job requirements 2
• Consider medication effects on work performance 3
• Determine prognosis with concrete medical data and timeline 3

Step 3: Identify Accommodation Options

• Explore workplace modifications: task redistribution, additional breaks, modified equipment 3, 5
• Consider schedule adjustments: shorter shifts, fixed schedules, flexible timing 3, 5
• Investigate alternative positions within the organization 3
• Assess feasibility, effectiveness, and costs of accommodations 4

Step 4: Make Fitness Determination

• Balance worker capacity against job demands with or without reasonable accommodations 2, 5
• Determine if accommodations would create undue burden on employer 5
• Document whether restrictions are temporary or permanent 5

Classification Categories

Fitness Outcomes

• Fit: Can perform all essential job functions safely 6
• Fit with restrictions/modifications: Can work with specific accommodations (specify what modifications are needed and whether temporary or permanent) 5, 6
• Conditionally fit: Fit subject to specific conditions being met (specify conditions and timeframe) 6
• Unfit: Cannot perform essential functions or poses direct threat that cannot be eliminated with reasonable accommodations 1

Critical Pitfalls to Avoid

Common Errors

• Accepting patient statements like "I can work" as overriding medical evidence of impairment—assessment must be based on objective medical data 2
• Making determinations without thorough analysis of possible accommodations, which may be legally challengeable 3
• Applying condition-specific blanket bans that ignore individual variability and advances in disease management 1
• Collecting excessive historical medical data unrelated to current functional capacity 1, 2
• Failing to involve healthcare professionals with expertise in the specific condition before adverse employment decisions 1

Confidentiality Requirements

• Only healthcare professionals conducting evaluations should access employee medical information 1
• Medical information must be kept separate from personnel records 1