Back to Basics: How the ADA restricts medical exams and inquiries for current employees

Summary

The article explains how the Americans with Disabilities Act (ADA) limits what employers can ask and require when a current employee requests an accommodation. Employers must engage in an individualized, interactive process but should avoid overly probing disability-related questions. If a disability is obvious or already known, little documentation is required; if not, employers may request limited documentation or a narrowly tailored medical exam that focuses only on functional limitations relevant to the role. Medical records must be kept confidential and separate from personnel files. The piece also stresses manager training and prompt acknowledgement of requests to keep employees informed.

Key Points

Employers must follow an individualized, interactive process when an employee requests an accommodation.
The ADA restricts disability-related inquiries and medical exams for current employees — questions must be job-related and consistent with business necessity.
Obvious or known disabilities usually require minimal documentation; non-obvious conditions may justify limited documentation from a treating provider.
If necessary, employers can request a medical exam but it must be narrowly tailored to functional limitations relevant to the job, not a broad physical.
Employers should instruct examiners to confirm substantial limitations, describe relevant functional restrictions and suggest possible accommodations.
Medical records must be kept confidential and stored separately from personnel files, with access strictly limited.
Train managers and HR on ADA basics and set up a system to quickly acknowledge and handle accommodation requests to avoid frustration.
Remember other legal limits such as GINA when requesting medical or genetic information.

Context and relevance

This is a practical refresher for HR professionals and line managers who handle accommodation requests. As enforcement and litigation around workplace disability increase, getting the balance right — gathering enough information to evaluate accommodation needs without overreaching into prohibited medical inquiries — is essential. The guidance aligns with federal EEOC resources and Job Accommodation Network advice and is relevant to organisations aiming to reduce legal risk while supporting employees.

Why should I read this?

Quick, helpful and not full of legalese — if you deal with staff or run HR, this saves you from making the classic mistakes: over-asking, mishandling medical records or leaving requests ignored. It tells you what to ask, when to stop asking, and how to keep things tidy and compliant.