Job-Related Medical Examinations

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Employers may request an employee complete a medical examination when the examination is job-related and consistent with business necessity.  29 C.F.R. § 1630.10(a).  The employer must have a reasonable belief that the employee's ability to perform their job is being impaired by a medical condition or that the employee poses a direct threat due to a medical condition.

A medical examination is also considered job-related and consistent with business necessity when—

  • It is a follow-up to a request for a reasonable accommodation or
  • It is a periodic medical examination.

It is important that an employer's belief that a medical condition is affecting an employee's ability to perform essential job functions be based on objective evidence. The Amendments Act added a provision that employers cannot screen out an applicant because of uncorrected vision unless it is job-related and consistent with business necessity. 29 C.F.R. § 1630.10(b).

When considering the reliability of information learned from another person, employers should consider—

  • The relationship of the person providing the information to the employee in question.
  • The seriousness of the medical condition.
  • The motivation of the person providing the information.
  • How the person learned the information.
  • Any other evidence that may affect the reliability of the information.