It happens all the time. An employee calls out for several days and returns with a doctor’s note. Or HR gets an email saying the employee needs to work from home, avoid lifting, change their schedule, or remain off work for another month.

At that point, the employer usually wants to know one thing: Can we approve this, deny it, or ask for more information? Unfortunately, the answer usually is not that simple.

In California, a doctor’s note often is not the end of the analysis. It’s the beginning. Here are the practical steps employers should take after receiving medical documentation.

First, Figure Out What the Employee Wants

Do not get too hung up on the form of the request.

Employees do not have to use the words “reasonable accommodation” or “interactive process” to trigger an employer’s obligations. A note that says “off work until September 15,” “no lifting over 20 pounds,” or “must work from home” may be enough to put the employer on notice that the employee needs some kind of workplace change because of a medical condition.

The first question should be: What does this employee need to work, return to work, or remain employed? If the answer is not clear, ask.

Do Not Turn HR Into a Medical Investigator

Employers understandably want enough information to make a sound decision. But that does not mean HR is entitled to the employee’s diagnosis, complete medical history, or medical records.

Usually, what you need to know is much narrower: What are the employee’s restrictions? How long are they expected to last? What job duties are affected? What accommodation is being requested?

That is the information that helps you make a decision. Knowing the name of the employee’s medical condition does not.

A Doctor’s Recommendation is Not Automatically the Answer

This is another common mistake.

A doctor may write, “Employee must work remotely,” “Employee should not work more than six hours per day,” or “Employee cannot perform customer-facing duties.”

That does not automatically mean your employer must accept the doctor’s proposed solution exactly as written.

The employer still has to look at the employee’s limitations, the essential functions of the job, and whether there are other effective accommodations.

For example, if the note says the employee must work from home, HR should understand why. What limitation does remote work address? Does the job actually require the employee to be onsite? Could another accommodation solve the same problem?

The goal is not simply to approve or reject the doctor’s suggestion. You need to determine whether there is an effective, reasonable accommodation.

Look at the Job the Employee Actually Performs

This sounds obvious, but it is often where the analysis goes sideways.

Before deciding whether an accommodation will work, look at the employee’s real job duties. Not just the job description that was written six years ago and hasn’t been touched since.

Which duties are essential? Which are marginal? Does the employee really need to be onsite? Does the employee really need to lift 40 pounds? Could duties be adjusted temporarily? Would changing one task actually eliminate an essential function? These questions matter.

Employers generally are not required to eliminate essential job functions. But if you want to rely on that principle, you’d better be able to explain essential functions and why they matter.

If the Note Is Vague, Do Not Guess

Medical notes frequently are unhelpful:

• “Employee cannot work in a stressful environment.”
• “Employee needs flexibility.”
• “Employee should avoid prolonged standing.”

These statements do not give the employer enough information to evaluate the request. But an unclear note does not necessarily justify an immediate denial. Ask for clarification.

What does “flexibility” mean? What is the employee unable to do? How often does the restriction arise? How long is it expected to last? What accommodation would allow the employee to perform the job?

You don’t have to guess, and you shouldn’t.  Ask the follow-up questions and get the answers you need.

Keep Talking When Things Change

The interactive process is not a one-time event.

An employee may need a temporary accommodation and then request an extension. A restriction may become permanent. An accommodation that worked well for six months may suddenly stop working.

When the circumstances change, the conversation may need to start again. That is especially important with leave requests. An employee who initially needs four weeks off may later request additional time. Employers should evaluate the new information rather than assuming the original decision settles the issue forever.

Document How You Got There

Employers often document the final answer but not the process that led to it. That is risky.

The file should show when HR first learned about the issue, what information was requested, what the employee provided, what accommodations were considered, and why the employer ultimately approved or rejected a particular option.

Months later, the question is rarely just, “What did we decide?” It is usually, “Why did we decide it?” Good documentation answers both.

The Bottom Line

When a doctor’s note arrives, do not rush to stamp it “approved” or “denied.”

Figure out what the employee is asking for. Focus on restrictions, not diagnoses. Look at the actual job. Ask follow-up questions when the information is unclear. Consider alternatives. And document the process.

The best accommodation decisions do not come from a form or a doctor’s note standing alone. You must engage in a dialogue and thoughtful review of the facts.

Want more information about this important topic?

• Check out EmployersLawyer’s upcoming September 9 webinar, Accommodation Requests Done Right: Avoiding Costly Mistakes in California. Details here: Upcoming Webinars | EmployersLawyer 
• And don’t miss Shaw Law Group’s Effectively Managing Leaves of Absence and Reasonable Accommodations: Intensive Workshop (Advanced Topics) on September 22 and September 29. Space is limited, so register before it’s too late! LOA/RA Advanced Topics