Asking for updated disability documentation went too far
Under the federal Americans with Disabilities Act (ADA), employers may ask for reasonable documentation of employees’ limitations when conditions aren’t obvious or when they don’t already have enough documentation. This step occurs when employees ask for accommodations as part of an interactive process with employers. Once employers have enough information, they shouldn’t ask for updated documentation unless something has changed.
An employer learned that asking for updated documentation and pausing the accommodation process didn’t sit well with the Equal Employment Opportunity Commission (EEOC) or a court.
The story
Megan, an employee, had a disability. She asked to work fewer hours as a reasonable accommodation and gave her employer medical documentation to support her request. The employer approved the accommodation.
Megan also took time off under the federal Family and Medical Leave Act (FMLA) for which she supplied a certification.
Eventually, Megan asked to be reassigned to an open, part-time position as a reasonable accommodation. She applied for three vacant positions.
Before the employer proceeded with Megan’s reassignment request, it told her that she had to provide updated documentation. While waiting for the documentation, the employer paused the accommodation process. Several months later, Megan provided the documentation, but by then, the employer had filled the positions.
Megan went to the EEOC, and the agency sued the employer on her behalf.
The claim
The EEOC alleged that the employer violated the ADA by failing to reassign Megan to a vacant position as a reasonable accommodation.
The employer argued that Megan didn’t provide updated medical documentation before it filled all three positions. As a result, the employer claimed, it didn’t have to consider her accommodation request.
The decision
The court said it’s true that, generally speaking, employers have the right to ask for documentation on the medical necessity of an employee’s accommodation.
Case law doesn’t, however, say that employers may take no action on an employee’s request or pause the interactive process entirely when it’s already on notice of an employee’s disability.
Megan already gave the employer medical paperwork on two occasions:
- When receiving an earlier reasonable accommodation, and
- When taking FMLA leave.
The court found, therefore, that the employer’s requirement that Megan give it updated medical documentation before it took any action on Megan’s transfer request was done in bad faith. The employer already had sufficient information.
Thus, the court said, there was no general legal requirement that an employee who’s already provided medical documentation must provide more before triggering the employer’s obligation to continue the ADA interactive process.
Equal Employment Opportunity Commission v. William Beaumont Hospital d/b/a Beaumont Health System, Eastern District of Michigan, No. 23-cv-11560, 19 November 2025.
Key to remember: Employers that already have paperwork supporting an employee’s accommodation request shouldn’t ask for updated documentation, and they shouldn’t hold off on providing an accommodation while waiting.
