CLARIFYING WORK RESTRICTIONS

Clarifying Work Restrictions & Understanding Medical Notes

A medical note is a communication tool, not an administrative order. Its primary legal function is to establish an employee's functional limitations so the employer can conduct an individualized assessment.

When evaluating medical notes, Disability Coordinators and supervisors must apply three core principles:

• Medical Notes Are Accommodation Triggers: Unless a healthcare provider explicitly states an employee is completely unable to work in any capacity, any note listing restrictions, modifications, or medical needs is a request to initiate the interactive process- not an automatic authorization for medical leave.

• Doctors Set Functional Limitations; Employers Determine Accommodations: A medical provider's role is to define the individual's clinical baseline and functional ceiling (e.g., "Cannot lift over 15 lbs," "Requires 10-minute rest breaks every two hours"). It is the employer's responsibility—through the interactive process—to evaluate job functions and determine which operational accommodation will remove the workplace barrier. If a doctor suggests a specific accommodation (e.g., "Employee needs telecommute"), view that suggestion as a starting idea, not a binding directive, and begin the interactive process.

• Required Elements of Valid Documentation: When medical verification is required for non-obvious limitations, the documentation should identify:

  • The functional physical or mental limitations impacting job duties.

  • The expected duration for each limitation (whether temporary with an estimated end date, or permanent).

  • Note: Diagnosis, full medical history, and detailed treatment plans are strictly prohibited under FEHA.

Proactive Strategies for Disability Coordinators

If a medical provider offers vague, incomplete, or operational suggestions rather than clear functional limits, Disability Coordinators should use targeted, low-friction strategies to clarify restrictions without creating unnecessary administrative delays:

• Equip the Employee with Precise Questions: Medical offices rarely complete lengthy, generic forms efficiently. Provide the employee with a short, specific question or single sentence for their provider (e.g., "Please ask your doctor to clarify how many hours per day you can perform repetitive keyboarding").

• Direct Healthcare Provider Contact: With a signed release from the employee, the Disability Coordinator may contact the treating provider directly to ask targeted questions about functional restrictions. Keep inquiries strictly limited to essential job functions and functional limits.

• Focus on Function Over Terminology: If a doctor writes a vague note like "Employee needs light duty," do not reject the note out of hand. Use the interactive dialogue with the employee to understand the employee's difficulty relative to their specific daily tasks while seeking targeted functional clarification.