Employee Medical Examinations Policy

Purpose

To assess and monitor the physical and occupational capabilities of applicants and employees so that they can safely perform the essential functions of their job, without their health being put at risk by the work environment or posing a risk to others.

Types of examinations

1. Post-offer employment physical. Required of candidates after a conditional offer of employment, before they begin work. Scope varies by role, based on the physical/occupational demands of the position.
2. Independent medical examination (IME). May be requested for reasons including a post-offer physical, a short-term or long-term disability claim, a workers' compensation claim, or a job-performance-capability evaluation for a current or prospective role.
3. Medical surveillance evaluations. Baseline and periodic screenings required for employees exposed to regulated hazardous materials or conditions, consistent with applicable occupational safety requirements.
4. DOT-mandated examinations, for employees in positions subject to Department of Transportation regulation.
5. Fitness-for-duty examinations, which may be requested to determine an employee's ability to safely perform job functions — for example, following a layoff, a job-performance evaluation, an absence due to illness or injury, a material change in job requirements, or reasonable-cause circumstances (which include a drug/alcohol test).

Post-offer physical: process

• All candidates who receive a conditional offer of employment must complete a physical exam (and, where applicable, a drug test) before beginning work. The required elements vary based on the position's physical/occupational demands, but consistent with the ADA, the exam (and any resulting disability-related inquiry) must be required uniformly of all entering employees in the same job category, regardless of disability — the company may not single out individual candidates for screening.
• Offers are contingent on successfully completing the exam (and any required drug test); refusing to consent or to test results in withdrawal of the offer.
• Baseline testing for regular full-time roles may include occupational history, physical exam, vision and hearing screening (as relevant to the role), pulmonary function testing (as relevant to the role), and urinalysis/drug screening. Part-time or temporary roles may use a reduced baseline (history, physical exam, vision screening, and drug screening), with additional testing added where the specific job warrants it. "History" means the individual's own occupational and medical history only. Consistent with GINA, examiners must not ask about family medical history (including on standard intake forms), and the company must instruct any examining provider it engages not to collect it.
• If results are unsatisfactory and the individual cannot perform the essential job functions, HR reviews the results (an independent medical evaluation may be requested) to confirm whether the limitation actually affects essential functions. Where a reasonable accommodation would allow the person to perform those functions without undue hardship, the company provides it. Where no reasonable accommodation is available, the offer may be withdrawn consistent with applicable law. Any anticipated rejection on medical grounds should be reviewed with HR/legal before the offer is withdrawn.

Independent medical examinations (IME)

• Performed by a board-certified physician in the relevant specialty who is not currently treating the individual for the condition at issue.
• Typically addresses: history and treatment of the condition; the individual's own relevant past medical history; a current evaluation; recommendations on further diagnostics or treatment; whether the condition is temporary or permanent; whether modified duty or accommodation may be appropriate; the ability to safely perform essential job functions; and an estimated return-to-work date.
• The company (or its insurance carrier) provides the examining physician with relevant records, a description of the job's essential functions, and a clear explanation of why the IME is requested. Note that an IME is evaluative, not treatment-based — the usual physician–patient treatment relationship does not apply. As with any employment-related medical exam, the company must instruct the examining provider not to collect family medical history or other genetic information, consistent with GINA — this applies even though the IME is evaluative rather than treatment-based.

Recordkeeping and confidentiality

• Medical records are retained separately from personnel files, kept confidential, and stored for the duration of employment plus a retention period required by applicable law (this has historically been a lengthy period — for example, several decades in some jurisdictions — so confirm current requirements before setting a retention schedule). Records may be stored in any format that preserves and allows retrieval of the information, except that original imaging (such as chest x-rays) should be preserved in its original form where required.

Responsibilities

Role	Responsibility
HR / Occupational Health	Sets and administers medical examination standards in consultation with an occupational-medicine physician; oversees day-to-day implementation; maintains confidential records.
Examining physician	State-licensed, ideally board-certified in occupational medicine (or supervised by one); familiar with the role's physical/occupational demands.
Manager	Notifies HR of situations that may call for a fitness-for-duty or IME referral; supports accommodation efforts.