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CDC Telework Accommodations and Medical Privacy Risks

federal employment medical privacy reasonable accommodation rehabilitation act telework policy Dec 17, 2025

Federal employees expect reasonable accommodation requests to be handled carefully, confidentially, and by trained professionals. Recent reports out of HHS—and specifically the CDC—suggest a process that does the opposite, creating legal risk for the agency and real harm for employees with disabilities.

At issue is a new HHS accommodation policy that sharply restricts telework and pushes approval authority upward. At CDC, supervisors are allegedly instructing employees with pending accommodation requests to email medical documentation directly to the CDC chief operating officer to obtain up to 30 days of temporary telework. This workaround is reportedly being used because the agency is facing a backlog of more than 3,000 accommodation cases.

That alone should give any federal employee pause.

Why This Process Conflicts With Disability Law

For federal workers, the Rehabilitation Act governs disability accommodations and incorporates ADA standards. Agencies are required to engage in an interactive process, assess each request individually, and provide an effective accommodation unless doing so would cause undue hardship. This is not discretionary. It is a civil rights obligation.

Routing medical records by email to a senior executive for ad hoc review undermines that framework in several ways.

Unreasonable Delay Becomes a Legal Violation

Accommodation requests are time-sensitive by definition. When approval is centralized at the assistant secretary level or higher, decisions slow down. In disability law, delay itself can amount to a failure to accommodate. Symptoms do not pause while paperwork climbs the chain of command. Agencies are generally expected to reach full accommodation decisions within roughly 30 days, not rely on repeated short-term stopgaps.

Medical Confidentiality Is Not Optional

Medical documentation must be kept in separate, confidential files and shared strictly on a need-to-know basis. Directing employees to email private medical records to a political appointee creates obvious risks: improper disclosure, inadequate safeguarding, and potential retaliation concerns. Reports that trained reasonable accommodation and EEO staff were reduced while the backlog grew only heighten those risks.

“Not a Denial” Can Still Be a Denial

According to reporting, interim telework arrangements will expire without renewal, and employees will be required to return to the office or use leave—while supervisors are encouraged to characterize these outcomes as “not denials.” In practice, if telework is the only effective accommodation and an employee is forced onto leave instead of being allowed to work, the result functions as a denial regardless of the label used.

Courts look at real-world impact, not wordplay.

Risk Being Shifted Downward

Perhaps most concerning, supervisors who raised legal concerns were allegedly told the discussion was over and advised to consider professional liability insurance. That signals awareness of legal exposure, coupled with an attempt to push that risk onto individual managers rather than fixing the process.

These issues have already drawn scrutiny from Senators Tim Kaine and Raphael Warnock, who warned that the policy could disproportionately harm employees with disabilities and requested information from HHS leadership.

For employees being told to bypass normal accommodation channels, send medical records outside established systems, or use leave when they could work with an accommodation, the most important steps are to slow down and document everything. Policies, emails, timelines, and instructions matter.

Legal Disclaimer: The information provided in this article is for informational purposes only and should not be construed as legal advice. While I am a federal employment attorney, this post does not create an attorney-client relationship. Every situation is unique, and legal outcomes depend on specific facts and circumstances.

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