Telework Accommodation and Medical Records
disability rights eeo process federal employment rehabilitation act telework accommodation Feb 27, 2026If your agency is asking for your “full medical file” to approve telework, pause. Under the Rehabilitation Act (which applies ADA standards to federal employees), agencies are entitled to enough medical information to evaluate your request—not a wholesale audit of your health history.
For GS-9 and above employees navigating discipline, probation, or heightened scrutiny, this distinction matters. An overbroad medical request is not just intrusive. It can derail the interactive process and create unnecessary risk.
What Medical Documentation Is Actually Supposed to Cover
In a federal telework accommodation case, medical documentation should answer three focused questions.
1. What are the functional limitations?
The inquiry is about what you cannot do—or cannot do safely—because of a medical condition. The law centers on functional impact, not diagnostic labels or years of treatment history.
2. What workplace barriers do those limitations create?
The documentation should connect your limitations to your actual work environment. That may involve office noise, exposure triggers, commuting strain, or other site-specific conditions that interfere with performing essential functions.
3. Why is telework (or another modification) effective?
There must be a clear nexus between the limitation and the requested accommodation. A concise letter explaining why remote work removes the barrier is often sufficient.
Anything beyond those three categories should raise a careful, professional eyebrow.
Three Red Flags in the Interactive Process
Certain patterns signal that the process is drifting out of its legal lane.
Repeated requests without explanation. If you have already provided documentation addressing disability, limitations, and workplace barriers—and the agency keeps asking for “more” without identifying what is missing—that suggests delay, not clarification.
Broad, untethered record demands. Requests for “all treatment notes” or your “complete medical history” typically exceed what is job-related and consistent with business necessity.
Moving goalposts. When each submission triggers another form, another letter, another undefined “clarification,” with no decision in sight, the issue may no longer be documentation—it may be process management.
How to Respond Without Escalating
The goal is not confrontation. The goal is precision.
A calm written response can reset the discussion: request that the agency identify exactly what information is missing and explain why it is relevant to your functional limitations and the requested accommodation. Offer to provide targeted documentation from your provider addressing those specific gaps. State clearly that you do not consent to producing unrelated, broad medical records.
If timing affects your ability to work safely, request an interim accommodation—such as temporary continuation of telework—while the review is completed.
This approach keeps you cooperative and compliant, while protecting your privacy and strengthening the record.
Why Scope Matters
Overbroad medical demands can themselves become part of an EEO claim. Disability-related inquiries must be job-related and consistent with business necessity. When agencies stray beyond that boundary, it may signal a flawed interactive process.
Early legal guidance can narrow the medical scope, preserve confidentiality, and build a clean, defensible record if the matter escalates. For those seeking deeper step-by-step guidance, additional resources are available in the firm’s telework accommodation materials.
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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