Fix Return-to-Work Letters and Accommodation Requests Without a Full-Healed Gate

A return-to-work letter can put a doctor’s restriction and a company rule on the same page. The rule that demands a full-healed employee is usually the part that creates the dispute.

For HR leads and line managers, the safer move is to match the restriction to the actual job, document the conversation, and set a review date. The individualized judgment is the legal requirement; the documentation is good practice that makes the judgment defensible.

A blanket full-healed gate creates the dispute

A blanket return-to-work rule can look neutral, but it often ignores the difference between a temporary limitation and an essential function. If the employee can do the core work with a short restriction, refusing the return can create a disability discrimination problem.

Full-healed language also creates a false choice. An employee may be medically cleared for a limited set of tasks while still needing a short restriction. If the job can be performed within that limit, the employer needs a reason tied to the work, not a preference for a clean medical clearance.

The EEOC alleged that Schumacher fired P.A., an accounting clerk, in May 2024 while she was on leave recovering from cancer-related surgery. Schumacher fired the employee after she sought a five-pound lifting limit and three weeks without repetitive squatting, bending, or lifting. A four-year consent decree required the company to pay the former employee $112,500 as compensatory damages. The four-year consent decree required that P.A., the fired employee, be paid compensation that included back pay. U.S. District Judge Ed Artau of West Palm Beach approved the consent decree, and Schumacher denied the allegations and any unlawful conduct. The decree also required Schumacher to create a broad disability accommodation policy, hold recurring training for staff and supervisors, and send complaint and accommodation-request information to the EEOC. The company can use the same structure internally: a written policy, manager training, and a record of each request.

A short checklist keeps the file defensible

Use this list when a reasonable accommodation request or a return-to-work letter arrives. The list is short on purpose. A long form invites managers to treat the process as a legal exercise. A short form makes it easier to complete the same steps for every request. Each item should be testable in a minute, because the file needs to show a decision, not a debate.

• Remove full-healed language from the return-to-work form.
• Identify the written essential functions for the role before deciding.
• Document the interactive process: who discussed the restrictions, what was offered, and what the employee said.
• Set an end date and a review date for every temporary restriction.
• Confirm the approving manager completed accommodation training.
• Log the request in the accommodation tracker with date, role, and status.

The record should show the interactive process, not a legal theory. A manager can complete the checklist before approving the letter. Keep the language plain and short. The file should show what the employee can do, what the employer can adjust, and what remains unresolved. If a restriction is unclear, ask the doctor for a task-based description. If the doctor’s note is silent on a core task, note that gap and seek clarification before making a final decision.

The manager should own the job facts, not the gate

Line managers often see the restriction first and make the call before HR has identified the job’s essential functions. The process breaks there. A manager should say what the job actually requires, not whether a doctor’s note is good enough.

When a request comes in, the manager should identify the tasks that cannot be removed, the tasks that can be reassigned, and the tasks that can be done with a short limit. The default is a documented return plan.

Training should cover the same basics: what counts as an essential function, how to document a reasonable accommodation request, and why a strict return-to-work demand can create risk. Managers do not need to become lawyers. They need to know when to stop deciding and route the request to HR.

The interactive process works best as a short conversation with a written record. Time limits matter. A short restriction differs from a permanent change. A review date gives both sides a way to adjust without starting a new dispute. If the restriction changes, update the record and set the next review date.