When an individual’s impairment is substantiated with sufficient medical documentation, and it has been determined that the impairment is an ADA disability, there will rarely be a valid reason to request that the employee recertify the existence of the disability to continue providing accommodations for an arbitrary duration (i.e., annually), or to provide new accommodations related to the same impairment. Sometimes employers will request an update regarding whether there is a change in limitations or need for accommodation, but new medical information should not be requested to recertify or substantiate the existence of a disability when the disability is known and the need for accommodation is ongoing.
According to the Equal Employment Opportunity Commission (EEOC), employers cannot ask for medical documentation when the disability and/or need for reasonable accommodation is known or obvious, or the individual has already provided sufficient information to substantiate the existence of an ADA disability. However, individual circumstances might allow an employer to request updated information when it is job-related and consistent with business necessity.