An employee requested a medical exemption from a workplace policy but refused to provide adequate documentation or let her provider clarify her condition. A federal appeals court found that was enough to end the interactive process—and the employer’s obligation.
TL;DR: A recent Fourth Circuit decision confirms that the ADA’s interactive process depends on cooperation. If an employee refuses to provide information needed to evaluate an accommodation request, the employer may have no duty to accommodate at all.
A request for accommodation—without follow-through
An employee claimed she couldn’t comply with her employer’s COVID-19 vaccination policy because of a chronic immune condition. She requested a medical exemption under the ADA, but declined to submit current medical records or allow contact with her healthcare provider.
Instead, she offered a decade-old lab report and general medical articles. The employer’s medical officer reviewed the submission and asked for updated information or direct provider input. She refused. The exemption request was denied, and when she remained noncompliant with the policy, she was terminated.
She sued under the ADA for failure to accommodate, disability discrimination, and unlawful medical inquiry. The court dismissed all claims, and the Fourth Circuit affirmed.
Why the ADA process never got off the ground
The ADA requires employers to accommodate qualified individuals with disabilities, but only when the employer has enough information to understand:
- That the employee has a disability, and
- That the disability causes functional limitations requiring accommodation.
The employee doesn’t need to name a specific diagnosis or use legal terms—but they do need to provide facts. In this case, the employee’s refusal to authorize contact with her provider or supply current records meant the employer had no way to evaluate her request. That ended the ADA interactive process before it began.
The court emphasized: the employer can’t be faulted for failing to accommodate when the employee won’t explain what she needs or why.
Employees don’t have to name a diagnosis—but they do have to provide details
When an employee seeks an accommodation under the ADA, employers are entitled to ask for documentation that explains:
- That the employee has a physical or mental impairment,
- That the impairment creates functional limitations in the workplace, and
- That the requested accommodation would help address those limitations.
The employee does not have to identify a specific diagnosis or use the word “disability.” But unless both the disability and the need for accommodation are obvious, they must provide enough information—directly or through documentation—to allow the employer to evaluate the request.
Here, the employee refused to authorize provider contact or share updated records. What she submitted was vague, outdated, and unsupported. The court found that wasn’t enough to trigger the employer’s obligation to accommodate.
Employers don’t have to accept guesswork or incomplete information. If what’s submitted doesn’t show how the condition impacts job performance, it’s appropriate to ask for more. If the employee declines, the request can be lawfully denied.
The process breaks when one side disengages
The ADA’s interactive process only works when both parties engage. Employers must respond in good faith—but employees have a responsibility too.
In this case, the employer clearly explained what was needed: updated documentation or permission to speak with a provider. The employee declined. She didn’t clarify her limitations, didn’t allow provider contact, and didn’t submit the information needed to assess the request.
That disengagement ended the process before it truly began. Without enough information to understand the disability or the need for accommodation, the employer had no obligation to proceed further—and the court agreed.
The ADA protects employees with disabilities. But it also expects participation. When one side stops engaging, the process doesn’t just stall—it may legally come to an end.
What employers should take away from this ruling
✅ Ask for the right documentation
Make clear, specific requests. If you can’t evaluate the request without provider input, explain that and offer a release form.
✅ Keep the door open
Don’t issue a flat denial without giving the employee an opportunity to supplement. But you don’t have to wait forever.
✅ Document your effort to engage
Courts pay attention to process. If you asked multiple times and got no meaningful response, that matters.
✅ Remember: it’s a shared obligation
The interactive process requires communication from both sides. Employees don’t have to name a diagnosis, but they do need to provide enough information—unless the disability and need for accommodation are obvious—for the process to work as intended.
The bottom line
The ADA protects employees with disabilities—but it also expects them to engage. When an employee blocks the interactive process by refusing to share relevant information, an employer may be within its rights to deny the request and move forward.