Employment decisions should not be based on generalizations or stereotypes regarding the effects of diabetes. The impact of diabetes and its management varies widely among individuals.
Therefore, a proper assessment of individual candidates for employment or current employees must take this variability into account.
To read the Assocation's clinical practice recommendation on this issue, see the position statement Diabetes and Employment.
Can a potential employer conduct a medical examination of my diabetes?
A medical evaluation of worker with diabetes may occur only in limited circumstances. Employers may not inquire about your health status — directly or indirectly and regardless of the type of job — before making a job offer, but may require a medical examination once an offer of employment has been extended and before you begin the job.
The job offer may be conditioned on the results of the medical examination.
Can I be denied a job on the basis of a medical examination?
An employer may withdraw an offer only if it becomes clear that you cannot do the essential functions of the job or you would pose a direct threat to health or safety. This means that hiring you for the job in question poses a significant risk of substantial harm, and this threat cannot be eliminated with an accommodation.
When can my employer otherwise conduct employment examinations?
Your employer can also require an examination if you've had a problem potentially related to your diabetes on the job that could affect job performance and/or safety. In fact, employers are required to individually assess whether a worker poses a safety threat before it takes any adverse employment action.
In this situation, a physician may be asked to evaluate your fitness to remain on the job and/or your ability to safely perform the job.
In addition, if you have requested a reasonable accommodation for your diabetes, your employer is permitted to obtain medical information when your disability or your need for an accommodation is not obvious. Often, the “examination” here involves having your physician answer questions on a form about your diabetes and the accommodations you need.
Who must conduct the medical examination?
When questions arise about the medical fitness of a person with diabetes for a particular job, a health care professional with expertise in treating diabetes should perform an individualized assessment. A health professional who is familiar with the person with diabetes and who has expertise in treating diabetes is best able to perform such an assessment.
In some situations and in complex cases, an endocrinologist or a physician who specializes in treating diabetes or its complications is the best qualified health professional to assume this responsibility. The individual's treating physician is generally the health care professional with the best knowledge of an individual's diabetes.
Thus, even when the employer utilizes its own physician to perform the evaluation, the opinions of the treating physician and other health care professionals with clinical expertise in diabetes should be sought out and carefully considered.
What medical information is my employer entitled to evaluate?
The information your employer may request will vary depending on the type of job and the reason for the evaluation, but generally it should be limited to data relevant to your diabetes and job performance.
Since diabetes is a chronic disease in which health status and management requirements naturally change over time, it is inappropriate — and medically unnecessary — for employers to collect all past laboratory values or information regarding office visits whether or not related to diabetes. Only medical information relevant to evaluating your current capacity for safe performance should be collected and evaluated.
Information about your diabetes management (such as the current treatment regimen, medications, and blood glucose logs), job duties, and work environment are all relevant factors to be considered.
Only health care professionals tasked with such evaluations should have access to employee medical information, and this information must be kept separate from personnel records.
Can my employer require me to have a certain A1C level as a condition of employment?
An employment decision should never be made based only on one piece of data, such as a single blood glucose result or A1C result.
A1C values provide health care providers with important information about the effectiveness of an individual’s treatment regimen, but are often misused in assessing whether an individual can safely perform a job. Because they identify only averages and not whether the person had severe extreme blood glucose readings, A1C/eAG results are of no value in predicting short-term complications of diabetes, and thus have no use in evaluating individuals in employment situations.
The American Diabetes Association recommends that in most patients A1C levels be kept below 7%. This recommendation sets a target in order to lessen the chances of long-term complications of high blood glucose levels, but does not provide useful information on whether the individual is at significant risk for hypoglycemia or suboptimal job performance, or as a measure of “compliance” with therapy.
An A1C cut-off score is not medically justified in employment evaluations and should never be a determinative factor in employment.