Employment Examinations

Employment decisions should not be based on generalizations or stereotypes about the effects of diabetes. The impact of diabetes and its management can be very different for different people. When employers make decisions about people with diabetes or evaluate an employee's condition, they need to take this variability into account.

To read the Association'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 a worker with diabetes can happen only under certain conditions. Employers may not ask about your health status—directly or indirectly—before making a job offer, no matter the type of job. However, an employer may require a medical examination once an offer of employment has been made and before you begin the job.

Additionally, any medical examination must be required of all potential employees in the same job category. An employer may not single out an applicant for a medical examination just because the applicant has diabetes.

The job offer may be conditioned on the results of the medical examination.

Can I be denied a job because 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 poses a significant risk of substantial harm, and this threat cannot be eliminated with an accommodation.

Can my employer require a medical examination once I am on the job?
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, an employer is required to individually assess whether a worker poses a safety threat (usually through a medical examination) 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 can 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 an employer has questions 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.

Your treating physician generally has the best knowledge of your diabetes and in many cases can perform the assessment. But in some situations and in complex cases, another physician who is an expert in diabetes should be involved as well.

Employers often have physicians on staff to conduct medical evaluations, or have a contract with an outside physician to do so. Even when the employer uses its own physician to perform the evaluation, it should seek out and carefully consider the opinions of your treating physician and other health care professionals with expertise in diabetes.

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 performing the evaluation should have access to your medical information. Your supervisor does not need this information, and it 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 the sole basis for an employment decision.