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Can “Non-traditional” Health Care Providers Provide Medical Documentation?

ENews: Volume 15, Issue 3, Third Quarter, 2017

From the desk of Lisa Mathess, M.A., SHRM-CP, Lead Consultant, Motor Team


Under the ADA, when an employee requests an accommodation, the employer is entitled to sufficient medical documentation from an “appropriate health care professional” when the disability and/or need of accommodation are not obvious. Here at JAN, there has been an onslaught of questions pertaining to what constitutes an appropriate health care professional.

With the ever changing landscape of health care and wellness, more and more people are choosing “non-traditional” healthcare providers for their treatments and medical opinions. Non-traditional providers can refer to a variety of things, but what we see most often is chiropractors, acupuncturists, reflexologists, and massage therapists as opposed to physicians.

So can these non-traditional providers serve as appropriate health care professionals in terms of providing ADA documentation?

In some cases, yes, an employer should be willing to accept medical support that comes from a non-traditional provider. Let’s look at an example:

If an employee has a documented back impairment and a chiropractor is recommending periodic breaks for stretches and rest, then that could make sense. Chiropractors are trained to manage back impairments and their symptoms.

On the contrary, it becomes tricky if a chiropractor is providing medical documentation for someone with a mental health impairment, something a chiropractor is typically not trained to diagnosis or treat. So in this case, an employer may want to find out if the chiropractor is qualified to diagnose or treatment mental health impairments and if not, the employer can probably refuse to accept the documentation.

So it is a case-by-case determination when choosing to accept documentation from non-traditional providers; there is no hard and fast rule.

As far as the ADA goes, an employer should focus on the sufficiency of the documentation and whether the provider is qualified. For more insight on what is considered sufficient, visit JAN's A to Z: Medical Exams and Inquiries. If you have a question about medical documentation or anything else ADA and accommodation related, feel free to reach out to JAN and speak with a Consultant.

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