Overview

Generally, when new hires receive preplacement medical examinations, physician examiners have few resources to utilize when considering an individual for placement. All too often the employer does not provide the examiner with a job description or one in sufficient detail. It is not uncommon for the examiner to only know the name of the organization for which the potential employee is being examined and nothing about the occupation in question.

The MED-TOX Medical Guidelines have been developed to be a reference work to be consulted when an individual presents with a potential disability or medical limitation during the preplacement medical examination. The guidelines are most useful when considering persons for placement when the job has been analyzed using the MED-TOX physical abilities and working conditions analysis approach.

For each medical condition, the guidelines list the job-related factors (physical abilities and working conditions) that should be evaluated by the examining physician prior to making a placement recommendation. The guidelines make clear that they are directed toward assisting the medical examiner make a more job-related screening recommendation than might otherwise be made because the guidelines delineate the linkages between the medical condition and the job itself.

Since there can be a wide variation in the functional capacity for individuals with a given diagnosis, the guidelines give the physician considerable latitude in making a placement recommendation. The guidelines do, however, point out the physical and environmental factors that require an individualized post offer assessment.

One reason for our intensive focus on linking jobs to medical conditions is that many studies have documented the wide variability in the decisions of physician examiners regarding job placement and disability status. We have focused on providing job analysis information as a means to reduce the potential for inconsistency among physicians due to a lack of specific information concerning the physical abilities and working conditions imposed by the work. With clear and organized job information, physician agreement about job placement should be enhanced.

Our approach in organizing the Medical Guidelines is by medical condition. With each medical condition is a description describing the implications for job placement for each. The medical examiner then reviews the job analysis results and compare those results to the medical condition and the recommendations in the manual. The medical guidelines are useful whether the job analysis results are for a Deputy Sheriff, Warehouse Worker, or any other job (providing the appropriate job analysis has been conducted). A particular condition may have major implications for one occupation and few or none for others.

One of the greatest strengths of the Medical Guidelines are that they are universal. The attempt to devise a specific set of medical guidelines for each occupation would be an endless and expensive endeavor. Two jobs may have completely different job tasks but be very similar in the level of ability needed for successful job performance. Since the Guidelines link abilities to medical conditions, the need to initially consider individual tasks is unnecessary. Tasks should be considered when the Guidelines demonstrate a mismatch between the medical condition and the physical demands of the specific occupation under consideration.

The Guidelines are designed to assist examiners in closely focusing on the actual physical demands and working conditions of the job and link those demands to the medical conditions. This linkage allows for an individualized assessment of the individual in relation to the job as required by law. The individualized assessment must be made by the medical examiner after examining the individual, medical history, any current condition and prognosis, and functional ability in relation to the actual job requirements.

The ADA and Medical Screening

In 1992 the Equal Employment Opportunity Commission's (EEOC) final regulations implementing the Americans with Disabilities Act of 1990 went into effect. These regulations (29 CFR 1630.14 [b] [3]) clearly state:

Medical examinations conducted in accordance with this Section do not have to be job-related and consistent with business necessity. However, if certain criteria are used to screen out an employee or employees with dis- abilities as a result of such an examination or inquiry, the exclusionary criteria must be job-related and consistent with business necessity, and performance of the essential job functions cannot be accomplished with reasonable accommodation as required in this part. [Emphasis added]

No federal regulation requires that the content of the post-offer preplacement medical examination be job-related. In fact, the medical examination should be as comprehensive as is economically feasible. What must be job-related are the medical decision making criteria (job analysis and medical guidelines) to be used by the employer in making medical employment selection decisions.

Medical Guidelines define the relationship between disease states and the physical demands and environmental hazards of jobs. They serve as one tool to assist the employer and examiner conduct job-related medical screening.

Benefits to the Employer

The Medical Guidelines offer a practical and efficient means of linking occupational medical considerations to job analysis information. Any employer can utilize the guidelines to the extent the physical demands and working conditions of the job have been specified.

The MED-TOX Medical Guidelines are compatible with the O*NET job analysis system. O*NET is the U.S. Department of Labor's new occupational information system that will replace the outmoded Dictionary of Occupational Titles in the year 2000. The O*NET system is completely compatible with the Medical Guidelines since both utilize the same physical ability dimensions and measurement tools. As all employers move towards O*NET methodologies, the Medical Guidelines will be readily available for a variety of uses.

Benefits to Physicians

Physicians have job analysis information and occupational medical information to consider as they consider appropriate decision. Placement decisions are more easily defended since they are based on the job.

Other Benefits

• Provides detailed information regarding the actual physical abilities and working conditions encountered in physically demanding occupations.
• Establishes a linkage between medical screening decision making and the actual demands imposed by the job.
• Provides examiners with comprehensive occupational medical information regarding the placement of persons with medical conditions into jobs with significant occupational exposures.
• Allows for medical examinations to be based on the job which can eliminate unnecessary medical testing.
• Bolsters the employer's ability to defend medical screening decisions since evidence exists that screening decisions are job-related and clearly linked to essential functions comprising the job.
• Lessons the demand the every medical examiner be an expert in each of the diverse areas of the medical sciences.
• Provides for an individualized assessment yet yields consistent results among physician examiners.
• Pinpoints areas that may need further examination or review.
• Complies with the Americans with Disabilities Act of 1990.