Questions and Answers: Enforcement Guidance on Disability-Related Inquiries and Medical Examinations of Employees Under the ADA

May employers require employees to have periodic medical examinations? (Question 18)

• No, with very limited exceptions for employees who work in positions affecting public safety, such as police officers, firefighters, or airline pilots. Even in these limited situations, the examinations must address specific job-related concerns. For example, a police department could periodically conduct vision tests or electrocardiograms because of concerns about conditions that could affect the ability to perform essential job functions and thereby result in a direct threat. A police department could not, however, periodically test its officers to determine whether they are HIV-positive, because a diagnosis of this condition alone would not result in a direct threat.