How do I know if a medical certification is needed for FMLA leave?

Quick answer: Employers may require a medical certification to support FMLA leave for an employee's own serious health condition (including pregnancy/childbirth), care for a family member with a serious health condition, or care for a covered servicemember. When leave is requested for one of these reasons, the employer must give written notice that certification is required, and the employee generally has 15 calendar days to submit it. There's no official required form, though the DOL offers optional ones — the employer must supply a blank certification if one is needed.

Who this applies to / Prerequisites

• Employees requesting FMLA leave for their own serious health condition, a family member's serious health condition, or care of a covered servicemember
• Employers and HR/Leave teams responsible for issuing certification requests and evaluating completeness
• Applies to federal FMLA; some state leave laws follow the same rules but may differ

Steps

1. Notify the employee in writing that a medical certification is required, including the potential consequences of not returning it on time or submitting it incomplete or insufficient.
2. Supply the employee with a blank medical certification form (no official form is mandated, but the employer must provide one).
3. Employee submits the completed certification, generally within 15 calendar days of the request.
4. Review the certification for completeness (all applicable entries filled out) and sufficiency (information is not vague, ambiguous, or non-responsive).
5. If incomplete or insufficient, notify the employee in writing and allow 7 calendar days to cure and resubmit.
6. Once complete and sufficient, the certification is accepted. The employer generally cannot request additional information beyond this point, except in the specific circumstances outlined below.

What information can the certification include

• Health care provider's contact information and medical credentials
• Date the condition began and its estimated duration
• Appropriate medical facts about the condition (symptoms, diagnosis, hospitalization, doctor visits, medication, referrals, or other continuing treatment) — note: in California, employers cannot ask for a diagnosis, though employees may disclose one voluntarily
• For the employee's own condition: information establishing they cannot perform essential job functions, plus the nature and duration of work restrictions
• For care of a family member: information establishing the family member needs care, that care by the employee is medically necessary, and an estimate of frequency/duration of leave needed
• For intermittent or reduced schedule leave: information establishing medical necessity, estimated dates/duration of treatments and recovery periods, and frequency/duration of incapacity episodes

What if it doesn't work

• Certification comes back incomplete or insufficient: Notify the employee in writing and give them 7 calendar days to cure and resubmit.
• Employer doubts the validity of a certification: The employer may require a second opinion at their own expense, using a healthcare provider they choose (typically not someone they regularly employ). If the second opinion conflicts with the employee's, the employer may request a third, final and binding opinion — the provider must be jointly chosen or approved by both employer and employee, both acting in good faith.
• Leave continues into a new leave year: The employer can request a new certification (annual renewal/recertification) for each additional leave year.
• Employer wants to request recertification of an already-approved certification: Generally only allowed after 30 days, and only in connection with an employee absence, for leave related to the employee's own or a family member's serious health condition. If certified leave exceeds 30 days, the employer must wait until that leave period ends. Recertification can always be requested every six months, regardless of leave length, in connection with an absence.
• Recertification requested outside the standard timing: Allowed only if circumstances described in the prior certification have changed significantly (e.g., frequency of treatment or type of absence differs substantially from what was certified), or if the employer receives information casting doubt on the stated reason for absence or continuing validity of the certification.
• If you are considering recertification for an employee, contact your Leave Success Manager for next steps.
• If none of these apply, contact your Leave Success Manager.

Limits and exceptions

• This article covers medical certification under federal FMLA only, based on FMLA regulations and DOL guidance.
• Many state laws follow the same rules as FMLA, but some states have their own certification rules — check with your Leave Success Manager for state-specific questions.
• In California, employers cannot ask for a diagnosis on a medical certification, though employees may voluntarily disclose one.
• A certification is incomplete if any applicable entry is left blank, and insufficient if the information is vague, ambiguous, or non-responsive.
• If a certification is complete and sufficient, the employer generally cannot request additional information beyond the second/third opinion, annual renewal, and recertification exceptions described above.
• Recertification (outside the 6-month standard) requires either a significant change in circumstances or new information casting doubt on the certification — a general suspicion alone is not sufficient grounds.

Related questions

• How long does an employee have to submit an FMLA medical certification?
• What happens if an employee submits an incomplete FMLA certification?
• Can my employer request a second opinion on my medical certification?
• How often can my employer ask for a new medical certification?
• What information can my employer request on a medical certification?
• Does my employer have to use an official DOL form for medical certification?