COUNTY OF FRESNO DEPARTMENT OF HUMAN RESOURCES. Interactive Process Reference Guide

Transcription

1 DEPARTMET OF HUMA RESOURCES Interactive Process Reference Guide

2 Table of Contents Overview: General Overview and Objective... 2 Essential Information: Responsibilities and Timeline... 3 Interactive Process... 5 Accommodation of Permanent Work Restrictions in a Different Classification Glossary Attachments Flowcharts

3 Overview I. General Overview In accordance with the Federal Americans with Disabilities Act (ADA), California Fair Employment and Housing Act (FEHA), and the County of Fresno Personnel Rule 8 Section 8040, the County has an obligation to engage in the interactive process in a timely manner and provide a reasonable accommodation for employees with qualifying disabilities. A reasonable accommodation is one that does not create an undue hardship on the employer. This guide is intended to serve as a resource for departments as they engage in the interactive process to determine whether a reasonable accommodation can be made for an employee with a qualifying disability. This guide is intended to be used for both industrial (on-the-job) and non-industrial injuries and/or illnesses. Departments should approach the interactive process in the same manner, whether the disability is due to an industrial or non-industrial injury or illness. The compensability status of a workers compensation claim will dictate how and from whom disability notification is received, and which Human Resources representative will assist with department inquiries. Contact County of Fresno s Risk Management Division at for inquiries regarding industrial injuries/illnesses and County of Fresno s Employee Benefits Division at for inquiries regarding non-industrial injuries/illnesses. If information relating to accommodations for qualifying disabled job applicants is required, contact your department s assigned human resources analyst in Employment Services. Il. Objective To determine if a reasonable accommodation can be provided to employees with qualifying disabilities and to engage in a timely, good faith interactive process. 2

4 Essential Information Essential Information, Responsibilities & Timeline A. An employer shall initiate the interactive process when: An applicant or employee with a known physical or mental disability or medical condition requests reasonable accommodations; or The employer otherwise becomes aware of the need for an accommodation through a third party or by observation; or The employer becomes aware of the possible need for an accommodation because the employee with a disability has exhausted leave. From the point of first notification, begin using the Interactive Process Record Keeping Form (Ind. Temp., Ind. Perm., on-ind. Temp., on-ind. Perm.) for documentation purposes and continue using this form throughout the process. This form is an important tool in the record keeping of the interactive process; it is designed to ensure all steps in the process from initial notification through final resolution are completed. In addition, it serves as documentation that the employer has met its obligation under the law. An employee may have a qualifying disability under protected leaves such as the Family Medical Leave Act (FMLA), California Family Rights Act (CFRA), or Pregnancy Disability Leave (PDL). Departments should review and designate leaves as appropriate. Continued communication with Employee Benefits and submission of Job Change Information forms (JCI s) when needed for leave of absence approval is essential to complete the interactive process. B. Responsibilities Coordination of the interactive process takes place at the department level. It is the department s responsibility to promptly engage in the interactive process, to identify reasonable accommodation and to complete this process in a timely manner. Employees have the responsibility to actively participate and cooperate in the interactive process to identify reasonable accommodation. Risk Management advises departments of applicable state and federal laws and procedures with regard to the interactive process on an industrial injury/illness. Employee Benefits advises departments of applicable state and federal laws and procedures with regard to the interactive process on a non-industrial injury/illness. Employee Benefits will advise departments regarding the transfer process on all injuries or illnesses that result in permanent restrictions that cannot be accommodated by a home department. 3

5 Employment Services will provide the department with a current list of vacant positions in all County departments. The department shall identify positions for which the employee may meet minimum qualifications. Employment Services will review employee s application to confirm whether or not the employee meets the minimum qualifications for the identified positions. C. Timeline The interactive process should be initiated as soon as the employer is aware of the need for an accommodation. The employer has a duty to act in a timely manner and in good faith. The goal is to provide reasonable accommodations that allow the employee to continue working. Departments should have temporary positions and/or other tasks identified in order to return employees with temporary restrictions to work in a timely manner. Identifying accommodations for permanent restrictions may take additional time. Departments will need to consider the long term impacts of accommodating an employee s restrictions, and possibly identify other classifications within the department and/or County that can accommodate the restrictions. 4

6 Interactive Process Steps Step 1- Establish qualification pursuant to ADA/FEHA Review medical documentation to determine if the employee has a qualifying disability under ADA/FEHA (refer to Glossary). If the disability does not qualify under ADA/FEHA, a reasonable accommodation is not required by law. Step 2 - Identify the essential functions of the position A. Essential functions are the fundamental, crucial job duties performed in a position. They do not include marginal functions, which are extra or incidental duties. A function is considered essential when: The position exists to perform that function. There are a limited number of employees available who could perform that function. The function is highly specialized, and the incumbent is hired for special expertise or ability to perform it. B. Essential functions must be identified for each position (as opposed to job classification) and they must be based on the work performed, rather than the capabilities of an individual. Consult with the employee s immediate supervisor when identifying essential functions and determine if there are any other work environment factors that may be relevant to the employee and his/her reasonable accommodation request. The essential functions are documented on the Essential Functions Inventory Form (EFIF) and should be in the department s personnel file for every position prior to a request for a reasonable accommodation. C. In order to determine which functions are essential, the following questions should be asked: Is the function a primary reason for which the position was established? For example: A floating supervisor position exists to provide a substitute when regular supervisors on day, night or graveyard shifts are absent. An essential function of the job may be to work at any time of day. Does the function require specialized expertise? For example: Dual language positions may have essential functions related to speaking a second language fluently. Accountant positions may have essential functions that require licensure as a Certified Public Accountant. D. A function may be essential regardless of the amount of time spent performing it. Completely and accurately identifying the position s essential functions is critical in the interactive process. 5

7 Step 3 - Identify the employee s work limitations and/or restrictions A. If the department has knowledge of the disability and the limitations and/or restrictions are obvious, it is not necessary to have the employee provide medical documentation. Example: the employee has a cast on his/her leg. It is obvious that the employee would need an accommodation to avoid walking/standing for long periods of time. B. An employer may require an employee to provide documentation that is sufficient to substantiate that he/she has an ADA/FEHA disability and needs the reasonable accommodation requested, but the employer cannot ask for unrelated documentation. This means that, in most circumstances, an employer cannot ask for an employee's complete medical record because it is likely to contain information unrelated to the disability at issue and the need for accommodation. 1. Documentation is sufficient if it: a. Describes the nature, severity and duration of the employee's impairment. b. Describes the activity or activities that the impairment limits. c. Describes the extent to which the impairment limits the employee's ability to perform the activity or activities. d. Substantiates why the requested reasonable accommodation is needed. 2. Documentation is insufficient if: a. It does not specify the existence of an ADA/FEHA disability and explain the need for reasonable accommodation. b. The health care professional does not have the expertise to give an opinion about the employee's medical condition and the limitations imposed by it. c. The information does not specify the functional limitations due to the disability. d. Other factors indicate that the information provided is not credible or is fraudulent. If an employee provides insufficient documentation, an employer does not have to provide reasonable accommodations. 3. If the note is unclear, then it is necessary to obtain supporting medical documentation. Industrial Injury/Illness a. If it is an industrial injury/illness, Risk Management and/or the County s Third Party Administrator will contact the medical provider to obtain clarification if needed. b. For industrial injuries, work restrictions are listed by the medical provider on a Work Status Report. The Essential Functions Inventory Form can be provided to Risk Management and/or the Third Party Administrator and will be submitted to the medical provider. 6

8 on-industrial Injury/Illness Provide the employee with the following documents and forms: 1. ADA/FEHA cover letter: a. Include deadline by which the supporting documentation must be provided. b. Include in the cover letter the scheduled date the interactive meeting will take place. Request that, if possible, the employee provide the medical documentation before the meeting to allow time for you to review. 2. ADA/FEHA form (to be completed and signed by treating health care provider) 3. Essential Functions Inventory Form (EFIF) It is CRITICAL to clearly communicate to the employee what additional information is still required to continue with the interactive process; be as specific as possible in identifying what additional disability-related information is required to determine a reasonable accommodation. Step 4 - Schedule the Interactive Meeting A. Send the employee a letter requesting that he/she attend an interactive meeting. B. An interactive meeting may be conducted over the phone if the qualified employee is unable to attend the meeting due to his/her disability. C. Prior to the interactive meeting, gather and review all documents. D. Employees have a right to union representation if requested. Step 5 - Conduct the Interactive Meeting A. It is important that all interactive meetings are formal in structure, carefully planned and conducted by management level staff. The department representative opens the discussion by stating that the purpose of the meeting is to allow for an open dialogue between the employee and the department as required by law to determine if a reasonable accommodation is available. Both the department and employee have an obligation to engage in the interactive process in good faith. Once the purpose of the meeting is established, the following should be included in the discussion: 1. Analysis of the employee s job to determine its purpose and essential functions 2. Discussion of the job-related limitations imposed by the employee s qualifying condition and how those limitations may be alleviated with reasonable accommodation(s) specific to the related essential function(s) 7

9 3. Identification of potential accommodation(s) with input from the employee as to whether or not the potential accommodation(s) would enable him/her to perform the essential functions of his/her position 4. For temporary restrictions, identification of light duty assignments, which include potential tasks, other than the employee s usual duties, that can temporarily accommodate the employee s restrictions. These potential tasks do not have to be in an established classification as they are temporary and could include, but not be limited to, filing, interviewing, answering phone calls, processing mail, making copies, assisting clients in public areas (lobby, window), etc. 5. If several potential accommodations have been identified, consideration of each accommodation with the employee to determine the best option(s) for possible accommodation(s) B. In evaluating the reasonableness of an accommodation, the department will need to consider a range of issues. OTE: A department does not need to provide an accommodation that would create an undue hardship on its business operations. Employers have an obligation to provide reasonable accommodations.the following list provides some guidelines: 1. The employee's expressed preferences should be taken into consideration, but the County maintains its right to provide a reasonable accommodation that will be most beneficial to all. 2. Evaluate whether the employee can perform the job safely. 3. Assess the effectiveness of the accommodation(s) in enabling the employee to perform the essential functions of the job. 4. Assess the operational needs of the department, considering issues such as: a. The number of persons employed in the department and current vacancy rate for the position. b. The type of operation, including the composition, structure, functions of its workforce, and its geographic separateness. c. The impact of the accommodation on the operation of the department, including the impact on the ability of other employees to perform their duties and the impact on the department's ability to conduct business. d. The nature of the accommodation. 8

10 C. If a reasonable accommodation could not be identified through the interactive process that would allow the employee to return to or continue to work in his/her home department, then the employee with an industrial injury/illness will be referred to Risk Management for potential temporary placement in another county department if no funding issues or exclusions through the employee s labor union exist. Refer to the industrial Return to Work Program Early Return to Work Policies and Procedures beginning on page 3 for detailed information regarding an employee s temporary placement in a different county department. If reasonable accommodation in another county department is not identified then approving a leave of absence, if it is expected that the employee will be able to resume his or her duties when the leave is over, is considered a reasonable accommodation. This would be an appropriate and reasonable accommodation for an employee who needs additional time to heal or recuperate from an injury or illness. Medical documentation should include a probable return-to-work date. Employers are not required to grant an indefinite leave of absence. D. The department may encounter an employee who (1) refuses to engage in the interactive process, and/or (2) believes that the department is able to accommodate the restrictions in his/her current position regardless of whether it is reasonable and/ or creates an undue hardship. 1. An employee who refuses to engage in the process should be reminded that by law, both the department and the employee are obligated to engage in the interactive process and that the department is attempting to assist the employee in identifying what accommodations, if any, may be available. Refer to Personnel Rule 10 if, after explaining the roles and responsibilities of all parties in the interactive process, the employee continues to refuse to engage in the process. 2. An employee who believes that the department can accommodate in his/her current position should be informed that the interactive process will determine whether he/she is able to perform the duties of his/her current position. E. The interactive process is ongoing and may require several meetings. This can be due to incomplete medical documentation, a change in disability, staff or operational changes within a department, or the need to readdress an accommodation that is not working. Each meeting should be documented, and the records of that meeting kept in the employee s file. F. At the conclusion of any meeting during the process where it is determined that a reasonable accommodation can be made, clearly set forth the accommodation(s) so both parties have an understanding and consensus of the parameters of any accommodation, as well as the steps to implement and administer the accommodation. G. If an accommodation is identified in this first meeting and the employee refuses an accommodation proposed by the department, document the refusal on the Interactive Process Record Keeping Form. Remember that each step of the process should be clearly documented. 9

11 H. Follow up this meeting with a letter to the employee detailing the results of the meeting, including any accommodation identified and agreed to or refused. Step 6 - Implementation A. Once it is determined that a disability can be accommodated, implementation of the accommodation should be timely. Remember that the interactive is an ongoing process. An accommodation may need to be reassessed if it does not allow the employee to perform the essential functions of the job or there has been a change in disability or departmental operations. B. If a temporary disability cannot be accommodated in the home department then the injured/ill employee may be temporarily assigned to another county department, if no funding issues or exclusions through the employee s labor union exist. If a funding issue exists, if there is exclusion through the employee s labor union or if a temporary disability cannot be reasonably accommodated in any other county department, then a leave of absence should be considered as a reasonable accommodation. C. If a permanent restriction cannot be accommodated in an employee s same job classification, refer to the next section, Accommodation of Permanent Work Restrictions in a Different Classification. 10

12 Accommodation of Permanent Work Restrictions in a Different Classification Industrial and on-industrial Injuries/Illnesses Once an employee has been determined to have a permanent disability (for industrial injuries this is determined by a Permanent and Stationary P&S or Maximum Medical Improvement MMI status) and there is a need for accommodation, departments should follow the interactive process steps outlined in this reference guide. If a department is unable to accommodate the permanent work restrictions of an employee in his/her current position, the following procedures should be followed: A. Disability caused by an industrial injury/illness 1. Departments should identify positions in similar classifications within the department for which the employee meets the minimum qualifications and determine if the permanent work restrictions can be accommodated in those positions. Employee must complete an updated application in order to determine if he/she meets the minimum qualifications for alternate, vacant positions. 2. If no accommodation is available, or the only accommodation that is available would result in a demotion, the department shall refer the employee to Risk Management for an interactive and a search of vacant positions in other County departments. The department will need to provide Risk Management with the latest interactive letter to the employee outlining the details of the meeting and stating why an accommodation cannot be made in the department. The department should also notify Risk Management of any accommodations that could be made in other classifications within the department. a. Risk Management will first conduct a search to identify vacant positions within the same classification or similar salary range in other County departments for which the employee meets the minimum qualifications. County departments requesting to fill vacancies will hold interactive meetings to determine if the accommodation can be made. b. If no accommodation can be found within the same classification or similar salary range, the home department will conduct a search in different classifications at a lower salary range for which the employee meets minimum qualifications. If a vacant position in a different classification at a lower salary range was identified in the home department that can accommodate the employee s permanent restrictions, the home department will accommodate the employee. c. If the home department is not able to accommodate the employee in a different classification or lower salary, Risk Management will conduct a 11

13 search for vacant positions at a lower salary in other County departments. County departments requesting to fill vacancies will hold interactive meetings to determine if the accommodation can be made. 3. If a vacant position in another County department is identified that can accommodate the employee s permanent restrictions, both departments will work together with Human Resources to facilitate an effective transfer. 4. If Risk Management s search of other departments does not identify an accommodation, the employee will be referred back to the home department for processing according to County policies and procedures. If no reasonable accommodation can be made, after consulting with County Counsel, the department may consider other options such as disability retirement or separation. B. Disability caused by a non-industrial injury/illness 1. Departments should identify positions in similar classifications within the department for which the employee meets the minimum qualifications and determine if the permanent work restrictions can be accommodated in those positions. 2. If no accommodation is available, or the only accommodation available would result in a demotion, the department should contact Employee Benefits or Employment Services divisions of Human Resources for a list of vacant positions in other County departments. The department will conduct a search for positions in the same classification and/or salary range as the employee s current classification, for which the employee meets the minimum requirements. a. The department shall identify vacant positions for which the employee may meet the minimum qualifications. Employment Services will review the employee s application to confirm whether or not the employee meets the minimum qualifications for the identified positions. b. County departments requesting to fill vacancies will hold interactive meetings to determine if the accommodation can be made. c. If no accommodation can be found within the same classification or similar salary range, a different classification at a lower salary range for which the employee qualifies will be considered. If a vacant position in a different classification at a lower salary range was identified in the home department that can accommodate the employee s permanent restrictions, the home department will accommodate the employee. d. If the home department is not able to accommodate the employee in a different classification or lower salary range, vacant positions in other County departments will next be considered. County departments requesting to fill vacancies will hold interactive meetings to determine if the accommodation can be made. 12

14 3. If a vacant position in another County department is identified that can accommodate the employee s permanent restrictions, both departments will work together with Personnel Services to facilitate an effective transfer. 4. If a search of other departments does not identify an accommodation, the home department will process the employee according to County policies and procedures. If no reasonable accommodation can be made, and after consulting with County Counsel, the department may consider other options such as disability retirement or separation. 13

15 Glossary Glossary of Terms ADA Disability Employer Essential Functions FEHA Home Department Interactive Process Permanent & Stationary or Maximum Medical Improvement (P&S or MMI) Reasonable Accommodation Work Status Report Americans with Disabilities Act A physical or mental impairment that substantially limits one or more major life activities of such individual. In general, major life activities include, but are not limited to, caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, and working. A major life activity also includes the operation of a major bodily function, including but not limited to, functions of the immune system, normal cell growth, digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine, and reproductive functions. County of Fresno Those job duties and responsibilities that are determined by department management to be an integral part of a position (Fresno County Personnel Rules Definitions). Fair Employment and Housing Act The County department in which the employee worked prior to initiating the interactive process. A collaborative effort between the employer and an injured/ill employee with job restrictions, to communicate openly to determine if a reasonable accommodation is possible for the employee, which does not create an undue hardship for the employer. It is a meeting or series of meetings with the employee and the most important step in identifying whether or not a reasonable accommodation is available that is amenable to both the department and the qualified employee. (FEHA: Government Code 12940(n); ADA: 42 USC 12112(b)) The level in an employee s recovery when his/her medical condition is well stabilized and unlikely to change substantially in the next year, with or without medical treatment. A change or adjustment to a job or work environment that allows an injured/ill worker with restrictions or a disability to perform the essential functions of a job. Medical documentation received from a Workers Compensation medical provider stating an employee s disability, work restrictions, follow-up appointment date and anticipated discharge date. 14

16 Attachments Attachments, References, & Resources Flowcharts Return to Work Interactive Process Flowchart Temporary Restrictions Industrial Temporary Restrictions on-industrial Permanent Restrictions Industrial Permanent Restrictions on-industrial Form Hyperlinks Industrial Temporary Interactive Record Keeping Form Industrial Permanent Interactive Record Keeping Form on-industrial Temporary Interactive Record Keeping Form on-industrial Permanent Interactive Record Keeping Form References California Code of Regulations FEHA: Government Code 12940(n) ADA: 42 USC 12112(b), ADA: 42 USC Additional Resources: EEOC Enforcement Guidance: Job Accommodation etwork: Interactive Process: US DOL: Office of Disability Employment Policy: California Code of Regulations: Americans with Disabilities Act of 1990, as amended: 15

17 Return to Work Interactive Process Flowchart Temporary Restrictions - Industrial WSR LISTIG TEMPORAR RESTRICTIOS RECEIVED B DEPARTMET DEPARTMET IITIATES ITERACTIVE PROCESS TO IDETIF POSSIBLE ACCOMMODATIO CA DEPARTMET REASOABL ACCOMMODATE TEMPORAR RESTRICTIOS? EE RETURS TO WORK I A TMDA, OTIF RM OF ACCOMMODATIO WITHI 3 BUSIESS DAS OF KOWLEDGE OF EE S RESTRICTIOS RE-EVALUATE I 30 DAS OR WHE EW WSR IS RECEIVED, WHICHEVER OCCURS FIRST EE IS REFERRED TO RM FOR COSIDERATIO OF TMDA I ALTERATE DEPARTMET IF O FUDIG ISSUES OR EXCLUSIOS FROM EE S LABOR UIO EXIST WSR: Work Status Report TMDA: Temporary Modified Duty Assignment RM: Risk Management TTD: Temporary Total Disability EE: Employee LOA: Leave of Absence IS EE APPROVED FOR TMDA I ALTERATE DEPARTMET? EE IS PLACED OFF WORK O TTD. APPROPRIATE LOA MA BE APPROVED AS A REASOABLE ACCOMMODATIO RE-EVALUATE I OE-MOTH ITERVALS OR WHE EW WSR IS RECEIVED, WHICHEVER OCCURS FIRST EE RETURS TO WORK I A TMDA I A ALTERATE DEPARTMET RE-EVALUATE I 30 DAS OR WHE EW WSR IS RECEIVED, WHICHEVER OCCURS FIRST 16

18 Return to Work Interactive Process Flowchart Temporary Restrictions on-industrial DEPARTMET RECEIVES MD LISTIG TEMPORAR RESTRICTIOS DEPARTMET IITIATES ITERACTIVE PROCESS TO IDETIF POSSIBLE ACCOMMODATIO CA DEPARTMET ACCOMMODATE EE s RESTRICTIOS I A TMDA? EMPLOEE RETURS TO WORK I A TMDA RE-EVALUATE I 30 DAS OR WHE EW MD IS RECEIVED, WHICHEVER OCCURS FIRST MD: Medical Documentation TMDA: Temporary Modified Duty Assignment TTD: Temporary Total Disability EE: Employee LOA: Leave of Absence EE IS PLACED OFF WORK. APPROPRIATE LOA MA BE APPROVED AS A REASOABLE ACCOMMODATIO RE-EVALUATE I OE- MOTH ITERVALS OR WHE EW MD IS RECEIVED, WHICHEVER OCCURS FIRST 17

19 Return to Work Interactive Process Flowchart Permanent Restrictions - Industrial P&S/MMI REPORT IS RECEIVED WITH PERMAET WORK RESTRICTIOS DEPARTMET IITIATES ITERACTIVE PROCESS TO IDETIF POSSIBLE ACCOMMODATIO CA DEPARTMET ACCOMMODATE PWR I EE s CURRET POSITIO AD/OR SAME JOB CLASSIFICATIO? EMPLOEE IS RETURED TO WORK EMPLOEE IS REFERRED TO RM FOR A SEARCH I OTHER COUT DEPARTMETS IS THERE A VACAT POSITIO I THE SAME JOB CLASSIFICATIO FOR WHICH EE QUALIFIES? EE IS REFERRED TO DEPARTMET WITH VACAT POSITIO FOR ITERACTIVE MEETIG AD POTETIAL PLACEMET P&S: MMI: PWR: RTW: EE: RM: ADA: FEHA: Permanent and Stationary Maximum Medical Improvement Permanent Work Restrictions Return to Work Employee Risk Management Americans with Disabilities Act Fair Employment & Housing Act EE IS REFERRED TO HOME DEPARTMET TO DETERIE IF THERE IS A VACAT POSITIO I A DIFFERET JOB CLASSIFICATIO I THE HOME DEPARTMET FOR WHICH EE QUALIFIES EE IS REFERRED TO RM TO DETERMIE IF THERE IS A VACAT POSITIO I A DIFFERET JOB CLASSIFICATIO I AOTHER DEPARTMET FOR WHICH EE QUALIFIES EMPLOEE IS RETURED TO WORK EE IS REFERRED TO DEPARTMET WITH VACAT POSITIO FOR ITERACTIVE MEETIG AD POTETIAL PLACEMET EE IS REFERRED BACK TO HOME DEPARTMET TO BE PROCESSED ACCORDIG TO COUT POLICIES AD PROCEDURES 18

20 ITERACTIVE PROCESS REFERECE GUIDE OCTOBER 2015 Return to Work Interactive Process Flowchart Permanent Restrictions on-industrial DEPARTMET RECEIVES MD LISTIG PERMAET WORK RESTRICTIOS DEPARTMET IITIATES ITERACTIVE PROCESS TO IDETIF POSSIBLE ACCOMMODATIO CA DEPARTMET ACCOMMODATE PWR I EE s CURRET POSITIO AD/OR SAME JOB CLASSIFICATIO? EMPLOEE IS RETURED TO WORK IS THERE A VACAT POSITIO I OTHER DEPARTMETS I THE SAME JOB CLASSIFICATIO FOR WHICH EE QUALIFIES? EE IS REFERRED TO DEPARTMET WITH VACAT POSITIO FOR ITERACTIVE MEETIGS AD POTETIAL IS THERE A VACAT POSITIO I A DIFFERET JOB CLASSIFICATIO FOR WHICH EE QUALIFIES I HOME DEPARTMET? EMPLOEE IS RETURED TO WORK MD: PWR: RTW: EE: Medical Documentation Permanent Work Restrictions Return to Work Employee IS THERE A VACAT POSITIO I A DIFFERET JOB CLASSIFICATIO I OTHER COUT DEPARTMETS FOR WHICH EE QUALIFIES? EE IS REFERRED TO DEPARTMET WITH VACAT POSITIO FOR ITERACTIVE MEETIGS AD POTETIAL PLACEMET EE IS REFERRED BACK TO HOME DEPARTMET TO BE PROCESSED ACCORDIG TO COUT POLICIES AD PROCEDURES 19