Dena Kirk, MBA, OTR/L, COHPM, CEC, CEAS, CWCE
Administrative Director
SIH Occupational Medicine and Rehabilitation
Are you hiring the right employees? What process do you have in place to “capture” those employees with a previous injury or those who are at risk of sustaining an injury? If you are unable to accurately answer these questions, maybe you should consider implementing post offer employment testing.
For many businesses, pre-employment medical physicals and fitness screenings are often overlooked. Having the ability to identify and manage inappropriate or fraudulent Worker’s Compensations claims directly impacts bottom line profitability. It is important to identify and document pre-existing impairments in workers entering jobs that have risk factors for musculoskeletal injuries. How do companies do this? They initiate baseline examinations of prospective employees to evaluate whether the employees can perform the essential functions of the position. This is called Post-Offer Employment Testing.
Post-offer employment testing is a growing area of interest in business and industry. This type of testing is a medical screening under the ADA and may occur during the post-offer stage of the hiring process. The primary purpose of the test is to determine if an applicant can perform the essential functions of the job. Evaluating strength, flexibility, balance, endurance, and coordination provides information as to whether the applicant meets the physical demands of the job. The second purpose is to make the testing process beneficial to the applicant and to the employer by instructing the employee in proper posture, body mechanics, material handling strategies and injury prevention techniques. The third purpose of the post-offer employment test is to provide recommendations regarding reasonable accommodations if the applicant is a qualified person with a disability and can meet the essential functions of the job with reasonable accommodations.
The ADA requires only that post-offer employment testing be conducted as a separate, second step of the selection process after an individual has met all the other job requirements. The employer may make a job offer to such an individual, conditioned on the satisfactory outcome of a medical examination. If the employer requires post-offer employment testing, then all entering employees in that particular job category must meet the essential functions of the job, as outlined in the testing. The testing does not have to be given to all entering employees in all jobs, only to those in the same job category.
For example, Company A identifies that 3 out of the 16 positions at their facility are the most physically laboring positions and have also been identified as having the highest injury rates. Therefore, Company A would implement post-offer employment testing for all employees entering these physical labor jobs, rather than those entering sedentary or clerical jobs. The ADA does not require an employer to justify its requirement of a post-offer employment test. An employer may wish to conduct a post-offer employment test to determine if the employees have the physical or mental qualifications necessary to perform certain jobs. If a job requires continuous heavy level work (100#), the test would be useful to determine whether the applicant’s physical condition would permit him/her to perform the job.
The traditional “employee physical,” only gives employers information about whether or not the employee has achieved the medical clearance to perform the job (blood pressure, heart rate, urinalysis/drug screen, etc.). The post-offer employment test looks at the physical requirements. For example, does a 23 y/o 123 lb. female meet the essential functions of a construction worker? If the applicant can safely lift, push, pull and carry the required physical demands of a construction worker, which are between 75# and 100#, then yes, the applicant would “meet” the essential functions of a construction worker. Does a 40 y/o 185 lb. male meet the essential functions of a “roof bolter” in the coal mine? If the applicant safely meets the requirements for range of motion and pushing/pulling the required amount (100#) but does “not meet” the functions of kneeling, squatting, lifting, and carrying, then the prospective employee would “not meet” the essential functions of a “roof bolter” in the coal mine. In both instances, the employer is only given information describing “met” or “not met,” in regard to the applicant’s performance. In such an instance where the applicant did not meet the essential functions of the test, the employer has the final decision as whether or not to hire the applicant.
GOALS FOR TESTING:
- Reduce injuries
- Educate employees
- Reduce costs
RISKS ASSOCIATED BY NOT TESTING:
- Increased worker’s compensation costs
- Inappropriate or fraudulent work-related injury claims
- Lost productivity
- Excessive turnover or replacement costs
- Increased future liability and legal expenses
PROCESS:
- Review current injury data and select those positions which are at high risk for work-related injuries.
- Perform a job analysis for each “high-risk” position.
- Integrate the functional portions of the job analysis into each job description.
- Develop a test, which includes the most physically demanding parts of the job.
- Establish test validity to ensure the test measures what it is supposed to measure. We do this by selecting a sample of incumbents (current employees) to perform the test we developed. It is beneficial to make sure that the current employees can “meet” the physical demands of the test and to ensure that the test is not too hard or not too easy, but that it is a good representation of what is physically required on the job.
- The employees give feedback and make recommendations regarding the test. If needed, the test is then modified to outline the recommendations, identified by the employees.
- Institute the post-offer employment testing into the employment process and add this as a policy for the positions you have identified to test.
- Consult with your legal counsel and senior management staff to review the process to ensure you are ready to proceed with testing.
- The test is then ready to begin implementing with new hires for the identified positions.
Our team has assisted these employers with developing the right tools and resources in order to successfully mitigate health risks related to hiring and retaining employees. The question is this… “Are you ready to jump on board and start reducing your Worker’s Compensation costs?”
If you are interested in implementing post offer employment testing, find an expert in your area to assist with the process. For further questions, please reach out to Dena Kirk, Administrative Director at 618-942-2171, ext: 35429 or email at dena.kirk@sih.net.
If you would like information regarding the Legislative Guidelines related to employment practices, visit the EQUAL EMPLOYMENT OPPORTUNITY COMMISSION (EEOC) at www.eeoc.gov or the Department of Justice – AMERICAN’S WITH DISABILITIES ACT at www.usjoj.gov
