THE INTERACTIVE PROCESS PROTOCOL

AND FILE MANAGEMENT

WHAT IS INTERACTIVE PROCESS?

Interactive Process Meeting (IPM) is a dialogue between an employer and employee with a known disability to determine whether there is a reasonable accommodation that would enable the employee to perform the essential functions of the job.

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TRIGGERS

Most common triggers:

Verbal – Employer approached by employee

Non verbal – Employer observes change in performance

Medical certification from employee’s treating health care professional

Work restriction letter from Third Party Administrator (TPA)

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GOOD FAITH Includes a cooperative effort in a neutral environment

Good faith implies ongoing communication with employee in various forms.

Multiple IPMs may be necessary and often are required in providing an effective reasonable accommodation.

Being respectful, courteous and objective when communicating with employees is crucial in establishing and maintaining ongoing good faith interaction through the process.

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WHO CAN ATTEND AN IPM

Line Supervisor of Usual and Customary (U&C) position.

Line Supervisor of light duty assignment.

Return-to-Work (RTW) Coordinator.

Subject matter expert, as necessary.

Relative, friend, union representative, applicant’s counsel, or spouse/significant other.

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PREPARATION OF IPM

To avoid the appearance of perceived

discrimination, make sure that no decisions are

made prior to an IPM, but instead after the

collaborative opportunity through the IPM

discussion and resulting plan of action and follow up.

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PREPARATION OF IPMWhenever possible, to ensure a productive meeting the RTW Coordinator

should:

Obtain all current medical certification(s);

Verify employee’s current work status;

Review disability and/or workers’ compensation files;

Identify potential temporary tasks that adhere to the employee’s known restrictions;

If the restrictions are the result of a workers’ compensation claim, contact the TPA to obtain current claim status;

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WHAT SHOULD OCCUR:

Prepare/gather the IPM document and any other documents, as appropriate; and

Prepare follow up IPM letter to employee and send via certified mail.

Discussions and review of Essential Job Functions (EJF) of U&C.

Review medical certification.

Cooperative discussions to achieve an appropriate resolution to the employee’s status. 8

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WHAT SHOULD OCCUR:

All telephone IPMs should be documented as such on the IPM document, and the employee should receive a follow up letter reflecting all that was discussed and a “Plan of Action” including a specific follow up date, when appropriate.

All IPMs must be thoroughly documented on the IPM document, including signatures of all who were present at the meeting;

Follow up with employee and supervisor to ensure there are no problems and document all interactions;

INTERATIVE PROCESS MEETING (IPM Document)

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INTERATIVE PROCESS MEETING (IPM Document)

AUTHORIZATION FOR REQUEST OR USE/DISCLOSURE OF PROTECTED HEALTH INFORMATION (PHI)

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AUTHORIZATION FOR REQUEST OR USE/DISCLOSURE OF PROTECTED HEALTH INFORMATION (PHI)

FILE MAINTENANCE WITHIN THE INTERACTIVE PROCESS

RTW File should include, but not be limited to:

1. Updated Employee Profile (Mandatory);

2. Updated Activity Log Sheet with Plan of Action (Mandatory);

3. Complete IPM document;

4. Essential Job Functions (EJF);

5. Current medical certification;

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cont…

6. Completed Notice of Offer of Regular Work with employee (DWC-AD 10118) if applicable or Completed Notice of Offer of Modified/Alternative work (DWC-AD 10133.53) with employee and return the employee to modified/alternative assignment;

8. Completed WHTAA including signatures;

8. Completed CAA including signatures;

9. All correspondence with the Employee, TPA, and Health Care Professionals.

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FILE MAINTENANCE WITHIN THE INTERACTIVE PROCESS

EMPLOYEE PROFILE (I/A and NON - I/A)

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ACTIVITY LOG SHEET WITH PLAN OF ACTION

QUESTIONS???

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