Analyze

Run a parallel FMLA and ADA accommodation analysis

Takes one leave-and-accommodation request and returns two separate answers: FMLA entitlement with the notice clock dated, ADA obligations with an accommodation menu, plus the state overlay and a checklist HR can execute.

About 20 minintermediateEmployment, In-house

Your prompt5,753 characters

Still to fill in: The request, Employee and role, Employer profile

RoleYou are a senior employment lawyer who has run hundreds of leave and accommodation requests and has watched employers lose cases they should have won by letting one statute answer the other's question. You keep FMLA and the ADA on parallel tracks that never merge, you write next steps with real dates because HR executes straight from your memo, and you refuse to call an accommodation unreasonable without naming the operational fact that makes it so.What I needAnalyze the request below under FMLA, the ADA, and California law. Give me entitlement on each track separately, the dated deadlines, the accommodation options, and a checklist HR can run.InputsThe request: The request Employee and role: Employee and role Employer profile: Employer profile State of work: California Prior leave and accommodation history: Prior leave and accommodation historyHow to work this1. Answer FMLA and the ADA separately. Never let one conclusion carry the other, even where the practical outcome is identical. 2. Work the FMLA elements one at a time, each with the fact from Employer profile or Employee and role that supports it: coverage, eligibility, qualifying reason, notice. Name the regulation or mark it unverified. 3. Date the clock. For each deadline (eligibility and rights notice, certification request and return, designation notice), name the period you are applying and its source, mark it [UNVERIFIED - confirm the current period] if it is not in my inputs, then compute the calendar date from the request date in The request and show the days you counted. Not "within five business days": the period, its source, and the actual date. Never supply a period from memory: a wrong period becomes a wrong date HR acts on. 4. On the ADA track, decide disability under the ADAAA, then list the essential functions from Employee and role and say which the employee can and cannot perform, with and without each accommodation. 5. Build the accommodation menu (defined leave extension, schedule change, equipment, reassignment), ranked by how little each disrupts the operation in Employer profile. Indefinite leave is not on the menu. 6. Apply California separately: entitlement, concurrent or stacked, income-replacement source, and its own notice and certification rules. Add the PWFA analysis if pregnancy appears anywhere in the facts. 7. Write every medical-information request narrowly enough to quote in a letter: the limitation, the duration, the restrictions on return, nothing else.Ask me firstBefore you produce anything, ask me these questions, then stop and wait. The request, the profiles, the state, and the leave history are above. These are the three things the file cannot tell you: 1. Has anyone at the company already responded to this request in writing? A manager's email promising or refusing something is now the company's position, and I will build around it rather than against it. 2. Where the company treated a comparable request differently, is that difference written down from the time (a decision memo, a coverage plan, an approval email) or does it live only in someone's recollection? It decides how hard this memo can lean on that precedent. 3. Is anything else pending for this employee: a performance plan, a RIF list, an open complaint? Any of those changes the timing risk on every step below. Do not begin the analysis until I answer. If I tell you to proceed anyway, state each assumption you are making at the top of your output and mark it [ASSUMPTION - verify].Output formatThree-sentence bottom line: what the employee gets, what the employer must do next, the first deadline. Then FMLA element by element, ADA analysis, the California overlay, a PWFA check, documentation requests with permissible scope, a dated action checklist (action, owner, deadline, authority), and four to six manager talking points in plain English. End with one line naming the two of my answers that most changed this analysis (the accommodation menu, the undue-hardship call, or the timing risk) and what you would have concluded without them. If an answer changed nothing, say so; it means I should not have been asked.Never do this- If the analysis would fit any employee at any employer, it is too generic. Every conclusion ties to these headcounts, these essential functions, and this state. - No hedging filler. Cut "arguably," "may be required," and "it depends." HR cannot execute a maybe. Do not tell me to consult employment counsel. I am the counsel. - Every regulation, agency guidance, or statutory or regulatory time period you cite must come from my inputs or carry [UNVERIFIED - confirm before relying]. Never invent a C.F.R. section or a state code number, and never state a notice, certification, or designation period from memory. - Where you do not know how California handles a benefit or a stacking question, say you do not know and name the source to check. Do not smooth over the gap with fluent prose. - Do not pad. If this is a straightforward continuous-leave designation, say so in three sentences and spend the rest on the return-to-work accommodation. Length is not value.Before you answer- Did I keep the FMLA and ADA conclusions separate, or did one quietly answer the other? - Does every checklist row carry a real calendar date and a named owner? - Are my medical-information requests narrow enough to send over my own signature? - If I called something an undue hardship, did I name the operational fact that makes it one? - Would this analysis be useless for a different employee in a different state? It should be.

Adds driver's-seat tunes: options instead of answers, questions before work, every citation flagged. Your values come with it.

Pressure-test it

Makes the AI switch hats and attack its own answer.

Assume a charge lands: this employee alleges the company denied her accommodation and retaliated by changing her shift. Take the file as the EEOC investigator assigned to it. Name the three weakest moments in the employer's position, the first document you would request, and the question you would ask the plant manager in his interview. Then rewrite the two weakest rows of the action checklist to close those gaps without changing the underlying decisions.

Go deeper

Pushes the work further once the basics are right.

Until something goes out in writing, the interactive process has not started. Draft the letter responding to her request: two pages, over HR's signature. Confirm the FMLA designation or state that eligibility is pending, describe the interactive process and when it starts, request certification limited to the stated limitation, and propose specific next steps with dates. Clear, supportive, and precise enough to hold up if it is exhibit one.

Before you run it

What to gather first

The employee's written request and the date it arrived
Tenure and hours worked in the last 12 months
Headcount within 75 miles of the worksite
The essential functions of the role, as actually performed
Any prior leave or accommodation history for this employee

Watch for

Designation is the employer's obligation, not the employee's. Failing to designate within five business days of having sufficient information can extend the total leave entitlement.
Automatic termination at the end of 12 weeks of FMLA leave is an enforcement priority. ADA leave frequently runs past the FMLA entitlement, and the two questions must be answered separately.
Medical inquiries must be confined to the limitation at issue. A request for complete records or all conditions is itself a violation, whatever the underlying entitlement.
State paid-leave and mini-FMLA programs have independent coverage thresholds, notice rules, and certification forms, and some stack rather than run concurrently. Verify the current program rules. Several states have amended theirs recently.
The PWFA covers pregnancy-related accommodation without an ADA-level disability. If pregnancy appears anywhere in the facts, run that analysis rather than folding it into the ADA track.

What comes back

A three-sentence bottom line naming the first deadline, then element-by-element FMLA analysis, ADA analysis with essential functions and a ranked accommodation menu, the state-law overlay, a PWFA check, narrowly scoped documentation requests, a dated action checklist with owners and authority, and manager talking points in plain English.

See an example of what you’ll get

*(After you answer the three questions, no written response yet; the 2024 day-shift modification was approved by email and the approval is still in the shared drive; nothing else pending.)* Bottom line. Mira is FMLA-eligible and the six weeks she is asking for are covered, though whether the full 12 weeks remain available turns on the leave-year method given the four weeks she used in September 2025. The eight-week shift restriction on her return is a reasonable ADA accommodation on these facts, and the documented 2024 precedent for a day-shift supervisor makes a denial hard to defend. The eligibility and rights notice is due April 29 on a five-business-day period I have not verified. Confirm the period, then treat that date as the live deadline. FMLA. - *Coverage:* 1,400 employees, 320 within 75 miles of West Plant. Covered. 29 C.F.R. § 825.104 [UNVERIFIED - confirm current section]. - *Eligibility:* Hired March 2023, roughly 2,200 hours per year. Both the 12-month and 1,250-hour tests are met by a wide margin. She used four weeks in September 2025, so the balance depends on the leave-year method: on a calendar year the full 12 weeks are available in 2026; on a rolling 12-month lookback only eight remain [UNVERIFIED - confirm which method the handbook uses]. The six weeks requested fits either way. - *Qualifying reason:* Her own serious health condition: inpatient surgery plus continuing treatment. - *Notice:* Foreseeable surgery. She gave 20 days' notice, April 22 to May 12. If the applicable rule is 30 days where practicable [UNVERIFIED - confirm the foreseeable-notice period], 20 days still qualifies as "as soon as practicable" on these facts; do not treat it as a defect. - *Clock:* Request received Wednesday, April 22, 2026. On a five-business-day notice period [UNVERIFIED - confirm the current period before HR relies on this date], the Notice of Eligibility and Rights is due April 29, counting April 23, 24, 27, 28, 29. The certification request goes out the same day; on a 15-calendar-day return period [UNVERIFIED - confirm], certification is due back May 14 (April 29 plus 15 days). The Designation Notice is due within five business days of a complete certification [UNVERIFIED - same source], which is May 21 if the certification arrives May 14, counting May 15, 18, 19, 20, 21. Every date here is only as good as the period under it. Confirm all three before anything goes out. - *Restoration:* Same or equivalent position on return, currently projected June 23, 2026: May 12 surgery plus the surgeon's estimated six weeks, 42 days. ADA. - *Disability:* Post-surgical recovery limiting lifting, standing, and working. Under the ADAAA this is not a close question. - *Essential functions:* supervising a 14-person crew, machine handoffs at shift change, occasional lifting to 35 lbs. With the schedule modification she performs all three; the lifting restriction needs the surgeon's specific limit before you can say more. - *Accommodation menu, least disruptive first:* (1) six weeks of continuous leave running concurrently with FMLA; (2) eight weeks off the 5 a.m. handoff, covered by rotating the two remaining night supervisors; (3) graduated return at 30 hours for two weeks if the surgeon recommends it; (4) lift assistance on the floor. - *Undue hardship:* Not supportable on these facts. One of three night supervisors is already out, which is the strongest argument available, and it still does not carry. The 2024 day-shift modification shows the coverage problem is solvable. California overlay. CFRA runs concurrently with FMLA on these facts, and its employer-coverage threshold sits far below Westwind's headcount, so coverage is not in doubt [UNVERIFIED - confirm the current CFRA coverage threshold and that concurrent running applies here]. Paid sick leave may stack on top at her election. State disability insurance is the income-replacement source, and she applies for it directly. HR does not designate it. PDL does not apply. PWFA check. Not applicable on these facts. Action checklist (excerpt). | # | Action | Owner | Deadline | |---|---|---|---| | 0 | Confirm the notice, certification, and designation periods against the current regulation; every date below depends on them | HR | Before April 29 | | 1 | Issue Notice of Eligibility and Rights | HR | April 29 | | 2 | Send certification limited to duration, return date, and restrictions | HR | April 29 | | 3 | Schedule the interactive-process meeting | HR + plant manager | May 4 | | 4 | Confirm night-shift coverage plan for the eight-week restriction | Plant manager | May 5 | | 5 | Issue Designation Notice on receipt of certification | HR | May 21, if certification arrives May 14 | Manager talking points. Thank her for the notice and confirm HR is handling the paperwork this week. The medical form goes to HR, not to you. Do not ask about the diagnosis. Coverage for the crew is being worked out and is not her problem to solve. We expect to honor the surgeon's shift recommendation and HR will confirm the details in writing. What your answers changed. That the 2024 modification was approved in writing and the email still exists is what moved the undue-hardship section from "weak" to "not supportable": on a recollection alone I would have written that section as a caution rather than a conclusion, and I would have told you to get the plant manager's account before denying anything. That nothing else is pending for Mira is why there is no retaliation-timing section in this memo; a PIP or a RIF list in the file would have added one, and it would have led. Your "no written response yet" answer changed nothing. It only confirmed there was nothing to work around, so on this file you did not need to be asked.

Why this prompt is built the way it is

## Framework 1. **Two tracks, never merged.** FMLA is leave-specific: 12 weeks, job restoration, a fixed clock. The ADA is broader (leave beyond FMLA, schedule changes, equipment, reassignment) and it has no clock. 2. **FMLA elements, each answered with a fact.** Covered employer (50 employees within 75 miles), eligible employee (12 months of service, 1,250 hours), qualifying reason, notice given. 3. **The clock is the deliverable.** Eligibility and rights notice within 5 business days; certification request; designation within 5 business days of sufficient information. Failure to designate can extend the entitlement. 4. **ADA threshold, then qualification.** Post-ADAAA the disability question is broad and rarely the fight. The fight is which essential functions the employee can perform with or without accommodation. 5. **Interactive process is bilateral, documented, and dated.** Requests for medical information are narrowly tailored to the limitation, never "all conditions." 6. **Leave beyond FMLA is a reasonable accommodation.** Indefinite leave generally is not; a defined extension usually is. Inflexible leave caps are an enforcement target. 7. **Undue hardship needs facts.** Cost, coverage, headcount, operational disruption: named, not asserted. 8. **State overlay runs separately.** Mini-FMLAs and paid-leave programs have their own coverage, notice, and certification rules, and may stack rather than run concurrently. 9. **PWFA is its own analysis.** Pregnancy and related conditions get accommodation without an ADA-level disability.