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The best approach is to treat leave administration as a standardized case-management process, not simply an approval workflow. The administrator should consistently identify which laws and company benefits apply, document decisions, protect medical information, and keep the employee informed.
A practical leave-of-absence workflow
- Create one intake channel
- Give employees a clear way to request leave—HR portal, designated email, or leave administrator.
- Capture the basic facts: requested dates, expected duration, reason category, intermittent vs. continuous leave, and contact information.
- Train managers to recognize that an employee doesn't necessarily have to use words like "FMLA" or "reasonable accommodation" for a request to trigger further review.
- Run a coverage/eligibility check For each request, determine whether it potentially involves:
- FMLA
- ADA reasonable accommodation
- Pregnancy-related accommodation requirements
- Workers' compensation
- Military leave
- State/local leave laws
- Company-paid or unpaid leave policies
- Short- or long-term disability benefits
Don't treat these as mutually exclusive. A single absence can involve several programs simultaneously. 3. Send the right notices and request only necessary documentation For FMLA-covered situations, the Department of Labor requires specific eligibility and designation notices and establishes timing requirements; for example, an eligibility notice generally must be provided within five business days of learning that leave may qualify.
Medical certification can be useful, but avoid collecting unnecessary medical details. The DOL specifically notes that employers can request information sufficient to establish an FMLA-qualifying condition without needing an employee's entire medical history. Department of Labor 4. Evaluate accommodation separately
Don't automatically conclude that an employee has exhausted leave just because the company's standard leave entitlement has ended. Depending on the circumstances, additional leave, modified schedules, telework, or other changes may be reasonable accommodations under the ADA. The EEOC emphasizes individualized assessment and an interactive discussion rather than a rigid one-size-fits-all rule. EEOC EEOC 5. Maintain a single case record
A good leave-management system should show:
- Request date
- Leave type(s)
- Eligibility determination
- Documentation requested/received
- Notice deadlines
- Approved dates
- Intermittent-leave usage
- Paid-leave balances
- Benefit-premium obligations
- Expected return date
- Restrictions/accommodations
- Follow-up dates
- Final disposition
Keep medical documentation and accommodation information in appropriately restricted/confidential files rather than ordinary personnel records. EEOC 6. Automate deadlines and employee communications
This is where technology provides substantial value. Configure reminders for certification deadlines, recertification, expected return dates, benefit payments, and required notices. Employees should receive proactive updates rather than having to repeatedly ask HR for their status. 7. Manage the return-to-work process
Before the expected return date, confirm whether the employee is returning normally, returning with restrictions, requesting additional leave, or requesting an accommodation. For FMLA, reinstatement and any applicable fitness-for-duty requirements should be handled according to the applicable rules.
A useful operating model
I'd structure the administrator's process around five statuses:
Requested → Eligibility Review → Documentation/Interactive Process → Approved/Denied → Return/Closed
Within each case, use a decision matrix rather than letting the administrator make an ad-hoc judgment. For example:
| Question | Action |
|---|---|
| Could this be FMLA? | Perform FMLA eligibility/coverage analysis |
| Could another federal/state leave law apply? | Check applicable jurisdictional requirements |
| Is the request disability-related? | Evaluate accommodation obligations |
| Is documentation necessary? | Request only legally appropriate information |
| Is leave approved? | Record entitlement, dates, and conditions |
| Is leave ending? | Initiate return-to-work/accommodation review |
The key is consistency without rigidity: standardized intake, deadlines, documentation, and recordkeeping, while still evaluating accommodation and leave requests individually.
For a U.S. employer, I'd also build the workflow around the current Department of Labor FMLA employer guidance and EEOC accommodation guidance, then layer in the specific states and localities where employees work.
If you're designing this for an actual HR team, I can also give you a complete leave-administration SOP/checklist, including intake form fields, decision tree, SLAs, employee communications, and an Excel/HRIS tracking structure.
Sources9
- dol.govFact Sheet #28E: Employee Notice Requirements under the Family and Medical Leave Act | U.S. Department of Labor
- eeoc.govDisability Accommodations Tips | U.S. Equal Employment Opportunity Commission
- dol.govThe FMLA Leave Process | U.S. Department of Labor
- dol.govFact Sheet #28D: Employer Notification Requirements under the Family and Medical Leave Act | U.S. Department of Labor
- dol.govHow to Talk to Your Employer About Taking Time Off for Family and Medical Reasons | U.S. Department of Labor
- eeoc.govThe ADA: Your Responsibilities as an Employer | U.S. Equal Employment Opportunity Commission