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Attendance & Medical Absence FAQs

Attendance policies, sick leave, medical absences, and the intersection points where attendance management creates legal risk.

Last updated: July 03, 2026 • 8 answers in this category

When an attendance problem stops being an attendance problem

Controlling authority: DOL Fact Sheet #28 and EEOC ADA accommodation guidance. Texas has no paid sick leave mandate, so attendance obligations come from your own policy plus the FMLA and ADA.

When an attendance problem becomes a leave or accommodation issueA matrix plotting employer exposure against whether absences show a medical pattern and whether the employer has notice of a possible serious health condition or disability.No medical signalSome signalClear medical signalIsolatedabsencesRepeated butunexplainedPattern withstated reasonAttendanceManage asattendanceAsk firstInquire beforeyou disciplineLeave issueNotice hasattachedAttendanceConsistency isthe only testAsk firstA pattern isitself a signalLeave issueDesignate oraccommodateAsk firstDo not assumeit is conductLeave issueNotice hasattachedLeave issueDiscipline hereis interference
Figure Attendance is the most common route into an unintended FMLA or ADA violation, because the employer is applying a neutral policy and never makes a leave decision at all. The moment the employer knows enough to suspect a serious health condition, the attendance track closes. Faulkner HR Solutions. Original framework, 2026. Cite as: Faulkner, T.W. (2026). The Attendance Conversion Matrix. Faulkner HR Solutions.

Employer actions the DOL names as violations

Employer actions the Department of Labor names as FMLA violations U.S. Department of Labor, Fact Sheet #28 and Fact Sheet #77B. Table by Faulkner HR Solutions.
ActionWhy it is a violation
Assessing negative attendance points for FMLA leaveNamed expressly by the DOL. A no-fault attendance system that does not exclude FMLA absences generates violations automatically, on every absence, without anyone deciding anything.
Writing an employee up for missing work while using FMLA leaveThe absence is protected; the write-up is the adverse action.
Denying a bonus the employee had already qualified for before taking leaveThe entitlement predates the leave.
Changing the number of shifts assigned after leaveRestoration must be to the same or an equivalent position, including hours.
Moving the employee outside their normal commuting areaAn equivalent position includes geography.
Denying a promotion because the employee used FMLA leaveUse of leave cannot be a negative factor in any employment decision.
Failing to designate leave as FMLAFMLA runs whether or not the employer designates it. Failing to designate usually means the leave was consumed without the employer getting the benefit of the entitlement.
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Curated and reviewed by Dr. Thomas W. Faulkner, DBA, MBA, MSML, SPHR, LSSBB, principal consultant at Faulkner HR Solutions.