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January 12, 2026

What Managers Need to Know About FMLA Recertification (And What Creates Risk)

Managers play a vital role in spotting FMLA recertification triggers and managing employee leave. Learn what to watch for and how to support compliance.

Summary

Managers often spot FMLA absence and recertification triggers first.
Document absence patterns and report promptly to HR.
Avoid asking employees for medical details about their leave.
Don’t take employment action based on FMLA leave use.
Recertification clarifies medical need, not leave entitlement resets.

In our previous article, we covered when and how to request FMLA recertification the right way, including timing rules, valid triggers, and the five-step process.

But here’s something we didn’t cover: your managers are often the first to spot recertification triggers.

They’re on the front lines. They notice Friday absence patterns, see when an employee goes beyond their certified leave, and feel the impact when intermittent leave disrupts workflows.

If your managers don’t understand recertification—what it is, when it’s appropriate, and what they should avoid—they could create compliance risks.

Managers are your early warning system.

Managers aren’t FMLA administrators, but they’re in a good position to notice when leave use doesn’t align with what was originally certified.

What managers should watch for:

Train managers to recognize valid recertification triggers:

Patterns of absences on Mondays, Fridays, around holidays, or scheduled days off
Absences that exceed the certified frequency or duration (for example, certified for twice a month but happening three or four times a week)
Sudden changes in leave patterns (like working full-time for weeks, then suddenly taking frequent absences)

What managers should do:

Simply document and report. That’s it.

Managers should:

Objectively record the pattern (dates, times, observations)
Report it promptly to HR or the leave administrator
Trust HR to handle the recertification process

What managers should avoid:

Managers shouldn’t try to fix the problem themselves, confront the employee, or assume the leave isn’t legitimate. Even well-meaning managers can create compliance risks. That’s why training is important.

Don’t ask for medical information directly.

Managers shouldn’t ask employees:

About their medical condition
To provide medical documents to the manager
Why do they need to leave on certain days
About treatments, medications, or healthcare providers

All medical information requests should go through HR. This protects employee privacy and keeps medical information in the right hands.

Don’t take employment action based on leave use.

Managers shouldn’t say things like:

“If your attendance doesn’t improve, we’ll have to let you go.”
“You’re exceeding your approved leave, so you’re at risk.”
“One more absence and you’re done.”

If an employee goes beyond certified leave, recertification is the next step—not termination. Threats or attendance penalties can be seen as interfering with FMLA rights.

Don’t apply policies unevenly.

If a manager asks for recertification for one employee with a Friday pattern but ignores the same pattern for another, it could lead to discrimination risks. Consistency helps protect everyone. If they see a trigger for one employee, they should watch for it across the whole team.

Don’t pressure employees to take less leave.

Avoid comments like:

“We really need you to try to come in on Fridays.”
“Another FMLA absence? These are adding up!”
“The team is struggling with your absences. Can you cut back?”

These can be seen as interfering with FMLA rights. FMLA leave is a legal right. Managers should manage work around it, not discourage its use.

What recertification can and can’t do

Recertification doesn’t always fix the problem, which can be frustrating for managers and HR.

Healthcare providers may approve more leave.

When you ask for recertification, you might not get the answer you want. Providers often update certifications to allow more absences because they base decisions on medical need, not your operational challenges.

What to tell managers: Recertification isn’t about limiting leave. It’s about understanding what’s medically necessary. Sometimes that means the employee needs more leave than first estimated.

Recertification doesn’t reset the FMLA entitlement.

It confirms the ongoing need but doesn’t extend or reset the 12-week entitlement within the 12-month period.

Recertification doesn’t cancel past absences.

The absences that led to the recertification request, including extra absences, usually remain protected under FMLA. Recertification is about future leave.

When does recertification help?

Recertification can be useful when the healthcare provider confirms that some absence patterns don’t match the medical condition.

For example, the provider might say Monday/Friday absences aren’t medically necessary, so you only approve absences within the certified limits. They might confirm the condition requires leave only during flare-ups, not every Friday. Or they might confirm the original limit on absences, meaning extra absences aren’t protected.

When this happens, you have clear medical documentation to support approving some absences and denying others.

What to tell managers: Sometimes recertification gives us clarity. Sometimes it doesn’t. Either way, we’re following the right process, which protects everyone.

When to escalate and let HR handle it

One of the hardest things for managers is accepting that FMLA takes time.

Recertification isn’t instant. Employees need time to see providers. Providers need time to fill out forms. HR needs time to review and decide.

Train managers to:

Report triggers quickly
Provide objective documentation
Step back and let HR manage the process
Avoid asking repeatedly, “What’s the status?”

Managers’ urgency doesn’t speed up compliance. Pressuring for faster answers can create legal risks.

Managers manage work, not leave.

A manager’s job is to keep work moving, not manage leave. That means:

Planning coverage when employees are out
Distributing work fairly
Keeping productivity up despite absences

But it doesn’t mean:

Investigating if leave is legitimate
Policing medical conditions
Deciding on FMLA approval or denial

That’s HR’s role. Clear boundaries reduce risk for everyone.

The bottom line for manager training

Managers can help spot recertification triggers, but only if they know their limits.

Good training should cover:

What recertification is and why it matters (based on U.S. Department of Labor FMLA guidelines)
What triggers to watch for
How to document and report objectively
What managers shouldn’t do
Why the process takes time
What recertification can and can’t do

When managers know their role and its limits, they become a helpful early warning system instead of a risk.

Recertification is about understanding, not control.

FMLA recertification can be tricky. Managers need to know when to report, what boundaries to respect, and how to keep things running without interfering with employees’ rights.

HR needs to apply rules consistently, document well, and train effectively.

Done right, recertification helps clarify things. Done wrong, it can cause problems that cost more than the operational issues you’re trying to fix.

Get specialized help on FMLA recertification.

Handling FMLA recertification in real life takes more than knowing the rules. It means understanding how to apply them when every case is different.

Join Jim Jantz, JD, director of Compliance at MMA, on Tuesday, January 28, at 2 pm ET for FMLA Recertification Requests That Won’t Ruin Your Year, a 30-minute webinar covering:

The full medical certification process
When and why to request recertification
How to handle timing rules without risk
What to do if recertification doesn’t give the answer you want
Real-world examples and how to stay compliant

What Managers Need to Know About FMLA Recertification (And What Creates Risk)

Summary

Managers are your early warning system.

What recertification can and can’t do

When to escalate and let HR handle it

Managers manage work, not leave.

The bottom line for manager training

Recertification is about understanding, not control.

Get specialized help on FMLA recertification.

Contributor

Jim Jantz, JD

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