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Medical Eligibility Requirements

Attachment 3: Office of Personnel Management (OPM) Decision Criteria

Back to OPM Adjudication of Psychiatric/Psychological Objections

Psychiatric/psychological cases are extremely complex and require an extensive evaluation that cannot be accomplished by using only the results of a psychological screening test(s). Before reaching a conclusion about whether or not a medical objection is warranted, OPM evaluates the nature, extent, severity and chronicity, of the applicant’s psychiatric/ psychological condition; medication requirements; its duration; compliance with recommended treatment protocols; the duties and requirements of the job (i.e., safety sensitive and safety critical jobs, law enforcement, fire fighter, individuals holding security clearances); and the applicant’s past and present work history (especially the period covered by the psychiatric/ psychological condition). Even in cases where an explicit physical/medical standard has been approved which provides for disqualification on the basis of a psychiatric condition, OPM must decide if that blanket disqualification can be sustained under the provisions and guidance contained in 5 CFR 339, Medical Qualification Determinations (updated and revised and in the final clearance process as of the date of this memorandum); the ADA; EEOC; the Rehabilitation Act of 1973; and in accordance with Executive Order 12968 of August 2, 1995, Access to Classified Information, as it relates to adjudicative guidelines for determining eligibility for access to classified information.

The decision not to hire an applicant for medical (psychiatric/psychological) reasons or for a failure to meet medical/functional requirements must be based on the inability of the applicant or employee to meet the performance requirements of the job. It is not sufficient to cite the mere existence of a medical condition per se as the basis for a medical objection. Documentation is necessary to establish that there are tasks or duties which cannot be performed (with or without reasonable accommodation), or to establish the extent to which the medical condition presents an unacceptable risk of harm to the employee or others.

Any mental health diagnosis must be consistent with the diagnostic criteria as outlined in the Diagnostic and Statistical Manual of Mental Disorders, DSM-IV-TR, or the most current, accepted form of the DSM, and should include the results of a multi-axial assessment. According to the DSM-IV-TR, the multi-axial assessment “facilitates comprehensive and systematic evaluation with attention to the various mental disorders and general medical conditions, psychosocial and environmental problems, and the level of functioning that might be overlooked if the focus were on assessing a single presenting problem.”

Mental health professionals who elect not to use the multi-axial system must still follow DSM-IV-TR guidelines, or the most current, accepted form of the DSM, for reporting the results of a DSM-IV-TR assessment. In addition, some cases may require a neuropsychological evaluation to determine whether or not there are any alterations in cognitive functioning (i.e., long/short term memory problems, judgment, ability to process information, lengthened reaction time) that may adversely affect safe and efficient job performance.