Travel Time for FMLA Medical Appointments and Telework Accommodations for Disabilities: Two 2026 Developments Employers Shouldn’t Ignore
In 2026, managing employees can feel a bit like being an air traffic controller. Some employees are coming and going for medical appointments, others want to stay “in the clouds” working remotely, and employers are trying to keep everything moving without a collision. Two recent federal developments may not alter the entire flight plan but sharpen the rules of the runway by clarifying when travel time is protected leave and how telework should be evaluated as a potential accommodation. On January 5, 2026, and February 11, 2026, respectively, the Department of Labor (DOL) issued an opinion letter on Family and Medical Leave Act (FMLA) travel time , and the Equal Employment Opportunity Commission (EEOC) and the Office of Personnel Management (OPM) issued joint guidance regarding permitting telework as a disability accommodation . The guidance materials address different issues, under different laws, but both speak to the same reality: employers must be deliberate and di...