Managing FMLA Requests for Migraines: A Guide for Leave Managers  

By AbsenceSoft

·

February 4, 2025

Managing FMLA Requests for Migraines: A Guide for Leave Managers  

A headache doesn’t usually keep someone from working, especially with the help of an Aspirin and a bottle of water. But a migraine? A migraine can mean work is out of the question for hours, if not days. 

Migraines are severe, often chronic headaches that impact nearly 30 million people in the U.S. alone. These pulsing, throbbing episodes are more prevalent among women; in fact, they are a leading cause of disability for women younger than 50. 

Because migraines are both rampant and debilitating, they’re a common reason why workers need time away from work. In this blog post, we’ll explain how laws like the Family and Medical Leave Act (FMLA) apply to workers with migraines, and how leave managers can effectively and compassionately field migraine-related requests.   

Understanding migraines and the FMLA  

To understand how the FMLA applies to workers who experience migraines, it’s important to first understand what migraines are. Then, leave managers can better evaluate when workers can take FMLA leave to recover. 

What are migraine headaches? 

Put simply, migraines are extremely severe headaches. These debilitating episodes are marked by throbbing or pulsing, usually on one side of the head. According to the Cleveland Clinic, migraines are often accompanied by symptoms like fatigue, nausea, vision changes, and irritability. 

Because migraines are so painful, they can significantly derail a person’s daily life — work included. The National Institutes of Health reported that a third of migraine attacks happen during workdays. The research found that people with chronic migraines experience a higher rate of reduced productivity and missed days. 

Example:  Let’s imagine that Betsy is an IT professional who has a long history of migraines. Betsy’s migraines don’t strike often, but when they do, they are severe and lengthy. Her migraines bring on throbbing pain, nausea, and vision changes, known as auras. To find relief, Betsy must lie in a dark room and take medication prescribed by her neurologist. 

FMLA eligibility for migraines 

Do the FMLA’s provisions extend to people with migraines? The short answer is yes. 

The FMLA provides unpaid, job-protected leave for eligible workers with a serious health condition. The U.S. Department of Labor (the agency enforcing the FMLA) defines a serious health condition as something “that makes the employee unable to perform the functions of their job.” Considering the severe pain migraines can inflict on people, it follows that migraines could very likely keep an employee from accomplishing the essential functions of their job.  

It’s no surprise, then, that the DOL considers migraines a serious health condition. Still, it’s worth noting that FMLA coverage for migraines typically applies when an employee’s migraines require inpatient care and/or continuous treatment by a healthcare provider. 

Example: Betsy had been working at her current employer for a little more than a year before one of her migraines arrived on a workday. She called HR to report her absence, and HR immediately opened a leave of absence case. In the following days, HR determined that Betsy was eligible for FMLA leave and decremented her absence from her entitlement. 

Managing leave requests for migraines under the FMLA 

Migraines make leave management complicated. From the employee perspective, workers may be in so much pain that it’s physically difficult to report their absence. Employers that use leave technology like AbsenceSoft can implement a self-service portal that makes requesting leave much easier for suffering employees. 

The portal simplifies the process for managers and HR, too. Because migraines sometimes arrive undetected, leave managers often field last-minute notices. A platform allows leave managers and other stakeholders to track leaves of absence as soon as employees request them. From there, leave managers can easily begin the FMLA certification process. 

Migraines and intermittent FMLA leave 

Another way migraines complicate leave management? They are usually recurring, which means that employees who need leave for migraines usually need it repeatedly. Leave managers, then, must be prepared to manage intermittent FMLA leave — FMLA taken in smaller chunks of time. 

Intermittent leave is notoriously challenging to manage. To stay compliant, HR must carefully track how much leave each employee takes, and when employees’ FMLA entitlements reset. Unplanned, intermittent FMLA leave can have a significant impact on business operations, especially in industries like healthcare and education, where it’s essential to maintain headcount. 

Example: Betsy can’t predict when her migraines will arrive. When she calls to report an absence, it comes as a surprise to HR and her manager, who must find someone to help cover her workload for at least a day. Sometimes, however, Betsy doesn’t need a full day. If a migraine hits over the weekend, she may just need to take leave for part of Monday. All of these situations are examples of intermittent FMLA leave. 

Migraines and the ADA  

The FMLA isn’t the only federal law protecting employees with migraines. The Americans with Disabilities Act (ADA) provides accommodations to workers with migraines that impact major life activity. 

Example: When Betsy’s migraines strike, she can’t properly walk, think, or see — let alone help her colleagues with their IT problems. Because these episodes substantially impact basic functions of life (walking, thinking, seeing, and working), her condition qualifies as a disability, as defined by the ADA.  

This status requires Betsy’s employer to provide accommodations. If Betsy’s migraines were triggered by loud sounds, for instance, her company may need to provide noise-dampening headphones. 

Another common accommodation for migraines is intermittent leave. But what if Betsy has run out of FMLA leave? Or what if she didn’t qualify for FMLA to begin with? 

In these scenarios, it’s possible that the ADA would require her employer to provide intermittent leave anyways. The ADA provides intermittent leave as an accommodation for qualified employees with disabilities that require frequent or unpredictable absences. Even when the FMLA does not cover all of an employee’s necessary absences, employers must consider reasonable accommodations under the ADA to allow the employee to work. 

Migraines and the PWFA  

Headaches often accompany pregnancies. Unfortunately, it’s common for pregnant people to experience migraines, as well.  

Workers with pregnancy-related migraines can seek an accommodation under the Pregnant Workers Fairness Act (PWFA). The PWFA is a relatively new law granting reasonable accommodations to employees and applications with conditions linked to pregnancy, childbirth, or related medical conditions.  

Example: Let’s say Betsy, our hypothetical IT worker, is expecting, and her pregnancy is making her migraines worse. Even though she dealt with migraines before getting pregnant, the PWFA would still apply because the pregnancy worsened her migraines.  

One possible accommodation the PWFA could provide? Intermittent leave. Like the ADA, the PWFA requires that employers must consider granting employees additional time off when the FMLA does not cover an employee’s pregnancy-related absences. When arranging for such accommodations, employers should note that they may only seek medical documentation under limited circumstances. 

How technology can help manage FMLA, ADA, and PWFA requests from migraines  

Migraine-related leave and accommodation requests may cause headaches for HR — but they don’t have to. Technology simplifies the leave and accommodations process from beginning to end, bringing relief to leave managers and employees alike. 

See how the AbsenceSoft platform makes migraines easier to manage: 

  • Its self-service portal makes it easy for employees to submit a request, even when they’re dealing with a migraine. 
  • It instantly notifies managers, supervisors, and other stakeholders, who can start finding coverage for last-minute callouts immediately. 
  • It accurately tracks intermittent leave — down to 0.001 of a minute. 
  • It centralizes documentation for migraines so leave managers can seamlessly handle cases related to the FMLA, the ADA, the PWFA, and company policies. 

To learn how AbsenceSoft can help your team manage migraines and more, book a demo today

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