FCEs in Iowa Workers’ Compensation: What They Can — and Cannot — Prove
February 26, 2026
By: Thania Rios
Functional capacity evaluations (“FCE”) can be useful tools during workers’ compensation cases. However, it is important that all parties involved be acutely aware of their uses and limitations. An FCE is not equivalent to an independent medical examination (“IME”) or a report from a treating physician; it cannot provide an impairment rating. It can, however, resolve disputes between parties regarding a claimant’s employment prospects. When used wisely, a well-drafted FCE can shed an objective light on a claimant’s capacities and greatly assist deputies in weighing evidence.
An FCE is a report drafted by a qualified evaluator—who is, more often than not, a physical therapist—regarding a claimant’s physical abilities in a workplace setting. While preparing the report, the evaluator typically puts the claimant through a battery of tests that assess their ability to perform job-specific movements such as lifting, carrying, standing, sitting, reaching, and bending. After the tests have been conducted, the evaluator compares the results against standardized work classifications from the Dictionary of Occupational Titles: sedentary, light, medium, heavy, and very heavy work. Based upon the results, the evaluator will issue an opinion about the level of work that the claimant is capable of performing.
An FCE is most appropriate when a claimant has reached maximum medical improvement, but the parties disagree about the claimant’s future employment prospects or ability to perform certain jobs. In this situation, an FCE can offer an objective assessment of the claimant’s physical abilities. However, it is important to note that FCEs have a key limitation. An FCE alone, without any evidence from a physician, cannot establish the existence of a disability. The Agency “gives little weight to functional capacity evaluations by physical therapists that are not adopted by a licensed physician and conflict with activity restrictions imposed by licensed physicians.” Allen v. Annett Holdings, File No. 5024900
(App. July 28, 2011) at 9. As Deputy Walshire notes in his decision in Allen, “Such therapists simply lack the medical qualifications to make such medical assessments and causally relate their findings to a work injury.” Id.
While FCEs can be useful, parties to a case must make sure they are making appropriate use of them. If an FCE contradicts the medical evidence, it likely will not be given much weight by the fact finder; and if it is the only proof offered to substantiate a claimant’s alleged disability, their claim will likely not succeed.
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