1) What “exit health interview” usually means

In Philippine workplace practice, an exit health interview can refer to any of the following (often combined):

Occupational health exit interview: a consultation with the company physician/nurse about symptoms, exposures, ongoing treatment, or work restrictions.
Exit medical examination: physical exam and/or diagnostic tests (e.g., chest X-ray, audiometry, laboratory tests) to document health status upon separation.
Return-of-company-medical-records / referral: guidance on continuing care, follow-up, or where to seek treatment.
Health clearance step: used internally as part of “clearance” before final pay and release documents.

It’s important to separate what the law requires from what employers commonly require as a policy.

2) Is an exit health interview legally required after resignation?

General rule: No across-the-board requirement

There is no single Philippine law that universally mandates an “exit health interview” for every resigning employee.

But: exit health processes may be required in specific situations

An exit health interview or examination can become effectively required when it is the employer’s means to comply with occupational safety and health (OSH) duties—especially where the employee had exposure to workplace hazards that require medical surveillance or specific monitoring.

Key legal anchors in the Philippines include:

Labor Code (general employer obligations and labor standards framework)
Republic Act No. 11058 (Strengthening Compliance with OSH Standards)
Implementing Rules and Regulations (IRR) of RA 11058 (commonly applied through DOLE issuance)
Occupational Safety and Health Standards (OSHS) and industry-specific OSH rules
Republic Act No. 10173 (Data Privacy Act) for handling health information

So, while “exit interview” is not universally mandated, medical surveillance and exit examinations may be required depending on risk, exposure, and the applicable OSH rules.

3) When an exit health interview/exam becomes “required” in practice

A) When OSH rules require medical surveillance, including separation/termination exams

For certain jobs and exposures, OSH standards commonly require:

Pre-employment or baseline exams (to establish initial health status),
Periodic exams (to monitor deterioration),
Exit/separation exams (to document end-of-employment health status and support occupational disease tracking).

This is most relevant where the employee’s role involved exposure to hazards such as (examples):

airborne contaminants (dusts/fumes/chemicals),
excessive noise (hearing conservation),
lead/heavy metals,
radiation,
other toxic substances,
physically demanding or safety-critical work.

Purpose: not to “approve resignation,” but to (1) protect worker health, (2) help detect occupational illness early, and (3) document possible work-related exposures for compensation/claims and regulatory compliance.

B) When the exit health interview is tied to fitness-for-work / safety-critical clearance

If an employee is leaving from a role where safety is tightly regulated (e.g., certain high-risk operations), the employer may conduct a final health check to properly transition tasks, close open medical monitoring, and ensure safe handovers.

C) When it is part of a return-to-work/ongoing illness management that must be closed out

If the employee has:

a work-related injury/illness, ongoing restrictions, or pending compensation documentation, an exit health consultation may be used to:
record final status,
issue referrals,
summarize restrictions,
prepare documentation for possible claims (e.g., under employee compensation rules).

4) Can an employer require an exit health interview as a company policy?

Yes—as a reasonable management prerogative, with limits

Employers can institute policies to protect health and safety, including requiring an occupational health exit interview—provided it is lawful, reasonable, uniformly applied, and not discriminatory.

However, the policy must respect:

Right to privacy and data protection
Bodily autonomy / consent (especially for invasive tests)
Non-discrimination rules (e.g., not selectively targeting certain employees)
Labor standards rules on final pay and separation documents (see below)

5) Consent and refusal: can the employee say “no”?

This depends on what is being asked and why.

A) If it’s a non-invasive interview (questions about symptoms/exposures)

An employer can strongly encourage it, and may treat it as part of clearance. Still, the employee can generally refuse to answer certain questions—especially those not necessary for OSH compliance.

B) If it’s a medical exam or test

Health exams involve sensitive personal information and, depending on the procedure, bodily intrusion. As a rule:

employees should be informed of the purpose,
data to be collected,
how it will be used,
who will access it,
how long it will be retained.

For invasive or sensitive tests, explicit consent is the safer standard. If the exam is required under OSH rules for hazardous exposure monitoring, refusal can create a compliance and documentation issue; employers typically handle this by:

documenting the refusal,
offering the exam at no cost where legally required,
providing a written explanation of the OSH purpose,
preserving proof that the opportunity was provided.

Best practice: Employers should avoid framing refusal as “you can’t resign.” Resignation is a right (subject to notice requirements), and medical exams generally should not be used to block it.

6) Data Privacy Act: health data handling in exit health interviews

Health information is sensitive personal information under the Data Privacy Act (RA 10173). This has major implications:

A) Lawful purpose and proportionality

Only collect what is necessary for a legitimate purpose such as:

compliance with OSH standards,
occupational disease prevention/monitoring,
medical referral and continuity of care,
documentation for work-related claims.

B) Access control and confidentiality

Limit access to authorized medical/HR personnel on a need-to-know basis.
Ensure medical records are kept securely and separately where appropriate.

C) Transparency

Employees should receive a clear privacy notice covering:

what data is collected,
purpose,
retention,
sharing (if any),
employee rights (access, correction, etc.).

D) Retention

Employers generally should retain OSH-related medical records consistent with OSH and other applicable regulatory requirements and internal retention schedules, then dispose securely when no longer necessary.

7) Relation to “clearance,” final pay, COE, and release documents

A) Can an employer withhold final pay because the employee skipped the exit health interview?

A common friction point is tying health clearance to final pay.

Key principle: Employers can conduct clearance procedures, but they should not use them to unreasonably delay or effectively forfeit statutory entitlements.

In Philippine practice, DOLE policy guidance generally pushes employers to:

pay final pay within a reasonable period (often referenced as within 30 days in DOLE guidance, unless a more favorable company policy/contract applies),
issue the Certificate of Employment (COE) within the period required by policy guidance upon request.

If an exit health interview is truly for OSH compliance, employers should:

offer it promptly, at no cost when required,
document attendance/refusal, and
avoid indefinite withholding of final pay solely because a voluntary medical process wasn’t completed.

B) Releases and quitclaims

Some employers ask employees to sign a quitclaim/release upon receiving final pay. Exit health interviews sometimes become part of this package. In Philippine jurisprudence, quitclaims are scrutinized; they are not automatically invalid, but they must be voluntary and for a reasonable consideration, and not contrary to law/public policy.

8) Occupational disease and future claims: why exit health documentation matters

An exit health interview/exam can protect both sides:

For employees:

establishes a record of symptoms or suspected occupational illness,
supports claims if a disease manifests later,
helps obtain referrals and continuity of care.

For employers:

demonstrates compliance with OSH obligations,
shows that medical surveillance and advice were provided,
helps in exposure tracking and hazard control improvements,
reduces disputes about whether the employer ignored symptoms.

Practical tip: Employees with known exposure risks should keep copies of relevant health results and exposure summaries when available.

9) Designing a compliant exit health interview process (employer-side)

A robust Philippine-compliant approach usually includes:

A) Clear policy scope

Identify roles/exposures that require exit medical surveillance vs. those that only need a general wellness offboarding.
Avoid applying invasive exams to low-risk roles without justification.

B) Informed notice and scheduling

Provide written notice explaining purpose (OSH compliance vs. voluntary wellness).
Schedule within the notice period where possible.

C) Cost and time

If required for OSH compliance, the exam should generally be at employer cost and scheduled during a reasonable time.

D) Documentation

Document attendance, findings (as appropriate), and referrals.
If refused, document refusal with acknowledgment.

E) Privacy-by-design

Limit questions to OSH-relevant matters.
Restrict access to health data.
Define retention and disposal rules.

10) Employee-side guide: what to expect and what to ask for

If you’re resigning and HR requires an exit health interview/exam:

Ask why it’s required:
- Is it for OSH compliance due to exposure?
- Or is it a general HR wellness interview?
Ask what it includes:
- interview only?
- physical exam?
- lab tests?
- drug test? (If yes, ask legal basis/policy and how results are handled.)
Ask about privacy:
- who will see the results?
- will the manager see details or only “fit/unfit” conclusions?
- how long will it be stored?
Get copies of results that concern your health, where appropriate.
If you have symptoms that may be work-related, state them clearly and request a referral or documentation.

11) Common problem areas (and safer alternatives)

A) Using exit health exams as a “punitive” tool

Red flags:

only imposed on employees who resign,
imposed only on certain groups,
used to delay final pay,
used to fish for unrelated medical information.

Safer alternative:

risk-based medical surveillance aligned with OSH hazards, consistently applied.

B) Over-collection of data

Red flag:

collecting broad medical history unrelated to workplace risks.

Safer alternative:

limit to exposure and symptom screening relevant to the job hazards and legally required monitoring.

C) Sharing medical details with non-medical staff

Red flag:

emailing lab results broadly, or giving managers detailed diagnoses.

Safer alternative:

provide HR/management only functional outcomes (e.g., “completed” / “fit status”) unless disclosure is legally justified and necessary.

12) Bottom line

Not universally required: Philippine law does not impose a blanket requirement that every resigning employee undergo an “exit health interview.”
Sometimes required by OSH compliance: For employees exposed to certain hazards or covered by medical surveillance rules, an exit medical exam/interview may be part of legally expected OSH practice.
Policies are allowed but must be reasonable: Employers may require exit health steps as policy, but must respect privacy, consent standards, non-discrimination, and should not unreasonably delay final pay and required documents.
Health data is highly protected: Exit health interviews must comply with the Data Privacy Act, especially on purpose limitation, security, access, and retention.

If you want, I can also provide (1) a sample company policy template for exit health interviews and exit medical surveillance in the Philippines, and (2) a one-page employee handout explaining rights, consent, and data privacy in plain language.