A covered entity may require a medical examination after an offer of
employment has been made to an applicant and prior to the commencement
of the employment duties of such applicant, and may condition an offer of
employment on the results of such examination, if
1. all entering employees are subjected to such an examination regardless of
2. information obtained regarding the medical condition or history of the
applicant is collected and maintained on separate forms and in separate
medical files and is treated as a confidential medical record.