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PIP Compliance Checklist: What Makes a Performance Improvement Plan Defensible

A PIP exists to do two things: give the employee a real chance to improve, and document that you did. A PIP written to justify a decision already made does neither — it hands the plaintiff's attorney a dated exhibit showing exactly when the company started building a file. These are the eight checks that separate the two.

DefensibleHR.ai Compliance Team · Updated July 2026

The 8-point attorney checklist

1

Goals are objective, measurable, and role-relevant

Critical

Why it matters: "Improve attitude" and "be more of a team player" are subjective standards a jury can't verify and a biased manager can move at will — which is precisely how plaintiffs frame them. Vague goals also make the outcome unauditable: no one can say whether the employee met them, so the termination decision looks discretionary.

Check: Each goal has a number, a deliverable, or an observable behavior, tied to the actual job description — "close rate at or above 15%," "zero missed filing deadlines," not "show more commitment."

2

The problems predate the PIP — on paper

Critical

Why it matters: The most damaging question in a deposition: "If the performance was so bad, why is there no documentation before the PIP?" A PIP that materializes fully formed — especially after a raise, a good review, or a protected complaint — reads as pretext. The PIP should be the culmination of documented feedback, not the first written record.

Check: Prior reviews, one-on-one notes, or coaching emails corroborate the issues the PIP cites. If the last performance review says "exceeds expectations," reconcile that gap in the PIP itself.

3

Timing doesn't follow protected activity

Critical

Why it matters: Temporal proximity — a PIP landing days or weeks after a discrimination complaint, an FMLA request, a workers' comp claim, or a wage question — is the most common circumstantial evidence in retaliation cases, and retaliation claims now outnumber every other charge type at the EEOC. The performance issues may be entirely real; the timing still writes the plaintiff's opening statement.

Check: Before issuing, confirm whether the employee has engaged in protected activity recently. If yes, the pre-existing documentation (check #2) needs to be airtight, and legal review before delivery is cheap insurance.

4

Comparators are treated the same

Critical

Why it matters: Discrimination cases are won on comparators: "Two reps missed quota; only the 55-year-old got a PIP." Inconsistent application of performance management across employees with similar records — by age, race, sex, disability, or any protected class — is the core of a disparate-treatment claim, and your own records will be discovered.

Check: Others with similar performance issues have been handled similarly. If not, be prepared to articulate the legitimate difference — and write it down now, not after the charge arrives.

5

ADA and FMLA interactions are handled

Critical

Why it matters: Two traps. First, if the employee has disclosed (or discloses during the PIP) that a disability affects performance, the ADA interactive process is triggered — you may hold them to the same standards, but you must explore reasonable accommodations before pressing forward. Second, FMLA-protected absences cannot count against attendance or productivity metrics; a PIP that penalizes protected leave is interference on its face.

Check: Metrics exclude protected leave, and any disability disclosure routes to the accommodation process before the PIP clock keeps running.

6

The timeline and support are realistic

Warning

Why it matters: A 14-day PIP for goals that take a quarter to demonstrate, with no training, no check-ins, and no resources, tells a jury the outcome was predetermined — the PIP was theater. Courts and juries understand the difference between a genuine improvement plan and a paper trail being constructed.

Check: The duration matches the goals (30/60/90 days are common), scheduled check-ins are on the calendar, and the plan names the support provided — training, shadowing, reprioritized workload.

7

No promises — and no predetermined outcome

Warning

Why it matters: Language cuts both ways. "Successful completion will result in continued employment" is a promise that can outlive at-will status; "failure will result in termination" boxes you into firing someone who improved 90% of the way. Meanwhile, a manager's email saying "we just need the PIP on file before we let him go" is the single most quoted document in wrongful termination discovery.

Check: The PIP states that it doesn't alter at-will employment, outcomes "may include further action up to and including termination," and — critically — managers are coached that emails about the PIP are discoverable.

8

Follow-through is documented to the end

Warning

Why it matters: A PIP that starts with weekly check-ins and goes silent after week two suggests the employer stopped caring about improvement — or never did. The close-out matters most: a written summary of whether each goal was met, with evidence, is what makes the eventual decision (either way) defensible.

Check: Every scheduled check-in happened and produced a dated note; the PIP closes with a written outcome assessment against each goal, shared with the employee.

Quick checklist before you deliver a PIP

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Frequently asked questions

Is a PIP legally required before termination?

Generally no for at-will employees — but if your handbook or past practice promises progressive discipline, skipping it invites a claim. The legal risk isn't in skipping a PIP; it's in running one inconsistently across employees.

How long should a PIP last?

Long enough that improvement is genuinely possible — commonly 30, 60, or 90 days. A two-week PIP for quarter-long goals reads as a formality on the way to a predetermined outcome.

Can I issue a PIP right after an employee complained about discrimination?

You can, but close timing between protected activity and adverse action is classic retaliation evidence. Real performance problems should be documented from before the complaint — if the paper trail starts the week after, expect it to be the centerpiece of the claim.

What if a disability is affecting performance?

You may hold employees with disabilities to the same standards, but a disability disclosure triggers the ADA interactive process — explore accommodations before continuing. It's both required and your strongest evidence the outcome wasn't predetermined.

Does the employee have to sign the PIP?

No. The signature acknowledges receipt, not agreement — the document should say so. If they refuse, note the refusal with a witness and deliver a copy.

Related guides

This guide is general information, not legal advice, and reading it does not create an attorney-client relationship. Employment law varies by state and changes frequently; consult a licensed employment attorney about your specific situation. DefensibleHR.ai scan results are AI-generated starting points for review, not a substitute for counsel.