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Office of Legal Counsel and Compliance

Procedure for Pregnancy Accommodations ()

Effective Date: 08/18/2025

Policy Page

The following procedure details the process Employees and Students should follow in requesting, implementing, and challenging reasonable accommodations. This procedure in no way limits individuals’ rights under University policy or applicable law. 

Step 1: Requesting Reasonable Accommodations 

Employees: An employee should initiate the process by informing their supervisor, the Employee Accommodations Coordinator, or human resources services client partner that they require a reasonable accommodation for Pregnancy or a Related Medical Condition.  

Students: A student should initiate the process by informing the Student Accommodations Coordinator that they require a reasonable accommodation for Pregnancy or a Related Medical Condition. 

Job Applicants: Job applicants should initiate the process by informing the University Recruitment Specialist or the Employee Accommodations Coordinator that they require a reasonable accommodation for Pregnancy or a Related Medical Condition.  

Interactive Process by Role 

The following sections details the obligations of different individuals and entities throughout the interactive process:

Supervisors 
  1. When made aware that an Employee is Pregnant or has a Related Medical Condition resulting in a limitation at work, the supervisor should immediately engage the employee in the interactive process to determine if the employee needs a routine accommodation which is reasonable for the specific work environment.  
  2. The supervisor should document the interactive communications and any accommodations which are implemented. 
  3. If the Employee indicates that additional accommodations are needed, the supervisor should inform the Employee Accommodations Coordinator that the Employee is requesting additional accommodations and request the Employee Accommodations Coordinator make outreach. The supervisor should also inform the Employee Accommodations Coordinator of any accommodations that the Employee and supervisor have agreed upon.   
Employee Accommodations Coordinator 
  1. After the accommodation process has been initiated, the Employee Accommodation Coordinator will conduct outreach to the Employee or Applicant, and provide information about: 
    1. Scheduling a meeting to discuss needed accommodations 
    2. What documentation, if any, is necessary for the employee to provide 
    3. If appropriate, information about break time and locations for expression and cool storage of breast milk 
  2. After the meeting between the Employee Accommodation Coordinator and the employee, the Employee Accommodation Coordinator will work with the Employee’s supervisor/ department to assess any barriers to access, job requirements, technical standards, etc. and determine what reasonable accommodations will be provided 
  3. Issue an Accommodation Letter, and document all accommodations as well as any that an Employee has requested, but have not been implemented.  
Employees 
  1. Engage in the Interactive Process with the Employee Accommodations Coordinator by explaining their particular need for accommodations and when requested by the Employee Accommodations Coordinator, by providing medical information and documentation; 
  2. Work with supervisor, to implement reasonable accommodation(s), and 
  3. Promptly communicate with the Supervisor or Employee Accommodations Coordinator if a new or additional accommodation is needed or if there is a concern about an accommodation’s implementation. 
  4. Inform the Employee Accommodations Coordinator if/when the Employee is assigned to a different supervisor in order to ensure no disruptions to provided accommodations and/or, as needed, to review accommodations with new supervisor.  
Student Accommodations Coordinator  
  1. After the accommodation process has been initiated, the Student Accommodations Coordinator will send outreach to the student, and provide information about:  
    1. Scheduling a meeting to discuss needed adjustments 
    2. what documentation, if any, is necessary for the student to provide 
    3. if appropriate, information about break time and locations for expression of breast milk 
  2. After the meeting between Student Accommodations Coordinator and the student, the Student Accommodations Coordinator will work with the student’s faculty, academic departments and if appropriate graduate advisor to assess any barriers to access, course requirements, technical standards, etc. and determine what reasonable accommodations will be provided 
  3. Issue an Accommodation Letter.  
Students 
  1. Initiate the process by contacting the Student Accommodations Coordinator to schedule an initial meeting; 
  2. Engage in the Interactive Process with the Student Accommodations Coordinator by providing necessary information, including information about academic barriers related to Pregnancy or Related Medical Condition, and can sometimes include medical documentation;  
  3. Access the Accommodation Letter or accommodation letter provided by [Office], 
  4. Contact professors, provide them with the Accommodation Letter, and request accommodations promptly. 
  5. Remain connected with Student Accommodations Coordinator as needed. Promptly communicate with TIX Coordinator if new or additional accommodations are needed or if there is a concern about implementing a accommodation. 
Faculty 
  1. Collaborate and communicate with the Student and/or Student Accommodations Coordinator, as needed, to implement reasonable accommodations listed on the Accommodation Letter, 
  2. Implement reasonable accommodations provided on the Accommodation Letter consistently and promptly, 
  3. Immediately consult with the Student Accommodations Coordinator if questions or concerns about accommodation requests or the implementation of accommodations arise,  
  4. Immediately communicate to the Student Accommodations Coordinator any questions or concerns regarding accommodation requests or the implementation of accommodations that may fundamentally alter a course and 
  5. Respond promptly to the Student Accommodations Coordinator requests for information and collaboration. 

Step 2: Accommodation Follow-Up 

The Student Accommodations Coordinator and the Employee Accommodations Coordinator carefully evaluate all available information when determining reasonable accommodations.  If the Employee/Student/Applicant disagrees with the accommodation(s) provided in the Accommodation Letter or believes an accommodation has not been properly implemented, Employees and Applicants must notify the Employee Accommodations Coordinator and students must notify the Student Accommodations Coordinator. If the concern is not resolved, at that point Employees/Students/Applicants may proceed with Reconsideration by following the process outlined in the Reconsideration section below. 

Step 3: Reconsideration 

If concerns remain after completion of Step 2, the student or Employee may begin the Reconsideration process.  The Employee/Student/Applicant must initiate Reconsideration within 14 calendar days of the issuance of the Accommodation Letter. Outlines of the Reconsideration processes for Students and Employees/Applicants are provided below. 

Student Reconsideration: 

The Student shall email the Associate Vice President for Conflict, Resolution, & Policy a request to meet and a description of their concern(s) and/or reason(s) for requesting Reconsideration. 

The Student shall meet in person, by video call or phone call with the Associate Vice President for Conflict, Resolution, & Policy, or their designee, when concerns may be discussed, and additional information and/or documentation may be presented. 

The Associate Vice President for Conflict, Resolution & Policy or their designee may also seek information from Faculty and/or appropriate University administrators as well as seek external expertise as necessary. 

The Associate Vice President for Conflict, Resolution, & Policy, or their designee, will issue a written decision on the Reconsideration and email it to the Student.  The time required for a decision on Reconsideration will depend on various factors, including the nature and scope of the matter.  A reasonable effort will be made to resolve the matter as promptly as possible. 

Upon issuance of a written decision to the Student, faculty are required to implement any accommodation(s) determined by this process to be reasonable.   

Employee/Applicant Reconsideration: 

The Employee/Applicant shall email the Associate Vice President of Human Resources with a request to meet and a description of their concern(s) and/or reason(s) for requesting Reconsideration.  

The Employee/Applicant shall meet with the Associate Vice President of Human Resources, or their designee, when concerns may be discussed, and additional information and/or documentation may be presented. 

The Associate Vice President of Human Resources or their designee may also seek information from the supervisor and/or appropriate University administrators as well as seek external expertise as necessary. 

The Associate Vice President of Human Resources, or their designee, will issue a written decision on the Reconsideration and email it to the Employee and supervisor. The time required for a decision on Reconsideration will depend on various factors, including the nature and scope of the matter. A reasonable effort will be made to resolve the matter as promptly as possible. 

Upon issuance of a written decision to the Employee, supervisors are required to implement any accommodation(s) determined by this process to be reasonable. 

STEP 4: Final Review 

If the issue is not resolved through the Reconsideration process, within 5 calendar days of the issuance of the Reconsideration decision, the Employee/Student/ Applicant may notify the Director of Institution Compliance to request a review of the Reconsideration decision.  The Student/ Employee/Applicant shall submit a written request for review which identifies: 

  1. the issue of disagreement;  
  2. the substantive reason(s) the individual disagrees with the decision; and  
  3. the desired outcome.  
Review Committee 

The Director of Institutional Compliance will convene a Review Committee to address the matter. 

Student Review Committee 

Student matters will be considered by a Review Committee consisting of a representative from Student Affairs, the Vice Provost for Academic Affairs, and the Director of Equal Opportunity.  The Director of Institutional Compliance will serve as ex officio.  In the event that one of these members is unavailable or otherwise cannot serve on the Review Committee, the Director of Institutional Compliance will appoint a replacement member.  The Review Committee may appoint an additional ex officio member, such as a representative from the relevant academic unit if deemed appropriate by a majority vote of the Committee.   

The Student Review Committee will review all submitted information. It may meet with the student to discuss the concern(s) and obtain clarifying information if necessary. The Review Committee also has the discretion to request additional documents and information and to consult with other University officials as appropriate. 

The time required for a decision on a review will depend on various factors, including the nature and scope of the matter.  The Director of Institutional Compliance will issue a written decision on the Final Review.  The written decision is appealable to the Office of the Commissioner of Higher Education as a final campus decision. 

Employee/Applicant Review Committee 

Review of Employee/Applicant matters will be heard by a Review Committee consisting of the Vice President for People and Culture, the Student Accommodations Coordinator, and a relevant unit official.  The Director of Institutional Compliance will serve as ex officio.  In the event that one of these members is unavailable or otherwise cannot serve on the Review Committee, the Director of Institutional Compliance will appoint a replacement member.   The Committee may appoint an additional ex officio member, such as a representative from the relevant employment unit if deemed appropriate by a majority vote of the Committee.   

The Employee Review Committee will review all submitted information. It may meet with the Employee/Applicant to discuss the concern(s) and obtain clarifying information if necessary. The Review Committee also has the discretion to request additional documents and information and to consult with other University officials as appropriate. 

The time required for a decision on a review will depend on various factors, including the nature and scope of the matter.  The Director of Institutional Compliance will issue a written decision on the reconsideration. The written decision is appealable to the Office of the Commissioner of Higher Education as a final campus decision. 

Discrimination & Harassment Complaints 

Employees, Applicants or Students who have complaints related to discrimination, harassment, or retaliation on the basis of Pregnancy, Childbirth or Related Medication Conditions should report to the Office of Conflict, Resolution and Policy and follow the procedures in the University’s Discrimination, Harassment, and Retaliation policy.  

Confidentiality 

That an Employee, Applicant or Student is Pregnant, has recently been Pregnant, or has a Related Medical Condition is medical information. Such medical information will be kept confidential pursuant to state and federal law. Moreover, personally identifiable information will not be disclosed except to carry out the purposes of this policy and procedure and/or as required by applicable law. Pursuant to applicable law, supervisors/ managers and/or faculty will be informed only to the extent necessary to implement reasonable accommodations.