Accommodation of employee pregnancy and related conditions: manager’s role
Table of Contents
Which requests require health care provider certification?
Acting on employee accommodation requests or questions
Last updated: May 5, 2025
Overview
Whether you supervise faculty, staff or student employees, UW managers play an instrumental role in the accommodation process. You are often the first person an employee notifies that they might need an accommodation for pregnancy or a related condition, including break time for lactation and access to lactation spaces.
While you don’t need to be an expert in accommodation, it’s essential for you to be familiar with the University’s policy on accommodation for employee pregnancy and related conditions and know how to respond when an employee brings a concern to your attention. Your openness and support can guide employees to the right resources during important life transitions.
Key concepts
A manager needs to be able to recognize an accommodation request related to an employee’s pregnancy, childbirth, or related medical condition. The request can be based on a physical or mental condition, whether or not the condition meets the definition of disability under the ADA. The request can also include time off for medical appointments related to pregnancy, childbirth, or a related medical condition, and lactation breaks to pump breast milk.
Pregnancy accommodations are different than disability accommodations. An employer may have to grant an accommodation that doesn’t allow the employee to perform all their essential job functions if:
- Any inability to perform an essential function is for a temporary period;
- The essential function could be performed in the near future; and
- The inability to perform the essential function can be reasonably
accommodated.
Which requests require health care provider certification?
Managers should be aware that most pregnancy-related requests can be easily accommodated and do not require health care certification (see table below). These accommodations should be implemented immediately if requested by the employee.
Other requests may require a health care provider certification, and managers should contact their accommodation consultant for assistance in these situations. Please be aware that a manager cannot deny any request without first consulting their accommodation consultant.
| Accommodations that do not require health care provider certification | Accommodations that may require health care provider certification |
|---|---|
| Providing more frequent, longer breaks, or flexible restroom breaks. | Job restructuring, modified work schedules, reassignment to a vacant position. |
| Modifying a no food or drink policy. | Acquiring or modifying equipment, devices, or an employee’s workstation. |
| Providing seating or allowing the employee to sit more frequently if the job requires the employee to stand. | A temporary transfer to a less strenuous or less hazardous position. |
| Restricting lifting to 17 pounds or less. | Providing assistance with manual labor and additional limits on lifting. |
| Breaks for pumping and reasonable access to lactation spaces. | Scheduling flexibility for prenatal visits. |
| Accommodations related to nursing during work hours where the regular location of the employee’s workplace makes nursing during work hours a possibility because the child is in close proximity. | Any further pregnancy accommodation or modification an employee may request. |
Employee breaks for lactation
Breaks for pumping breast milk and reasonable access to lactation spaces is a common request that does not require health care provider certification. Managers are encouraged to be flexible and work with their employees to provide break time for the expression of breast milk up to 24 months as needed. The amount of time needed for pumping can vary by individual and can also change over time.
If a designated lactation space is not within reasonable proximity to the employee’s workstation, consider creating a temporary lactation space for the employee. Both designated and temporary lactation spaces must meet the criteria and amenities listed in APS 46.7. Please keep in mind that all lactation spaces must be private and cannot be in restrooms. Additional guidance and a checklist for creating a temporary lactation space can be found on the WorkLife’s Amenities and Guidelines for lactation spaces webpage.
Acting on employee accommodation requests or questions
When an employee reaches out about accommodations:
- Listen attentively and respond with empathy to their concerns.
- Do not ask questions about their medical condition.
- Share the UWHR webpage Accommodation for pregnancy and related medical conditions with your employee via email and copy the applicable accommodation consultant listed in the table below.
- Familiarize yourself with relevant policies and guide your employees to appropriate resources.
- Respond promptly to the employee’s accommodation request and keep an open mind when engaging in the interactive process.
- Document any accommodation requests and implementation efforts.
- Reach out to your UW accommodations specialist if you have questions.
Determining your designated UW accommodation specialist
| Requesting employee | Assigned UW accommodation specialist | How to reach them |
|---|---|---|
| Faculty | Disability Services Office (DSO) | Email dso@uw.edu or call (206) 543-6450 |
| Medical Centers staff | Your assigned Medical Center's leave and accommodation specialist | Select UW Medical Human Resources - Leave Management at hr.uw.edu/contact-us/or call 206-598-6116 |
| UW Facilities staff | UW Facilities HR managers | UW Facilities Partner Resources |
| All other employees, including student employees | Your unit's UWHR leave and accommodation specialist | Find your campus leave and accommodation specialist |
Resources
- UW APS 46.7 Reasonable Accommodation of Employee Pregnancy and Related Medical Conditions
- UWHR Accommodation for pregnancy and related medical conditions
- Temporary disability leave for pregnancy and childbirth
- Meal and rest periods
- UW Lactation Spaces