What Managers Need to Know About the PWFA

10/27/2025

Front-line managers are often the first to hear when an employee needs help during pregnancy—and how they respond can make or break compliance. The Pregnant Workers Fairness Act (PWFA) requires employers to handle accommodation requests respectfully, confidentially, and in coordination with HR. In this guide, we’ll break down what managers need to know about the PWFA, including how to recognize a request, what to say (and what not to say), and when to escalate to HR.

Why Manager Awareness Matters Under the PWFA

Under employment law, managers and supervisors act as agents of the company. Their actions—or inactions—are legally considered the actions of the employer. This is why PWFA manager awareness is so critical. A mishandled conversation, a delayed response, or an improper denial of a request can create significant legal liability for the entire organization.

The PWFA doesn't just protect employees; it sets a standard for how employers must respond to their needs. The law requires a timely, respectful, and consistent process for handling accommodation requests. When managers are not trained on their specific PWFA supervisor role, they can inadvertently make mistakes that lead to EEOC complaints, lower employee morale, and increased turnover. Effective pregnancy accommodation training turns supervisors into the first line of defense for compliance, not the primary source of risk.

Recognizing a PWFA Accommodation Request

One of the most important aspects of PWFA manager training is learning to recognize an accommodation request. A request does not have to be formal, in writing, or use any "magic words" like "PWFA" or "reasonable accommodation."

A request can come up in a casual conversation and sound like:

• "I'm having a hard time standing for my whole shift since becoming pregnant."
• "My doctor said I shouldn't be lifting heavy boxes anymore."
• "This morning sickness has been really tough. I'm struggling to get here on time."
• "I need to sit down more often."

Managers must treat any mention of a physical or mental limitation related to pregnancy, childbirth, or a related condition as a potential accommodation request. The correct response is not to solve it on the spot, but to recognize it and escalate it to Human Resources immediately. This initiates the formal PWFA reasonable accommodation process and ensures the company responds compliantly.

How to Respond When an Employee Shares a Pregnancy Limitation

That first conversation is critical. A manager's response can either build trust and ensure compliance or create fear and legal risk. The PWFA supervisor response should be supportive, professional, and consistent.

What to Say (and Do):

• Listen and Thank: Start by thanking the employee for bringing their need to your attention. Say something like, "Thank you for letting me know. I appreciate you telling me." This shows support and encourages open communication.
• Show Empathy: Acknowledge their situation without being intrusive. A simple, "That sounds challenging" can go a long way.
• Focus on Work: Keep the conversation focused on the work-related limitation. You can ask, "How is this affecting your ability to do your job?"
• Escalate Immediately: The most important step is to explain the next step. Say, "Our process is to have you connect with HR to discuss this further. Let's get them involved so we can explore some options."

What NOT to Say (and Do):

• Don't Make Promises: Avoid saying, "No problem, we can definitely do that." You don't have the authority to approve an accommodation alone.
• Don't Deny the Request: Never say, "Sorry, we can't do that" or "That's against our policy." All requests must go through the interactive process.
• Don't Ask Intrusive Medical Questions: Do not ask for a diagnosis or details about their pregnancy. Stick to the work limitation.
• Don't Suggest Leave: A major PWFA violation is forcing leave. Avoid saying, "You should probably just take leave" or "Maybe it's time to start your maternity leave early." The goal of the PWFA is to keep employees working safely.

The Manager’s Role in the Interactive Process

While HR leads the formal interactive process, managers play a vital supporting role. The manager’s role in accommodations is to provide practical insight into the employee's job and the team's operations.

During the PWFA interactive process training, managers learn their responsibilities include:

• Providing Job Information: HR will likely ask you about the employee's essential job functions versus their marginal duties. Your input helps determine which tasks can be modified.
• Brainstorming Solutions: You may be asked to help identify potential job adjustments, such as reassigning a marginal task to another team member or identifying a piece of equipment that could help.
• Implementing the Accommodation: Once HR approves an accommodation, you are responsible for implementing it on the ground—for example, by adjusting the schedule or ensuring a stool is available.
• Maintaining Open Communication: Check in with the employee periodically to ensure the accommodation is working effectively. Report any issues back to HR.

Crucially, managers should never make the final accommodation decision on their own. That decision rests with HR after a thorough and documented interactive process.

Examples of Reasonable Accommodations Managers May Encounter

Managers will encounter a wide range of pregnancy accommodation scenarios. Understanding common PWFA examples helps supervisors recognize what is possible and why it’s important to escalate requests to HR.

Common situations and potential accommodations include:

• Standing Roles: A cashier or retail associate may need a stool to sit on periodically.
• Lifting Duties: A warehouse worker or stock clerk might need heavy lifting duties temporarily reassigned.
• Morning Sickness or Fatigue: An office employee may need a later start time or more frequent, short breaks.
• Prenatal Appointments: Any employee might need a flexible schedule to attend regular medical appointments.
• Postpartum Recovery: A returning employee may need modified duties or a temporary telework arrangement while recovering from childbirth.
• Lactation: A nursing mother will need flexible break times and a private, clean space (that is not a bathroom) to pump.

Whether any of these is "reasonable" depends on the specific job duties and business needs, which is why HR must lead the evaluation.

Confidentiality and Professionalism

A manager handling pregnancy medical info has a legal and ethical duty to maintain confidentiality. This is a non-negotiable part of the job.

• Information is Private: All medical information related to an employee's pregnancy is confidential. This includes the fact of the pregnancy itself if the employee has not shared it widely.
• Need-to-Know Basis: This information should only be shared with HR or, in very limited circumstances, with others who are essential to implementing the accommodation.
• No Team Announcements: Never discuss an employee’s pregnancy, health condition, or accommodation with their coworkers, other subordinates, or other managers. If team members ask about a schedule change or other adjustment, the appropriate response is, "I'm not able to discuss private employee matters, but we have made arrangements to ensure our work gets done."

Breaching PWFA confidentiality can expose the organization to legal liability and destroy employee trust.

Common Mistakes Managers Should Avoid

Most PWFA manager mistakes are unintentional but can have serious consequences. Training should focus on preventing these common compliance errors:

• Ignoring or Delaying a Request: Telling an employee "we'll see" and never following up is legally the same as a denial.
• Making Assumptions: Assuming a pregnant employee can't or doesn't want to do certain tasks can be discriminatory. Always let the employee and their healthcare provider define the limitations.
• Playing Doctor: Questioning the employee's stated needs or suggesting alternative medical solutions is inappropriate and risky.
• Requiring a Doctor's Note for Obvious Needs: A visibly pregnant employee asking for a water bottle or more frequent bathroom breaks does not need to provide medical documentation. Demanding it can be a violation.
• Suggesting Leave as a First Option: The PWFA explicitly prohibits forcing an employee to take leave if another reasonable accommodation would allow them to keep working.

How Managers and HR Work Together on PWFA Requests

A compliant PWFA process is a partnership between managers and HR. Each has a distinct but complementary role. This PWFA HR coordination ensures decisions are both operationally sound and legally compliant.

• HR's Role: Leads the formal interactive process, requests and reviews any necessary medical documentation, makes the final accommodation decision, and documents every step of the process.
• Manager's Role: Acts as the first point of contact, recognizes and escalates requests to HR, provides information on essential job functions, helps implement the approved accommodation, and maintains confidentiality.

When this partnership works well, the employee receives timely support, the business continues to run smoothly, and the organization's legal risk is minimized.

Training Managers for PWFA Compliance

Effective PWFA supervisor training is an ongoing effort, not a one-time event. It should be integrated into your existing compliance programs.

• Incorporate PWFA into Regular Training: Add PWFA modules to your standard anti-discrimination, harassment, and ADA training sessions.
• Use Role-Playing Scenarios: Have managers practice responding to common requests. This builds muscle memory for saying and doing the right thing in a real situation.
• Provide Written Guidance: Equip managers with a PWFA manager checklist, simple scripts, and a clear flowchart of the escalation process.
• Reinforce Key Principles: Continually remind managers of the core principles: recognize, refer, respect, and record.

Investing in PWFA certification for managers and HR can provide a deeper level of expertise and demonstrate the organization's commitment to compliance.

Quick Reference — Manager PWFA Compliance Checklist

When an employee raises a pregnancy-related need, managers should follow these five simple steps.

• [✓] Recognize: Listen for any mention of a physical or mental limitation related to pregnancy, childbirth, or a related condition. Treat it as a potential accommodation request.
• [✓] Respond: Thank the employee for sharing their needs. Listen with support and without judgment.
• [✓] Refer: Escalate the request to HR immediately. Do not try to solve it on your own.
• [✓] Respect: Keep the information completely confidential. Do not discuss it with anyone other than HR.
• [✓] Record: Make a simple note for yourself of the date, the employee's name, the general request, and the fact that you referred it to HR.

Train Your Managers to Handle PWFA Requests Correctly

Help your supervisors stay compliant and confident. Your front-line leaders are the key to a successful and lawful PWFA program. Our PWFA Manager Training & Certification Program covers recognition, response, and escalation—so your team supports pregnant workers the right way and protects your organization from risk.

Frequently Asked Questions

What should a manager do if an employee requests pregnancy accommodation?
A manager should listen supportively, thank the employee for bringing it to their attention, and immediately escalate the request to HR. They should not try to approve, deny, or solve the request on their own.

Can a manager deny a PWFA request?
No. A manager does not have the authority to deny a PWFA accommodation request. All requests must go through the formal interactive process led by HR to determine if a reasonable accommodation can be provided without causing undue hardship.

How should managers handle confidentiality under the PWFA?
Managers must treat all information about an employee's pregnancy, health, and accommodations as strictly confidential. This information should not be shared with coworkers or anyone who does not have a legitimate business need to know.

Do managers need special PWFA training?
Yes. Because managers act as agents of the employer, they must receive training on their specific responsibilities under the PWFA. This includes how to recognize a request, respond appropriately, escalate to HR, and maintain confidentiality to avoid legal risk for the organization.