Practical Examples of Reasonable Pregnancy Accommodations under the PWFA

10/23/2025

The Pregnant Workers Fairness Act (PWFA) requires employers to provide reasonable accommodations for employees affected by pregnancy, childbirth, or related medical conditions—and most of these adjustments are simple, low-cost, and temporary. From flexible schedules to modified tasks or extra breaks, these accommodations help pregnant workers stay safe and productive without disrupting operations. This guide will share practical examples of reasonable pregnancy accommodations under the PWFA and explain how HR teams can apply them effectively.

Understanding What ‘Reasonable Accommodation’ Means under the PWFA

Under the PWFA, a "reasonable accommodation" is a change or adjustment to a job or work environment that allows a qualified pregnant or postpartum worker to perform their essential job duties safely. The PWFA accommodation definition is intentionally broad and flexible. "Reasonable" does not mean expensive, elaborate, or permanent. Often, the most effective solutions are simple, temporary, and cost little to nothing to implement.

The concept builds on principles established by the Americans with Disabilities Act (ADA), but with a critical distinction. While the ADA requires accommodations for disabilities, the PWFA applies to "known limitations" related to pregnancy, childbirth, or related medical conditions. These limitations do not need to rise to the level of a disability. This pregnancy accommodation law of 2023 was designed to be practical, ensuring workers get the support they need without navigating complex legal definitions.

Why Accommodations for Pregnancy Are Different from ADA Accommodations

While the process of providing accommodations under the PWFA borrows from the ADA framework, there are key differences that HR professionals must understand. The most significant is the scope. PWFA vs. ADA accommodations differ primarily in what triggers the employer's duty to act. The ADA applies to physical or mental impairments that substantially limit a major life activity. The PWFA applies to temporary, and often minor, limitations associated with a healthy pregnancy.

Because pregnancy-related needs are often straightforward and temporary, the PWFA interactive process is typically simpler and faster than what might be required under the ADA. A pregnant employee needing more frequent bathroom breaks is a common scenario that can usually be resolved in a single conversation.

Documentation requirements are also more limited. Under the PWFA, employers should only request medical documentation when it is necessary to understand the employee’s limitations and need for accommodation. For obvious, common-sense requests, demanding a doctor’s note creates an unnecessary barrier and can be seen as a violation. Pregnancy vs. disability accommodations are fundamentally different in duration and scope, requiring a more agile and less bureaucratic approach from employers.

Common Examples of Reasonable Accommodations for Pregnant Workers

PWFA reasonable accommodations can be grouped into several categories. The following pregnancy accommodation examples illustrate the types of PWFA workplace adjustments employers might be expected to make. These are some of the most common reasonable accommodations for pregnant employees.

Physical Adjustments

These accommodations involve changes to an employee's physical tasks or workstation.

• Seating: Allowing a cashier, retail associate, or assembly line worker to use a stool or chair instead of standing for their entire shift.
• Lifting Assistance: Modifying heavy-lifting duties by having a coworker assist, using lifting aids, or temporarily reassigning the task.
• Workstation Modifications: Adjusting the height of a desk or chair, providing an ergonomic keyboard, or making other changes to reduce physical strain.
• Closer Parking: Providing a parking spot closer to the building entrance to reduce walking distance for an employee experiencing fatigue or mobility issues.

Schedule and Leave Modifications

These changes help employees manage their time and energy during pregnancy and postpartum recovery.

• Flexible Schedules: Allowing an employee to adjust their start and end times to manage morning sickness or fatigue.
• Breaks: Providing more frequent or longer breaks for rest, hydration, or snacks.
• Leave for Appointments: Allowing an employee to use unpaid leave or a flexible schedule to attend prenatal or postnatal medical appointments.
• Telework: Permitting temporary remote or hybrid work if the job duties can be performed from home.
• Postpartum Recovery Time: Providing unpaid leave or modified duties to support an employee's recovery after childbirth.

Work Environment Modifications

These adjustments alter the employee’s surroundings to make them safer or more comfortable.

• Lactation Support: Providing a private, clean space (that is not a bathroom) and reasonable break time for an employee to express breast milk. This is a critical component of postpartum workplace support.
• Limiting Exposure: Modifying duties to limit an employee’s exposure to chemicals, extreme temperatures, or other potentially hazardous conditions.
• Food and Drink: Allowing an employee to keep a water bottle or snacks at their workstation, even if it is against company policy.

Temporary Reassignments

In some cases, temporarily moving an employee to a different role may be the most effective accommodation.

• Light-Duty Roles: Moving an employee from a physically demanding job to a less strenuous one, such as an administrative or clerical position.
• Hazard-Free Positions: Reassigning an employee away from tasks that could pose a risk to their pregnancy.

It is critical to note that an employer cannot force an employee into a reassignment if another reasonable accommodation would allow them to remain in their current role. The interactive process is meant to be a dialogue, and the employee’s preferences should be considered.

Temporary vs. Ongoing Accommodations — What’s the Difference?

A key feature of the PWFA is its focus on temporary pregnancy accommodations. Many of the adjustments a worker needs during pregnancy—like avoiding heavy lifting or having more frequent breaks—will only last for a matter of months. Once the employee has recovered from childbirth, they may no longer need those specific accommodations.

However, some accommodations may be ongoing. For example, an employee needing lactation breaks will require that support for as long as they continue to pump at work. A worker experiencing postpartum depression may need a flexible schedule or other accommodations for a longer period.

Because needs can change, HR teams should periodically revisit accommodations to ensure they remain effective and necessary. A simple check-in with the employee every few months can help determine if adjustments are needed. This flexibility is central to providing effective postpartum workplace support and ensuring PWFA compliance.

How to Handle Pregnancy Accommodation Requests

The PWFA accommodation process is designed to be straightforward. An employee does not need to use legal terms or even mention the PWFA to make a request. A simple, plain-language communication is enough to trigger the employer’s obligations.

Here is how to request pregnancy accommodations and how employers should respond:

1. Recognize the Request: Requests can be verbal or written and can come from the employee or a representative (like a family member or doctor). Train managers to recognize any communication about a work-related need due to pregnancy as a formal request.
2. Engage in the Interactive Process Promptly: Begin a good-faith dialogue with the employee to understand their limitations and explore potential solutions. The goal of this interactive process for pregnancy is to find a workable accommodation quickly.
3. Offer an Effective Accommodation: Employers are not required to provide the employee’s preferred accommodation, but they must provide one that is effective. If there are multiple effective options, the employer can choose which one to implement.
4. Document the Process: Keep a record of the request, the conversation, the decision made, and the accommodation provided. This documentation is crucial for demonstrating compliance.

The Employer’s Role — Best Practices for Compliance

Meeting PWFA employer responsibilities goes beyond just responding to requests. It involves creating a supportive and compliant workplace culture.

Key best practices for HR compliance with pregnancy law include:

• Acknowledge Requests Early: Do not let requests linger. A prompt response shows good faith and prevents delays that could be seen as a denial.
• Maintain Confidentiality: All medical information related to an accommodation must be kept confidential and stored separately from the employee’s personnel file.
• Avoid Retaliation: It is illegal to punish an employee for requesting or using an accommodation.
• Don’t Force Leave: Never force an employee to take leave if another reasonable accommodation would allow them to continue working.
• Train Your Managers: Managers are your first line of defense. They must be trained to recognize requests and escalate them to HR without making unlawful inquiries or promises.

What Does “Undue Hardship” Mean Under the PWFA?

An employer is not required to provide an accommodation if it would cause an "undue hardship." This is the same standard used under the ADA. PWFA undue hardship is defined as an action requiring significant difficulty or expense when considered in light of several factors, including:

• The nature and cost of the accommodation.
• The employer’s overall financial resources.
• The size and nature of the employer’s operations.

This is a high bar to meet, and most common pregnancy accommodations—like providing a stool or allowing more breaks—will not rise to this level. If an employer denies a request based on undue hardship, it must be prepared to document exactly why the accommodation was not feasible. Vague claims of cost or inconvenience are not enough to meet the legal standard for this reasonable accommodation law for employers.

How to Align PWFA Accommodations with ADA and FMLA Policies

The PWFA, ADA, and Family and Medical Leave Act (FMLA) often intersect, and employers must understand how to coordinate their policies. Effective PWFA and FMLA coordination can help prevent unnecessary leave and ensure full compliance.

Here is a simple breakdown:

• PWFA: Provides reasonable accommodations for limitations related to pregnancy, childbirth, and related conditions. The goal is to keep the employee working.
• ADA: Provides reasonable accommodations for qualified individuals with disabilities. A pregnancy-related complication could qualify as a disability if it substantially limits a major life activity.
• FMLA: Provides up to 12 weeks of unpaid, job-protected leave for serious health conditions, including pregnancy and childbirth.

Often, a simple PWFA accommodation can prevent the need for an employee to use FMLA leave. For example, providing light duty for a few weeks might allow an employee to continue earning a paycheck instead of taking unpaid leave. Clear communication and a well-defined interactive process are essential for navigating PWFA vs. ADA scenarios and managing pregnancy leave vs. accommodation decisions.

Real-World Example: How a Simple Adjustment Prevented Leave

Here is a short pregnancy accommodation case study that illustrates the PWFA in action.

A logistics company employed a warehouse associate whose job required her to be on her feet all day and occasionally lift boxes weighing up to 40 pounds. When she became pregnant, she began experiencing severe fatigue and back pain. Her doctor recommended she limit standing for long periods and avoid heavy lifting.

She verbally told her supervisor about her limitations. Instead of placing her on unpaid leave, the supervisor contacted HR. Through the interactive process, they determined she could be temporarily assigned to a role that involved processing shipping labels and performing inventory checks at a desk. This light-duty assignment allowed her to remain employed and earn her full salary throughout her pregnancy.

This is one of the best reasonable accommodation success stories. The employee avoided financial hardship, and the company retained a trained and valuable team member. It was a win-win that demonstrates the practical benefits of the PWFA.

Key Takeaways — Accommodating Pregnancy Doesn’t Have to Be Complicated

The PWFA is about practical solutions, not legal hurdles. For employers and HR teams, the path to compliance is straightforward.

• Most accommodations are low-cost and based on common sense.
• Open communication and flexibility matter more than formal paperwork.
• Manager training is the most critical element of a successful compliance strategy.
• The goal is to keep employees healthy, productive, and retained.

Learn How to Manage Pregnancy Accommodation Requests with Confidence

Train your HR and management teams to handle pregnancy accommodation requests correctly under the PWFA. Explore our PWFA Compliance Training & Certification Program to protect your employees and your organization. This specialized training provides the tools, templates, and knowledge needed to build a fair, supportive, and legally compliant workplace.

Frequently Asked Questions

What are reasonable pregnancy accommodations under the PWFA?
Reasonable accommodations are changes to the job or work environment to help a pregnant or postpartum worker. Examples include flexible schedules, modified job duties, providing a stool for a standing job, more frequent breaks, and time off for medical appointments.

Do employers have to provide the accommodation an employee requests?
Not necessarily. Employers are not required to provide the employee’s preferred accommodation, but they must provide one that is effective in addressing the employee's limitation. If multiple effective options exist, the employer may choose which one to implement.

Can an employer ask for medical documentation under the PWFA?
An employer can only request medical documentation when it is reasonable and necessary to confirm the pregnancy-related limitation and the need for an accommodation. For obvious and simple requests, asking for a doctor's note is discouraged.

Are pregnancy accommodations temporary or permanent?
Most pregnancy accommodations are temporary and last only for the duration of the pregnancy or the immediate postpartum recovery period. However, some accommodations, like those for lactation or ongoing postpartum conditions, may last longer.

How does PWFA interact with ADA and FMLA?
The PWFA, ADA, and FMLA can all apply to the same employee. The PWFA requires accommodations to keep an employee working, while the FMLA provides job-protected leave. The ADA applies if a pregnancy-related condition qualifies as a disability. Employers must comply with the law that provides the greatest protection to the employee.

Who is covered by the PWFA?
The PWFA applies to private and public sector employers with 15 or more employees. It protects both qualified employees and job applicants.