Pregnancy-related reasonable accommodation procedures for employees and job applicants

Procedure No.: UW-5101

Revision No.: 1

Effective Date: 08/10/2026

PREGNANCY-RELATED REASONABLE ACCOMMODATION PROCEDURES FOR EMPLOYEES AND JOB APPLICANTS

Related Policy: UW-5101 Pregnancy-Related Reasonable Accommodation for Employees and Job Applicants

Responsible Office: Employee Disability Resources (EDR)

Contact: Jenn Streator, Interim Director, Employee Disability Resources Office

608-263-2407

employee.access@wisc.edu

Procedure Statement                                                     

These procedures outline the steps to follow if a qualified UW-Madison employee or job applicant makes a request for reasonable accommodation due to a known limitation related to, affected by, or arising out of their own pregnancy, childbirth, or related medical conditions.

Who Does This Procedure Apply To?

This procedure applies to qualified UW-Madison employees (including student hourly) and job applicants with known limitations, regardless of probationary or initial evaluation status except as described in these procedures.  

Individuals with Student Assistant or Post Degree Training titles seeking employment-related (i.e., non-academic) accommodations are employees for purposes of this policy.

These procedures also apply to others at UW-Madison including, but not limited to:

• Office of Compliance
• Office of Human Resources
• Recruitment contacts, including hiring authorities, human resource contacts, search and screen committees, etc.
• Divisional Disability Representatives (DDRs)
• Employee Disability Resources (EDR) staff
• Divisional Human Resources personnel
• Divisional Budget Officers
• School, College, and Division administration
• Managers and supervisors

 Procedure Detail

1. Informal Accommodation Requests

1. UW-Madison permits informal accommodation requests: 

1. For known limitations related to, affected by, or arising out of pregnancy, childbirth, or related medical conditions; and

2. Where the limitation and the need for accommodation due to the limitation are obvious; and

3. Where extensive discussion and a formal decision letter from the DDR are not needed.

2. The following simple modifications, known as predictable assessments, are considered reasonable accommodations that likely do not impose undue hardship when requested by a qualified employee or job applicant: 

1. Carry or keep water near and drink, as needed;

2. Take additional restroom breaks, as needed;

3. Sit in jobs that typically require standing and stand in jobs that typically require sitting, as needed; and

4. Take breaks to eat and drink, as needed.

3. An employee or job applicant seeking informal accommodation must discuss their needs with their employer or prospective employer (e.g., supervisor, manager, individual who directs the employee’s tasks and/or has supervisory authority, recruitment contact, human resources personnel).  The employee or job applicant must describe the:

1. Limitation related to, affected by, or arising out of pregnancy, childbirth, or related medical conditions,

2. Modification or adjustment they are seeking, and

3. Duration they need the modification.

4. The informal accommodation must be implemented as soon as possible.

5. When informal accommodation is provided to an employee or job applicant:

1. The Pregnancy-Related Informal Accommodation Reporting Form must be submitted to Employee Disability Resources (EDR) by the employer or prospective employer (e.g., supervisor, manager, individual who directs the employee’s tasks and/or has supervisory authority, recruitment contact, human resources personnel).

2. Upon receipt of the form, EDR will notify the DDR and the employee’s supervisor or recruitment contact accordingly.

6. If there is a barrier to providing a predictable assessment (e.g., keeping food and/or water in an employee’s workspace), the employer or prospective employer must notify the DDR as soon as possible. The DDR, in consultation with the EDR office, will determine whether the formal accommodation process is necessary.

2. Initiating Formal Accommodation Requests 

1. An employee or job applicant (or their representative) seeking reasonable accommodation for a known limitation (as defined in the policy):

1. Will make an accommodation request to the Divisional Disability Representative (DDR) in the school/college/division/administrative unit where they work or where they are applying for a job and share what is difficult at work and how their known limitation affects their work.

1. A job applicant who needs accommodation related to the recruitment/hiring process should make their request as early as possible.

2. Timely notification by the job applicant allows the DDR adequate time to engage in the interactive process and coordinate any approved accommodation, since recruitment processes follow established timelines.

2. May submit their request:

1. Via the Reasonable Accommodation Request Form for Employees and Job Applicants which must be submitted to the appropriate DDR; or

2. Via email to the appropriate DDR with information requested on the Reasonable Accommodation Request Form for Employees and Job Applicants; or

3. By talking with the appropriate DDR, providing information requested, and confirming the request in writing during the interactive process; or

4. In writing during the interactive process if the request is made to someone other than the DDR (e.g., supervisor or recruitment contact). If the employee or job applicant is unsure of what to request as an accommodation, they do not need to include it in the initial request. The DDR will assist in identifying possible accommodation(s) during the interactive process.

5. Is not required to share medical information or the reason for their accommodation request with their supervisor or recruitment contact.

6. Will provide medical information when requested by the DDR regarding their known limitation and work-related limitations.

2. The supervisor or recruitment contact will:

1. Provide the employee with their DDR’s contact information when they are made aware of a possible request for an accommodation.

2. Notify the DDR of any requests made directly to them as soon as possible.       

3. Not share medical information, the reason for accommodation, or the fact an individual requested or has accommodation(s) with others unless the DDR has determined there is a need to know.

4. For job applicants, not share accommodation or medical information with a candidate’s prospective or new unit, regardless of whether the candidate is external or internal.

3. The DDR will:

1. Notify EDR immediately upon receiving a request for accommodation. Some requests may be time-sensitive (e.g., job applicants, training requests, travel requests).

2. Document and maintain a record of the request for accommodation, share it with the employee or job applicant to confirm accuracy, and start the interactive process.

3. Provide the Reasonable Accommodation Request form for Employees and Job Applicants only if requested by the employee or job applicant but not delay the interactive process. 

4. Not share medical information, the reason for accommodation, or the fact an individual requested or has accommodation(s) with others, unless there is a need to know.

3. Interactive Process

1. An employee or job applicant seeking reasonable accommodation must:

1. Actively participate in the interactive process with the DDR in their unit. Engagement in the interactive process includes, but is not limited to, responding in a timely manner to inquiries from the DDR or others concerning:

1. Essential job functions and responsibilities;

2. Work or recruitment related limitations;

3. Impact of the known limitation on their ability to perform job duties or apply, interview, or participate in other recruitment/hiring activities for a position; and

4. Other workplace barriers (e.g., parking, events, trainings).

2. Participate in conversations about possible accommodation(s).

2. The supervisor will:

1. Provide the employee with their DDR’s contact information both verbally and in writing if the employee shares with them that they are having difficulty at work due to a known limitation.

2. Notify the DDR when an employee shares that they are having difficulty at work due to a known limitation as soon as possible, and include the following information:

1. Details of verbal conversation(s) with employee;

2. Documentation, if any, provided by employee;

3. Relevant emails (personal or work); and

4. Relevant text or other messages.

3. Actively participate in the interactive process which includes, but is not limited to, providing information in a timely manner to inquiries from the DDR or others concerning:

1. Essential job functions and responsibilities; and

2. The impact of a known limitation on the employee’s ability to perform job duties.

4. Participate in conversations about possible accommodation(s).

3. The recruitment contact will:

1. Provide DDR contact information for a job applicant who shares that they are having difficulty with the recruitment/hiring process due to a known limitation.

2. Notify the DDR when a job applicant shares that they are having difficulty with the recruitment/hiring process due to a known limitation as soon as possible, and include the following information:

1. Details of verbal conversation(s) with job applicant;

2. Documentation, if any, provided by job applicant;

3. Relevant emails (personal or work); and

4. Relevant text or other messages.

3. Actively participate in the interactive process which includes, but is not limited to, providing information in a timely manner to inquiries from the DDR or others concerning:

1. Application process;

2. Details of the interview (e.g., format, location, parking, schedule); and

3. Other recruitment activities.

4. The DDR will initiate the interactive process by contacting the employee or job applicant as soon as possible upon receiving a request. For a job applicant to receive accommodation related to the recruitment process, it is critical for the DDR to review an accommodation request as quickly as possible because each recruitment has an established timeline.  

5. The DDR will meet one-on-one with the employee or job applicant and separately with the position’s supervisor or recruitment contact to discuss and review the request. EDR assists with these meetings.

1. When meeting with the employee or job applicant the DDR will:

1. Discuss the reasonable accommodation process, roles, and confidentiality;

2. Learn about and discuss an employee’s essential job functions, performance, access barrier(s), and accommodation request; or in the case of a job applicant, access barriers(s) in the recruitment/hiring process and the accommodation request;

3. Identify the work or recruitment/hiring-related barriers resulting from the known limitation;

4. Discuss how the known limitation is impacting the employee’s ability to perform the essential functions of their position; or in the case of job applicants, the ability to participate in the recruitment/hiring process;

5. Discuss how the known limitation is creating other workplace barriers for the employee (e.g., parking, events, trainings);

6. Review self-confirmation and any supporting documentation that has been received and/or identify medical documentation that is needed;

7. Review the employee’s or job applicant’s request for a reasonable accommodation and identify potential reasonable accommodation(s) or, if needed, effective alternative reasonable accommodations;

8. Send a letter summarizing the meeting to the employee.

2. When meeting with the supervisor(s) or recruitment contacts the DDR will:

1. Discuss the reasonable accommodation process, roles, and confidentiality;

2. Review the employee’s or job applicant’s accommodation request;

3. Learn about and discuss the employee’s or job applicant’s position, essential job functions, and the employee’s performance as it relates to the accommodation request;

4. Not share the known limitation, or work or hiring-related limitations unless there is a need to know;

5. For employees, discuss the impact of work-related limitations on the employee’s ability to perform the essential functions of their position and other workplace barriers;

6. For job applicants, discuss access barriers in the recruitment/hiring process and the accommodation request;

7. Identify and discuss potential reasonable accommodation(s);

8. Instruct the supervisor to not share any of this information with others unless the DDR identifies there is a need for others to know; the DDR will identify who has a need to know and what information can be shared.

9. May consult with other UW-Madison personnel (e.g., occupational health staff, ergonomic specialist, facilities access specialist), as appropriate, to identify effective reasonable accommodation(s).

10. During the interactive process, the employee, job applicant, supervisor, and/or DDR may consult with EDR for guidance and assistance at any time.

3. EDR will:

1. Consult with DDRs and provide guidance about accommodation requests and other matters related to known limitations;

2. Attend meetings related to the interactive process as needed;

3. Interpret the application of regulations and enforcement agency guidance to accommodation requests and other employment matters;

4. Review accommodation-related documentation;

5. Identify possible accommodation(s) and related resources;

6. Identify whether others (e.g., health care provider, occupational health staff, ergonomic specialist, facilities access specialist,) need to be consulted to determine reasonable accommodation(s);

7. Provide assistance with communication for DDRs related to the interactive process as needed;

8. Review modified and denied accommodation decisions;

9. Record all accommodation decisions; track and report related data.

4. Medical Documentation

1. If the need for accommodation is obvious, medical documentation may not be necessary.

2. If the DDR determines that medical documentation is required:

1. The employee or job applicant will:

1. Provide any medical information and documentation requested by the DDR within the timeframe requested;

2. Inform the DDR if they need additional time to provide medical documentation, and with the DDR determine a mutually agreeable new deadline when possible;

3. Not share medical information or the reason for their accommodation with their supervisor or recruitment contact.

2. The supervisor or recruitment contact will:

1. Provide all received medical information and/or documentation to the DDR;

2. Not retain medical documentation; and

3. Not request or share medical information or the reason for accommodation with others unless the DDR determines there is a need to know.

3. The DDR will:

1. Inform the employee or job applicant in writing if medical information is needed and the specific information that is being requested;

2. Provide written guidance if the medical documentation is insufficient, or if a second opinion is requested; 

3. Review medical documentation to determine if the employee or job applicant has a known limitation;

4. Identify whether other UW-Madison personnel (e.g., occupational health staff, ergonomic specialist, facilities access specialist,) have a need to know medical information to identify possible reasonable accommodation(s) or implement approved accommodation(s);

5. Only share minimal medical information that others need to know to identify or implement an accommodation, and instruct the recipient to not share the information with others;

6. Retain medical documentation in a secure location that is separate from the job applicant or employee personnel file and not transfer medical documentation to another unit unless requested by the employee.

4. EDR will:  

1. Assist in identifying the exact nature of medical information needed;

2. Assist in interpreting medical documentation received from the employee or job applicant;

3. Assist the DDR in determining if the medical documentation is sufficient and if it confirms a known limitation under the applicable laws; 

4. Assist the DDR in determining who has a need to know and what information can be shared;

5. Only share minimal medical information that others need to know to identify or implement an accommodation and instruct the recipient to not share the information with others; and

6. Maintain confidential records separate from employee or job applicant personnel records.

3. If an employee or job applicant asks that details about their accommodation request not be shared with their hiring manager/search committee or supervisor, the DDR must consult EDR to determine if the nature of the requested accommodation permits the interactive process to exclude them.

5. Accommodation Decisions and Implementation

1. The DDR will:

1. Evaluate each option when there is more than one reasonable accommodation that addresses the same barrier, by considering the needs of the unit or recruitment process and the individual needs of the employee or job applicant. Per the policy, when more than one reasonable accommodation addresses the same barrier, the DDR will make an effort to approve an employee’s or job applicant's preferences which may not always be possible.

2. Consult EDR before approving an alternative accommodation.

3. Consult EDR before denying an accommodation request.

4. Notify the employee or job applicant of a decision about their accommodation request in writing and copy the supervisor and EDR. The DDR must include the reason why an alternative accommodation is approved, or why the request is denied, and must include information about the appeal process.

5. After notification:

1. Assist the supervisor, or other parties as necessary, to procure the necessary equipment or services approved as an accommodation without delay; and,

2. Work with the supervisor or recruitment contacts, or other parties as necessary, to promptly implement the accommodation.

2. If there is a delay in processing, procuring, or implementing the approved accommodation, the DDR will:

1. Communicate in writing with the employee or job applicant, as well as the supervisor, about the reasons for the delay; and,

2. Determine whether an interim reasonable accommodation that meets operational needs can be made, and offer the interim reasonable accommodation to the employee. 

3. If a department has concerns about the impact of the cost of accommodation on their budget, they must consult their DDR who will first work with the school, college, division level budget representative. The DDR will consult EDR related to this funding analysis. EDR and the DDR may consult the Office of the Vice Chancellor for Finance and Administration as needed.

4. After implementation of reasonable accommodation(s), the employee, supervisor, and DDR will evaluate the effectiveness of the accommodation.

1. The DDR will check in with the employee and the supervisor (as needed), document the interaction, and consult with EDR as necessary.

2. The employee and/or supervisor are responsible for reporting any concerns with the accommodation to the DDR.

5. Per the policy, any equipment purchased or loaned as part of an approved reasonable accommodation is the property of the department.

1. The employee must return the equipment when their employment ends with their department.

2. An employee who takes a new position in a new department may request from their former DDR that the equipment be transferred to the new department. The former and new DDRs will confer to determine whether this is feasible.

6. If an employee or job applicant needs an adjustment to their current accommodation, they must consult with the DDR. If they have a new accommodation request, they must follow the procedures outlined in this document to make a new accommodation request.

7. After an accommodation is implemented:

1. If the employee has performance issues related to their known limitation:

1. The DDR will evaluate if there are any additional reasonable accommodations.

2. The DDR will determine if temporary reassignment as a reasonable accommodation needs to be considered.

3. If the employee does not engage in the interactive process, and the university is not able to determine reasonable accommodation, and the employee is unable to perform the essential functions at a satisfactory level without accommodation, the employee’s lack of performance will be addressed through the applicable performance management process.

2. If the employee has performance issues unrelated to their known limitation, those performance issues will be addressed through the applicable performance management process.

8. Additional procedures for Faculty: 

1. The DDR will inform the faculty member’s department chair (or functional equivalent), about the accommodation request as necessary.

2. The DDR and department chair (or functional equivalent) and department administrator, if necessary, will meet to review the request as outlined in these procedures and also determine what information (if any) needs to be shared with the department’s executive committee.

3. The DDR will inform the employee and department chair (or functional equivalent) of the decision.

4. Faculty accommodation requests related to tenure clock extensions and post tenure review extensions must be approved and communicated in accordance with UW-807 Faculty Policies and Procedures Chapter 7 – Faculty Appointments.

1. The DDR must review documentation and, if applicable, write a letter of support for the faculty member's executive committee to consider when voting.

2. If the executive committee does not recommend granting a request for tenure clock extension or post tenure review extension, it must inform the DDR prior to notifying the faculty member of the decision, in which case:

1. 1. 1. The DDR must inform EDR; and

      2. The DDR and EDR will meet with the department chair (or functional equivalent) to discuss the decision from the accommodation perspective. 

6.  Interim Reasonable Accommodation

1. The DDR, in consultation with EDR, may conduct an individualized assessment and determine whether interim reasonable accommodation is available, absent undue hardship.  The university may offer interim reasonable accommodation as soon as possible when:

1. The interactive process is ongoing;

2. There is a sudden onset of a known limitation;

3. The employee requests the removal of an essential job function(s) because they think it is risky and/or unsafe for the employee to perform;

4. The employee is waiting for a medical appointment; or

5. The employee is waiting for an accommodation decision.

2. The DDR must consult with EDR when interim reasonable accommodation is not available.

3. Leave may be considered as an interim reasonable accommodation only if the employee requests leave as an accommodation, or if there is no other interim reasonable accommodation that does not cause undue hardship.

7. Informal Resolution

1. The employee or job applicant may contact EDR if they have questions, are concerned about the interactive process or the DDR (e.g., the DDR is their supervisor).

2. EDR will review the concern, accommodation request, limitations that are impacting access (including any previous or new medical documentation provided by the employee or job applicant), and the record of the interactive process.

3. Based upon this review, if appropriate, EDR may make recommendations to the DDR or others involved in the interactive process, regarding the employee or job applicant’s concern.  

8. Appeal Processes

Employees and job applicants may be directed to the Office of Compliance for appeals.