HR & Workforce Policy Series
PWFA Response Checklist
for Christian Employers
A pregnancy-related accommodation request requires a careful, not automatic, response.
The Pregnant Workers Fairness Act generally requires covered employers with 15 or more employees to consider reasonable accommodations for known limitations related to pregnancy, childbirth, or related medical conditions, unless the accommodation would impose an undue hardship.
A request does not need to be written, mention the PWFA, or use the words "reasonable accommodation." When an employee communicates that a pregnancy-related condition is affecting work, the employer may already have a duty to respond.
Use this five-step checklist to begin the process.
Step 1
Recognize the Request
An employee may be requesting an accommodation when they say they need a workplace change because of pregnancy, childbirth, recovery, lactation, or a related physical or mental condition.
Examples may include requests for:
- Additional food, water, or restroom breaks
- A chair or permission to sit while working
- Schedule changes for medical appointments
- Temporary lifting or physical-work restrictions
- Changes to uniforms or safety equipment
- Telework or temporary reassignment
- Leave for childbirth, recovery, miscarriage, or related care
- A private space and appropriate break time to express breast milk
Do not require the employee to use a particular form or legal terminology before recognizing the request.
Step 2
Respond Without Promising an Outcome
Managers should acknowledge the request and promptly route it to the person responsible for accommodations.
Suggested Manager Response
"Thank you for letting me know. We take accommodation requests seriously. I'm going to share this with the appropriate person so we can review your request and follow up with you."
Managers should not approve, deny, debate, investigate, or express a personal opinion about the request.
Step 3
Begin an Individualized Review
There is no one-size-fits-all answer under the PWFA. The employer should communicate with the employee to understand:
- The workplace limitation
- The accommodation being requested
- How long the accommodation may be needed
- Which job duties are affected
- Whether another effective accommodation should be considered
An employer generally should not automatically deny a request because the employee cannot perform every current job duty. In some circumstances, temporarily suspending an essential function may need to be considered.
Employers also should not require an employee to take leave when another reasonable accommodation would allow the employee to continue working.
Step 4
Request Medical Information Only When Appropriate
Medical documentation is not required for every PWFA request. In some circumstances, the need for an accommodation will be obvious or already known.
When documentation is legally appropriate, request only the information reasonably necessary to evaluate the limitation and accommodation. Pregnancy-related medical information should be treated as confidential and maintained separately from ordinary personnel records.
Avoid requesting complete medical histories or unrelated health information.
Step 5
Document the Process and Protect the Employee
Maintain a clear record of:
- When and how the request was received
- The limitation and requested accommodation
- Communications with the employee
- Accommodations considered
- Any supporting information properly requested
- The decision and its legitimate basis
- The accommodation provided and any follow-up needed
Employees must not be penalized for requesting or using a reasonable accommodation. Closely review employment actions involving attendance, performance, scheduling, discipline, promotion, or termination while an accommodation request is pending or in effect.
Pause and Seek Guidance When
Additional review may be necessary when:
- The request presents a potential conflict with the organization's sincerely held religious beliefs
- The request involves an abortion-related service or accommodation
- The employee may be unable to perform an essential job function temporarily
- The requested accommodation may significantly disrupt operations or create substantial expense
- Medical documentation may be necessary
- Multiple federal, state, or local laws may apply
- The employee disputes the proposed accommodation
- An attorney, the EEOC, or another government agency contacts the employer
- The organization is considering denying the request
- The employer is uncertain about its legal obligations or CEA protections
Do not assume that a religious organization is entirely exempt from the PWFA. The application of religious protections and defenses depends on the employer, the position, the request, and the specific circumstances.
For CEA Members
Additional Protection and Tools for CEA Members
Qualifying CEA members may have additional protections arising from CEA litigation and related legal agreements. Those protections address specific government mandates and are not a substitute for properly handling each accommodation request.
Coverage is fact-specific and may depend on active, continuous membership and other eligibility requirements.
Members Have Access To:
- The expanded PWFA Member Response Checklist
- The CEA PWFA Response Playbook
- Manager intake and routing forms
- Medical-documentation decision rules
- Essential-function and undue-hardship worksheets
- Religious-liberty escalation guidance
- Model employee communications
- Counsel escalation and case-preparation tools
- Access to CEA's Trusted Counsel Network
Not Yet a CEA Member?
CEA equips Christian employers with practical workplace resources, legal protections, policy intelligence, and access to experienced counsel so they can lead faithfully and respond confidently when workplace mandates intersect with biblical convictions.
Explore CEA MembershipThis resource provides general educational information and does not constitute legal advice or create an attorney-client relationship. PWFA obligations may be affected by the facts of a request and by other federal, state, or local laws. Employers should consult qualified employment counsel before denying an accommodation or responding to a request involving a potential religious conflict.