UMGC Policy VI-1.03 UMGC Policy on Workplace Pregnancy Accommodations

Purpose

The purpose of this Policy is to outline the University of Maryland Global Campus’s (UMGC) commitment and obligations under the Pregnant Workers Fairness Act (PWFA) and related federal and state laws. This Policy ensures that employees, job applicants, and candidates with known limitations related to pregnancy, childbirth, or related medical conditions are provided with reasonable accommodations, unless doing so would cause undue hardship to UMGC.

This Policy is intended to affirm UMGC’s commitment to nondiscrimination, equal access, and compliance with federal and state laws protecting individuals affected by pregnancy and related conditions. It is grounded in compliance with the PWFA, Title VII of the Civil Rights Act of 1964, as amended by the Pregnancy Discrimination Act of 1978, the Americans with Disabilities Act (ADA), and the Maryland Fair Employment Practices Act. Through this Policy, UMGC affirms its legal and ethical responsibility to create a fair, inclusive, and supportive workplace that protects the rights and well-being of individuals affected by pregnancy and related conditions.

Scope and Applicability

The purpose of this Policy is to establish a clear framework for providing reasonable accommodations to employees and applicants with known limitations related to pregnancy, childbirth, or related medical conditions. It ensures compliance with federal and state laws, including the Pregnant Workers Fairness Act (PWFA), and affirms UMGC’s commitment to fostering an inclusive and equitable workplace that protects the health, dignity, and equal opportunity of all individuals.

This Policy applies to all members of the University of Maryland Global Campus (UMGC) workforce, full-time, part-time, adjunct faculty, staff, temporary employees, and student workers, as well as applicants and candidates for employment. It is the responsibility of the individual or a designated support person to identify the employee as persons who are pregnant, post-pregnant, or trying to become pregnant when requesting accommodation. It is also the responsibility of the requesting individual to provide supporting documentation of their disability from a relevant credentialed professional that demonstrates how the disability affects their ability to perform the essential functions of their job or to participate in and benefit from UMGC programs, services, and/or activities. All supporting pregnancy-related documentation, as defined in Section III of this policy, will be kept confidential and separate from personnel records.

1. Employees: Applicants and Candidates who are pregnant, post-pregnant, or trying to become pregnant have the same obligation as all members of the community to meet and maintain UMGC’s job performance, technical standards, and codes of conduct.
2. Fundamental Alteration: A fundamental alteration is a change to a core job task or responsibility that significantly changes the essential function of the job.
3. Interactive Process: The interactive process is the ongoing, timely communication between the employee and the employer, or other UMGC personnel, for the express purpose of identifying and providing reasonable accommodation.
4. Known Limitation: A known limitation is a physical or mental condition related to, affected by, or arising out of pregnancy, childbirth, or related medical conditions that the employee or the employee’s representative has communicated to the employer, whether such condition meets the definition of disability.
5. Pregnancy or Related Conditions: Pregnancy or related conditions include, but are not limited to, pregnancy, childbirth, termination of pregnancy, or lactation; recovery from pregnancy.
6. Qualified Employee: A qualified employee is an employee or applicant who, with or without reasonable accommodation, can perform the essential functions of the employment position. An employee or applicant shall still be considered qualified if any inability to perform an essential function is for a temporary period, if the essential function could be performed in the near future, and if the inability to perform the essential function can be reasonably accommodated.
7. Reasonable Accommodations for Staff, Faculty, Job Applicants, and Job Candidates: Reasonable accommodations are any changes to a job, the work environment, or the way things are usually done that allow an individual with a pregnancy-related limitation to apply for a job, perform job functions, or enjoy equal access to benefits available to other individuals in the workplace. Accommodations must address the pregnancy-related limitation and may temporarily alter the employee’s essential job functions, provided they do not create an undue hardship.
8. Retaliation: Retaliation is any adverse action taken against an employee or applicant for requesting, using, or supporting another individual in seeking reasonable accommodation under this policy. Retaliation is strictly prohibited.
9. Support Person: A support person is an individual designated by the employee, such as a health care provider, advocate, or family member, who may assist in the interactive process or provide information regarding an employee’s known limitation.
10. Undue Hardship: Undue hardship means significant difficulty or expense incurred by UMGC in providing accommodation. This determination considers the nature and cost of the accommodation, the overall financial resources of UMGC, the impact on university operations, and other factors as defined by law.

Roles and Responsibilities

UMGC is committed to ensuring that employees, job applicants, and candidates with pregnancy-related limitations receive reasonable accommodations in compliance with PWFA and other applicable civil rights laws. UMGC and its representatives are required to engage in an interactive process with the individual to identify, assess, and implement appropriate accommodations.

The Employee Accommodations Manager, housed within the Office of Community Engagement and Opportunity, is responsible for evaluating requests, determining reasonable accommodations, and developing individualized Accommodation Plans. Approved accommodations are documented in an official Accommodation letter, which is retained in both the employee’s personnel file and in the Employee Accommodations unit’s records. All supporting medical or disability-related documentation is kept strictly confidential and maintained separately from personnel records in accordance with federal and state privacy requirements. To ensure compliance, UMGC has designated the Employee Accommodations Manager to coordinate and monitor the University’s adherence to federal, state, and local civil rights obligations.

For Pregnancy Accommodation Requests:
UMGC Employee Accommodations Manager
Office of Community Engagement and Opportunity
Administration Building
3501 University Boulevard East
800-888-8682 ext. 17930
employee-accommodations@umgc.edu

Policy Statement

UMGC is committed to creating and maintaining a welcoming and inclusive educational and working environment for people of all abilities. In accordance with PWFA and other applicable laws, UMGC affirms the principle that no qualified employee’s or applicant’s known limitations related to, affected by, or arising out of pregnancy, childbirth, or related medical conditions shall exclude them from participation in, or deny them the benefits of, the services, programs, or activities of UMGC, nor shall they be subjected to discrimination. Discrimination based on pregnancy is strictly prohibited, and the University strictly forbids retaliation against individuals for requesting, using, or asserting their rights under this Policy.

Enforcement

A complaint may be submitted by any employee who believes they have been denied reasonable accommodation related to pregnancy, childbirth, or a related medical condition at UMGC or through any vendor, partner, or service affiliated with the University.

If the matter involves the denial of reasonable accommodation, the individual may appeal the decision by submitting a written appeal to the ADA Compliance Officer. Complaints should be submitted, using the ADA complaint form, and sent to the ADA Compliance Officer at adacompliance@umgc.edu. The ADA Compliance Officer, or their designee, will review the appeal and provide a written response outlining the outcome and any further actions or remedies available.

UMGC ADA Officer
Email: adacompliance@umgc.edu
Phone: (301) 985-7930
UMGC Headquarters
3501 University Boulevard East
Administration Building
Adelphi, MD 20783

Office for Civil Rights (OCR)
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202-1100
Customer Service Hotline: (800) 421-3481
Facsimile: (202) 453-6012
TDD: (877) 521-2172
Email: OCR@ed.gov
Web: http://www.ed.gov/ocr

Equal Employment Opportunity Commission (EEOC)
301 W. Preston Str​eet,
Suite 607
Baltimore, MD 21201
Phone: 1-800-669-4000
Fax: 410-962-4270

Maryland Commission on Civil Rights (MCCR)
William Donald Schaefer Tower
6 Saint Paul Street, Ninth Floor
Baltimore, MD 21202-1631
Phone: 410-767-8600
Fax: 410-333-1841
TTY: 410-333-1737

The PWFA, which is administered and enforced by the EEOC, requires covered employers to provide reasonable accommodations to a worker’s known limitations related to pregnancy, childbirth, or related medical conditions, unless the accommodation will cause the employer an undue hardship.

1. UMGC Policy on Non-Discrimination and Anti-Harassment
2. UMGC Policy on Workplace Reasonable Accommodations
3. Americans with Disabilities Act (ADA)
4. The FMLA (Family and Medical Leave Act)
5. Title VII of the Civil Rights Act of 1964 (Title VII)
6. Pregnant Workers Fairness Act (PWFA)
7. Providing Urgent Maternal Protections for Nursing Mothers (PUMP) Act