Procedure for Reasonable Accommodations for Employees with Work Limitations related to Pregnancy, Childbirth, or Related Medical Condition

I. Purpose

This policy provides the College with authority to grant reasonable accommodations for pregnancy and pregnancy-related conditions.

The College supports faculty and staff as they balance family, professional and academic responsibilities. This policy provides a framework for possible accommodations to qualified pregnant and postpartum workers. These rights are also in accordance with the Family and Medical Leave Act of 1993 (FMLA), the Pregnancy Discrimination Act, the Pregnant Workers Fairness Act (PWFA), and the Providing Urgent Maternal Protections for Nursing Mothers Act (PUMP Act).

Henry Ford College extends reasonable workplace accommodations to employees with work limitations related to pregnancy, childbirth, or related medical conditions (“Covered Employees”). Covered Employees seeking accommodations should contact Human Resources to engage in an interactive process designed to ascertain reasonable accommodations that do not create an undue hardship for the College. A review of the essential functions of the employee’s position may be undertaken in assessing the requested temporary accommodations.

II. What is a Reasonable Accommodation?
The College’s policy on Reasonable Accommodations for Employees with Work Limitations related to Pregnancy, Childbirth, or Related Medical Conditions provides detailed information defining and providing examples of reasonable accommodations. In summary, a reasonable accommodation is a modification or adjustment that allows a covered employee to perform the essential functions of their position.

III. Requesting a Reasonable Accommodation
1. Contact Human Resources
2. Explain the difficulties you may be experiencing to fulfill the essential functions of your position.
3. Provide ideas, if you have them, for what could help you be successful in completing the essential functions of your position during this temporary time due to a physical or mental condition related to your pregnancy, childbirth, or related medical condition.

IV. Employee Interactive Process
Human Resources, in collaboration with the employee’s department leadership, will engage in a good-faith interactive discussion with the employee about the employee’s specific temporary needs and the employee’s requested accommodation that could meet those needs. The interactive process is a critical step to determine the needs of the employee so they can continue to be successful at their job during this temporary accommodation.
1. The employee must notify Human Resources of their needs.
2. The employee and Human Resources will engage in the interactive process to discuss the employee’s needs and how those needs can be accommodated.
3. File a claim with Henry Ford College’s 3rd party administrator.
4. Depending on the request, the employee may be asked for medical documentation.
5. Human Resources will collaborate with the employee’s supervisor to discuss the temporary need of the employee’s request.
6. Human Resources will advise the employee of the decision of the accommodation request both verbally and in writing.
7. Human Resources will periodically follow up with the employee and the supervisor to determine the effectiveness of the accommodation and if any modifications need to be addressed to maintain continued success.

V. Accommodation Decisions
Accommodation decisions can be revisited at any time by the employee or employer to ensure the employee’s needs as well as the college’s needs are being met. It is the intention of the college to explore all reasonable accommodation requests without undue hardship specifically if medical needs change or additional information is provided to make any changes. The interactive process is an ongoing discussion between the employee and the employer.

VI. Definitions:

Conditions related to pregnancy – can be during or after pregnancy. Examples include, but are not limited to, morning sickness and lactation.

Reasonable Accommodation – a modification or adjustment that allows a Covered Employee to perform the essential functions of their position. Examples may include, without limitation, a modified work schedule; more frequent or longer paid or unpaid breaks; time off, with or without pay, to attend to a pregnancy-related complication; providing equipment or seating; private space for expressing breast milk; and assistance with manual labor.

Undue Hardship – an action requiring significant difficulty or expense by the College.

VII. Related Documents
Reasonable Accommodations for Employees with work Limitations related to Pregnancy, Childbirth, or Related Medical Conditions (need link)
Employee Handbook
HFC Bylaws | HFC Policies (hfcc.edu)
Pregnant Workers Fairness Act (PWFA) PWFA Infographic (eeoc.gov)
Providing Urgent Maternal Protections for Nursing Mothers Act (PUMP Act)
Frequently Asked Questions – Pumping Breast Milk at Work | U.S. Department of Labor (dol.gov)

VIII. History
Current Procedure adopted: May 9, 2024

This procedure supersedes and replaces all procedures related to this subject