Manager Responsibilities - Reasonable Accommodation Tips
Notice concerning the Pregnant Workers Fairness Act of 2022
This document was issued prior to enactment of the Pregnant Workers Fairness Act (PWFA), which took effect on June 27, 2023. The PWFA expands the rights of workers affected by pregnancy, childbirth, or related medical conditions to receive reasonable accommodations, absent undue hardship. To learn about protections under the PWFA, visit What You Should Know About the Pregnant Workers Fairness Act.
The laws enforced by the EEOC require employers to provide reasonable accommodations (changes to the way things are normally done at work) because of an employee's disability or religious beliefs, in certain circumstances.*
Ensuring that managers understand their reasonable accommodation responsibilities may help prevent disability discrimination and religious discrimination.
You may decide to designate one person, or a small group of people, to handle reasonable accommodation requests. If so, ensure that this person or group of people understands:
- Your business's rules and policies regarding reasonable accommodation;
- How to recognize a request for a disability accommodation or a religious accommodation;
- How to respond to a disability accommodation or religious accommodation request;
- The circumstances under which they may request additional medical or religious information or documentation, if needed to establish whether the individual's medical condition or religious beliefs are protected by law, or to determine whether and what type(s) of accommodation might be effective;
- The importance of responding promptly and effectively to accommodation requests;
- The importance of keeping requests for disability accommodation confidential; and
- The importance of keeping any medical information obtained as a result of a reasonable accommodation request confidential and in a separate medical file.
Managers who are not designated to handle reasonable accommodation requests also have responsibilities. In particular, ensure that they understand:
- Your business's rules and policies regarding reasonable accommodation;
- How to recognize a request for a disability accommodation or a religious accommodation ;
- Who to contact if they receive a disability accommodation or religious accommodation request;
- The importance of keeping requests for disability accommodation confidential;
- The fact that there are strict rules about when employers may legally request medical information from applicants or employees; and
- The importance of keeping any medical information obtained as a result of a reasonable accommodation request confidential and in a separate medical file.
* Federal, state and local laws may require you to provide reasonable accommodations for other reasons. Federal, state and local government websites may have additional information about these laws.
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