Policy on Pregnancy, Parenting and Caregiving

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Policy Category: Executive 

Effective Date: 08/01/2021 

Responsible Officer: Executive Director of Equity and Compliance 

History: Updated 4.23.2024, Updated 9/26/2025 

Responsible Office: Office of Institutional Equity 

Location: Link

Purpose

This policy recognizes the rights of qualified students and employees with known limitations relating to pregnancy or childbirth; In furtherance of the university’s commitment to inclusion and access, this policy also provides a mechanism through which eligible caregivers may seek reasonable modifications.

Scope/Applicability 

This policy applies to all members of the Wentworth community, students, employees, and affiliates.

Legal 

  • Pregnant Workers Fairness Act
  • Title IX
  • Title VII  
  • Americans with Disabilities Act  

Policy 

Reasonable Accommodations: The university will provide reasonable accommodations to qualified students, employees, or applicants with known limitations relating to pregnancy or childbirth.  

Reasonable Modifications: The university will provide reasonable modifications to eligible caregivers with known limitations relating to caregiving  

Lactation: The university will provide parents reasonable breaks for the purpose of expressing breastmilk; the university will provide employees with access to a private lactation spaces, as defined, for the purpose of expressing breastmilk.  

Discrimination and Retaliation: The university prohibits discrimination on the basis of sex, which includes discrimination on the basis of a pregnancy or parenting. The University prohibits retaliation against individuals who exercise their rights under this policy and/or related laws.  

Definitions

Discrimination based on Pregnancy or Parenting: An intentional or unintentional act that adversely affects employment and/or educational opportunities that is related to pregnancy or childbirth. Discrimination may be classified as either disparate impact (facially neutral practices that fall more harshly on one  group  than  another and cannot be justified by business necessity) or disparate treatment (treatment of an individual that is less favorable than treatment of others based on discriminatory reasons).  

Eligible Caregiver: A qualified employee, student, or applicant who is:

  1. primarily responsible, either independently or jointly, for providing care to a child under the age of 12;
  2.  primarily responsible, either independently or jointly, for providing care to a family member with a disability who requires substantial support in carrying out major life activities necessary for independent living.  

Essential Functions: Fundamental duties of a position  

Interactive Process: The procedure through which the University works together with pregnant and parenting individuals and/or eligible caregivers for the purpose of identifying and coordinating reasonable accommodations and/or supportive measures. The Interactive Process includes a review of obstacles to access and a discussion of possible accommodations.

Known Limitation:

  • Known Limitation Related to Pregnancy or Childbirth: Physical or mental condition related to, affected by, or arising out of pregnancy, childbirth, or related medical conditions; Qualified individuals with known limitations related to Pregnancy or childbirth are eligible for reasonable accommodations.  
  • Known Limitations Related to Caregiving: Obstacles to access related to, affected by, or arising out of responsibilities relating to caregiving. Qualified individuals with known limitations related to caregiving are eligible for reasonable modifications.

Private Lactation Space: A location, other than a bathroom, for parents to use to express milk; the private lactation space shall be shielded from view and free from intrusion by coworkers and the public.

Qualified Individuals: Qualified employees and qualified students, as defined.  

  • Qualified Employee: an employee or applicant who, with or without reasonable accommodation, can perform the essential functions of the employment position
  • Qualified Student: student who, with or without reasonable accommodation, meets the academic and technical standards requisite to admission or participation in a university program  

Reasonable Accommodations and Modifications: Modifications or adjustments that enable a qualified employee, applicant, or student with a known limitation to enjoy equal benefits and privileges of employment or education, as applicable;  

Accommodations or modifications are not regarded as reasonable if they: 

  1. Are unduly extensive, substantial, or disruptive
  2. Would fundamentally alter the nature of a program, course, or activity;
  3. Would fundamentally alter the university’s mission; or
  4. Would compromise the health and safety of the university community

For employees, reasonable accommodations or modifications enable an employee to perform the essential functions of a job. Accommodations may include the provision of equipment or devices, job restructuring, modified work schedules, or removal of physical barriers from a work area. However, modifications that may impact students, including changes to student schedules and/or changes to the academic calendar, will not be reasonable.  

For students, reasonable accommodations or modifications enable a student to have an equal opportunity to access and use benefits, privileges, and services.  

Retaliation: Speech or conduct that targets an individual or group because of their participation in a procedure related to this policy, where such conduct adversely impacts participation in a university program or activity and/or terms or conditions of employment. 

Procedure(s)

Reasonable Accommodations or Modifications  

Submitting a Request

Students, employees, and applicants, may request a reasonable accommodation or modification through the Office of Institutional Equity (hereinafter “OIE), using the online request form.  

Upon receipt of a request for reasonable accommodation or modification, OIE will review the documentation, and schedule a meeting with the qualified individual to review the request.

Documentation

In limited circumstances, documentation may be required to support a request for accommodation or modification.  

Interactive Process 

OIE works collaboratively with the qualified individual and relevant campus partners to identify, explore, and implement reasonable accommodations or modifications.  

Communication of Request: For employees, OIE will communicate the request to the employee’s supervisor. For students, OIE will communicate the request to the faculty or staff member responsible for implementation of the accommodation.  

Exploration of Accommodations or Modifications: While the university considers the preference of the qualified individual when coordinating reasonable accommodations or modifications, the university may offer an alternative accommodation or modification, as long as the alternative is effective in mitigating the identified barrier to access. Requests will either be granted as submitted or explored further through an interactive process.  

Communication of Outcome: Upon completion of the interactive process, outcome of the process will be documented in writing. Documentation will include a summary of the request, the interactive process, and any approved accommodations/modifications. If it is determined that the request is not reasonable, OIE will provide an explanation for denial of the request.  

For employees, copies will be provided to the employee and the supervisor. For students, copies will be provided to the student and the faculty or staff member responsible for the implementation of the accommodation or modification.

Duration of Accommodations and/or Modifications  

Accommodations and modifications will be reviewed periodically. The university reserves the opportunity to revisit these accommodations, as necessary and appropriate, based on employee needs, university need, or other relevant factors.

Private Lactations Spaces

While individuals are not prohibited from breastfeeding in public spaces, the University will provide a room or other location where the parent can breastfeed or express milk in private.

Dedicated Lactation Spaces: Designated lactation rooms are available throughout campus, in each of the following locations:

Beatty Hall: The lactation room in Beatty Hall is located next to room 313, near the exit sign.

CEIS: The lactation room in CEIS is located next to room 315, near the group study lounge.

Wentworth Hall: The lactation room in Wentworth Hall is next to classroom 305.

Requesting Access to Lactation Spaces: Lactation rooms may remain locked to ensure their availability for parents who are breastfeeding. To gain access to lactation rooms, contact the Office of Institutional Equity. 

Discrimination and Retaliation

Discrimination: Discrimination based on Pregnancy or Parenting is a form of sex discrimination and is addressed pursuant to the University’s Non-Discrimination Policy. Employees may report discrimination using the online reporting form.  

Retaliation: Retaliation against an individual who exercises their rights under this policy is a form of discrimination an is addressed pursuant to the University’s’ Non-Discrimination Policy.  Employees may report discrimination using the online reporting form.

Additional Information & Related Documents  

Interpretation & Revision

Any questions of interpretation regarding this policy shall be referred to the Executive Director of Equity and Compliance. They will be the final authority regarding the interpretation of this policy.  

This policy shall be reviewed every three years; however, minor changes and updates can be made at any time.    

Wentworth will typically apply the policy in place at the time it receives a report concerning the respected policy.  

Review and Revision History  

This policy was drafted by representatives from Human Resources and The Office of Institutional Equity. This policy was reviewed by Cabinet and approved by the President on 08/01/2021 and updated on 9/26/2025.