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Pregnancy & Nursing Accommodation FAQs

Pregnancy accommodations, pumping breaks, and the federal rules that apply to Texas employers of nearly every size.

Last updated: July 03, 2026 • 10 answers in this category

The Pregnant Workers Fairness Act: what it changed for employers

Controlling authority: the Pregnant Workers Fairness Act, effective 27 June 2023, with the EEOC final regulation effective 18 June 2024. Covers employers with 15 or more employees, including state and local government.

The Pregnant Workers Fairness Act: what it changed for employers U.S. Equal Employment Opportunity Commission, What You Should Know About the PWFA. Effective 27 June 2023; final regulation effective 18 June 2024. Table by Faulkner HR Solutions.
ProvisionThe ruleWhy it matters
Covered employers15 or more employees, private and state or local governmentSame threshold as the ADA, different trigger.
What triggers itA known limitation — the employee has communicated itThe limitation may be minor, modest or episodic: morning sickness, migraines, needing a water bottle.
“Qualified” — first routeCan perform the essential functions with or without accommodationThe ordinary route.
“Qualified” — second routeCannot perform essential functions, but the inability is temporary, they could perform in the near future, and it can be reasonably accommodatedThis is new. Temporary suspension of an essential function can itself be the accommodation.
Forcing leaveProhibited where another reasonable accommodation would let the employee keep workingSending a pregnant employee home on leave is often the unlawful option, not the safe one.
Imposed accommodationsMay not require the employee to accept an accommodation not reached through the interactive processThe process itself is mandatory.
Related medical conditionsIncludes lactation, miscarriage, postpartum depression, edema, placenta previa, and recovery from deliveryReaches well beyond an active pregnancy.

When you may not ask for medical documentation

When a Texas employer may not ask for medical documentation under the PWFA U.S. Equal Employment Opportunity Commission, PWFA guidance. Table by Faulkner HR Solutions.
SituationAsk for documentation?Detail
The limitation and the need are obviousNoAn obviously pregnant employee asking for a larger uniform cannot be made to prove it.
The employer already knows the limitation and the needNoYou cannot demand a fresh note each time an existing accommodation is used.
Currently pregnant, and needs the bathroom, food, water, or to sit or standNoThese four predictable needs are carved out expressly.
Lactating, and needs modifications to pump or nurseNoAlso carved out.
You would not normally ask in that situationNoIf your policy only requires a note after three consecutive days, you cannot demand one for a single day.
OtherwiseYes, but narrowlyLimited to confirming the condition, confirming it relates to pregnancy, and describing the change needed. You may never require examination by a provider you select.
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ADA Accommodation Risk Checker

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Curated and reviewed by Dr. Thomas W. Faulkner, DBA, MBA, MSML, SPHR, LSSBB, principal consultant at Faulkner HR Solutions.