✍️ Article

PWFA Accommodation Request: What to Document From Request to Implementation

Under the Pregnant Workers Fairness Act, the most useful personal record is not just a copy of the first request. It is the entire request → discussion → decision → implementation → follow-up timeline.

The free PWFA Pregnancy Accommodation Request & Process Log is built around that complete workflow.

What starts the process?

EEOC guidance explains that a worker does not need magic legal words. The worker needs to communicate that there is a limitation related to pregnancy, childbirth or a related medical condition and that an adjustment or change at work is needed because of it.

Record:

  • date you first raised the need;
  • person you told;
  • limitation described;
  • adjustment requested;
  • whether the request was oral, email, message or form;
  • any immediate temporary measure offered.

Track the interactive process, not only the final answer

EEOC describes the interactive process as communication between worker and employer about the known limitation and needed adjustment.

Create a log entry every time something meaningful happens:

  • supervisor conversation;
  • HR email;
  • documentation request;
  • proposed alternative accommodation;
  • delay explanation;
  • approval or denial;
  • implementation date;
  • follow-up after trying the accommodation.

A timeline makes it much easier to distinguish “still discussing” from “nothing happened for three weeks.”

Record alternatives separately

An employer may provide a different effective accommodation rather than the exact one requested, depending on the circumstances.

For each alternative, record:

Field Why it matters
Proposed accommodation What the employer offered
Date proposed Shows timing
Effective? Whether it actually addresses the limitation
Trial start/end Useful for temporary arrangements
Problems observed Documents implementation issues
Follow-up requested Keeps the process moving

The GentleTools PWFA log lets you compare the requested accommodation with employer alternatives instead of overwriting one with the other.

Documentation requests are not automatic in every situation

EEOC guidance identifies circumstances where requesting supporting documentation is not reasonable, including certain obvious or already-known limitations and several common pregnancy-related needs.

The tool therefore records what documentation was requested and when, but does not tell you that every request is valid or invalid.

Measure implementation quality

Approval on paper is not the end of the story.

Track each use as:

  • provided as agreed;
  • partially provided;
  • delayed;
  • unavailable;
  • substituted;
  • not needed that day.

That converts “this accommodation isn’t working” into a dated pattern.

FAQ

Do I have to say “PWFA” when requesting accommodation?

EEOC guidance says workers do not need to use specific legal words. They need to communicate the limitation and need for a work adjustment.

Is every employer covered?

Coverage and exceptions are legal questions. The tool is a record system, not an eligibility determination.

Does GentleTools contact my employer?

No. Nothing is sent. The record stays in your browser unless you export it yourself.

Use the PWFA Pregnancy Accommodation Request & Process Log to preserve the full process instead of only the first email.