Student Pregnancy and Related Conditions

1. Policy

1. The policy currently addresses students who are pregnant or experiencing related conditions but does not explicitly consider students affected by another person’s pregnancy, such as partners or adoptive parents. Clarifying whether and how the policy applies in these situations may improve clarity and inclusiveness.

2. References

1. n/a

3. Definitions

1. 3.B. Consider revising the definition for clarity. The definition begins with “treating someone differently” and then uses “i.e.” to narrow that phrase to conduct that disadvantages an individual. This construction may be confusing, as differential treatment does not always rise to the level of adverse or discriminatory conduct. Clarifying the standard at the outset may improve readability and precision. Additionally, the current inline numbering makes the definition more difficult to follow.
2. 3.B. Consider moving the illustrative examples out of the definition and into the substantive procedure section. The definition may be clearer and more effective if it focuses on defining discrimination itself, while the procedure explains the types of facts or conduct that may support a complaint or investigation.
3. 3.G. The definition of retaliation currently references only “sexual harassment.” Consider revising this provision to also expressly include retaliation related to sex based discrimination more broadly, consistent with the scope of this policy and the Personnel Definitions. Expanding the language in this section would help ensure internal consistency and avoid unintended gaps in coverage.

4. Procedures

1. 4.A. Consider adding language to clarify that, while students are not required to disclose a pregnancy or related condition, a student seeking reasonable accommodations must disclose sufficient information to allow the Office of Accessibility & Disability Services (ADS) to assess, coordinate, and implement the requested accommodation. Perhaps consider: “A student requesting reasonable accommodations is expected to provide sufficient information for ADS to engage in the interactive process and coordinate appropriate accommodations.” This clarification may help set appropriate expectations for both students and employees.
2. 4.B. The prohibition on employees “informally provid[ing] accommodations” could benefit from further clarification. As drafted, this language may be read to discourage faculty or staff from exercising ordinary academic judgment or providing generally available flexibility (e.g., routine deadline extensions or attendance discretion). Consider adding language that distinguishes between (1) generally available academic flexibility that faculty may provide at their discretion and (2) pregnancy or condition related accommodations that must be requested and coordinated through ADS. This clarification may help prevent unintended chilling effects while preserving ADS’s role in coordinating formal accommodations. Consider adding a sentence to 4.B.2. stating “This provision does not prohibit faculty or staff from applying generally available academic flexibility or classroom practices that are offered to students broadly; however, pregnancy or condition related accommodations requiring modification of policies or expectations must be coordinated through ADS.”
3. 4.C.1. Consider revising “should contact ADS” to “must contact ADS” when a student is requesting an accommodation or academic adjustment based on pregnancy or a related condition. This change would reinforce that ADS is the designated office responsible for coordinating accommodations and clarify that accommodations require an affirmative request through ADS.
4. 4.C.2. Consider clarifying the role of faculty or staff in the interactive process, particularly in circumstances where a proposed accommodation may implicate essential course or program requirements, safety standards, or whether the accommodation would constitute a fundamental alteration. Additional guidance on when and how faculty or program leadership should be consulted could help ensure consistent and informed decision making.
5. 4.C.2. Additionally, consider addressing how disagreements are resolved if ADS and a faculty or staff member do not agree on whether a proposed accommodation is reasonable or would fundamentally alter a course or program. While the draft describes the interactive process, it does not identify a clear mechanism for resolving an impasse, which could lead to uncertainty or inconsistent outcomes.
6. 4.C.4. Consider clarifying the process by which a student accepts or declines an offered accommodation. For example, if a student informs a faculty member that they do not wish to use an approved accommodation for a particular exam, assignment, or course activity, it is unclear whether that decision constitutes a formal declination or whether acceptance or declination must be communicated to ADS. Clarifying whether accommodations are accepted or declined on a global or case by case basis, and how that decision should be documented or communicated, may help prevent confusion and ensure consistent implementation.
7. 4.C.5. The list of examples of reasonable accommodations may be helpful to students by illustrating the types of accommodations that may be available. However, including a detailed example list in this procedure could create inconsistency with the Student ADA Access and Reasonable Accommodations Policy if that policy does not contain a comparable list. Consider aligning the two policies or clarifying that the list is non exhaustive and intended solely for illustrative purposes.
8. 4.C.6. Consider adding a hyperlink to the Student ADA Access and Reasonable Accommodations Policy where the appeal process is referenced. Providing a direct link would make it easier for students to locate the applicable appeal procedures and promote clarity and consistency across related policies.
9. 4.D. Consider revising the terminology used in this section. The phrase “leave of absence” is commonly associated with employment and may not align with student facing terminology or processes related to enrollment changes. Depending on the circumstances, students may instead encounter withdrawal, medical withdrawal, incompletes, deferred admission, or other enrollment mechanisms.
10. 4.D. Consider using terminology that more closely matches existing student forms, processes, and enrollment classifications, or clarifying that “leave of absence” is an overarching term that includes relevant enrollment changes such as withdrawal, incompletes, deferrals, or other approved changes. This clarification may help reduce confusion and improve alignment with current student processes.
11. 4.D. Additionally, consider clarifying how the return to status language operates in practice. While the phrase “to the extent practicable and consistent with other college policies and program requirements” is helpful, returning a student to the same academic and extracurricular status may not always be possible due to factors such as program closures, teach out arrangements, catalog changes, selective or cohort based programs, or the passage of time affecting the applicability of prior coursework. Additional guidance on how such situations are handled may improve clarity and manage expectations.
12. 4.F.1. Consider expanding the listed options for consulting with the Title IX Coordinator to expressly include video conferencing or other virtual meeting options. Including these modalities would improve accessibility and flexibility for students who may be unable to meet in person due to pregnancy related conditions or other barriers.
13. 4.F.3.c.(5). Consider whether the 30 calendar day investigation timeline adequately accounts for circumstances in which a key faculty or staff member is unavailable, such as an adjunct who is off contract or a faculty member who is unavailable during summer or intersession periods. Clarifying whether and how the timeline may be extended for good cause in these situations may help ensure investigations are both thorough and fair while maintaining compliance with procedural timelines.
14. 4.F.3.e. Consider including “involved faculty” to this list of recipients.
15. 4.F.4.d. The language stating that the Vice President shall forward the appeal to “any other party” is unclear and raises questions about who is intended to receive the appeal. Consider revising this language to “any other involved party” or otherwise identifying the intended recipients more specifically. Clarifying this provision would help ensure transparency and consistent administration of the appeal process.