The PWFA expects the same interactive process as the ADA, and offering leave as the only option does not satisfy it. In EEOC v. Urological Specialists of Oklahoma, a medical practice agreed to a four-year consent decree and $90,000 after allegedly pushing a pregnant employee onto unpaid leave instead of granting simple accommodations. ComPsych’s ADA Coach Sara Bilodeau walks through the case below.
What happened
According to the EEOC’s complaint, the practice has five clinics and about two dozen physicians across Oklahoma, Arkansas, and Missouri. In 2023, a medical assistant in the final trimester of a high-risk pregnancy asked for accommodations her doctor recommended: the ability to sit periodically, short breaks, and part-time work if available.
The EEOC alleges the practice placed her on unpaid leave instead. About a month after she gave birth, she was ready to return, but the practice would not guarantee her job or her lactation breaks. When she said she would not come back without guaranteed breaks, the practice terminated her employment. The EEOC also alleged that the HR director said he did not know what the PWFA was.
The EEOC brought claims under both the Pregnant Workers Fairness Act and the ADA.
How it resolved
Before filing suit, the EEOC proposed a conciliation agreement that included roughly $47,000 in damages, EEOC review of future accommodation requests, revised policies, training, and quarterly reporting. The parties did not settle, and the EEOC filed suit in September 2024.
In February 2026, a federal judge approved a consent decree with $90,000 in monetary relief, nearly double the earlier proposal. Over the four-year term, the practice must designate personnel responsible for PWFA and ADA compliance, adopt written accommodation procedures, train supervisors and employees, log every accommodation request in a tracking system, and report periodically to the EEOC.
Key takeaways for employers
- Treat the PWFA like the ADA. The interactive process is required, and if you cannot grant a specific, reasonable request, document a good faith reason such as undue hardship.
- The PWFA bars requiring leave when another reasonable accommodation would work. If your default response to a pregnancy accommodation request is leave, update that policy.
- Lactation accommodations remain part of the obligation after the baby is born.
- Training needs to reach the HR professionals who field these requests every day, not just general counsel.
- Build the infrastructure before you need it. Notice postings, a tracking system, and a designated compliance contact are what the EEOC required here after the fact.
An important caveat: This case resolved by consent decree, so there was no ruling on the merits and the facts above are allegations from the EEOC’s complaint. A consent decree is not precedent. It does show what the EEOC expects from employers, and the jump from the pre-suit offer to the final settlement shows that declining to resolve a matter early rarely lowers the cost.
Received a pregnancy or disability accommodation request you are unsure about? Reach out to your ADA coach before making a decision.
