Pregnancy Accommodations at Work: What Oklahoma Law Requires

In February 2026, Urologic Specialists of Oklahoma, Inc. agreed to pay $90,000 to settle a federal pregnancy discrimination lawsuit brought by the EEOC. According to the EEOC's complaint, a medical assistant at the practice's Tulsa facility entered the final trimester of a high-risk pregnancy in 2023. Her doctor recommended she be allowed to sit, take short breaks, and work part-time. Rather than provide those accommodations, the EEOC alleged, the practice forced her onto unpaid leave, refused to guarantee her job when she returned, and refused to guarantee breaks for expressing breast milk. When the assistant said she couldn't return without those guaranteed breaks, Urologic Specialists fired her.

The settlement in EEOC v. Urologic Specialists of Oklahoma, Inc. (Case No. 24-cv-00452-JFJ, N.D. Okla.) resolved the case without an admission of liability, but the allegations themselves illustrate a pattern that employment attorneys see constantly — employers who treat pregnancy accommodations as optional favors rather than legal obligations. If you're pregnant and your employer is refusing to modify your working conditions, denying break time, or pressuring you onto unpaid leave, you have rights that didn't exist three years ago.

The Pregnant Workers Fairness Act: A Fundamental Shift

Before June 27, 2023, pregnant workers relied on a patchwork of imperfect protections. The Pregnancy Discrimination Act (PDA), an amendment to Title VII (42 U.S.C. § 2000e(k)), required only equal treatment — employers had to treat pregnant employees the same as other employees similar in their ability or inability to work. That meant if an employer offered light duty to a worker recovering from knee surgery, it had to offer light duty to a pregnant worker with similar physical limitations. But if the employer offered light duty to nobody, pregnant workers were out of luck.

The Pregnant Workers Fairness Act (42 U.S.C. § 2000gg) changed the framework entirely. Instead of equal treatment, the PWFA requires affirmative accommodation. Employers with 15 or more employees must now provide reasonable accommodations for known limitations related to pregnancy, childbirth, or related medical conditions — regardless of whether they accommodate anyone else. The comparison game is over. If you have a pregnancy-related limitation and a reasonable accommodation exists, your employer must provide it unless they can demonstrate undue hardship.

This distinction matters enormously in practice. Under the old PDA framework, a case like the one the EEOC brought against Urologic Specialists might have been harder to win — the employer could have argued it didn't provide sitting breaks or part-time schedules to any employee with temporary medical conditions. Under the PWFA, that argument is irrelevant. The question is simply whether the accommodations were reasonable and whether the employer engaged in the required interactive process.

What Accommodations Must Employers Provide?

The PWFA's final regulations, issued by the EEOC in April 2024 and effective June 18, 2024, provide extensive guidance on what constitutes a reasonable accommodation for pregnancy-related limitations. The accommodations are deliberately broad because pregnancy affects workers differently, and rigid categories would leave gaps.

Common reasonable accommodations include allowing the employee to sit while performing tasks that don't require standing, providing more frequent or longer breaks for rest, hydration, or bathroom use, modifying work schedules to accommodate prenatal appointments or fatigue, temporarily reassigning the employee to a less physically demanding position, providing closer parking, allowing additional break time to eat or drink, permitting telework when the job duties allow it, and providing time off for recovery from childbirth. According to the EEOC, the Urologic Specialists case involved three of the most basic accommodations on this list — sitting, short breaks, and a modified schedule — none of which the practice provided.

Critically, the PWFA establishes that an employer cannot require an employee to take paid or unpaid leave if another reasonable accommodation would allow the employee to keep working. This provision directly addresses the type of conduct alleged in the Urologic Specialists case, where the EEOC said the practice forced the medical assistant onto unpaid leave rather than accommodating basic physical limitations. If a pregnant employee can perform her essential job functions with a reasonable modification — say, a stool to sit on between patients — the employer cannot sidestep its obligations by placing her on leave instead.

The only defense an employer has for refusing a reasonable accommodation is undue hardship — a showing that the accommodation would impose significant difficulty or expense relative to the employer's size, financial resources, and the nature of its operations. For a medical practice operating five clinics with two dozen physicians, providing a chair and periodic breaks does not remotely approach undue hardship. That's why the EEOC pursued this case, and that's why it settled for $90,000 plus sweeping injunctive relief.

The Interactive Process: What Employers Must Do

When a pregnant employee requests an accommodation — or when the employer becomes aware of a pregnancy-related limitation that might require one — the PWFA requires both sides to engage in an interactive process. This is a genuine, good-faith dialogue aimed at identifying an accommodation that works. The framework mirrors the ADA's interactive process for disability accommodations, and courts are likely to apply the same principles.

The process starts when the employee communicates her need. She doesn't need to use the words "reasonable accommodation" or cite the PWFA — plain language is sufficient. Telling a supervisor "my doctor says I need to sit during my shifts because of my pregnancy" is enough to trigger the employer's obligations. Once triggered, the employer must respond promptly and meaningfully, discuss the specific limitations, explore potential accommodations, and implement a solution that is effective.

What matters legally is whether the employer genuinely tried. An employer who takes the request, sits on it for weeks, demands excessive documentation, and then denies it without explanation has failed the interactive process even if it never explicitly says "no." Bureaucratic delay and stonewalling are violations. The EEOC alleged a similar pattern at Urologic Specialists — that the practice denied the requested accommodations without genuine exploration of alternatives.

Employees have obligations too. You should provide medical documentation when reasonably requested, communicate clearly about what limitations you face and what would help, and be willing to consider alternative accommodations if your first choice isn't feasible. But the burden of finding a workable solution falls primarily on the employer, and the employer cannot simply ignore the request or default to unpaid leave.

Breastfeeding and Lactation Protections

The Urologic Specialists case highlights an aspect of pregnancy accommodation law that many employers still ignore: lactation and breastfeeding protections. According to the EEOC's complaint, the practice refused to guarantee breaks for expressing breast milk — and when the employee said she couldn't return to work without them, Urologic Specialists fired her.

Two federal laws now protect lactation rights in the workplace. The PUMP for Nursing Mothers Act, signed into law in December 2022, requires employers to provide reasonable break time for employees to express breast milk for a nursing child for up to one year after the child's birth. (The law's enforcement provision — the right to file a lawsuit — took effect on April 28, 2023.) The employer must also provide a place, other than a bathroom, that is shielded from view and free from intrusion. The PWFA separately recognizes lactation as a pregnancy-related condition eligible for reasonable accommodations under the interactive process.

Together, these statutes make it clear that an employer who refuses to provide pumping breaks — or who retaliates against an employee for requesting them — violates federal law. The EEOC's allegations against Urologic Specialists illustrate the pattern: the complaint alleged the practice denied accommodations during pregnancy, refused to guarantee post-pregnancy lactation breaks, and then terminated the employee when she insisted on them.

How This Intersects with FMLA and the ADA

Pregnant employees often have overlapping protections under multiple statutes, and understanding how they interact is critical.

The Family and Medical Leave Act provides up to 12 weeks of unpaid, job-protected leave for pregnancy and bonding — but only for employees who have worked at least 12 months and 1,250 hours for an employer with 50 or more employees within 75 miles. The PWFA's coverage is broader: it applies to employers with just 15 employees and has no service-length requirement. For employees at smaller companies or those who haven't yet accumulated a year of service, the PWFA may be the only source of workplace protections. For a detailed breakdown of FMLA rights in Oklahoma, see our comprehensive guide.

The Americans with Disabilities Act covers pregnancy-related conditions that rise to the level of a disability — such as gestational diabetes, preeclampsia, or severe hyperemesis gravidarum. Uncomplicated pregnancy alone is generally not a disability under the ADA. The PWFA fills this gap by requiring accommodations for pregnancy-related limitations whether or not they constitute a disability. If your pregnancy involves a complication that qualifies as a disability, you may have claims under both the ADA and the PWFA.

The practical takeaway: if you need accommodations during pregnancy, you may be protected by one, two, or all three of these statutes simultaneously. An employer who violates any of them faces separate liability under each. In the Urologic Specialists case, the EEOC brought claims under both the PWFA and the ADA, broadening the settlement value and the scope of required relief.

What to Do When Your Employer Refuses Accommodations

If your employer denies a pregnancy accommodation, fails to engage in the interactive process, or retaliates against you for requesting one, several steps can protect your legal position.

First, put every request in writing. Even if you initially made the request verbally, follow up with an email that memorializes what you asked for, what your doctor recommended, and what the employer's response was. Written documentation is the foundation of every successful employment discrimination case. If your employer responds verbally — especially with a denial — send a follow-up email confirming what was said: "Per our conversation today, you stated that you're unable to provide the part-time schedule my doctor recommended. Please let me know if I've misunderstood your position."

Second, keep copies of your medical documentation. Retain records of every doctor's note, every accommodation recommendation, and every form your employer asks you to complete. Forward copies to a personal email account or print hard copies. If you're terminated and lose access to your work systems, evidence on company servers may become inaccessible.

Third, file an EEOC charge within 300 days. Before you can file a PWFA lawsuit, you must file a charge of discrimination with the EEOC. In Oklahoma, the deadline is 300 days from the discriminatory act — and this deadline is strictly enforced. After the EEOC investigates, you receive a right-to-sue letter providing 90 days to file in federal court. For a step-by-step guide to the filing process, see our article on filing an EEOC charge in Oklahoma.

Fourth, consult an employment attorney before taking irreversible steps. The strategic decisions you make early — whether to resign, how to frame an internal complaint, whether to accept a severance offer — can determine whether your case is strong or weak. If your employer is building a pretextual case for termination, an attorney can help you recognize the pattern and build your record while you're still employed.

Lessons from the Urologic Specialists Settlement

The consent decree settling EEOC v. Urologic Specialists of Oklahoma didn't just require a $90,000 payment to the former employee. It imposed four years of oversight requiring the practice to designate personnel responsible for PWFA and ADA compliance, adopt formal policies and procedures for handling accommodation requests, train all supervisors and employees on pregnancy and disability accommodation rights, implement a tracking system for all accommodation requests, post notices informing employees of their right to be free from pregnancy and disability discrimination, and report periodically to the EEOC.

As the EEOC's lead trial attorney noted in announcing the settlement, the PWFA's requirements are "simple and fair," and the policies required by the decree should serve as "a model that all employers should follow." The message is clear: employers who deny basic pregnancy accommodations won't just face monetary damages. They'll face years of federal oversight and mandatory institutional changes.

For Oklahoma employees, the case reinforces that the PWFA is being actively enforced — and that the EEOC is pursuing cases even when the accommodations at issue are as basic as allowing a pregnant worker to sit down.

Frequently Asked Questions

What is the Pregnant Workers Fairness Act?

The PWFA is a federal law, effective since June 27, 2023, that requires employers with 15 or more employees to provide reasonable accommodations for known limitations related to pregnancy, childbirth, or related medical conditions. Unlike the older Pregnancy Discrimination Act, which only required equal treatment, the PWFA requires employers to affirmatively accommodate pregnant workers — similar to the ADA's framework for disability accommodations.

What kind of accommodations can I request under the PWFA?

You can request any modification that helps you perform your job while managing a pregnancy-related limitation. Common examples include sitting instead of standing, more frequent breaks, modified schedules, temporary reassignment to lighter duties, time off for prenatal appointments, telework arrangements, and breaks for expressing breast milk. The specific accommodation depends on your job and your medical needs, and your employer must engage in the interactive process to find an effective solution.

Can my employer force me to take unpaid leave instead of accommodating me?

No. The PWFA specifically provides that an employer cannot require an employee to take paid or unpaid leave if another reasonable accommodation would allow the employee to continue working. This was a central allegation in the Urologic Specialists case — according to the EEOC, the practice forced the medical assistant onto unpaid leave rather than providing basic accommodations like a chair and short breaks. That type of conduct violates the PWFA.

Does the PWFA apply if my pregnancy is uncomplicated?

Yes. The PWFA covers limitations related to pregnancy, childbirth, and related medical conditions regardless of whether the condition rises to the level of a disability under the ADA. Even common pregnancy symptoms like fatigue, morning sickness, or the need for more frequent bathroom breaks can qualify for reasonable accommodations under the PWFA.

How long do I have to file a pregnancy accommodation claim?

You must file a charge with the EEOC within 300 days of the discriminatory act in Oklahoma. After the EEOC completes its investigation or issues a right-to-sue letter, you have 90 days to file a lawsuit in federal court. These deadlines are strictly enforced and cannot be extended — do not delay.

What if I was fired for requesting pregnancy accommodations?

Termination in retaliation for requesting pregnancy accommodations violates the PWFA, and may also violate the ADA, the PDA, and the Oklahoma Anti-Discrimination Act (25 O.S. § 1101). You should document the timeline between your accommodation request and termination, preserve all evidence, and file an EEOC charge within 300 days. Retaliation claims are often the strongest component of pregnancy accommodation cases because the cause-and-effect timeline is difficult for employers to explain away.

Do small employers have to comply with the PWFA?

The PWFA applies to employers with 15 or more employees. If your employer has fewer than 15 employees, the PWFA does not apply — but you may still have protections under Oklahoma state law or other federal statutes depending on your specific circumstances.

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The Urologic Specialists settlement is a reminder that pregnancy accommodation law has teeth — and that Oklahoma employees have more protections today than at any point in the history of employment law. If your employer is denying reasonable accommodations, forcing you onto unpaid leave, or retaliating against you for asserting your rights, contact Addison Law for a consultation. The earlier you document what's happening and seek guidance, the stronger your case becomes.

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This article is for general information only and is not legal advice.