EEOC May Narrow Pregnancy Protections for Veterinary Teams

Has the EEOC changed the PWFA?

As of Nov. 3, 2026, the U.S. Equal Employment Opportunity Commission (EEOC) had not finalized revisions to the Pregnant Workers Fairness Act (PWFA), and current federal protections remained in effect.

A Nov. 2 report in The New York Times said the EEOC is preparing to revise the regulations, potentially narrowing which medical conditions qualify for workplace accommodations. The reported proposal could affect explicit protections for fertility treatment, abortion-related care, and other reproductive health conditions.

The EEOC's regulatory agenda anticipates a proposed rule in November 2026, with public comment expected to extend into January 2027. That is a planned proposal, not an adopted change.

Takeaway: Employers should continue following current rules.

What does the PWFA require now?

The PWFA took effect in June 2023 and generally requires employers with at least 15 employees to provide reasonable accommodations for qualified workers experiencing limitations related to pregnancy, childbirth, or associated medical conditions. Employers need not accommodate a request that would cause undue hardship, meaning significant difficulty or expense in their operations.

Possible accommodations include additional breaks, temporary changes to physical duties, adjusted schedules, time off for medical appointments, and other modifications designed to help workers remain employed.

In 2024, the EEOC finalized regulations covering a broad range of pregnancy-related and reproductive health conditions: miscarriage, postpartum depression, lactation, fertility treatments, abortion, endometriosis, and certain other conditions.

The rules also state that employers generally cannot require leave when another reasonable accommodation would let the employee keep working.

Takeaway: Current rules remain the governing standard.

What could the proposal change?

One possible revision would remove explicit references to certain reproductive health conditions that do not involve an ongoing pregnancy, including fertility treatment and abortion-related care.

Under current regulations, for example, an employee undergoing in vitro fertilization may qualify for reasonable scheduling accommodations tied to appointments and treatment. Narrowing the language could make employer obligations less certain.

Regulators also reportedly consider broader religious exemptions that could let qualifying employers decline accommodations when they conflict with sincerely held religious beliefs.

Supporters of narrowing argue the regulations extend protections beyond what Congress intended. Supporters of the current rules argue reproductive conditions are closely connected to pregnancy and that removing explicit references would create barriers and uncertainty.

Takeaway: The proposal could narrow coverage, but no change is final.

What changes for veterinary teams?

Pregnant veterinarians might need temporary adjustments to diagnostic-radiation duties, help lifting large dogs, reduced exposure to certain hazardous medications, or modified work around animals that pose injury risks. Additional breaks or schedule changes may also be necessary.

Veterinary teams encounter anesthetic gases, ionizing radiation, zoonotic pathogens, pharmaceuticals, and physically demanding patients. Those factors make individualized risk assessment and duty modification relevant at the practice level.

Infection-prevention protocols, radiation-safety procedures, anesthetic-gas scavenging systems, and hazardous-drug policies remain essential safeguards. Pregnant workers may need changes based on medical recommendations and the hazards in their workplace.

Technicians and assistants often perform physically intensive tasks on long shifts. In busy hospitals with limited staffing, a request for rest or an appointment can affect the entire team.

Fertility treatment also requires frequent monitoring visits, blood tests, ultrasound examinations, medication administration, and procedures on biological timelines. Veterinarians and technicians may have surgical schedules, patient appointments, emergency cases, or on-call duties that cannot shift easily.

Narrowing fertility language would not eliminate every legal protection: Title VII of the Civil Rights Act, the Americans with Disabilities Act, and some state laws may apply. OSHA requirements and other state rules operate separately from the PWFA.

Takeaway: Veterinary employers should plan around current duties while tracking the proposal.

How do smaller practices differ?

The PWFA generally reaches employers with at least 15 employees, so some independently owned clinics fall outside its federal coverage. State pregnancy-accommodation laws, anti-discrimination rules, and other requirements may still apply, depending on location and workforce size.

For owners and practice managers, the federal threshold does not settle every duty. Even where an accommodation is not legally required, flexible scheduling, cross-training, and temporary duty changes can support retention and workplace safety despite staffing shortages.

Takeaway: A practice below the federal threshold still must check state law.

What should veterinary employers and employees do now?

Veterinary employees should not assume their existing protections have disappeared. Those seeking accommodations for pregnancy, childbirth, or another covered condition may continue to request them from a covered employer; the accommodation depends on medical needs, essential job responsibilities, and workplace circumstances.

Practice owners likewise should avoid premature policy changes based only on reports of possible revisions. They should continue following applicable current law and use the EEOC's PWFA guidance for employees and covered employers.

Takeaway: Current law controls until an effective rule replaces it.

Which veterinary settings are affected?

This is an employment proposal, not a clinical study; it provides no species sample size, study design, or change to prescribing, vaccination, animal-welfare protocols, or clinical recommendations.

• Companion-animal practices: Its examples include lifting large dogs, diagnostic radiation, surgery, emergency work, and hospital staffing, so schedule or duty changes could affect patient scheduling and team coverage.
• Food-animal practices: No food-animal-specific findings or hazards appear in the report; it addresses veterinary workplaces generally.
• Public health: Zoonotic pathogens and infection prevention appear as worker-safety considerations, but the proposal creates no new animal-disease control program or public-health mandate.

Takeaway: The rule concerns worker accommodations, not veterinary medicine itself.

What should practices watch next?

With women comprising the overwhelming majority of the veterinary workforce, clear policies for pregnancy, fertility treatment, reproductive health, and occupational safety remain workforce-management issues amid unpredictable schedules and retention concerns.

The next concrete milestone is publication of the EEOC's proposed regulations, which will show which protections may change and how they would apply; current rules govern until then.