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ROGER WILLIAMS UNIVERSITY TITLE IX PREGNANCY AND PARENTING STUDENT POLICY[1]

COMPLIANCE 

Reporting: Any member of the 51���� community may report a violation of this policy to any Mandated Reporter. All Mandated Reporters must promptly forward such reports to the Title IX Office. The Title IX Coordinator is responsible for overseeing complaints of discrimination involving pregnant and parenting students. 

The Title IX Coordinator for 51���� is: 

Dr. Jen Stanley
Center for Student Development Building - Room 104
(401) 254-3123
jstanley@rwu.edu 

Complaints may also be filed with the U.S. Department of Education’s Office for Civil Rights at: 

Office for Civil Rights (OCR) 

U.S. Department of Health and Human Services Government Center
J.F. Kennedy Federal Building - Room 1875
Boston, MA 02203
Customer Response Center: (800) 368-1019
Fax: (202) 619-3818
TDD: (800) 537-7697
Email: ocrmail@hhs.gov 

Complaints may be filed online, using the form available. 

Information Sharing Requirement: When a student, or a person who has a legal right to act on behalf of the student, informs any 51����employee of the student’s pregnancy or pregnancy-related conditions (as defined below), the 51����employee is required to provide the student with the Title IX Coordinator’s contact information and communicate that the Coordinator can help take specific actions to prevent discrimination and ensure equal access to the University’s education program and activity. If the employee has a reasonable belief that the Title IX Coordinator is already aware of the pregnancy or pregnancy-related condition, the employee is not required to provide the student with the Title IX Coordinator’s contact information. 

Upon notification of a student’s pregnancy or related condition, the Title IX Coordinator will contact the student and inform them of the University’s obligations to:

• Prohibit sex discrimination;
• Provide reasonable modifications; and
• Review option for a medical leave of absence.

The Title IX Coordinator will also notify the student of the process to file a complaint for alleged discrimination, harassment, or retaliation, as applicable.

POLICY STATEMENT 

51���� (RWU) is committed to creating and maintaining a community where all individuals enjoy freedom from discrimination, including discrimination on the basis of sex, as mandated by Title IX of the Education Amendments of 1972 (Title IX). Sex discrimination, which can include discrimination based on current, potential, or past pregnancy, marital status, or parental status, is prohibited and illegal in admission, educational programs and activities, hiring, leave policies, employment policies, and health insurance coverage. 51���� hereby establishes a policy and associated procedures for ensuring the protection and equal treatment of pregnant individuals, persons with pregnancy-related conditions, and new parents, regardless of gender identity or expression.

Under the Department of Education’s (ED) Title IX regulations, an institution that receives federal funding “shall not discriminate against any student, or exclude any student from its education program or activity, including any class or extracurricular activity, on the basis of such student’s pregnancy, childbirth, false pregnancy, termination of pregnancy, or recovery therefrom.” According to the ED, appropriate treatment of a pregnant student includes granting the student leave “for so long a period of time as is deemed medically necessary by the student’s physician,” and then effectively reinstating the student to the same status as was held when the leave began.

This generally means that pregnant students should be treated by the University similarly to someone who has a temporary medical condition. University personnel will work with the student to ensure they are aware of available support and possible modifications. To the extent possible, 51����will take reasonable steps to ensure that pregnant students who take a leave of absence or medical leave return with an academic plan to complete their degree. The Title IX Coordinator will work with faculty and the Assistant Provost for Student Success to identify appropriate accommodations. The Title IX Coordinator retains ultimate oversight for ensuring that the University complies with these requirements. 

As with disability accommodations, information about pregnant students’ requests for modification will be shared with faculty and staff only to the extent necessary to provide the reasonable supports. The student will need to request the accommodations and provide permission for staff to coordinate with faculty. Faculty and staff will be notified that all information associated with such requests are private and will not disclose this information unless necessary. Administrative responsibility for these modifications lies with the Title IX Coordinator and Student Accessibility Services, who will maintain all appropriate documentation related to accommodations.

In situations such as group work, performances, and labs, the Title IX Coordinator and the Assistant Provost for Student Success will work with the student and faculty to devise an appropriate plan.  

Students are encouraged to work with their faculty members and RWU’s appropriate administrative offices, such as the Title IX Office and SAS, to devise a plan for how best to address the conditions as pregnancy progresses, anticipate the need for leave, minimize the academic impact of their absence, and get back on track as efficiently and comfortably as possible. The Title IX Coordinator in collaboration with the Assistant Provost will assist with plan development and implementation as needed.

SCOPE OF POLICY 

This policy applies to all aspects of RWU’s program, including, but not limited to admission, educational programs and activities, and extracurricular activities. Note, protections of employment law may exceed those outlined by this policy. Please refer to 51����Human Resources for additional policies and resources.

DEFINITIONS 

a)     Caretaking: caring for and providing for the needs of a child

b)    Medical Necessity: a determination made by a health care provider (of the student’s choosing) that a certain course of action is in the patient’s best health interests

c)     Parenting: the raising of a child by the child’s parents in the reasonably immediate post-partum period

d)    Pregnancy and Pregnancy-Related Conditions: include (but are not limited to) pregnancy, childbirth, false pregnancy, termination of pregnancy, conditions arising in connection with pregnancy, lactation, and recovery from any of these conditions

e)    Pregnancy Discrimination: includes treating an individual affected by pregnancy or a pregnancy-related condition less favorably than similar individuals not so affected, and includes a failure to provide legally mandated leave or modifications

f)      Pregnant Student/Birth-Parent: refers to the student who is or was pregnant. This policy and its pregnancy-related protections apply to all pregnant persons, regardless of gender identity or expression

g)     Reasonable Modifications: (for the purposes of this policy) changes in the academic environment or typical operations, which do not fundamentally alter the education program or activity, that enable pregnant students or students with pregnancy-related conditions to continue to pursue their studies and enjoy the equal benefits of RWU

h)    Pregnancy-Related Disabilities: impairments resulting from pregnancy may be considered disabilities even if they are temporary (ex: gestational diabetes, preeclampsia, etc.) – and while there is no official list of these impairments they will be considered on an individual basis

REASONABLE MODIFICATIONS FOR STUDENTS AFFECTED BY PREGNANCY, CHILDBIRTH, OR RELATED CONDITIONS  

a)     51����and its faculty, staff, and other employees will not require students to limit their studies as the result of pregnancy or pregnancy-related conditions. 

b)    The benefits and services provided to students affected by pregnancy will be no less than those provided to students with documented temporary medical conditions who register with SAS. 

c)     Students with pregnancy-related disabilities, like any student with a short-term or temporary disability, are entitled to reasonable accommodations so that they will not be disadvantaged in their courses of study or research, and may seek assistance from the Title IX Office or Student Accessibility Services (SAS). 

d)    No artificial deadlines or time limitations will be imposed on requests for adjustments, but 51����may be limited in its ability to impact or implement modifications/accommodations retroactively. 

e)    Reasonable modifications that may be considered based on individual circumstances and needs include, but are not limited to: [2]

1.     Providing alterations requested by a pregnant student to protect the health and safety of the student and/or the pregnancy (such as allowing the student to maintain a safe distance from hazardous substances); 

2.     Making modifications to the physical environment (such as accessible seating); 

3.     Providing mobility support; 

4.     Working with individual faculty on deadlines and/or allowing the student to make up tests or assignments missed for pregnancy-related absences;

5.     Granting leave per RWU’s medical leave policy or implementing for classes that will be resumed at a future date; or 

6.     Allowing breastfeeding students reasonable time and space to pump breast milk in a location that is private, clean, and reasonably accessible. 

Nothing in this policy requires fundamental changes to the essential elements of any academic program. 

LACTATION SPACE ACCESS

51����provides students with access to a lactation space that is functional and appropriate, and this space is regularly cleaned, shielded from view, and free from the intrusion of others.

The lactation space is located in the following location:

Global Heritage Hall (GHH) Room 113
(Building 14 on the 51����Campus Map)

To request access to this space, please submit a or contact the Title IX Coordinator. 

MODIFIED ACADEMIC RESPONSIBILITIES POLICY FOR NEWLY PARENTING STUDENTS 

Students with child caretaking/parenting responsibilities who wish to remain engaged in their coursework while adjusting their academic responsibilities because of the birth or adoption of a child or placement of a foster child may request an academic modification period during the first two (2) months from the time the child entered the home. 

Students seeking a period of modified academic responsibilities should consult with their academic advisor and with the Title IX Office to determine appropriate academic adjustment requests. The Title IX Office will communicate all requests under this policy to students’ academic advisors and coordinate modification-related efforts with the advisors unless the students specifically request that their advisors be excluded. 

Students are encouraged to work with their advisors and faculty members to discuss their needs. Students who are interested in reducing their overall course load, may request part-time status through the Title IX Office who will communicate the request to the Advising Office for approval.  

If, for any reason, caretaking/parenting students are not able to work with their advisors/faculty members to obtain appropriate modifications, students should alert the Title IX Office as soon as possible, and the office will help facilitate needed adjustments. 

Students may request modified academic responsibilities under this policy regardless of whether they elect to take a leave of absence. 

LEAVE OF ABSENCE

Enrolled students may elect to take a medical leave of absence because of pregnancy and/or the birth, adoption, or placement of a child. The leave term may be extended in the case of extenuating circumstances or medical necessity. 

Students who are enrolled in the 51����Student Health Insurance Plan will retain that coverage while on leave under this policy.  

To the extent possible, 51����will take reasonable steps to ensure that upon return from leave, students will be reinstated to their program in the same status as when the leave began. 

Students may request the Title IX Office’s assistance if financial aid agencies and external scholarship providers require information about such a leave of absence.

STUDENT-EMPLOYEE LEAVE

Pregnancy and pregnancy-related conditions may be regarded as a justification for a student-employee’s leave of absence from job duties without pay for a reasonable period of time, at the conclusion of which the student-employee will be reinstated to the status that they held when the leave began or to a comparable position, without decrease in rate of compensation or loss of promotional opportunities, or any other right or privilege of student employment.

RETALIATION AND HARASSMENT

Harassment of any member of the 51����community based on sex, gender identity, gender expression, pregnancy, or parental status is prohibited. 

51����employees are prohibited from interfering with students’ right to take leave, seek reasonable modification, or otherwise exercise their rights under this policy.  They also are prohibited from retaliating against students for exercising the rights articulated by this policy, including by imposing or threatening to impose negative educational outcomes because students request leave or modification, file a complaint, or otherwise exercise their rights under this policy.

HOUSING-RELATED MODIFICATIONS 

Pregnant students’ on-campus housing status will not be altered based on pregnancy status unless requested by the pregnant student. Parenting students’ access to housing is governed by the 51����Housing Contract.

DISSEMINATION OF THE POLICY AND TRAINING 

A copy of this policy will be made available to 51����employees in annually required training and posted on the 51����website. 51����will notify all new students about this policy and the location of this policy as part of orientation. The Title IX Office will make educational materials available to all members of the 51����community to promote compliance with this policy and familiarity with its procedures.

[1] This policy is only applicable to students. Information for employees can be found in the 51���� Family Leave Policy & Procedure. For additional information and to request supports, employees should contact Human Resources at (401) 254-3028 or human_resources@rwu.edu. 

[2] Please note that these examples are intended to illustrate the varying types of modifications that may be considered. Actual implementation of modifications will depend on individual circumstances and instructor discretion. Students are encouraged to reach out to the Title IX Coordinator to discuss specific questions or concerns.

Reasonable modifications for students affected by pregnancy, childbirth, or related conditions are granted on an individualized basis.

Requests can be submitted through the .

51����provides students with access to a lactation space that is functional and appropriate, and is regularly cleaned, shielded from view, and free from the intrusion of others.

The lactation space is located in the following location:

Global Heritage Hall (GHH) Room 113

(Building 14 on the campus map).

This lactation room is available for students, employees, and guests of RWU. Access to the room can be requested through the  or by contacting the Title IX Coordinator, Dr. Jen Stanley, at jstanley@rwu.edu or (401) 254-3123. 

51���� is committed to supporting pregnant and parenting students through the course of their studies. Information about your pregnancy will be treated confidentially and sensitively on a need-to-know basis.  Any student who needs support or accommodations is encouraged to contact the following offices for additional information:

Title IX Office
Center for Student Development, 1st Floor
Phone: (401) 254-3123

Office for Student & Family Assistance
Center for Student Development, 1st Floor
Phone: (401) 254-3042

Student Accessibility Services
University Library, 1st Floor
Phone: (401) 254-3841

Center for Student Academic Success
University Library, 2nd Floor
Phone: (401) 254-3456

The Title IX Coordinator is responsible for overseeing complaints of discrimination involving pregnant and parenting students. 

The Title IX Coordinator for 51���� is: 

Dr. Jen Stanley 
Center for Student Development Building – Room 104
(401) 254-3123
jstanley@rwu.edu 

Complaints may also be filed with the U.S. Department of Education’s Office for Civil Rights at: 

Office for Civil Rights (OCR) 
U.S. Department of Health and Human Services Government Center
J.F. Kennedy Federal Building - Room 1875
Boston, MA 02203

Customer Response Center: 1 (800) 368-1019
Fax: (202) 619-3818
TDD: 1 (800) 537-7697
Email: ocrmail@hhs.gov  

Complaints may be filed online, using the OCR Complaint form available.