Title IX Pregnancy and Related Conditions Policy (Interim)

1.0 Policy Purpose

Nondiscrimination Statement

Vassar College does not discriminate in its education program or activity against any applicant for admission, student, applicant for employment, or employee on the basis of current, potential, or past pregnancy or related conditions as mandated by Title IX of the Education Amendments of 1972 (Title IX). The College prohibits members of the College community from adopting or implementing any policy, practice, or procedure which treats an applicant for admission, student, applicant for employment, or employee differently on the basis of current, potential, or past parental, family, or marital status. This policy and its pregnancy-related protections apply to all pregnant persons, regardless of gender identity or expression.

2.0 Scope

This Policy applies to all faculty, employees, students, and other individuals participating in or attempting to participate in Vassar College’s program or activities, including education and employment.

3.0 Policy

3.1 ​Definitions

1. Familial Status. The configuration of one’s family or one’s role in a family.
2. Marital Status. The state of being married or unmarried.
3. Parental Status. The status of a person who, with respect to another person who is under the age of 18, is a biological, adoptive, foster, or stepparent; a legal custodian or guardian; in loco parentis with respect to such a person; or actively seeking legal custody, guardianship, visitation, or adoption of such a person.
4. Pregnancy and Related Conditions. The full spectrum of processes and events connected with pregnancy, including pregnancy, childbirth, termination of pregnancy, or lactation; related medical conditions; and recovery therefrom.
5. Reasonable Modifications. Individualized modifications to the College’s policies, practices, or procedures that do not fundamentally alter the College’s education program or activity.

3.1 Information Sharing Requirements

Any College employee who becomes aware of a student’s pregnancy or related condition is required to provide the student with the Assistant Vice President (AVP) for Institutional Equity and Title IX Coordinator’s contact information and communicate that the Title IX Coordinator can help take specific actions to prevent discrimination and ensure equal access to the College’s education program and activity. If the employee has a reasonable belief that the Title IX Coordinator is already aware of the pregnancy or related condition, the employee is not required to provide the student with the Title IX Coordinator’s contact information.

Contact information:

Belinda Guthrie, AVP for Institutional Equity & Title IX Coordinator
Phone: (845) 437-5334
Email: guthrie@vassar.edu

Office for Institutional Equity
Vassar College
124 Raymond Avenue, Box 645
Poughkeepsie, New York 12604-0645
Office: Main Building, 1st Fl., South-182
Phone: (845) 437-7924
Email: equity@vassar.edu
Web: https://offices.vassar.edu/institutional-equity

Upon notification of a student’s pregnancy or related condition, the AVP for Institutional Equity and Title IX Coordinator will contact the student and inform the student of the College’s obligations to:

1. Prohibit sex discrimination.
2. Provide reasonable modifications.
3. Allow access, on a voluntary basis, to any separate and comparable portion of the institution’s education program or activity.
4. Allow a voluntary leave of absence.
5. Ensure lactation space availability.
6. Maintain a Resolution Process for alleged discrimination.
7. Treat pregnancy as comparable to other temporary medical conditions for medical benefit, service, plan, or policy purposes.

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

3.2 Reasonable Accommodations and Modifications for Students

3.2.1 Requesting Accommodations and Modifications

Students who are pregnant or are experiencing related conditions are entitled to Reasonable Modifications to prevent sex discrimination and ensure equal access to the College’s education program and activity. Any student seeking medical assistance or reasonable modifications or accommodations should contact the Vassar College Student Health Service, Baldwin Hall, (845) 437-5800, health@vassar.edu. The College Health Service is a confidential campus resource. Students may also contact the AVP for Institutional Equity and Title IX Coordinator to discuss their individual needs and the availability of Reasonable Modifications.

Students are encouraged to request Reasonable Modifications as promptly as possible, although retroactive modifications may be available in some circumstances. Reasonable Modifications are voluntary, and a student can accept or decline the offered Reasonable Modifications. Not all Reasonable Modifications are appropriate for all contexts.

Reasonable Modifications may include:

• Breaks during class to express breast milk, breastfeed, or attend to health needs associated with pregnancy or related conditions, including eating, drinking, or using the restroom
• Intermittent absences to attend medical appointments
• Alternative arrangements for attendance, as medically necessary
• Changes in schedule or course sequence
• Time extensions for coursework and rescheduling of tests and examinations
• Allowing a student to sit or stand, or carry or keep water nearby
• Counseling services or assistance with case management through the CARES Office
• Accommodations for accessibility needs, including changes in physical space or supplies (for example, access to a larger desk or a footrest)
• A larger uniform or other required clothing or equipment
• Other changes to policies, practices, or procedures determined by the AVP for Institutional Equity and Title IX Coordinator

3.2.2 Role of Dean of Studies Office

In situations where academic accommodations are required and in academic contexts such as fieldwork placements, clinical rotations, performances, labs, and group work, the Dean of Studies Office will work with the student to devise an alternative path to completion, if possible. In progressive curricular and/or cohort-model programs, medically necessary leaves are sufficient cause to permit the student to shift course order, substitute similar courses, or join a subsequent cohort when returning from leave. Students are encouraged to work with their Class Advisor in the Dean of Studies, faculty members, and the College’s support systems to devise a plan for how to best address the conditions as pregnancy progresses, anticipate the need for leaves, minimize the academic impact of an absence, and get back on track as efficiently and comfortably as possible. The AVP for Institutional Equity and Title IX Coordinator will assist with plan development and implementation as needed.

Supporting documentation for Reasonable Modifications will only be required when it is necessary and reasonable under the circumstances to determine which Reasonable Modifications to offer to determine other specific actions to take to ensure equal access.

Information about pregnant students’ requests for modifications will be shared with faculty and staff only to the extent necessary to provide the Reasonable Modification.

3.2.3 Role of Office of Accessibility and Educational Opportunity

Students experiencing pregnancy-related conditions that manifest as a temporary disability under the Americans with Disabilities Act (ADA) or Section 504 of the Rehabilitation Act are eligible for reasonable accommodations just like any other student with a temporary disability. The AVP for Institutional Equity and Title IX Coordinator will consult with the Director for the Office of Accessibility and Educational Opportunity to ensure the student receives reasonable accommodations for their disability as required by law.

3.2.4 Certification to Participate

All students should be informed of health and safety risks related to participation in academic and co-curricular activities, regardless of pregnancy status. A student may not be required to provide health care provider or other certification that the student is physically able to participate in the program or activity, unless:

• The certified level of physical ability or health is necessary for participation;
• The institution requires such certification of all students participating; and
• The information obtained is not used as a basis for pregnancy-related discrimination.

3.2.5 Lactation Space

The College provides students and employees with access to lactation spaces that are functional, appropriate, and safe. Such spaces are regularly cleaned, shielded from view, and free from the intrusion of others.

3.2.6 Student Leave of Absence

Students are permitted to take a voluntary leave of absence for a reasonable time as deemed medically necessary by their healthcare provider 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 consistent with the College’s academic policies.

To the extent possible, the College will take reasonable steps to ensure that students who take a leave of absence or medical leave return to the same position of academic progress that they were in when they took leave, including access to the same or an equivalent course catalog that was in place when the leave began.

Continuation of students’ scholarships, fellowships, or similar College-sponsored funding during the leave term will depend on student registration status and the policies of the funding program regarding registration status. Students will not be negatively impacted by or forfeit their future eligibility for their scholarship, fellowship, or similar College-supported funding by exercising their rights under this policy.

The College can and will advocate for students with respect to financial aid agencies and external scholarship providers in the event that a leave of absence places eligibility into question.

4.0 Policy Dissemination and Training

A copy of this policy will be made available to faculty and employees in annually required training and posted on the College’s website. The College will alert all new students about this policy and the location of this policy as part of orientation. The Office for Institutional Equity will make educational materials available to all members of the College community to promote compliance with this policy and familiarity with its procedures.

5.0 Responsible Department and Positions

• Assistant Vice President for Institutional Equity & Title IX Coordinator, Office for Institutional Equity

7.0 Review History

• Policy adopted Aug 1, 2024

8.0 Revision History

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This Policy is implemented on an interim basis for renewable six-month intervals to comply with recent changes to federal or state laws, implementing regulations, and enforcement guidance for Title IX.