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Religious Workplace Accommodation Request Procedures

University of Virginia 
Religious Workplace Accommodation Request Procedures

The University of Virginia (“UVA”) is committed to providing equal opportunity to Employees who have sincerely held religious beliefs.  This includes making reasonable efforts to accommodate Employees’ religion.  Religion includes all aspects of religious observance and practice as well as belief.  

Religion includes not only traditional, organized religions such as Christianity, Judaism, Islam, Hinduism, and Buddhism, but also religious beliefs that are new, uncommon, not part of a formal church or sect, only subscribed to by a small number of people, or that may seem illogical or unreasonable to others.  A practice may be a religious belief held by an individual even if newly adopted, not consistently observed, or different from the commonly followed tenets of the individual's religion.

These procedures apply to Academic Division and UVA Medical Center Employees.  Applicants for UVA or UVA Health System employment should contact the UVA Office for Equal Opportunity and Civil Rights for additional information. NOTE: These procedures do not apply to religious exemptions from required vaccinations and inoculations. Such requests are handled in accordance with UVA Health Policy OCH-002: Occupational Health Screening and Maintenance. 


A reasonable workplace accommodation is a modification to an Employee’s work or environment to enable the Employee to participate in their religious practice or belief which does not cause an Undue Hardship to UVA operations or activities. Examples of workplace accommodations include:

  • granting an Employee leave for religious observances or to attend religious services;
  • providing a time and place to pray;
  • allowing the flexibility to wear religious dress to work;
  • providing flexible scheduling, voluntary shift substitutions or swap with supervisory approval, job reassignments; and 
  • modifying workplace policies or practices.

This is not an exhaustive list. Reasonable accommodations are determined on a case-by-case basis.

UVA is committed to providing accommodations, upon request, to ensure access to employment opportunities, benefits, programs, and services to all employees who have sincerely held religious beliefs. However, reasonable religious accommodations  are not required or permitted when such accommodation would cause Undue Hardship, violate other laws, or interfere with the safety and security of UVA or its operations. Undue Hardship is a burden that would result in substantial increased costs in relation to UVA's business. Undue Hardship must be based on an individualized assessment of current circumstances that show that a specific reasonable accommodation would cause such burden or expense.  

In addition, while an Employee may have a preferred accommodation, which UVA will seek to implement, UVA is not required to accept the Employee’s preferred accommodation if there is more than one alternative that permits the religious belief or practice. When there is more than one alternative accommodation, UVA may select any of the accommodations, provided that the accommodation effectively eliminates the religious conflict.  Approved accommodations do not apply retroactively and Employees are encouraged to engage in the interactive process when the need for accommodations arises. 


Failure to provide a reasonable accommodation for a sincerely held religious belief may violate UVA’s HRM-009: Preventing and Addressing Discrimination and Harassment Policy (“PADH Policy”).  The PADH Policy also prohibits discrimination and harassment based on religion or lack thereof. The HRM-010: Preventing and Addressing Retaliation Policy prohibits retaliation against an Employee who requests a religious accommodation or submits a good-faith complaint alleging religious harassment or discrimination.  

Employees who believe they have been denied a reasonable accommodation for religion, retaliated against for making such a request, or otherwise subjected to religious discrimination, may file a complaint with the UVA Office for Equal Opportunity and Civil Rights (“EOCR”) in accordance with the Preventing and Addressing Discrimination, Harassment, and Retaliation (“PADHR”) Complaint Procedures.  Employees also may file a complaint with an external agency authorized to accept such complaints or pursue other remedies available to them under state or federal law.

Employees may seek the advice or the assistance of the Senior Compliance Director for EOCR or the Associate Vice President for EOCR regarding technical assistance or issues that are not resolved during the accommodation process.  Please email or call (434) 924-3200 for assistance. 


1.    Initiating the Request

Employee: The Employee is responsible for requesting a religious workplace accommodation. Employees should request an accommodation as soon as possible, in writing (the request may be submitted by email), to either the Employee’s Supervisor or the Employee Relations (“ER”) Consultant for the Employee’s department/school/office/unit. The written request should include the following information:

  • reason for request (an explanation of how your religious beliefs, observance, or practice conflict with your work duties);
  • suggested accommodation;
  • whether the accommodation is temporary or permanent; and
  • if temporary, anticipated length of time. 

NOTE: Employees who have a disability and need assistance with submitting a written accommodation request may contact UVA’s ADA team at or (434) 924-3200 for assistance.

2.    Responding to an accommodation request

Supervisor: Upon receipt of the request for accommodation, the Supervisor must notify their ER Consultant as soon as possible. 

Employee Relations: If the ER Consultant is notified of the request first, the ER Consultant will notify the Supervisor and other leadership about the request as soon as possible. 

3.    Evaluation of request and the interactive process 

Supervisor: The Supervisor, in consultation with the ER Consultant, will promptly evaluate the request, taking into account the specific facts of the request, including the Essential Functions of the job, operations, the potential impact on Department/School/Office/Unit operations, and the availability of alternative accommodations.  If the requested reasonable accommodation does not constitute an Undue Hardship and the Employee and Supervisor agree upon the most effective reasonable accommodation, the Supervisor may provide the reasonable accommodation without engaging in an extensive interactive process but they must send the notification in Section 4. 

  • The interactive process. The Supervisor and ER Consultant should begin an interactive process with the Employee when: (1) the specific limitation, problem, or barrier is unclear; (2) an effective reasonable accommodation is not obvious; or (3) the parties are choosing between different reasonable accommodations. The interactive process is a series of communications with the Employee to determine appropriate reasonable accommodations. If the Supervisor believes additional information is necessary to evaluate the request or to clarify limitations, or if subsequent steps are required to process the accommodation request, the Supervisor must contact the ER Consultant for assistance before denying the request. Although there is usually no reason to question whether the practice at issue is religious or sincerely held, the Supervisor should consult with the ER Consultant if they have a bona fide doubt about the basis for the accommodation request; in such instances, the Supervisor, in consultation with the ER Consultant, may be able to make a limited inquiry into the facts and circumstances of the Employee’s statement that the belief or practice at issue is religious and sincerely held, and gives rise to the need for the accommodation.
  • Consideration of alternatives. If after engaging in the interactive process, the Supervisor believes the request is not reasonable or imposes an Undue Hardship, the Supervisor must consider alternative accommodations and discuss the alternatives with the Employee. Undue Hardship must be based on an individualized assessment of current circumstances that show that a specific reasonable accommodation would cause significant difficulty or expense. 

In determining whether the accommodation would constitute an Undue Hardship, the Supervisor and ER Consultant should consider: (1) the type of workplace; (2)  the nature of the Employee’s duties; (3) the cost of the accommodation in relation to the size and operating costs of UVA; and (4) the number of  Employees who will need a particular accommodation, and the burden on the School/Department/Unit’s business and operations, e.g., diminished efficiency in other jobs, an increase in other Employee’s share of potentially hazardous or burdensome work, or infringement on other Employees’ ability to perform their duties.

  • Required step before denial. If the Supervisor believes the specific requested accommodation is not reasonable, creates an Undue Hardship, or that alternative accommodations are not available, the Supervisor must first consult with the ER Consultant before denying the accommodation.  If after consultation, the Supervisor and ER Consultant believe denial of the specific accommodation is appropriate or no alternative accommodations are available, they must consult with the Senior Compliance Director for EOCR or Associate Vice President for EOCR and the Office of University Counsel before denying the request.
  • Final decision. The Supervisor, after consultation with the ER Consultant (and EOCR and Office of University Counsel, as necessary), makes the final determination regarding approved accommodations.
  • Temporary accommodations. During the interactive process, the Supervisor should consider making modifications on a temporary basis while a permanent accommodation is being considered.  In such cases, the Supervisor or ER Consultant should provide regular updates to the Employee regarding the efforts being made to implement a permanent accommodation. 
  • Employee: The Employee is expected to participate in the interactive process, including promptly responding to requests for meetings or additional information from the Supervisor or ER Consultant. 

4.    Notification of Outcome/Implementation of the accommodation  

Supervisor: At the conclusion of the interactive process, the Supervisor will notify the Employee in writing by email of the outcome of the process and the basis for the decision and copy the ER Consultant. 
For approved accommodations, the Supervisor (or ER Consultant) will email the Employee and copy the ER Consultant (or the Supervisor if the ER Consultant sends the message) the following information outlining the accommodation and advise the Employee to reply to the message to acknowledge that the information is correct:

  • date accommodation was granted;
  • anticipated length of accommodation; and
  • details regarding the accommodation granted.

The ER Consultant will maintain a copy of the email message.

Employee: The Employee is responsible for promptly notifying their Supervisor or ER Consultant if they believe an accommodation being provided is ineffective.


All documentation should be maintained separately from general personnel files (either in electronic or hard copy format) and shared only with those who are involved in the accommodation process or when required by law.


Employee: An Employee is any UVA full-time or part-time employee, including faculty and student employees, wage employees, and post-doctoral students being paid by grants.

Employee Relations (“ER”) Consultant: The ER Consultant works in collaboration with Employees, Supervisors, EOCR, and other Human Resources professionals to resolve workplace matters and serve as a strategic partner through interactive processes.

Essential Functions: Essential Functions are fundamental job duties that bear more than a marginal relationship to the job at issue. If the job description contains the Essential Functions of the job including physical, behavioral, and minimal qualification requirements, that description will be considered evidence of the Essential Functions of the job. If the position exists to perform a function, then that function is essential. A function also may be essential if: it requires specialized skills; it requires a significant amount of time; there are significant consequences if the function is not performed; or there are a limited number of Employees to perform the function.

Supervisor: For purposes of these procedures, a Supervisor is the person who has authority to undertake or recommend tangible employment decisions (e.g., hiring, firing, and promoting) affecting an Employee.

Undue Hardship: Undue Hardship is a burden that would result in substantial increased costs in relation to UVA's business. Undue Hardship must be based on an individualized assessment of current circumstances that show that a specific reasonable accommodation would cause such burden or expense.  The University must rely on objective information in making this determination, rather than potential or hypothetical hardship. Undue Hardship cannot be determined solely by the Supervisor. 

July 24, 2023