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Reasonable Accommodations Policy

POLICY STATEMENT

Gratz College has a desire and a legal and educational obligation to provide equal access to College’s resources, coursework, programs, and activities, as well as employment opportunities for all qualified individuals in compliance with federal disability law, including the Americans with Disabilities Act of 1990 (ADA), Americans with Disabilities Act Amendments Act of 2008 (ADAAA), and Section 504 of the Rehabilitation Act of 1973. These laws provide a framework for qualified individuals with documented disabilities to request reasonable accommodations needed to participate in a program or place of employment. 

 

BACKGROUND

This policy establishes the framework for which Gratz College establishes disability eligibility criteria, makes disability eligibility determinations, establishes appropriate Reasonable Accommodations, and provides accommodations for public events.
 
This document provides the following: a description of Gratz College’s overarching policy;  definitions of key terms; the process for students, employees and potential employees, and guests/visitors to access reasonable accommodations; and, the process to appeal determinations of eligibility.  
 
 

REASONABLE ACCOMMODATIONS

Reasonable Accommodations are defined as adjustments or modifications that enable a qualified individual with a documented disability to participate as fully as possible in an educational program or place of employment or public event.  A Reasonable Accommodation is any change to an educational program, the job, the work environment, a public environment,  or the way things are customarily done that allows and individual with a disability to apply for a job, perform job functions, or enjoy equal access to benefits available to other individuals in the workplace or in academic environment. Reasonable Accommodations may include changes to activities, programs, coursework, events, work environment, so long as it does not modify essential functions of the job or fundamentally alter academic requirements that are essential to the academic program, practice, course, or standard of instruction, or result in undue financial or administrative hardship on the institution.
 
An institution is not required to lower academic standards quality or production standards to make an accommodation; nor is an employer obligated to provide personal use items such as glasses or hearing aids. 
 
Reasonable Accommodations are distinguished from services of a personal nature, which Gratz College does not provide, but the student or employee may choose to employ. Such services of a personal nature may include individual assistants or coaches. 
 
Examples of covered conditions under this policy include, but are not limited to: Attention Deficit/Hyperactivity Disorder (ADHD); autism spectrum disorders (ASD); chronic medical conditions (cystic fibrosis, diabetes); learning disabilities; mental health disabilities (bipolar disorder, depression, post-traumatic stress disorder); mobility disabilities (use of wheelchair or other assistive device); neurological disorders (traumatic brain injury, epilepsy, motor or tic disorders); orthopedic disabilities (bone or muscle disorders, connective tissue disorders); and sensory disabilities (hearing, vision). 
 
Temporary Medical Conditions (TMC) such as injuries, acute illnesses, surgeries, pregnancy and/or related medical conditions, and breastfeeding and expelling breast milk, may not qualify as permanent disabling conditions. However, Gratz College does provide assistance to students or  employees and guidance on working with a temporary medical condition while attending or working at the College. 

 

PROCEDURES TO REQUEST AN ACCOMMODATION

The procedures to request a Reasonable Accommodation can be found in the sections below. The sections are organized into the following three categories: Students, Employees and Applicants for Employment, and Guests and Visitors.

 

PROCEDURES FOR STUDENTS

The following are the steps that a student should take to request a Reasonable Accommodation at Gratz College. All forms and documents referenced below are located on the Accessibility Services section of the College website at: https://www.gratz.edu/students/policies/accessibility-services.
 
I. Otherwise Qualified Individual with a Disability Determination 
A student who may require a Reasonable Accommodation(s) must first be determined as an Otherwise Qualified Individual with a Disability under the Americans with Disabilities Act of 1990 and Amendments Act of 2008 (“ADA”) or Section 504 of the Rehabilitation Act of 1973, as amended (“Section 504”). In order for the College to make this determination, students must complete the following steps:
 
  1. Students are required to provide the information outlined in the Student Documentation Guidelines at: https://www.gratz.edu/students/policies/accessibility-services/student-documentation-guidelines.
  2. Students must complete Student Accessibility Services Verification Form and return the form to the Gratz College ADA Coordinator.  The instructions and the form can be found on the Accessibility Services section of the College website at: https://www.gratz.edu/students/policies/accessibility-services/student-accessibility-services-verification-form-instructions.
II.  Process
The processes for requesting an accommodation and for appealing a determination are outlined in the Reasonable Accommodation Procedure – Students at: https://www.gratz.edu/students/policies/accessibility-services/student-reasonable-accommodation-process.

 

PROCEDURES FOR EMPLOYEES AND APPLICANTS FOR EMPLOYMENT

The following are the steps that an employee or applicant for employment should take to request a Reasonable Accommodation at Gratz College. All forms and documents referenced below are located on the Employment section of the College website at: https://www.gratz.edu/employment.
 
I. Otherwise Qualified Individual with a Disability Determination 
An employee or applicant for employment who may require a Reasonable Accommodation(s) must first be determined as an Otherwise Qualified Individual with a Disability under the Americans with Disabilities Act of 1990 and Amendments Act of 2008 (“ADA”) or Section 504 of the Rehabilitation Act of 1973, as amended (“Section 504”). In order for the College to make this determination, an employee or applicant must complete the following steps:
 
  1. An employee or applicant for employment who may require a Reasonable Accommodation(s) must first be determined as an Otherwise Qualified Individual with a Disability under the Americans with Disabilities Act of 1990 and Amendments Act of 2008 (“ADA”) or Section 504 of the Rehabilitation Act of 1973, as amended (“Section 504”).
  2. Employees and applicants are required to provide the information identified on the Employee Accommodation Request Documentation Guidelines.
  3. Employees and applicants must complete an Employee Request for Accommodation Form and return it to the HR Representative. 
II.  Process
The processes for requesting a Reasonable Accommodation and for appealing a determination are further detailed in the  Reasonable Accommodation Process – Employee or Applicant for Employment  at: https://www.gratz.edu/employment/employee-accessibility-policies.
 
 

PROCEDURES FOR GUESTS AND VISITORS

Guests and visitors of the College’s campuses, facilities, or events are encouraged to contact the Gratz College ADA Coordinator or the event sponsor (if not Gratz College) at least ten (10) Working Days in advance of the event to request accommodation arrangements. 
 
While Gratz College will attempt to accommodate requests received after this time period, the College is under no obligation to provide them.

 

APPEAL PROCESS FOR STUDENTS, EMPLOYEES, APPLICANTS FOR EMPLOYMENT, GUESTS AND VISITORS

I.  Appeal Process
A student, employee, applicant for employment, guest or visitor who feels as though they have been denied a reasonable accommodation, or is dissatisfied with the determination that they are not eligible as an Otherwise Qualified Individual, may appeal these decisions. The process for making an appeal is as follows:. 
  1. Submit an appeal in writing within five (5) days of notification of the denial to Philip Moore,  Section 504 Coordinator, at pmoore@gratz.edu.  
  2. The Section 504 Coordinator will schedule meeting(s) with the various individuals involved in the process.   
  3. The Section 504 Coordinator will render a decision in writing.  The decision of the Sec. 504 Coordinator is final.
II. Complaint to the Office for Civil Rights (OCR)
The availability and use of this Gratz College Appeal Process does not prevent a student, employee, or applicant for employment  from filing a complaint of discrimination with external agencies such as the U.S. Department of Education, Office for Civil Rights (OCR). That office will determine whether a further investigation is warranted.
 
Information about how to file a complaint with OCR can be obtained at: How to File a Discrimination Complaint with the Office for Civil Rights (ed.gov)

 

DEFINITIONS

Section 504 Coordinator: The College’s Section 504 Coordinator is the 34 CFR § 104.7(a) designee that coordinates the College’s overall efforts to comply with the ADA and Section 504 of the Rehabilitation Act, as amended (1998). The Section 504 Coordinator reviews concerns and appeals of eligibility determinations and Reasonable Accommodation determinations for employees, students, and guests. 
 
ADA Coordinator: The College’s ADA Coordinator is responsible for establishing disability eligibility criteria, making disability eligibility determinations, and establishing appropriate Reasonable Accommodations for students and visitors, as appropriate.
 
Americans with Disabilities Act of 1990 and Amendments Act of 2008 (“ADA”): Federal anti-discrimination law that protects the rights of qualified individuals with a disability.  
 
Disability: The term “disability” means, with respect to an individual: A physical or mental impairment that substantially limits one or more of the major activities of such individual; A record of such impairment; or, Being regarded as having such impairment. 
 
Essential Job Functions: The primary job functions or tasks that an individual must be able to perform with or without a Reasonable Accommodation. The Essential Job Functions are listed by job title with the Office of Human Resources. 
 
Guests and Visitors: Individuals who are neither Gratz College students nor employees who participate in College programs or events.
 
Human Resources (HR) Representative:  The College’s HR Representative is responsible for establishing disability eligibility criteria, making disability eligibility determinations, and establishing appropriate Reasonable Accommodations for employees and applicants for employment, as appropriate.
 
Otherwise Qualified Individual with a Disability: Individuals who meet essential disability eligibility requirements. 
 
Reasonable Accommodation: Modifying a job process, work environment or educational environment to enable an otherwise qualified individual with a disability to perform the essential functions of the job or fully participate in an educational activity, program, coursework, or event. 
 
Section 504 of the Rehabilitation Act of 1973, as amended (1998): Federal law that states that no otherwise qualified individual with a disability in the United States shall, solely by reason of his or her disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance. 
 
Undue Hardship: is defined as an action requiring significant difficulty or expense when considered in light of factors such as an employer's size, financial resources, and the nature and structure of its operation.
 
Working Days: Days when Gratz College is open for business.

 

RESPONSIBILITIES

Section 504 Coordinator Responsibilities (for Students, Employees/Applicants for Employment, Guests/Visitors)
  • Reviews concerns and appeals of eligibility determinations and Reasonable Accommodation determinations for employees, students, guests, or visitors in accordance with this regulation. 
  • Evaluates the College’s decisions in accordance with applicable guidelines under the ADA and Section 504. 
  • Determines whether the College has erred in its decision to deny eligibility or Reasonable Accommodation and communicates with both the College and student/employee/guest in a timely fashion. 
ADA Coordinator Responsibilities (for Students, Guests/Visitors)
For Students: 
  • Evaluate disability documentation in determining if an individual is an Otherwise Qualified Individual with a Disability under the criteria of this regulation and the ADA and Section 504. 
  • Set forth disability documentation guidelines. 
  • Determine eligibility for Reasonable Accommodation(s). 
  • Review disability documentation and the request for Reasonable Accommodation(s). 
  • Review essential academic requirements of the course and program including clinical skills or requirements of the course or program as well as essential employment requirements of the field the student is considering.
  • Discuss Reasonable Accommodation(s) with the student.  
  • Discuss Reasonable Accommodation(s) with the student’s course instructor.
  • Identify and document the Reasonable Accommodation(s) agreed upon by the student and the ADA Coordinator. 
  • Oversee the process in a timely fashion. 
  • Facilitate the resolution of appeals regarding Reasonable Accommodation(s). 
For Guests/Visitors:
  • Evaluate individual requests for Reasonable Accommodation(s).
  • Set forth criteria in determining disability documentation.
  • Determine eligibility for event/program accommodation(s)
  • Review disability documentation and the request for accommodation, if appropriate. 
  • Facilitate the resolution of appeals regarding Reasonable Accommodation(s). 
HR Representative Responsibilities (for Employees/Applicants for Employment)

Evaluate disability documentation in determining if an individual is an Otherwise Qualified Individual with a Disability under the criteria of this regulation, the ADA and Section 504. 

  • Set forth criteria in determining disability documentation. 
  • Determine eligibility for Reasonable Accommodation(s). 
  • Review Essential Job Functions/job description and the individual’s ability to perform Essential Job Functions as listed under the job title. Essential Job Functions are listed by job title in the Human Resources Office. 
  • Discuss Reasonable Accommodation(s) with the employee.
  • Discuss Reasonable Accommodation(s) with the employee’s Supervisor.
  • Identify and document the Reasonable Accommodation(s) agreed upon by the employee and the Employee’s Supervisor. 
  • Oversee the process in a timely fashion.
  • Facilitate the resolution of appeals regarding Reasonable Accommodations.
Student Responsibilities: 
  • Self-identify as an individual with a disability (see Procedures section). 
  • Provide disability documentation to the ADA Coordinator.
  • Provide a completed Accessibility Services Verification Form to the ADA Coordinator to determine eligibility and accommodation services. Include specific academic accommodations needed to perform essential academic requirements. 
Faculty Responsibilities: 
  • Faculty must include the most current accessibility statement on their course syllabi. 
  • If a student self-identifies as an individual with a disability or makes a request for an accommodation, faculty should refer the student to the ADA Coordinator  to review the academic accommodation processes. The faculty member will encourage the student to seek assistance from the ADA Coordinator to document the need for a Reasonable Accommodation. 
Employee Responsibilities:
  • Must self-identify as an individual with a disability to the HR Representative Office.  
  • Provide disability documentation to the  HR Representative.  
  • Provide completed request form for job accommodations to the HR Representative  for request for services. Include specific job accommodations needed to perform Essential Job Functions.
Supervisor Responsibilities: 
  • If an employee self identifies as an individual with a disability or makes a request for an accommodation or job modification, the Supervisor will refer the employee to the HR Representative to review the job accommodation process. 
  • Encourage the individual to seek assistance from the HR Representative or ADA Coordinator to document the need for accommodation.
     

INSTITUTIONAL CONTACT INFORMATION

Please contact the individuals listed below if you have questions or concerns about services for an individual with a disability, means of accommodating, verification of a disability, or your responsibility for responding to the needs of individuals with disabilities:
 
ADA Coordinator, Naomi Housman, at accessibility@gratz.edu.
HR Director, Thomas Cipriano (HR Representative) at tcipriano@gratz.edu
Section 504 Coordinator, Philip Moore, at pmoore@gratz.edu
 
For more information, please visit the Accessibility Services section of the College website at: https://www.gratz.edu/students/policies/accessibility-services.