Reasonable Accommodations Procedure – Students
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.
This regulation establishes the process and the appeal procedures for which Accessibility Services establishes disability eligibility criteria, makes disability eligibility determinations, and establishes appropriate Reasonable Accommodations.
III. 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. A reasonable accommodation is any change to an educational program or the way things are customarily done that allows an individual with a disability to apply to the institution, or enjoy equal access to benefits available to other individuals in the academic environment. Reasonable accommodations may include changes to activities, programs, coursework, or events so long as it does not 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 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 may choose to employ. Such services of a personal nature may include individual caretakers or assistants.
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 (TMCI) such as injuries, acute illnesses, surgeries, pregnancy with accompanying medical conditions, and breastfeeding and expelling breast milk, may not qualify as permanent disabling conditions. However, the College does provide assistance to students and guidance on working with a temporary medical condition while attending at Gratz College.
IV. Procedures to Request an Accommodation - Student
The following are the steps that a student should take to request a reasonable accommodation at the College. All forms and documents are located online at LINK.
I. Otherwise Qualified Individual with a Disability Determination
A. 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”).
B. Students are required to provide the information identified on the Student Documentation Guidelines.
C. Students must complete the Student Accessibility Services Verification Form and return the form to the ADA Coordinator.
In instances where the requested accommodation may alter an essential course or program requirement, the College’s determination regarding the request will be made by College employees who are trained, knowledgeable, and experienced in the area of study in question through a careful, thoughtful, and rational review of the academic program and its requirements, taking into account possible alternatives for the essential requirement, as well as whether the essential requirement in question can be modified for a specific student with a disability and/or temporary medical condition.
Information and documentation received by Accessibility Services is confidential, to the extent required by law, and is used for the sole purpose of determining eligibility for accommodations and coordinating services requested. Pertinent aspects of the information will be disclosed for discussion for determining appropriate accommodation(s). Access to a student disability file is restricted to those on a “need to know” basis in accordance with the Family Educational Rights and Privacy Act (FERPA). The Authorization for Release of Medical Information also serves as a release form allowing discussions to take place between the ADA Coordinator, Section 504 Coordinator, and the healthcare professional where appropriate or applicable. Disability-related information, including submitted documentation, is maintained by the Accessibility Services for five years from the time a student is separated from the College.
The ADA Coordinator may require additional or new documentation if the original documentation presented is outdated, vague, incomplete, or does not meet the Documentation Guidelines.
III. Reasonable Accommodation Determination
The determination of a Reasonable Accommodation will be made as soon as it is feasible, after the application for academic accommodations request and appropriate disability documentation have been submitted to and reviewed by the College’s ADA/Section 504 Coordinator or their representative and any other individuals identified as appropriate.
IV. Reasonable Accommodation(s) Interactive Process
If the ADA Coordinator determines that the student is an Otherwise Qualified Individual with a disability under ADA and/or Section 504, reasonable accommodations will be discussed with the student. The ADA Coordinator will engage in an interactive process with the student and, as necessary, relevant College officials (e.g., course instructors) and others to determine the appropriate accommodation(s).
A. Once the Student Accessibility Services Verification Form is received, the ADA Coordinator will reach out to the student to schedule a time to meet.
B. During the interactive process, the College’s ADA Coordinator or representative may communicate with appropriate offices and individuals at the College before a determined Reasonable Accommodation can be fully implemented.
C. See “Responsibilities” section below for each participant’s role in the process.
Please note that a student with a disability is still responsible for adhering to the Gratz College Code of Student Conduct.
V. Appeal Process
A student 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 in writing using the following process.
Must appeal within five (5) days of notification of the denial to the Section 504 Coordinator, Philip Moore, EdD, MFA, at Section504@gratz.edu.
The Section 504 Coordinator will schedule meeting(s) with the various individuals involved in the process. The Section 504 Coordinator will render a decision in writing. The decision of the Section 504 Coordinator is final.
VI. Complaint to the Office for Civil Rights (OCR)
The availability and use of this Gratz College Appeal Process does not prevent a student 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 from: How to File a Discrimination Complaint with the Office for Civil Rights (ed.gov)
VII. Timely Notice
While a student may submit a request for reasonable accommodations at any point during their academic career, the accommodations are not applied retroactively. Therefore, the College advises students to begin the registration process as early as possible. Incoming 1st year students or transfer students are advised to start the process as soon as they have been admitted to Gratz College. Current Gratz College students should contact the ADA Coordinator as soon as they have established a need for accommodations. A student’s failure to give timely notice may hinder Gratz College’s ability to adequately coordinate services and provide instructors with reasonable notice of the approved accommodations.
VIII. Renewal of Accommodations: Current Students with an Existing Reasonable Accommodations Memo
Renewal of a student’s reasonable accommodations memo must be made each term that the student is in attendance at the College. This must be done before the student’s instructors can provide reasonable accommodations. Accommodation requests are not retroactive. The memo is effective for one (1) year from date of issuance. It is highly encouraged that you request your accommodations at least two (2) weeks prior to the start of a new term (after the one year period) by scheduling an appointment with the ADA Coordinator. The ADA Coordinator will review any requested changes or updated documentation and will meet with the student and others, as needed, to determine the appropriate academic adjustment and/or auxiliary aids and services for the student if need be. Students will be notified, in a timely manner, of all specific adjustments or services that have been agreed to and of any denial of requests for adjustments or services and the reason(s) for any denial.
IX. Accommodation Modifications
A student may make a written request to the College’s ADA Coordinator to modify an established Reasonable Accommodation or request an alternative accommodation. The request will be considered using the procedure described above. Upon request, the ADA Coordinator will work to coordinate and provide new accommodations or modifications to existing accommodations in a timely manner.
XI. Reasonable Accommodations Memo
Once the appropriate forms and documentation are received, and a student is approved for reasonable accommodations, the ADA Coordinator will issue a Reasonable Accommodations Memo to the student and the student’s faculty.
Once the student has received the memo, it is the student’s responsibility to produce this memo to the faculty and discuss the manner in which the accommodation will be provided (as noted in the memo). In order to implement accommodations at the course level, the student should note the procedures outlined in the Reasonable Accommodations Memo that the ADA Coordinator provides. Instructors’ syllabi accommodation procedures must not violate procedures set forth in the accommodations memo or any law pertaining to this policy.
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 students.
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, 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 an individual; a record of such impairment; or being regarded as having such impairment.
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 the College is open for business.
Section 504 Coordinator Responsibilities:
Reviews concerns and appeals of eligibility determinations and Reasonable Accommodation determinations for students 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 in a timely fashion.
With the ADA Coordinator, convene the ADA compliance team to conduct an annual review of policies at a date to be determined each year in October.
ADA Coordinator Responsibilities:
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).
- With the Section 504 Coordinator, convene the ADA compliance team to conduct an annual review of policies at a date to be determined each year in October.
Must self-identify as an individual with a disability (see Procedures section).
Provide disability documentation to Accessibility Services.
Provide a completed Student Accessibility Services Verification Form to Accessibility Services for request for services. Include specific academic accommodations needed to perform essential academic requirements.
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 Accessibility Services to review the academic accommodation processes. The faculty member will encourage the student to seek assistance with Accessibility Services to document the need for a Reasonable Accommodation.
VII. 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 firstname.lastname@example.org.
Section 504 Coordinator, Philip Moore, EdD, MFA, at Section504@gratz.edu.
For more information, pleases visit Accessibility Services - Gratz College.