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Pima County Community College District Standard Practice Guide

SPG Title:  ADA & Equal Opportunity, Reasonable Accommodation Guidelines for Students
SPG Number:   SPG-1501/AD
Effective Date:  1/7/08
Approval Date:   1/7/08
Review Date(s):  7/20/99, 12/14/07, 10/19/12
Revision Date(s):  7/20/99, 12/14/07, 10/19/12

Schedule for Review & Update: Annually
Unit Responsible for Review & Update:   Provost/Executive Vice Chancellor, Academic and Student Services
Sponsoring Unit/Department:  Provost/Executive Vice Chancellor, Academic and Student Services
Regulation Title & No.:  Standards for ADA/504 Compliance, RG-1501/A
Board Policy Title & No.: Affirmative Action/Equal Employment Opportunity, BP-1501 
Legal Reference: Americans with Disabilities Act, as amended in 2008 (ADA); Rehabilitation Act of 1973, as amended (Section 504)
Cross Reference: Disabled Student Resources, BP-3603 and RG-3603/A; Disabled Students’ Complaint Procedure, SPG-1501/AG


I.  GENERAL SCOPE

The purpose of this SPG is to provide guidelines to promote consistent application of the College’s reasonable accommodation process, in compliance with the requirements of Section 504 of the Rehabilitation Act of 1973, as amended (the “Rehabilitation Act” or “Section 504”), and Titles II and III of the Americans with Disabilities Act, as amended in 2008 (the “ADA”). All students who make a request for an accommodation pursuant to these Guidelines will be given prompt consideration and advised properly of this process.

Pima College is committed to accommodating every qualified individual with a disability in the most integrated setting appropriate to the needs of the individual student and in a timely and effective manner, unless the accommodation would: (1) result in a fundamental alteration of a service, program, or activity; (2) result in a direct threat to the health or safety of the student or others that cannot be adequately reduced or eliminated by reasonable accommodation; and/or (3) result in an undue burden or hardship to the College.

II.      DEFINITIONS AND CONCEPTS

An individual with a disability is any person who: (1) has a physical or mental impairment that substantially limits one or more major life activities; (2) has a record of such an impairment (has a history of, or has been classified as having a mental or physical impairment that substantially limits one or more major life activities); and/or (3) is regarded as having such an impairment (is perceived by others in the College as being limited in performing certain life activities.  Disabilities include, but are not limited to, deafness, blindness, intellectual disability, partially or completely missing limbs, mobility impairments requiring use of a wheelchair, autism, cancer, cerebral palsy, diabetes, epilepsy, HIV/AIDS, multiple sclerosis, muscular dystrophy, major depression, bipolar disorder, post-traumatic stress disorder, obsessive-compulsive disorder, and schizophrenia.  An impairment that is episodic or in remission meets the definition of disability if it would substantially limit a major life activity when active.

Major life activities include, but are not limited to: (1) Caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, sitting, reaching, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, interacting with others, and working; (2) The operation of a major bodily function, including functions of the immune system, special sense organs and skin; normal cell growth; and digestive, genitourinary, bowel, bladder, neurological, brain, respiratory, circulatory, cardiovascular, endocrine, hemic, lymphatic, musculoskeletal, and reproductive functions. The operation of a major bodily function includes the operation of an individual organ within a body system; and (3) In determining other examples of major life activities, the term “major” shall not be interpreted strictly to create a demanding standard for disability.

Any individual who has a relationship with or is a primary care giver for a person with a disability is protected from discrimination under the ADA.

An individual with a disability does not include someone whose impairments are due to (1) current substance use/abuse or (2) whose conditions pose an unreasonable danger to others for which accommodations will not be made.

A reasonable accommodation is a modification or adjustment to a course, program, service, job, activity, or facility that enables a qualified student with a disability to have equal opportunity.  A reasonable accommodation may also include the use of auxiliary support services such as visual scanners, large print materials, qualified interpreters, or note-takers. Accommodations are intended to be individualized and flexible, based on the nature of the disability and the academic environment.

Qualified Interpreter means an interpreter who is able to interpret in the language needed by the deaf student effectively, accurately and impartially, both receptively and expressively, using any necessary specialized vocabulary. In this SPG, whenever the term interpreter is used it means a qualified interpreter who is licensed by the State of Arizona. Each interpreter assigned to a team of interpreters must be a qualified interpreter. If interpreting services are being supplied simultaneously to more than one deaf student, the interpreters assigned must be qualified for each student. If the College makes the determination that an interpreter is not qualified to interpret in a particular situation, the College shall promptly replace the interpreter.

Otherwise qualified describes an individual with a disability who, with or without reasonable accommodation, meets the essential qualifications or criteria for participation in the services, programs, activities, or otherwise takes advantage of opportunities offered by the College. All students, with or without disabilities, will be held to the same academic and code of conduct standards of the College.

To be equally effective, an aid, benefit or service need not produce the identical result or level of achievement for disabled and non-disabled persons; it merely must afford the student to whom it is provided equal opportunity to achieve equal results, gain equal benefit, and reach the same level of achievement.

An appropriate integrated setting is one that does not unduly segregate or subject an otherwise qualified individual with a disability to different or separate treatment in the delivery of aid, benefits, or services. An integrated setting is one in which individuals both with or without disabilities can participate in and/or receive services together.

Programs for students include, but are not limited to: academic majors and degree plans (including coursework); counseling; advising; financial aid; physical education; athletics; recreation activities; transportation; student organizations; placement; field trips; and any other programs offered by the College.

Undue hardship is defined by the ADA as an action that is "excessively costly, extensive, substantial, disruptive, or that would fundamentally alter the nature or operation of the business."

Under the ADA, "direct threat" means a significant risk of substantial harm to the health or safety of the individual or others that cannot be eliminated or adequately reduced by reasonable accommodation.

EXAMPLES OF SERVICES AND ACCOMMODATIONS

The College will determine what constitutes an effective and reasonable accommodation on an individual, case-by-case basis. Types of accommodations may include equipment, specially trained personnel, general student services, referral services, materials in alternative formats, accommodations for assistive dogs, and mobility assistance. Except in emergency situations, carrying a mobility-impaired individual will not be considered an appropriate or reasonable accommodation. Personal assistance, such as feeding and personal hygiene, is not considered a service accommodation.

The following are some examples that may be required accommodations for individuals with disabilities:

  • Deaf and Hard of Hearing: Qualified licensed interpreters for classes and College-sponsored events, closed caption decoders, note-taking assistance, appropriate testing modifications, peer tutors (for reading, writing and math) and Communication Access Real-Time Transcription (“CART”).
  • Physically Disabled: Appropriate referral for issues of architectural access, adaptive equipment or classroom modifications, mobility assistance, allowance for -service animals, writing assistance, note-taking assistance.
  • Visually Impaired or Blind: Visual scanners, note-taking assistance, appropriate testing modifications, taped textbook service, peer tutors (for reading, writing and math), reading and/or writing assistance, alternative format materials such as Braille or large print.
  • Learning Disabled: Appropriate test accommodations, peer tutoring (reading, writing and math), tutoring referrals, taped textbook service, reading/writing assistance, note-taking assistance, appropriate classroom/program accommodations indicated in diagnostic assessment documents.

III.    RIGHTS AND RESPONSIBILITIES

The rights and responsibilities of students and the College in regard to obtaining and providing reasonable accommodation pursuant to these Guidelines are outlined in a separate document entitled “Rights and Responsibilities of Disabled Students.” That document can be found on the College’s website at www.pima.edu/current-students/disabled-student-resources/rights-and-responsibilities.html. Printed copies of this document are available in the DSR Office and from DSR Specialists at each of the College’s campuses. Any questions regarding the rights and responsibilities of either a student or the College-should be directed to the DSR Office at 206-6688 or the ADA/504 Coordinator at 206-4539.

IV.    DISABLED STUDENT RESOURCE PROGRAM

The Disabled Student Resource Program (DSR) is the office designated to provide accommodations and services, resources, and programs to facilitate equal learning for disabled students at the College. Among other things, DSR will perform the following functions in meeting the College’s obligations under the Rehabilitation Act and ADA:

  • Maintain medical records related to a student’s disability and student requests for accommodation;
  • Consult with and assist students with disabilities, or persons assisting such students, when requested;
  • Review student accommodation requests and consult with relevant departments when determining reasonable accommodations;
  • Determine whether an individual is a qualified individual with a disability, whether the individual is “otherwise qualified” to participate in a service, program, or benefit of the College with or without a reasonable accommodation, whether the individual is entitled to an accommodation, and, if so, the nature of the accommodation;
  • Provide and arrange, or coordinate, the provision of reasonable accommodations;
  • Review all decisions of unit administrators, supervisors, faculty, or department heads that conclude that a proposed accommodation will result in an undue financial hardship, a fundamental alteration of a program or activity, or will create a direct threat;
  • Assist in ensuring access to websites, web-based courses, distance learning, and technology in libraries, computer labs, and other student service sites;
  • Provide input in the review of all blueprints, whether for new construction, alteration, or renovation projects, to determine compliance with the ADA Accessibility Guidelines and monitor all construction projects;
  • Provide technical assistance to the campuses on barrier removal, modification, or substitution of alternate paths of travel or location of activities.

V.      ELIGIBILITY REQUIREMENTS

5.1     Eligibility

DSR applicants must be admitted or enrolled College students and they must provide DSR with qualifying disability documentation verifying the nature and extent of the disability prior to receiving any accommodations DSR Specialists are responsible for evaluating disability documentation and determining accommodation eligibility.

All documentation must be provided to DSR on professional letterhead and contain the dates of assessment, signatures, titles, and license/certification numbers of the diagnosing professionals.  Diagnoses of disabilities that do not contain the required information may not be used for determining eligibility for academic accommodations. DSR reserves the right to request reassessment when questions arise regarding previous assessment or previous service provision.

5.2     Confidentiality

All information obtained in the process of determining whether a student is a qualified individual under Section 504 or the ADA, and in determining effective accommodations for an individual is considered confidential. DSR shall maintain all information and records related to disability and requests for accommodation and ensure they are confidential and not shared except where disclosure is required by law or is necessary to facilitate legitimate College processes.

Qualified interpreters provided by the College shall adhere to confidentiality in accordance with the Registry of Interpreters for the Deaf (RID) Code of Ethics.

To ensure confidentiality, all medical and/or psychological documentation should be addressed directly to the requesting DSR Specialist and the envelope marked as "Confidential" by the sender.

VI.    STUDENT REQUEST FOR ACCOMMODATION

Students are strongly encouraged to make a request for accommodation at the earliest opportunity possible. While students may request an accommodation, or the need for one, at any time, the College cannot guarantee that an accommodation will always be immediately available.  The College will make every effort, however, to provide students with the appropriate and/or requested accommodation as quickly as practicable under the circumstances.

6.1     Request

Students who require accommodations must contact the DSR Office, located on each campus, in a timely manner. Contact should be made prior to the start of classes or as soon as the disability becomes known.

6.1.1  Special Procedures for Requesting Common Access

The College provides federally mandated interpreting services and other accommodations to qualified students who are deaf or hard of hearing. Services involve a variety of sign languages/signing systems/modes of communication and Communication Access Real-Time Transcription (CART) services. These services are provided by qualified hourly interpreters, or by agencies that, by contract, provide qualified interpreters to the College.

The College is responsible for funding all interpreting services related to all enrolled degree and non-degree students. These services are provided for all academic courses and course-related activities such as internships, field trips, and other student activities. If the academic or other student program includes expenses (e.g. travel, per diem, and lodging expenses) beyond the actual cost of the disability accommodation, the sponsoring department is responsible for the extra costs.

Students must provide required disability documentation, which includes a current audiogram.  Services shall be requested in advance through DSR and, specifically, through the student’s DSR Specialist.

All student interpreting services requests are processed through DSR’s Services Coordinators, who shall select a qualified interpreter, or interpreters, for each student who requires such services. Requests are processed on a first-come, first-served basis with a priority given to currently enrolled students. Questions about the College’s interpreting services may be directed to the Service Coordinators.

Students who require interpreting services for academic classes take priority over other student activities. Students must follow applicable DSR procedures in submitting all requests.

NOTE to continuing students at the College: To facilitate the availability of interpreting services from the first day of class, qualified students with a hearing-related disability must contact their DSR Specialist within ten days of enrolling to facilitate accommodations from the first day of class. If a student fails to follow this policy, DSR will make every effort to accommodate the student as close to the first day of class as possible, but will do so on a first-come, first-served basis.

NOTE to new students at the College: Students who are new to the College will enroll in classes during orientation. Therefore, new College students with a disability should attend an orientation session as early as possible upon admission to the College and complete all specified DSR procedures in order to facilitate the availability of services.

6.2     Procedure for Determining Eligibility

6.2.1  The student will be asked to provide documentation to a DSR Specialist regarding the disability and limitations on participation in courses, programs, services, jobs, activities, and/or use of facilities within 10 days of the request for accommodation.

6.2.2  The DSR Specialist will promptly review the documentation and determine whether a student has a disability and whether the student is eligible for reasonable accommodations.  (The College is required by law to provide reasonable accommodations to students identified as qualified under the ADA and Section 504 of the Rehabilitation Act. Denying an accommodation to a qualified student is considered a violation under the Act.)

6.2.3  If the initial documentation is incomplete or inadequate to determine the extent of the disability and reasonable accommodations, the DSR Specialist may require additional documentation. Any cost of obtaining documentation is the sole responsibility of the student. If the College desires a second professional opinion, the College will be responsible for the costs incurred in obtaining the opinion.

6.2.4  Pending receipt of documentation, DSR Specialists reserve the right on a case-by-case basis to approve interim services for accommodations for up to one semester until all paperwork is received and eligibility is determined. This shall not be construed, however, as an obligation for DSR to provide any interim service.

6.3     Notification

6.3.1  The DSR Specialist will notify the student, verbally and in writing, and in a timely manner whether the student meets eligibility requirements under the ADA/Section 504 and/or whether the student’s accommodation request has been approved or denied.

6.3.2  If a determination is made that a student does not meet the eligibility requirements under the ADA/Section 504 and/or a student’s accommodation request is denied, the reason(s) for the decision will be provided to the student in writing.

6.3.3  Denials based on "undue hardship" or "direct threat" must describe in detail the "undue hardship" or "direct threat" and state the reason for the denial and must be reviewed and approved by the Provost or designee.  

6.4     Student Service Plans

6.4.1  Once a student has been deemed “qualified” pursuant to the appropriate eligibility criteria, the student and the DSR Specialist will meet to discuss reasonable accommodations, academic adjustments, and/or auxiliary aid or services, as applicable.

The College will provide reasonable accommodations, academic adjustments, and auxiliary aids and services as needed by the student in order to afford him/her an equal opportunity to participate in the College’s programs, activities and services (including extracurricular activities). With respect to auxiliary aids and services, the College shall give primary consideration to the requests of the student including the specific sign language/signing system/ mode of communication requested by the student.

6.4.2  Consultation with faculty, staff, and outside professionals regarding essential elements and reasonable accommodations will occur in situations that are new, complex, or sensitive.

6.4.3  The DSR Specialist will prepare the service plan for the student, outlining the provision of reasonable accommodations, and will present the plan verbally and in writing to the student. The following items will be addressed in the plan:

  • What accommodation(s) will be provided.
  • Why they will be provided (the disability accommodated).
  • When and where they will be provided.
  • Who is responsible for providing them.

6.4.4  Once the plan is developed, the student will be given a letter to give to the faculty outlining what accommodation(s) are to be provided to the student by the faculty. The service plan and a copy of any letters to faculty concerning accommodations to be provided to the student shall be placed in the student's DSR file that is maintained by the DSR department.

6.4.5  The DSR Services Coordinator will be responsible for scheduling auxiliary aids and personnel supported services identified in the service plan.

6.5     Implementation

6.5.1  Implementation is the responsibility of the instructor and/or service/activity area affected by the scheduled accommodation or adjustment. The instructor will be notified, in writing, of the accommodation plan by the DSR Specialist. A copy of the accommodation plan may also be forwarded to the appropriate Department Chair if needed.

6.5.2  DSR Specialists and the DSR Services Coordinator will be available to discuss auxiliary aids, professional services scheduling, course/program adjustments, and alternative formats with the instructor if clarification of the accommodation and/or adjustment is needed.

6.5.3  The student may elect to confirm the service schedule and availability of aids or services with the DSR Specialist and/or DSR Services Coordinator.

6.5.4  The student is responsible for notifying a DSR Specialist when accommodations or services need to be changed. Any requested change must be supported by the appropriate medical documentation, if applicable.

6.5.5  A student who is unable to resolve a problem related to ADA/504 services may file a grievance utilizing SPG 1501-AG (Disabled Students’ Complaint Procedure).

6.6     Monitoring

The DSR Specialist assigned to the student will be responsible for verifying that the student is receiving the accommodation(s) and/or adjustment as outlined in the plan and recorded on the "Service Request Form" and faculty letter.

VII.   OTHER CONSIDERATIONS

7.1     Faculty Responsibilities

7.1.1  Faculty members will not contest the existence of a disability if it has been properly documented and formal notification provided. Faculty members will be expected to assist with the provision of reasonable accommodations when appropriate and necessary. (The College is required by law to provide reasonable accommodations to students identified as qualified under the ADA and Section 504 of the Rehabilitation Act. Denying an accommodation to a qualified student is considered a violation under the Act.)

7.1.2  Faculty members are not expected to compromise course expectations or quality of student work in the provision of accommodations or adjustments, but are expected to provide the accommodations or adjustments deemed reasonable to provide an equal opportunity for a student with a disability to meet course expectations.

7.1.3  Each syllabus will include a statement notifying students with disabilities of the procedures to request accommodations.

For example: "Pima Community College complies with the provisions of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. To receive prompt accommodation, students with disabilities who require special accommodations should directly contact the Disabled Student Resources Office as soon as possible."

7.1.4  Faculty who receive student requests for accommodations or adjustments will immediately refer students to the DSR Office for formal processing and a determination of eligibility. The faculty member will not make any determination of eligibility for or appropriateness of accommodation requests.

7.1.5  Faculty members will meet with a DSR Specialist, DSR Services Coordinator, and/or the student to discuss essential course elements and reasonable accommodations in situations that are new, complex or sensitive.

7.2     Faculty Disputes Regarding Particular Accommodations to Students

7.2.1  A faculty member may file a written dispute with the Provost that any accommodation is a direct threat or fundamentally alters the nature of the faculty member’s course. The Provost or her or his designee will review the matter and make a final decision regarding the accommodation.   

7.2.2  A faculty member will be required to provide the accommodation until a final decision is reached in the dispute process.

7.3     Facilities

7.3.1  The College will ensure the systematic removal of physical obstacles that most directly impact students, employees and visitors. The removal of barriers to accessibility of programs and services includes the general areas of exterior routes and parking, classroom buildings, office buildings, laboratories, shops, athletic facilities, recreational facilities, art/ performance facilities, student centers, libraries, and administrative offices.

7.3.2  Accommodations that involve structural or physical barrier removal will require evaluation by the College's AVC of Facilities. The coordination and implementation of the accommodation will be the responsibility of the AVC of Facilities.

7.3.3  Program accessibility is the responsibility of each Campus President. College classes, programs, and activities that are held in leased public and private facilities will be reviewed by campus personnel to ensure accessibility for individuals with disabilities.  Contractual and/or lease agreements for such facilities will reflect compliance efforts to ensure accessibility. Appropriate language which ensures accessibility issues are addressed in agreements will be reviewed by the Purchasing, Grants and Contracts Department prior to a College designee finalizing any such agreement or contract.

VIII.  REPORTING

8.1     DSR Specialists and the DSR Services Coordinator will provide performance reports to the Provost annually. Information in an annual report will include: (1) the number of accommodation requests made, (2) the outcome of such requests, (3) the types of accommodations or adjustments provided, (4) expenditures for accommodations or adjustments, (5) the time taken to process the requests, and (6) the time taken to implement the accommodations or adjustments.

8.2     DSR Specialists will also develop reports, as needed, for campus related reporting requirements.

IX.    TRAINING

9.1     DSR staff will provide training and/or education sessions regarding student accommodation issues for campus faculty, staff (exempt and non-exempt), supervisors, and administration on a regular basis as well as the general public when appropriate.

X.      COMMUNICATION

Information pertaining to DSR services and resources will be publicized and made known on all campuses and to all students. Brochures and other types of materials will be developed to explain student rights and responsibilities under the ADA and Section 504, and to explain College policies and procedures for accommodations. Copies of these Guidelines are available on the web at: http://www.pima.edu/policies/standardguidlines/PSC-1501-AD.shtml and printed copies may be obtained from DSR and the ADA/504 Coordinator.

XI.    STUDENT SAFETY

DSR Specialists will develop action-plans for students with disabilities that may affect their ability to exit a building during an emergency (e.g. when elevators may be unavailable or unsafe.)

Due to the constant movement of students on a campus, the action plan may involve designating responsibility to classroom instructors, maintenance staff, support staff, and/or other College personnel as assistance providers for unaccompanied individuals with disabilities in emergency situations.