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Pima County Community College District Standard Practice Guide

SPG Title: ADA & Equal Opportunity Evaluation and Reporting Guidelines for ADA/504 Compliance
SPG Number:  SPG-1501/AE
Effective Date: 8/18/97
Approval Date: 6/17/97
Review Date(s):   7/20/99
Revision Date(s):  7/20/99
Sponsoring Unit/Department:  EEO-Affirmative Action Office
Regulation Title & No.:  Standards for ADA/504 Compliance, RG-1501/A
Board Policy Title & No.: Affirmative Action/Equal Employment Opportunity, BP-1501
Legal Reference: American with Disabilities Act of 1990; Section 504 of Rehabilitation Act of 1973, as Amended
Cross Reference:  Resolution Directing Americans with Disabilities Act Compliance; Competitive Employment, BP-4201 and RG-4201/A; Disabled Student Resources, BP-3603 and RG-3603/A


GENERAL SCOPE

This guideline is established for the purpose of identifying and defining the methods and processes by which the College will record and evaluate compliance efforts in meeting the spirit and intent of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973, as well as assignment of responsibilities in the reporting and evaluation process.  The reporting and evaluation process will provide information by which the College can assess the effectiveness of the services provided, identify avenues for program improvement, and determine patterns and trends within the program.

DEFINITIONS

An individual with a disability is any person who: (1) has a physical or mental impairment which substantially limits one or more major life activities (e.g., performing manual tasks, walking, seeing, hearing, speaking, breathing, or learning); (2) has a record of such an impairment (e.g., medical history); (3) is regarded as having such an impairment (e.g., generally perceived by College personnel to be limited, impaired and/or disabled); or (4) is a recovering alcoholic or rehabilitating drug addict (but is not a current drug or alcohol user).  Also, any individual who has a relationship with or is a primary caregiver for a person with a disability is protected from discrimination under the ADA.

For reporting purposes, an individual with a disability is someone who has self-identified to DSR personnel or ADA human resources personnel in the accommodation request process.

A qualified person with a disability is a person with a disability who satisfies the requisite skill, experience, education, and other job related requirements of an employment position that is currently held or desired.  Further, a qualified person with a disability can, with or without reasonable accommodation, perform the essential functions of a position.

Reasonable accommodation is any modification or adjustment to a job, an employment practice, or the work environment that enables an individual with a disability to work at their fullest capacity and enjoy an equal opportunity for employment.

A reasonable accommodation or adjustment is not simply the "easiest" or "most desirable" accommodation, rather it must be an effective accommodation which provides the individual with a disability an equal opportunity to be considered for a job, to perform the essential functions of a job, and/or enjoy equal benefits and privileges of a service or job.

Examples of reasonable accommodations include but are not limited to: provision or modification of structures, equipment or devices; accommodation for use of needed assistive dogs, equipment or devices; extended testing time; provision of an interpreter or scribe; job restructuring; provision of written instructions; flexible work schedule; reassignment to a vacant position or modified duties; alternative work station or site; or reallocation of non-essential job functions.

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. 

SECTION I - SELF-EVALUATION SURVEY AND SURVEY RESULTS

The ADA/504 Executive Committee established that the College will conduct a self-evaluation survey at least once every three years to measure improvement in knowledge of College employees regarding ADA and Section 504 issues, and service improvement for individuals with disabilities.

1.1   The survey will be conducted under the direction of the ADA/504 Executive Committee and the ADA/504 Officer will monitor the survey process on behalf of the Committee

1.2   Results of the survey will be compiled and analyzed by the Institutional Research Office in coordination with the ADA/504 Officer.

1.3   The self-evaluation report will be prepared by the ADA/504 Officer and reviewed and approved by the ADA/504 Executive Committee.

1.4   The ADA/504 Executive Committee will provide recommendations for further program or service improvements based on the results of the self-evaluation survey as reported by the ADA/504 Officer.

1.5   The survey and resultant report will include all ADA/504 practices, programs and services throughout the College.

SECTION 2 - ANNUAL REPORT OF PERFORMANCE

Each year, the ADA/504 Officer will monitor the collection of summary reports from each of the ADA/504 Coordinators, DSR Specialists, and the DSR Services Coordinator.  The reports are due annually on September 1 to the ADA/504 Officer and will provide the College with an overview of compliance efforts in the implementation of practices outlined in the Employee/Applicant Standard Practice Guide and the Student Standard Practice Guide within the ADA/504 Compliance Program.

SECTION 3 - EMPLOYMENT PRACTICES

The ADA Human Resources Coordinator is responsible for an annual audit of the employment process and employment-related accommodations in the District Central Office (includes DSSC). For the period of July 1 to June 30.  ADA Employment and Facilities Coordinators maintain an on-going, annual record and audit of all employment-related accommodations processed at their individual campuses.  Results of the audits are summarized in reports provided to the ADA/504 Officer, due September 1 each year.  Included in the reports are summaries of the following:

3.1   Job Analysis: Job Specifications which do not include the essential duties, including physical and mental requirements, will be identified and updated throughout the year.  In addition, all positions open for recruitment, affected by a change of duties or responsibilities, or affected by revisions to development of a new class specification, will have essential duties as well as physical and mental requirements identified.  A summary of these activities will be reported annually by the ADA Human Resources Coordinator

3.2   Job Announcement: Essential functions of the job will be part of the job announcement.  In addition, a statement encouraging applicants "to contact the ADA Human Resources Coordinator if assistance is needed in the hiring process" will be included in each job announcement.  The implementation of this practice will be included in the annual report which will include the number of applicants as a whole, the number of applicants requesting an accommodation in the process, the number of applicants receiving an accommodation, and the types of accommodations provided by the human resources staff and/or the hiring unit.

3.3   Evaluation Criteria:  The ADA Human Resources Coordinator will review evaluation criteria to ensure that the application, supplemental questionnaire, minimum qualifications, preferences, testing requirements, and interview questions do not tend to screen out individuals with disabilities.   The results of these reviews will be recorded in the annual report.

3.4   Employment Testing and Accommodations: A review of performance tests, and accessibility to performance tests, will be reviewed by the ADA Human Resources Coordinator to ensure that the testing instrument and/or testing process measures an applicant's ability to do the job, not the ability to take a test.  Results of these reviews will be summarized in the annual report.

3.5   Employment and Testing Accommodations: Examples: The ADA Human Resources Coordinator will ensure that the following types of alternative formats and/or accommodations are made available to support the College's employment process for individuals with disabilities.  The utilization of these accommodations will be reported annually by the ADA Human Resources Coordinator.  They include but are not limited to:

  • Substitution of a written test for an oral test, or written instructions for oral instructions, for individual with impaired hearing;
  • Administration of a test in large print, or Braille, by a reader, or on a voice equipped computer for individuals with visual impairments;
  • Allowance for use of tape recorders, diction machines, or computers to record test answers for individuals with mobility impairments;
  • Provision of extra time (usually one-and-a-half time) to complete a test for individuals with certain learning disabilities or impaired writing mobility;
  • Simplified test language for individual who have limited language skills due to a disability;
  • Scheduled rest breaks for individuals with mental or physical disabilities that require such relief;
  • Ensured accessibility to a test site for an individual with a mobility disability and/or an individual who utilizes an assistive dog;
  • Individual testing accommodation, if group performance is not a key issue, for an individual who requires minimal distractions due to a learning disability.

3.6   Attendance and Leave Policies: On a case-by-case basis, exceptions to standard attendance and leave policies may be required to provide an reasonable accommodation for an employee.  (However, application of exceptions to these policies must be done in a consistent and fair manner by all departments and supervisors.)  These exceptions will be summarized and recorded in the annual performance report by the ADA Human Resources Coordinator for District Central Office personnel, and by ADA Employment and Facilities Coordinators on individual campuses and at the DSSC.

3.7   Workers Compensation Issues: A review of the inter-relationship of the College Workers Compensation Program and the ADA Program will be conducted annually by the ADA Human Resources Coordinator to identify and/or resolve possible conflicts regarding light duty obligations, return to work examinations, recovery after rehabilitation, off-the-job injuries, and any other classifications that may pose a conflict between the two programs.  A summary of the audit is included in the annual report.

3.8   Training Opportunities: The ADA Human Resources Coordinator will report on the College's efforts to provide equal access and equal opportunity for individuals with disabilities to participate in any/all training opportunities provided by the College.  ADA Employment and Facilities Coordinators will report on training opportunities provided on their individual campuses.  The reports will include any accommodations provided by the College to ensure equal access to training and in the most integrated settings possible.

3.9   Accessibility and Communication: The ADA Human Resources Coordinator and ADA Employment and Facilities Coordinators will audit and report on any barriers identified in the communication process between the human resources office or offices providing personnel-related services and individuals with disabilities.

3.10  Compensation: The ADA Human Resources Coordinator will conduct an annual audit of the compensation system to ensure that policies do not adversely affect employees with disabilities.  A summary of the audit will be included in the annual performance report.

3.11  ADA Training: The ADA Human Resources Coordinator will report any training activities provided throughout the reporting year to human resources staff concerning issues related to recruitment, testing, interviewing, pre-employment inquiries, selection committees, and accommodations.  The ADA Human Resources Coordinator and ADA Employment and Facilities Coordinators will report on any training provided to administrators, supervisors, and/or work units who requested ADA employment-related training/ education sessions during the reporting year.

3.12  Work Unit Training: The ADA Human Resources Coordinator will provide a summary of work unit training provided to District Central Office work units to sensitize employees to an accommodated employee's disability and accommodation.  ADA Employment and Facilities Coordinators will provide an annual report of work unit training provided on their individual campuses.

3.13  Employee Service Plans: The ADA Human Resources Coordinator will record and report on the creation and implementation of ADA Employee Service Plans for District Central Office personnel during the reporting year.  ADA Employment and Facilities Coordinators will report on the creation and implementation of ADA Employee Service Plans on their individual campuses.  Further, annual reviews of each ADA Employee Service Plan will be conducted jointly by the ADA Human Resources Coordinator or the ADA Employment and Facilities Coordinators and the appropriate supervisor.  The reviews will be recorded and reported on the annual performance report by the affected Coordinator.

3.14  Employee Disputes and Dispute Resolution: Employees may dispute the reasonableness, effectiveness, or timeliness of an accommodation through the ADA/504 dispute process (outlined in SPG-1501/AC).  A summary of the dispute and dispute resolution will be recorded by the appropriate ADA Coordinator on the annual performance report.

3.15  Supervisor Disputes and Dispute Resolution: Supervisors may dispute the reasonableness or effectiveness of an accommodation through the ADA/504 dispute process (outlined in SPG-1501/AC).  A summary of the dispute and dispute resolution will be recorded by the appropriate ADA Coordinator on the annual performance report.

Reporting outlines have been provided as part of this Standard Practice Guide.  The numerical sequence of items on the report outline correspond to the numerical sequence of items within this Guide.  ADA/504 Coordinators, DSR Specialists, and the DSR Services Coordinator will review the reporting outlines and guidelines during their specified training period as outlined in the ADA/504 Educational Plan.

SECTION 4 - FACILITIES

4.1   As outlined in the Facilities Transition Plan, 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 include 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.

4.2   Accommodations that involve structural or physical barrier removal will require evaluation by the Campus ADA Employment and Facilities Coordinator in conjunction with the College ADA Facilities Coordinator.  The coordination and implementation of the accommodation will be the responsibility of the ADA Facilities Coordinator, and these activities will be reported annually by the ADA Facilities Coordinator.  Location, type of accommodation, cost of accommodation, and whether the accommodation addressed student or employee needs will be recorded and reported.

4.3   College classes, programs, and activities that are held in leased public and private facilities will be reviewed to ensure accessibility for individuals with disabilities.  It is the responsibility of the Campus President to ensure off-campus sites and facilities meet ADA/504 compliance standards for program accessibility.  Contractual and/or lease agreements for such facilities will reflect language and efforts to ensure accessibility.  Appropriate language which ensures accessibility issues are addressed in agreements will be reviewed by the Procurement and Grants and Contracts Department.  Off-site lease activity will be reported by the ADA Employment and Facilities Coordinators on the annual report to the ADA/504 Officer.

SECTION 5 - DISABLED STUDENT RESOURCES PROGRAM

DSR Specialists and the DSR Services Coordinator will provide an annual report to the Lead Campus 504 Student Coordinator by August 1 each year.  The Lead Campus 504 Student Coordinator and the College 504 Program Coordinator will provide annual evaluation and performance reports to the ADA/504 Officer on September 1 each year.  The annual reports will provide the College with an indication of the types and levels of service provided between July 1 and June 30, and will also become a planning and evaluation tool for administrative decision making regarding program services, and personnel, facilities, and equipment needs.

5.1   Student Requests for Accommodation: DSR Specialists will record and report all students (unduplicated count) who contact the DSR office with a request for accommodation due to disability.

5.2   Eligibility Determination: DSR Specialists will record and report the eligibility determination for each student who contacts the DSR office with a request for accommodation due to disability.  Additionally, DSR Specialists will monitor and report on the number of calendar days between request for accommodation and receipt of documentation for eligibility determination.

5.3   Interim Accommodations: Students may be provided with interim DSR Services for up to 10 days pending receipt of documentation for eligibility determination.  The number of students receiving interim accommodations will be recorded and reported by DSR Specialists.

5.4   Notification: DSR Specialists will notify students, verbally and in writing, whether an accommodation request has been approved or denied.  Notification information (including number of calendar days between request for accommodation and notification and determination such as "not qualified" or "did not complete documentation requirements") will be recorded and reported.

5.5   If a denial of eligibility or accommodation is based on a "substantial change in nature" or "fundamental alteration" of the program or course, or "undue hardship", or "direct threat", the information will be recorded and reported by the College 504 Program Coordinator.

5.6   Dispute: A student may elect to file a dispute based on the adverse determination of eligibility for any of the reasons cited above in sections 5.4 and 5.5.  The Lead Campus 504 Student Coordinator will record and report the outcome of disputes for the annual report to the College 504 Program Coordinator and ADA/504 Officer.

5.7   Service Plan: When a student has been identified as qualified under Section 504, the student and a DSR Specialist meet to discuss reasonable accommodations and a student service plan.  The number of completed plans will be recorded and reported by DSR Specialists.

5.8   The DSR Services Coordinator will be responsible for scheduling auxiliary aids and personnel supported services in the service plan.  The DSR Services Coordinator will record and report (a) the number of calendar days from the receipt of request to implementation, (b) the type(s) of accommodations, equipment and/or aids provided, and (c) location of services.

5.9   Implementation: DSR Specialists will record and report the implementation scheduled classroom accommodations by faculty including (a) the number of calendar days between request for accommodation and implementation, and (b) the types of accommodations being provided.

5.10  Disputes due to reasonableness, effectiveness and/or timeliness of accommodations will be recorded and reported by the Lead Campus 504 Student Coordinator including the basis for the dispute and the outcome of the dispute.

5.11  The Lead Campus 504 Student Coordinator will also record and report on faculty disputes arising from the request for accommodation and/or student service plan.  A faculty member/instructor may dispute that the accommodation or adjustment will fundamentally change or alter the nature of the course or course standards, or that the accommodation will pose a direct threat to the student or others.  The Lead Campus 504 Student Coordinator will record and report the results of such disputes for the annual report forwarded to the College 504 Program Coordinator and ADA/504 Officer.

SECTION 6 - EDUCATIONAL PLAN AND ADA/504 TRAINING

The ADA/504 Educational Plan describes the efforts which will ensure that College employees receive appropriate and timely education or training sessions that are relevant to their responsibilities as College employees.  The ADA/504 Officer coordinates and monitors the district-wide training efforts.  An annual report of training/educational sessions will be provided to the ADA/504 Officer by ADA Employment and Facilities Coordinators, the ADA Human Resources Coordinator, the Lead Campus 504 Student Coordinator, and DSR Specialists.

6.1   ADA and 504 Coordinators: Training for ADA and 504 Coordinators is scheduled for 12 hours over four days and is facilitated by the ADA/504 Officer.  The ADA/504 Officer will maintain attendance rosters of training and include a summary of training activities with ADA and 504 Coordinators in the annual report to the ADA/504 Executive Committee.

6.2   DSR Specialists and DSR Services Coordinator: DSR Specialists and the DSR Services Coordinator receive six hours of training over two consecutive days.  The ADA/504 Officer facilitates these training sessions.  The ADA/504 Officer will maintain a roster of training participants and provide a summary of training sessions in the annual report to the ADA/504 Executive Committee.

6.3   Work Unit Training: Work unit training is provided when an employee with an accommodation joins a particular work unit.  Work unit training is facilitated by the ADA Human Resources Coordinator for the District Central Office (DCO), and by ADA Employment and Facilities Coordinators on campuses.  ADA Coordinators will maintain a roster of participation for each session provided and include a summary report in the annual report forwarded to the ADA/504 Officer.

6.4   Human Resources Personnel: The ADA Human Resources Coordinator provides ADA and 504 related training to human resources personnel in the DCO, DSSC, and on campuses.  A roster of participants for each session will be maintained by the ADA Human Resources Coordinator and a summary of training will be forwarded to the ADA/504 Officer annually.

6.5   College Administrators/Managers: College Administrators and Managers receive nine hours of training over three consecutive days.  ADA Employment and Facilities Coordinators and the ADA Human Resources Coordinator facilitate these training sessions.  ADA Coordinators will maintain rosters of each training session provided, and a summary report of training will be forwarded to the ADA/504 Officer annually.

6.6   Campus Department Chairs and Faculty: Campus Department Chairs and Faculty receive three hours of training during one day, facilitated by the Lead Campus 504 Student Coordinator and facilitated by DSR Specialists and the DSR Services Coordinator.  A roster of participants for each session will be maintained by the Lead Campus 504 Student Coordinator and training activities will be reported annually to the College 504 Program Coordinator and ADA/504 Officer.

6.7   Supplemental Work Unit Training: Work unit supervisors will receive a training/education session in ADA and/or 504 issues for their work unit.  These training sessions are requested through ADA Employment and Facilities Coordinators on the campuses and the ADA Human Resources Coordinator in the DCO.  Training sessions will be conducted by an appropriate ADA Coordinator unless a special request is made for a specific ADA or 504 Coordinator, the ADA/504 Officer, or DSR Specialists.  A roster of participants for each session will be maintained by the ADA Coordinators and a summary of training sessions will be forwarded to the ADA/504 Officer annually.

6.8   Tutors and Lab Aides: DSR Specialists and the DSR Services Coordinator will provide periodic training to tutors and lab aides to ensure familiarity with assistive devices and equipment as well accommodations for learning disabilities.  DSR Specialists will maintain a roster of training participants for each session and will provide a summary of training sessions to the ADA/504 Officer annually.

SECTION 7 - ACADEMIC AND NON-ACADEMIC PROGRAMS

The College will conduct an ADA/504 self-evaluation to determine the current status of compliance efforts in academic and non-academic program areas, as well as employment related issues.  Areas of concern, or areas for improvement, will be noted for each of the academic and non-academic program areas, and efforts to improve compliance efforts will be initiated by the College 504 Program Coordinator in conjunction with appropriate College personnel. The College 504 Program Coordinator will provide an annual summary report of activities and improvements.

A.    On a rotating basis, the College conducts an annual review of existing academic programs and services through the Program and Services Review schedule process.  During the review process, reviewers will ensure that efforts related to ADA and 504 compliance will be reviewed and evaluated.  Assurance of compliance efforts for ADA and 504 issues will be under the direction of the Assistant Vice Chancellor for Educational Services (the College 504 Program Coordinator) in conjunction with the Lead Campus 504 Student Coordinator.

B.    New academic programs have a formal process for implementation.  Assurance of compliance efforts for ADA and 504 issues will be under the direction of the Assistant Vice Chancellor for Educational Services (the College 504 Program Coordinator) in conjunction with the Lead Campus 504 Student Coordinator.

C.    Student services will be reviewed by the College 504 Program Coordinator on an annual basis to ensure ADA and 504 issues have been addressed and resolved within each service area.

7.1   The College 504 Program Coordinator will work with Institutional Research to develop appropriate review items under the annual program review process.  Summary reports for these items will be provided by reviewers to the College 504 Program Coordinator.  The College 504 Program Coordinator will include these items in the annual report to the ADA/504 Officer.  Items will include, but not be limited to:

  • accessibility of facilities for physically and visually impaired students
  • availability and use of assistive devices and aides for students
  • faculty implementation of DSR approved accommodations for students
  • faculty awareness of ADA and 504 standard practices

7.2   The College 504 Program Coordinator will work with the curriculum office to ensure that new occupational, academic, and transfer programs approvals include a review of prerequisites and standards that may inadvertently exclude individuals with disabilities from receiving the benefits of the new program.  Review items will include but not be limited to:

  • admissions testing which focuses on test taking ability (i.e. timed tests) rather than prerequisite knowledge or skills
  • performance of physical activities not normally associated with the occupation or profession
  • the ability to include alternative modes of instructional delivery that would accommodate individuals with disabilities
  • accessibility to facilities that will be designated for the course or program

7.3   Services provided by the College to students will be reviewed to ensure appropriate accessibility to physical resources, personnel, and assistance for completion of related paperwork, if needed.  The Lead Campus 504 Student Coordinator will coordinate with appropriate College personnel to ensure physical structures are accessible and personnel are trained to ensure compliance.  An annual report of these activities will be provided by the Lead Campus 504 Student Coordinator to the College 504 Program Coordinator and ADA/504 Officer.

SECTION 8 - AVAILABILITY OF EQUIPMENT AND AIDES

The DSR Services Coordinator will maintain an inventory of equipment and aides available to College students with disabilities on a district-wide basis. This information will be forwarded to the Lead Campus 504 Student Coordinator annually, by the DSR Services Coordinator, noting any additions and deletions to equipment, aides, personnel rosters, and resultant levels of service (volume of usage).  The Lead Campus 504 Student Coordinator will include this information on the annual report to the College 504 Program Coordinator and ADA/504 Officer.

SECTION 9 - BUDGET AND EXPENDITURES

9.1   The Lead Campus 504 Student Coordinator will provide the ADA/504 Officer with an annual report of expenditures related to accommodations for students with disabilities.

9.2   The ADA/504 Officer will maintain information related to the annual expenditures for employees and applicants receiving accommodations.

SECTION 10 - REPORTING MECHANISM

10.1  The ADA Human Resources Coordinator will provide an annual report to the ADA/504 Officer by September 1 each year for the reporting period July 1 through June 30.

10.2  ADA Employment and Facilities Coordinators will provide an annual report to the ADA/504 Officer by September 1 each year for the reporting period July 1 to June 30.

10.3  The College ADA Facilities Coordinator will provide an annual report to the ADA/504 Officer by September 1 each year for the reporting period July 1 to June 30.

10.4  DSR Specialists and the DSR Services Coordinator will provide annual reports for the reporting period July 1 to June 30 to the Lead Campus 504 Student Coordinator by August 1.  The Lead Campus 504 Student Coordinator will review the reports and include them in his/her annual report to the College 504 Program Coordinator and ADA/504 Officer by September 1.

10.5  The College 504 Program Coordinator will provide an annual report to the ADA/504 Officer by September 1 each year.

10.6  The ADA/504 Officer will compile the above listed reports into a central summary report, forwarded to the ADA/504 Executive Committee for review by October 1 each year.

10.7  The ADA/504 Executive Committee will forward a final report to the Chancellor's Cabinet by January 1 for review and dissemination.