Pima County Community College District Regulation

II. Policy of Nondiscrimination

It is the policy of Pima County Community College District to comply with the Americans with Disabilities Act (ADA) of 1990 and Section 504 of the Rehabilitation Act of 1973 as amended, as well as other applicable federal and state laws and regulations that prohibit discrimination on the basis of disability. No qualified person will, because of disability, be denied access to, participation in, or the benefits of any program, activity, or service offered by the College.

The College will make every effort to (1) ensure that qualified individuals with a disability are provided a reasonable accommodation, and (2) promote respect for the dignity and equal treatment of individuals with disabilities.

III. ADA/504 Executive Committee

The ADA/504 Executive Committee is charged with oversight of the College's self-evaluation process and monitoring of the College's compliance efforts regarding the ADA and Section 504 of the Rehabilitation Act as amended. Further, the Executive Committee will ensure completion of all projects included in the College's ADA Transition Plan.

The Committee is chaired by the Senior Vice Chancellor. Membership of the Committee includes: (1) One Campus President, (2) Vice Chancellor for Finance and Administrative Services (3) Assistant Vice Chancellors from Educational Services, Administrative Services and Facilities, and Vice Chancellor for Human Resources, (4) EEO/Affirmative Action Officer, (5) ADA/504 Officer, (6) ADA Human Resources Coordinator, (7) ADA Facilities Coordinator, (8) Lead Campus 504 Student Coordinator, (9) one ADA Employment and Facilities Coordinator, and (1) one DSR Specialist.

IV. Compliance Mechanism

A College-wide structure has been developed to ensure compliance with the ADA and Section 504. The structure will be comprised of designated district personnel, and designated and assigned campus personnel who will have key roles and responsibilities in ensuring compliance in the accommodation request process for employment and student related matters. Designees' ADA and/or 504 responsibilities will become part of the individual's regular job duties.

A. District Roles and Responsibilities

The College District Office will have designated individuals involved in matters related to ADA and 504 compliance. Designated positions include: *ADA/504 Officer *ADA Human Resources Coordinator *ADA Facilities Coordinator *College 504 Program Coordinator

The ADA/504 Officer will have responsibility for reviewing and monitoring the College compliance mechanism. Accommodation requests, complaints, implementation issues, budget issues, funding review and approval processes, ADA and 504 Coordinator training, and technical assistance to Coordinators will be included in these monitoring responsibilities. This position will also coordinate the College's annual evaluation and reporting process for ADA and Section 504. Findings will be forwarded to the ADA Executive Committee by the ADA/504 Officer.

The ADA Human Resources Coordinator will be responsible for evaluating and establishing eligibility for all employee and applicant requests for accommodation and/or adjustment initiated at the District office. Training and development of human resources staff in ADA employment and accommodation compliance issues is the responsibility of this position. The ADA Human Resources Coordinator will coordinate the efforts of and provide technical assistance to ADA Employment and Facilities Coordinators at each of the campuses, and will also provide annual evaluation and performance reports to the ADA/504 Officer.

The ADA Facilities Coordinator will be responsible for providing technical assistance and guidance to district office personnel whenever an ADA accommodation is identified as requiring structural and/or equipment modifications. The ADA Facilities Coordinator will also provide technical assistance and guidance to campus-based ADA Employment and Facilities Coordinators. The ADA Facilities Coordinator will provide annual evaluation and performance reports to the ADA/504 Officer.

The College 504 Program Coordinator will be responsible for monitoring and evaluating the delivery, consistency and quality of services for students. The College 504 Program Coordinator will work in tandem with the Lead Campus 504 Student Coordinator to implement and oversee quality of service issues related to education and training for faculty and staff as outlined in the College's ADA/504 Education Plan. The College 504 Program Coordinator will be responsible for providing annual evaluation and performance reports to the ADA/504 Officer.

B. Campus Roles and Responsibilities

Each campus will have designated as well as assigned individuals involved in matters related to ADA and 504 compliance in the delivery of College services, and student and employment related matters.

Designated Positions Include:

• ADA Employment and Facilities Coordinators
• Lead Campus 504 Student Coordinator

Assigned Positions Include:

• Disabled Student Resource (DSR) Specialists
• Disabled Student Resource (DSR) Services Coordinator

Each campus will have a designated ADA Employment and Facilities Coordinator. Each Employment and Facilities Coordinator will be responsible for work accommodation or adjustment requests, equipment and structural modification requests, and provision of training, technical assistance, and guidance for campus employees. ADA Employment and Facilities Coordinators will provide ADA evaluation and performance reports on an annual basis to the College's ADA/504 Officer.

The Lead Campus 504 Student Coordinator will be responsible for operationalizing the campus-based DSR programs and providing technical assistance, guidance, and conflict resolution services to Campus Disabled Student Resources (DSR) Specialists and the DSR Services Coordinator in matters related to delivery of services in accommodation requests for students. The Lead Campus 504 Student Coordinator will work in tandem with DSR Specialists to provide education and training for faculty and staff as outlined in the Colleges ADA/504 Education Plan. The Lead Campus 504 Student Coordinator will oversee the ADA/504 student accommodations budget and will also be responsible for collecting and compiling data and information from DSR Specialists and the DSR Services Coordinator and forwarding an annual evaluation and performance report to the College 504 Program Coordinator.

Campus Disabled Student Resource (DSR) Specialists will be assigned to campuses in regular, full- or part-time positions to specifically address ADA/504 accommodation and compliance matters for students. DSR Specialists will be responsible for intake, evaluation, recommendation, negotiation, implementation, coordination, and monitoring of students' academic, service, activity, and/or facility accommodation requests, as well as advocating accommodation requests on behalf of students. Annual evaluation and performance reports will be provided to the College 504 Student Coordinator by each of the DSR Specialists.

DSR Specialists will, upon request, provide technical assistance in the evaluation of proof of disability documentation for employee accommodation requests.

In addition, DSR Specialists will provide on-campus technical assistance and training for faculty, staff, and administrators regarding ADA/504 compliance and accommodations.

A Disabled Student Resource Services Coordinator will be a regular, full-time position assigned to the ADA lead campus to coordinate the provision of auxiliary aids and services for all DSR Specialists and District sponsored activities such as the performances at the Center for the Arts, non-credit public interest classes, public meetings, and job fairs. The DSR Services Coordinator will also schedule and assign interpreters, note takers and readers for classrooms, laboratories, and other College sponsored activities where and when needed.

Auxiliary aids, notetakers, interpreters, and readers will be made available to DSR Specialists through a central inventory and personnel roster that will be maintained by the DSR Services Coordinator. The DSR Services Coordinator will provide annual performance reports of services and equipment utilization to the College 504 Student Coordinator.

V. Self-Evaluation Process The College will develop an on-going self-evaluation plan to review its programs, services, and facilities. The College will also develop Standard Practice Guides, which describe the specific methods, and processes to initiate, maintain, and/or improve compliance with ADA and 504 regulations.

The self-evaluation process will provide information by which the College can determine improvements and successes, as well as needed improvements, in its programs, services, facilities, and activities for disabled individuals.

VI. Accommodation Requests

Standard Practice Guides (SPGs) will be developed by the Equal Employment Opportunity/Affirmative Action Office for employee, applicant, and student requests for accommodation. The SPGs include descriptions of the College-wide structure that will initiate, implement, maintain, and monitor compliance with the ADA and Section 504. SPGs will also include roles and responsibilities of District and Campus designees for ADA and 504 accommodation requests.

VII. Accommodation Disputes

Issues involving effectiveness, reasonableness, or implementation of the guidelines will follow the procedures outlined in SPG-1501/AC, Reasonable Accommodation Guideline for Employee/Applicants, or SPG-1501/AD, Reasonable Accommodation Guideline for Students.

Issues involving substantial change in the nature or fundamental alteration of the program or course will follow the procedure outlined in SPG-1501/AD, Reasonable accommodation Guideline for Students.

In matters of disputes related to undue hardship decisions, or direct threat decisions, the Chancellor or his designee, in conjunction with legal counsel, will provide final decisions as outlined in SPG-1501/AC, Reasonable Accommodation Guideline for Employee/Applicants, or SPG-1501/AD, Reasonable Accommodation Guideline for Students.

If a request for accommodation by a student or an employee who followed the appropriate SPG is denied based on the determination that the individual is not qualified under federal and/or state regulations or internal policy, the internal process is finalized.

Issues involving allegations of discrimination or harassment based on either the individual's disability or implementation of an accommodation for the individual will be processed through the College's internal discrimination complaint procedure as outlined in SPG-1501/AA, ADA & Equal Opportunity/Discrimination Complaint Procedure.

The Equal Employment/Affirmative Action (EEO/AA) Office has oversight and monitoring responsibility for this complaint process.

VIII. Notice to the Public

A. All college publications and notices will state that accommodations or materials in alternate format are available through the college when an advance notice is given. Normally this notice should be five (5) working days. This information will be incorporated into the College Identity Standards Manual and will be reviewed annually by the EEO/AA Office. Updates will be made as needed by EEO/AA staff.

B. Various College and campus publications will identify by name, location, and telephone number, all individuals designated to assist with accommodation requests and with applicant, employee and student complaints.

Campus DSR Specialists and EEO/AA Office staff will review and update information on an as needed basis, and at least once annually.

C. The College will post notices and develop materials to inform employees, students and the general public about availability of accommodations, appropriate processes and procedures, and the College's commitment to ADA/504 compliance.

IX. Evaluation and Reporting

The College has developed an ADA/504 Evaluation and Reporting Standard Practice Guide (SPG) by which the College will review, monitor, evaluate, and report its compliance efforts under the ADA and Section 504. The following areas will be included in the SPG:

A. Transition Plan/Self Evaluation Survey

A transition plan for employment, programs and services was developed from the original self-evaluation study report. The College will conduct a self-evaluation survey at least every three (3) years to measure improvement in the knowledge of employees regarding ADA/Section 504 issues.

B. Educational Plan

A district wide educational plan will be developed under the direction of the ADA Executive Committee. The plan will include a detailed description of the mandatory professional development and training program for College personnel.

C. Employment Practices

The College will institute employment practices that ensure no qualified person is subjected to discrimination in employment or employment-related activities on the basis of a disability or perceived handicap. The Standard Practice Guide will describe the self-evaluation and reporting process for College related recruitment, testing, hiring, promotion, compensation, training, and other employment-related procedures and policies.

D. Academic Programs, Sponsored Activities and Student Services

The College is committed to the provision of educational and recreational opportunities for all individuals who may benefit from its programs, services, and/or activities. The Standard Practice Guide will describe the self-evaluation and reporting process for College policies and procedures related to recruitment, admission, academic program, occupational training, counseling, advising, financial aid, and recreational activities and services of the College.

E. College Facilities and Equipment

The systematic removal of physical obstacles that directly impact students, applicants, employees, contractors, and visitors will be ensured through a prioritization plan for and annual review of College facilities and equipment. A Transition Plan, completed in 1995, specifies the activities and plan for the College. The Standard Practice Guide will describe the self-evaluation and reporting process for College ADA and 504 activities including those related to modifications, adjustments, equipment and aids.

X. Privacy and Confidentiality

Each College designee or regular employee who is involved in ADA and Section 504 related cases will maintain a high standard of professional conduct regarding privacy and confidentiality. The contents of a disabled individual's medical records, psychological reports, rehabilitation reports, and/or any other information of a personal or medical nature will be discussed only on a need-to-know basis with other affected College personnel, medical personnel, and/or rehabilitation specialists or case managers.

XI. Budget and Funding

A. Funding for Accommodations

The Lead Campus 504 Student Coordinator will have monitoring responsibility for the student accommodations budget to ensure student accommodations are effective and adequate. The Lead Campus 504 Student Coordinator will have the responsibility for ensuring that the funding and federal reporting requirements are met for all classroom accommodation activities of the District.

B. Accounting of Expenditures

The ADA/504 Officer will have budget oversight for the activity and resources of the ADA program as it relates to employee accommodations. The ADA/504 Officer will have responsibility for ensuring that the funding and federal reporting requirements are met for all non-classroom accommodation activities of the District.

XII. CENTRAL REPOSITORY

The Affirmative Action Office is responsible for maintaining documentation regarding the ADA and Section 504 of the Rehabilitation Act. All documentation related to applicant and employee accommodations, including proof of disability, will be forwarded to the EEO/AA office for retention when an accommodation has been implemented or denied and when a dispute has been resolved.

Student documentation regarding accommodations requests, including proof of disability, will be retained in the appropriate Disabled Student Resource Program office. The West campus (as the Lead Campus) will be the central repository for any student records no longer utilized by DSR personnel. However, if there is a dispute by a student or student's instructor regarding "undue hardship", "direct threat", or "fundamental alteration" or "substantial change in nature of the course or program", copies of all documentation related to the dispute will be forwarded to the ADA/504 Officer. All documentation received by the College will become the property of the College. Further, all documentation related to ADA and 504 accommodation requests or disputes will be treated as confidential, with access limited to ADA and 504 personnel and EEO/AA staff.

HyperLinks to Associated Documents

BP-4201, RG-4201/A, BP-3603, RG-3603/A