Procedures P-V-1.30 Procedures for UMGC Policy on Student Reasonable Accommodation

For UMGC to arrange for the accommodations that will best meet students’ needs, students will submit a detailed request for accommodations along with clear documentation of the disability or chronic medical condition.

1. Reasonable Accommodation Request
   1. The following is a brief overview of the process for requesting accommodations.
      1. The student will complete and submit the Accessibility Services Student Intake form and submits documentation.
      2. After reviewing the intake form, Accessibility Services will email the student next steps. If documentation is still needed, the email will include a request for documentation. If documentation has been received, the email will include a request to conduct an intake meeting with a scheduling link.
      3. The student will schedule an intake where the functional impact of their disability is discussed and an accommodation plan is drafted.
      4. Accessibility Services will send a draft accommodation letter to the student for review. The student may suggest edits, which are reviewed by Accessibility Services. If no edits are necessary, the student will respond to the email with their acknowledgement and approval, and the letter is finalized.
      5. The student will submit a request to have their accommodation letters distributed to faculty members for upcoming courses. This step is repeated before the start of each term that a student registers for courses (fall, winter, spring, and summer).
      6. Accommodation letters are distributed via email to the instructor, student, and academic program supervisor (e.g., Portfolio Director) at least one week before the start of the course or as soon as possible (typically within 48 business hours*) if the request is submitted after the start of the course.
      7. Accommodations are not retroactive and begin on the day the instructor is notified by Accessibility Services.
   2. On the Student Intake Form, the student will describe the specific accommodation needs and return the form to Accessibility Services. Disability Supporting Documentation should be submitted to Accessibility Services as soon as possible (we recommend within 10 business days* to ensure accommodations are received in a timely manner).

   3. Documentation should show that the student has a disability that currently or permanently causes an impairment.

   *This timeframe includes Monday through Friday between 9 a.m. and 5 p.m. Eastern time, excluding weekends, University holidays, or University planned and unplanned closures.

2. Accommodation Determination
   1. Accessibility Services will review the student’s accommodation request and engage the student in an interactive dialogue to determine and implement a reasonable accommodation.
   2. During the communication process, Accessibility Services will consult with relevant faculty and staff and will conduct a student intake, and accommodations will be applied based on the discussion between Accessibility Services and the student. Occasionally, other departments, a third-party vendor, or outside disability-related organizations may also be consulted depending on the nature of accommodation being sought.
   3. All accommodation requests are reviewed on a case-by-case basis and may be implemented in a specific course or courses. In other words, an accommodation may be implemented in a specific course due to the nature of the assignments, assessments, or course materials but may not apply to other courses or may not be considered reasonable due to the course or program objectives.
3. Implementation
   1. Once a student completes the intake process, they are actively registered with Accessibility Services. Each term in which they are enrolled in classes (e.g., fall, winter, spring, or summer), students will request that their accommodation letters be distributed in order to begin receiving accommodations in the new courses.
   2. Accessibility Services will collaborate with stakeholders and attempt to provide reasonable accommodations within ten (10) business days after receiving the documentation needed to support a request.
   3. If a student believes they have been denied reasonable accommodations by Accessibility Services, they may appeal the decision by contacting the Director of Accessibility Services. If they are unable to resolve the concern, the student may contact the ADA Compliance Officer. An appeal differs from a grievance.
      1. Appeals are appropriate when a student complaint relates to an accommodation approval.
      2. Grievances are appropriate when a student complaint relates to accommodation implementation.
   4. If a student believes that reasonable accommodations are not being implemented by UMGC (e.g., by a program, by an instructor, or at an event), the student should contact their accommodation manager in the Accessibility Services office immediately. If the accommodation manager is unable to resolve the concern, students are encouraged to follow the informal grievance process by contacting the Director of Accessibility Services at accessibilityservices@umgc.edu. However, students may opt to go directly to Fair Practices. The Fair Practices Officer can be contacted directly at fairpractices@umgc.edu.
   5. Faculty members are responsible for reviewing accommodation letters upon receipt and implementing the accommodations immediately. Any questions or concerns about whether an accommodation fundamentally alters the course or program should be directed to Accessibility Services, and the academic program supervisor (e.g., Portfolio Director) should be copied on these communications. Accessibility Services has a responsibility to respond to these communications in a timely manner. The student should not be included in the communication until the question or concern has been resolved. If Accessibility Services is unable to resolve the concern, the ADA Compliance Officer should be contacted immediately.
   6. Temporary Accommodations: The ability for the University to implement temporary accommodations does not guarantee that they can be provided long term. The process for requesting temporary accommodations is the same as requesting permanent accommodations. However, when accommodations expire, the interactive process will need to be revisited to determine if additional or different accommodations are needed.
      1. Implementing a temporary accommodation may occur when:
         1. time is needed to research a permanent accommodation solution, to acquire equipment, or to arrange a service;
         2. it is necessary to test an accommodation to determine if it is effective;
         3. the medical condition is temporary but sufficiently severe enough to entitle the student to an accommodation (e.g., during surgery recovery); or
         4. it is necessary to avoid temporary adverse conditions in the educational environment.
4. Exceptions, Waivers, and Substitutions
   1. The process to request a course substitution or waiver due to the existence of a disability is initiated through Accessibility Services as part of the Accommodation Request. Accessibility Services will collaborate with the Academic Department to determine whether a substitution or waiver is an appropriate accommodation. These requests are handled on a case-by-case basis and may take longer than the process outlined in the associated policy.
   2. To be eligible for consideration for a course substitution, the student will need to provide Accessibility Services with documentation from a certified professional, substantiating a disability and documenting its specific impacts on the student’s ability to complete the course. The proposed course substitution cannot constitute a fundamental alteration of the student’s academic program. The proposed course substitution must satisfy the degree requirements for a student’s academic program.
   3. In the case when a course substitution and/or waiver is not approved, Accessibility Services will communicate with the student to discuss and explore alternative accommodations.
5. Grievance Procedures

   1. Students who believe that, in violation of this Policy, they have been subjected to discrimination, harassment, or retaliation due to their disability or who believe their reasonable Accommodation Plan is not being implemented, may file an informal grievance with the Director of Accessibility Services at accessibilityservices@umgc.edu. Formal grievances may be filed with Fair Practices, a unit within the Office of Community Engagement & Opportunity. These complaints can also be directed to the U.S. Department of Education. Contact information for these offices is below:

      UMGC Fair Practices
      3501 University Boulevard East
      Administration Building
      Adelphi, MD 20783
      Phone: 800-888-8682 ext. 17955
      Email: fairpractices@umgc.edu

      External Complaints
      Students may also file a Complaint externally by contacting:

      U.S. Department of Education
      Office for Civil Rights
      Lyndon Baines Johnson Department of Education Bldg.
      400 Maryland Avenue, SW
      Washington, DC 20202-1100
      Email: OCR@ed.gov

   2. Time Limits

      Complaints of discrimination or retaliation in violation of this Policy must be made to Fair Practices within thirty (30) calendar days following an incident of discrimination or retaliation. Fair Practices may waive the time limit upon a showing of good cause. Complaints must be raised with the Office of Civil Rights within 180 days.

6. UMGC’s Responsibility

   UMGC remains dedicated to removing barriers and ensuring access for all students and applicants who engage with our systems. At times, accommodations may be needed to ensure accessibility while UMGC works to correct inaccessible course content. Students are encouraged to report any accessibility barriers they encounter via email to adacompliance@umgc.edu. For more information about ADA compliance, visit UMGC ADA Compliance.

7. Related Policies and Resources
   1. UMGC Policy V-1.30 Student Reasonable Accommodation
   2. For more detailed procedures and forms, visit UMGC Accessibility Services.