Bryn Mawr College

Guidelines for Providing Accommodations

Contents

• Introduction
• Definition of Terms
• Rights and Responsibilities
• Eligibility Criteria
• Documentation Guidelines
  

  -  Documentation of an Attention Deficit/Hyperactivity Disorder

  -  Documentation of a Learning Disability

  -  Documentation of a Physical Disability or Chronic Medical Condition

  -  Documentation of a Psychological Disability
  
  

• Procedures

  -  Determining Appropriate Accommodations

  -  Requesting Accommodations
  
  

• Requests for Modifications in Housing Arrangements
  - Documentation Guidelines
  - Determination of Reasonable Modifications in Housing

• Policy Regarding Service Animals
• Disclosure and Confidentiality

• Complaint Resolution Procedures
  

• Emergency Evacuation Procedures for Students with Disabilities

Introduction

Bryn Mawr College welcomes the full participation of individuals with disabilities in all aspects of campus life.  The College is committed to providing equal educational opportunity for all qualified students with disabilities in accordance with Section 504 of the Rehabilitation Act of 1973 (504) and the Americans with Disabilities Act of 1990 as amended (ADAAA).  Students with access needs due to a learning, physical, or psychological disability are encouraged to contact Access Services as early as possible for additional information and to discuss their needs.

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Definition of Terms

An individual with a disability is a person who has a physical or mental impairment that substantially limits one or more major life activities; has a record of such an impairment; or has been regarded as having such an impairment. 

The term substantially limits means the individual is restricted with regard to the condition, manner, or duration with which s/he performs a major life activity compared to most people in the general population. 

With regard to post-secondary education, a qualified person with a disability is one who, with or without accommodation, meets the standards for admission to or participation in an educational program, activity, or service. 

Appropriate academic adjustments and reasonable accommodations refer to modifications necessary to ensure that College requirements do not discriminate against students with disabilities or have the effect of excluding students on the basis of disability.  A reasonable accommodation helps to minimize, as much as possible, the limitations resulting from the disability and provides the individual with an equal opportunity to participate in College programs and activities.  The College is not required to make a modification that it can demonstrate would substantially alter an essential element of a College requirement, standard, or program.  Reasonable accommodations may include the elimination of physical barriers whenever possible, and academic adjustments such as the following if appropriate: the use of a calculator, spell-checker, tape recorder, or notetaker; reduced courseload; alternate formats for print materials; sign language interpreters or captionists; adaptive equipment; assistive technology; and substitution of specific required courses when appropriate.  Testing accommodations such as extra time, a distraction-reduced room, scribes, and readers are also provided when necessary.

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Rights and Responsibilities

Students with disabilities that substantially limit them in the College environment have the right to . . .

• Equal opportunity to participate in the College’s courses, programs, services, and activities
• Reasonable accommodations, academic adjustments, auxiliary aids and services when necessary
• Respect for their privacy regarding disability-related information, except as disclosures are required or permitted by law

Students with disabilities have the responsibility to . . .

• Meet basic requirements for admission to the College
• Satisfy essential academic requirements and technical standards of the College and their major program of study
• Disclose their disability to the Coordinator of Access Services as early as possible if they need to request accommodations                  
• Provide the required documentation of disability when necessary
• Follow identified procedures for requesting accommodations
• Request accommodations as early as possible each semester

The College, through its faculty and staff, is entitled to . . .

• Establish and maintain requirements and standards for admission to the College, and for participation in its courses, programs, services, and activities                                        
• Request current, relevant documentation that verifies a disability and the need  for reasonable accommodations, at student expense
• Require that students request accommodations in a timely manner 
• Deny a request for an accommodation if the student fails to provide current relevant information verifying a disability and need for the accommodation, or the request  requires a fundamental alteration of a course, program, or service

 The College has the responsibility to . . .

• Ensure that admissions policies and procedures are implemented in a non-discriminatory manner with regard to individuals with disabilities
• Ensure that courses, programs, services, activities, and facilities, when viewed   in their entirety, are accessible to individuals with disabilities. 
• Provide appropriate reasonable accommodations, academic adjustments, auxiliary aids, and services in a timely manner
• Maintain appropriate confidentiality of disability-related information

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Eligibility

To be eligible for services and reasonable accommodations, a student must meet the following criteria:

• Have an identified disability as defined by 504/ADAAA               
• Provide the Coordinator of Access Services with the required information  verifying  a disability that currently causes substantial functional limitations           in a college environment                   
• Contact the Coordinator to request accommodations in a timely manner

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Documentation Guidelines

Students are encouraged to request accommodations and to provide the required information as early as possible to allow sufficient time for consideration and planning.  To confirm eligibility for reasonable accommodations, the documentation must be a written report of an evaluation by a qualified professional, not related to the student, verifying the existence of a disabling condition, identifying deficits that currently cause substantial limitations in a college setting, and relating the current impact of the condition to the requested accommodations.  It should be on letterhead stationery, indicate the date of the most recent evaluation, and include the signature, title, and credentials of the professional conducting the evaluation. 

All documentation should be submitted to the Coordinator of Access Services as early as possible.  Additional information may be necessary to substantiate the need for accommodations.  If inadequate documentation is submitted, accommodations may not be arranged until the necessary information is received.  It is the student’s responsibility to obtain any required documentation.

Documentation of an Attention Deficit/Hyperactivity Disorder

To document an attention disorder (AD/HD), a student must submit a current report (preferably no more than three years old) based on the results of a comprehensive evaluation by a psychiatrist or licensed psychologist experienced in diagnosing AD/HD in young adults and adults.  The report must include the following information:

• Clear statement of a diagnosis of AD/HD, level of severity, and date of the most recent evaluation
• Description of the methods, criteria, and tests used to make the diagnosis
• Summary of a thorough diagnostic interview with relevant information about the individual’s history, including evidence of early onset and symptoms across multiple settings
• Description of current symptoms that meet diagnostic criteria
• Analysis of evaluation results, including any relevant test data, to substantiate the diagnosis         
• Ruling out of alternate diagnoses or explanations for the symptoms
• Overview of treatment plan, including any prescribed medication and its effect on symptoms
• Discussion of whether any symptoms currently cause substantial limitations to academic functioning
• Recommendations for appropriate accommodations to help compensate for substantial limitations resulting from the AD/HD, with a rationale for each one

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Documentation of a Learning Disability

To document a learning disability (LD), a student must submit a current report (preferably no more than three years old) from a comprehensive psycho-educational or neuropsychological evaluation performed by a licensed psychologist or certified school psychologist experienced in evaluating LD in young adults and adults.  Test instruments must be well recognized and age appropriate, and the most recent edition should be used.  Adult norms are preferred. 

At a minimum, the following areas must be assessed:

• Cognitive functioning
• Academic achievement including current levels of reading, mathematics, and writing ability, with assessment of performance under timed conditions 
• Information processing ability including visual, auditory, and spatial perception; processing speed and fluency; memory; and executive functioning  

The report must include the following information:

• List of tests administered, and an outline of all test results with standard scores and percentiles
• Summary of a thorough diagnostic interview including relevant history
• A clear statement diagnosing LD
• Data and analysis substantiating the diagnosis
• Discussion of processing strengths and weaknesses, and whether any deficits currently cause substantial limitations to academic functioning
• Recommendations for reasonable accommodations to help compensate for the deficits, with a rationale for each one

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Documentation of a Physical Disability or Chronic Medical Condition

A student with a physical disability or chronic medical condition may be required to provide information to support a request for an accommodation or to help identify appropriate accommodations.  The documentation must be a written report of an evaluation by an appropriate professional (e.g., medical doctor, physical or occupational therapist, audiologist) relating the current impact of the condition to the requested accommodations. 

At a minimum, information about the following must be included:

• Nature and severity of the condition, and the date of the most recent examination
• Description of the methods, criteria, and tests (if any) used to make the diagnosis
• Summary of relevant history, examination findings, and current symptoms
• Overview of any treatments, medications, or devices currently prescribed  and their effect
• Discussion of whether any manifestations of the condition currently cause substantial limitations to functioning in a college environment
• The expected duration or progression of the condition
• Recommendations for reasonable accommodations to help compensate for substantial limitations resulting from the condition, with a rationale for each one
• Time period for which these accommodations are recommended

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Documentation of a Psychological Disability

To document a psychological disability, a student must submit a current report based on a comprehensive evaluation performed by an appropriate professional (i.e., psychiatrist, licensed psychologist, or clinical social worker) relating the current impact of the condition to the requested accommodations. 

The evaluation must include the following information:

• DSM diagnosis, nature and severity of the condition, and date of the most recent evaluation
• Description of the methods, criteria, and tests (if any) used to make the diagnosis
• Summary of relevant history, evaluation findings, and current symptoms
• Overview of treatment plan and timeframe, including any prescribed medications and their effect
• Discussion of whether any symptoms currently cause substantial limitations to functioning in a college environment
• Recommendations for reasonable accommodations to help compensate for substantial limitations resulting from the condition, with a rationale for each one
• Time period for which these accommodations are recommended

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Procedures

Determining Appropriate Accommodations

The College provides reasonable accommodations for qualified students who disclose a disabling condition that currently causes substantial limitations to their functioning in a college environment.  Decisions about eligibility for accommodations and the identification of reasonable accommodations are made by the Coordinator of Access Services in collaboration with the student, and other College professionals as appropriate, based on the following considerations:         

• Current limitations resulting from the condition that have a substantial effect on functioning in a college setting, as indicated in the documentation
• Student’s current experiences and description of need
• Course and program requirements

Please note that a prior history of accommodation does not mean that similar accommodations will automatically be provided at the College.  Consideration of a student’s current functioning is important in evaluating eligibility for accommodations.  Also, the College is not obligated to make an adjustment that would fundamentally alter an essential element of a course or program.  Reasonable accommodations are implemented to provide students with equal access; they do not guarantee success.  Accommodations will not be implemented retroactively.

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Requesting Accommodations

Students with learning, physical, and psychological disabilities who require accommodations should contact the Coordinator as early as possible to discuss their needs and to submit the necessary documentation.  Students requiring facilities access are encouraged to contact the Coordinator whenever necessary.  Students requesting academic accommodations should use the following procedures each semester once the required documentation is on file:             

• Contact the Coordinator of Access Services within two weeks of confirmation of registration to request accommodations and to schedule an appointment.
• Meet with the Coordinator to discuss reasonable accommodations and to prepare confidential accommodation verification forms for faculty, when appropriate.
• Present the verification form to each professor and meet with her/him at the start of each semester to review the accommodations.  Students should discuss with faculty the specific arrangements for testing accommodations, which may include modifications to previous arrangements, no later than one week prior to the exam date.  Without advance notice, it may not be possible to provide the accommodation for the scheduled test date. 

Appropriate accommodations may include arrangements that require ample advance planning, so early notice is essential.  For academic accommodations requiring considerable planning and preparation (e.g., alternatives to print materials, ASL interpreters, CART), it is strongly recommended that requests be made at least four weeks before the first class.  Such notice will help to alleviate unnecessary inconvenience and delays. 

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Requests for  Modifications in Housing Arrangements

The College will consider modifying housing assignment procedures or arrangements when necessary to provide equal access to the residence halls for students with disabilities.  Students should contact the Coordinator of Access Services to request modifications in housing and to provide the required documentation as early as possible to allow sufficient time for consideration and planning. Requests should be made well in advance of established Residential Life timeframes; otherwise, options may be limited.  New students are required to submit requests and the supporting documentation no later than June 1.  Returning students must submit requests and provide the required information by March 30.  For students who wish to live on campus during the summer months, the deadline is May 1.

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Documentation Guidelines

Students may be required to provide current documentation of a disability or significant chronic medical condition to verify eligibility for a modification and to help determine appropriate accommodations in campus housing.  All information should be submitted to the Coordinator of Access Services and will be maintained on a confidential basis.  The information must be a written report of an evaluation by an appropriate professional not related to the student (i.e., medical doctor, psychologist, physical or occupational therapist, audiologist).  It should verify the existence of a disabling condition that currently causes substantial limitations to the student’s ability to function in a residential environment, and relate the current impact of the condition to the modifications requested.  The report should be on letterhead stationery, provide the date, and include the signature, title, and credentials of the professional providing the information.  At a minimum, the following information should be included:

• Nature and severity of the condition, and the date of the most recent evaluation
• Description of the methods, criteria, and tests (if any) used to make the diagnosis
• Summary of relevant history, evaluation findings, and current symptoms
• Overview of any treatments, medications, or devices currently prescribed and their effect
• Discussion of whether any manifestations of the condition currently cause substantial limitations to the student’s ability to participate in campus housing
• The expected duration or progression of the condition
• Recommendations for reasonable accommodations to help compensate for substantial limitations to the student’s ability to live in the dormitory, with a rationale for each one
• Time period for which the accommodations are recommended

Students are also required to complete and submit a form, Request for Modifications in Residential Life, which is available from the Access Services office. 

Determination of Reasonable Modifications in Housing

Reasonable accommodations and procedural modifications in housing are determined by the Coordinator of Access Services in collaboration with the Director of Residential Life, the student, and other College professionals as appropriate, based on the following considerations:

• Nature and severity of the condition’s impact on the student’s ability to live in         a dormitory setting, as indicated in the evaluation report
• Student’s description of need
• College policies and procedures

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Policy Regarding Service Animals

In accordance with Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990 as amended (ADAAA), Bryn Mawr College will provide reasonable accommodations for individuals with disabilities when necessary to ensure equal access to our programs, services, and activities.  Although animals are not allowed in College facilities, an appropriately trained service animal, as defined below, will be permitted if necessary to ensure access for a person with a disability. 

According to the ADAAA, a service animal is a dog that has been individually trained to do work or perform tasks for the benefit of an individual with a disability.  The work or tasks must be directly related to the effects of the handler’s disability.  Other animals, whether wild or domestic, trained or untrained, are not considered to be service animals.  Dogs that are not trained to perform specific tasks that mitigate the effects of a disability, including animals used for emotional support, well-being, comfort, or companionship, are not considered to be service animals. 

The health and safety of Bryn Mawr’s students, faculty, and staff are of utmost importance.  The handler is responsible for the overall care and management of the service animal, including appropriate waste clean-up.  A service animal should have a harness, leash, or other tether, unless that is not feasible due to the nature of the disability or the dog’s work.   If it becomes disruptive or aggressive, or is not housebroken, a service animal may be required to leave the College.

Bryn Mawr students with disabilities who need to bring a service animal with them to the College should contact the Coordinator of Access Services prior to their arrival, and may be asked to provide the following information:  

• Verification of a disability and the need for a service animal
• A description of the specific work or tasks the dog has been individually trained to perform to mitigate the effects of the disability
• Documentation indicating that the dog has up-to-date vaccinations and appropriate licensure

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Disclosure and Confidentiality

Disclosure of a disability is voluntary. Disability-related information is considered confidential material and does not become part of the student’s academic record at the College. It will not be released without written consent unless required or permitted by law. Information about a disability is shared with members of the campus community only with permission from the student, on a need-to-know basis.

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Complaint Resolution Procedure

Bryn Mawr College is committed to ensuring equal access for individuals with disabilities in accordance with Section 504 of the Rehabilitation of 1973 and the Americans with Disabilities Act of 1990 as amended.  When students believe they have been subjected to discrimination on the basis of disability, the following procedures are available to address their concerns.  If appropriate current documentation of a disability is not on file, the student may be requested to provide it to the Access Services office.

A student who believes s/he has been denied equal access or a reasonable accommodation is encouraged to meet with the Coordinator of Access Services as soon as possible to discuss her/his concerns and seek resolution informally.  If the student prefers, or the outcome is not to the student’s satisfaction, s/he should contact the College’s ADA/504 Compliance Officer no later than the end of the semester in which the situation occurred.  The Compliance Officer may be reached at 610-526-7630. 

The Compliance Officer will schedule a meeting with the student as quickly as possible after being contacted.  If, after consultation with the Compliance Officer and any resulting actions, the student continues to believe that disability discrimination has occurred, s/he should submit a written statement to the Compliance Officer within two weeks of their last contact.  The statement should include an explanation of the facts relevant to the concern and the actions taken previously to resolve it if any. 

The Compliance Officer will convene an access review committee which will include appropriate administrators and faculty knowledgeable about disabilities and/or information relevant to the complaint.  The committee members may communicate with the following individuals to gather pertinent information: the student, the Coordinator of Access Services, individuals suggested by the student and others with relevant knowledge of the issues involved.  The committee will render a decision which will be forwarded to the student in writing within 30 days of the committee’s initial notification of the complaint.  All information related to the process will be kept confidential by all parties involved. 

For additional information, please see the “Statement of Procedures Concerning Sexual Harassment and Other Forms of Harassment and Discrimination” available in the Bryn Mawr College Student Handbook.  Retaliation against any individual because s/he has initiated a good faith disability discrimination complaint will not be tolerated by the College.

 Students who continue to believe discrimination on the basis of disability has occurred may contact the Office for Civil Rights of the U.S. Department of Education in the Philadelphia area at 215-656-8541 or OCR_Philadelphia@ed.gov.

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Emergency Evacuation Procedures for Students with Disabilities

Students with disabilities are advised to prepare for an emergency ahead of time and to familiarize themselves with the College’s Emergency Response Guide which is available online at http://www.brynmawr.edu/emergency.  They should locate and remember important areas in buildings they frequent including exits, exit routes, rescue areas, stairways, elevators, and telephones.  Individuals who will need assistance leaving a building during an emergency are advised to identify in advance someone nearby who can assist them.  They should discuss with that person a plan for leaving the building and/or informing emergency personnel of their presence and location so assistance can be provided.  Students with hearing impairments who require visual alarms in their dorm rooms should inform the Coordinator of Access Services about their needs as early as possible.

Resident students with disabilities that limit their ability to move quickly are urged to contact the Coordinator at (610) 526-7351, at the start of each semester to request that Public Safety be informed about their identity and campus residence so assistance can be provided if an evacuation is necessary. 

They also should inform Residential Life staff in advance about their need for assistance in the event of an emergency in the dormitory.  Those needing assistance to evacuate should identify two individuals on their halls beforehand (e.g., one HA and one student) who can assist them and inform emergency personnel of their presence in the hall.  They should discuss with these individuals in advance the specific nature of the assistance needed.  In the event relocation is required, the College will make every effort to provide accessible housing, when  necessary.                                    

At a minimum, students with conditions affecting their ability to evacuate a building should take the following steps during an emergency:

• If a campus phone is available, dial 911 for Public Safety, and state your location and situation.  If using a cellular phone, dial 610-526-7911 to reach Public Safety.
• Do not use elevators, which may shut down in emergency situations.  Rescue personnel will determine whether circumstances warrant the evacuation of a person who is non-ambulatory.
• Ask for assistance to exit the building, if possible, or to go to one of the following locations: the designated Area of Rescue Assistance, the nearest stairwell with doors that separate the stairs from the hall, or a room with a door and exterior window near a stairway.  
• Note the room number or other identifying features of your location.  Ask someone leaving the building to notify emergency personnel of your location and situation.
• If you go to a stairwell, please attempt to position yourself so as not to block access to the stairs   for rescue personnel entering and for those exiting the building.

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