The Office of Accessibility Services (OAS) at Delaware Valley University (the “University”) is committed to supporting an inclusive, equitable, and accessible environment. This comprehensive policy addresses OAS’ support of students with disabilities; how requests for reasonable accommodations and/or auxiliary aides are to be submitted and reviewed; and compliance with applicable laws, including but not limited to Section 504 of the Rehabilitation Act of 1973 (the “Rehabilitation Act”) and Title III of the Americans with Disabilities Act of 1990 (the “ADA”), and associated regulations, as applicable.
At the University, one of our core values as an educational community is to respect all people. It is important that any community member can access and participate in their chosen academic and extra-curricular pursuits regardless of their status as an individual with a disability. This policy is intended to help ensure that value informs OAS’ work in reviewing requests for accommodation and putting them into action.
I. Scope
These policy and procedures apply to all qualified students with a disability or who otherwise may need to request reasonable accommodations and/or auxiliary aides in any of the University’s programs and activities. It is for all types of students (including accepted but not deposited; undergraduate and graduate; degree-seeking and non-degree seeking; full-time and part-time students). The University also provides reasonable accommodations for any prospective students who may need them in order to complete the admission process, provided any such individual meets the academic and technical standards requisite to admission or participation in the relevant University program or activity. Individuals who may need accommodations in order to apply should contact OAS using the contact information below.
Importantly, the University cannot accommodate disabilities of which it is unaware. Therefore, it is each student’s responsibility to disclose his or her condition, request reasonable accommodations, and follow procedures described below in order to be granted an accommodation or receive other assistance from the University.
OAS is responsible for the oversight and implementation of the request process for reasonable accommodations by students with disabilities. In the case of academic coursework taken at another institution of higher learning, the Assistant Dean of Students for Accessibility Services will serve as consultant and source of information for students who may need to arrange accommodations at these locations.
Note: Students engaged in academic work off-site (such as internships for course credit and study abroad) should contact OAS to determine whether the University or another entity (such as the business where the student is interning) is responsible for making any required accommodations.
The Human Resources Office is responsible for processing accommodation requests for employees of the University. Therefore, this policy generally does not apply to student-employees who are seeking accommodation relating to their jobs. OAS may coordinate with the Human Resources Office to assist such students when necessary.
II. Purpose
This policy and procedures support the University’s commitment to providing all students with an accessible and fair learning environment. They also reflect and put into practice the University’s Core Values and Non-Discrimination Statement.
This policy is also intended to ensure the University’s compliance with the ADA and the Rehabilitation Act, which require reasonable accommodations be made for qualified students with disabilities and prohibit the University from excluding such students from, or denying them the benefits of, its programs or activities.
III. Definitions
Note: The following terms are applied by the University in accordance with applicable law and regulations, including the Rehabilitation Act and the ADA. To the extent that any of the below explanations deviate from applicable law or regulations or such authorities change, the University shall interpret this policy as necessary to be consistent with its legal obligations.
Accommodations are defined as any reasonable modifications in any physical space, policy, practice, or procedure intended to allow a qualified student with a disability equal access to the University’s programs or activities. When necessary, accommodations may be made inside or outside the classroom, in University housing facilities, clubs and organizations, and extra-curricular activities.
Examples of potential accommodations that may be suitable in certain circumstances include:
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Accommodations that will generally not be approved include:
- Fundamental or technical changes to a particular program or field of study;
- Fundamental alteration to the University’s academic or technical standards;
- Any modification or adjustment to the essential requirements of any program of instruction, program or activity, or essential to any directly related licensing requirement;
- Any modifications or adjustments that would result in undue hardship on the University, considering the nature, cost, and impact of the accommodation, and other factors; or
- Any modification or adjustment that would result in a direct threat to the health or safety of others.
Auxiliary aids and services are devices, equipment or services that may be provided to qualified students with impaired sensory, manual, or speaking skills. Some of the various types of auxiliary aids and services may include:
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Disability is (1) a physical or mental impairment that substantially limits one or more major life activities; (2) a record of such an impairment; or (3) being regarded as having such an impairment.
A Qualified Student is a person who meets the academic and technical standards requisite to admission or participation in the University's relevant education program or activity or, as applicable, a person who meets the essential eligibility requirements for the receipt of such services.
IV. Role of the Office of Accessibility Services (OAS)
OAS is committed to supporting an inclusive, equitable, and accessible environment. The Assistant Dean of Students for Accessibility Services is responsible for the oversight of the Office and all related functions. Among those functions is performing an individualized and interactive review of all student-initiated accommodation requests that the Office has developed and, as a part of that process, identifying reasonable accommodations to eliminate barriers for qualified students with disabilities. The Assistant Dean, or their designee, is also responsible for notifying appropriate University personnel (such as a faculty) of any student’s approved accommodations or auxiliary aides.
In addition to academic accommodation, the Assistant Dean makes accommodation or auxiliary aide determinations for other University programs and activities, such as residential and athletics programs. The Assistant Dean or their designee also works with other University departments such as Facilities, Public Safety, Housing and Residence Life, the Registrar, Athletics, and Student Involvement to address access and service issues related to other aspects of a qualified student's educational experience.
When requests relating to medical or health issues arise as accommodation requests impacting other University processes, such as course withdraw or hiatus requests, the Assistant Dean may serve as a resource for any ADA-related questions that students may have.
In addition to the above, the Office of Accessibility Services also serves as a support for all students, including but not limited to those with approved accommodations. Questions and concerns about reasonable accommodations or auxiliary aides or services should be directed to the following:
Kelly Hojnacki
Assistant Dean of Students for Accessibility Services
kelly.hojnacki@delval.edu
215.489.2215
Students should also contact the above if there are changes or updates to the student’s condition that may necessitate adjustments to identified reasonable accommodations.
In addition to these responsibilities, the Office of Accessibility Services continuously strives to identify opportunities to make all aspects of the University environment accessible for all members of the University community.
V. Policy
It is the policy of Delaware Valley University to provide qualified students with disabilities with reasonable accommodations as required by law, the University’s educational standards, and appropriate ethical practice.
Decisions about whether a student is a qualified student with a disability and what constitutes a reasonable and appropriate accommodation or available auxiliary aides are made by the Assistant Dean of Students for Accessibility Services or their designee(s).
The determination of what accommodations or auxiliary aides are appropriate will be made on an individualized basis for each class, program, or activity in which a qualified student seeks to attend or participate.
VI. Procedure for Requesting Accommodations
To be considered for an accommodation, a student or applicant must submit a request to the Office of Accessibility Services, by completing the online accommodation request form - Disability Accommodation Request Form. Students or applicants who need assistance in accessing the request form should inform the Office using the contact information above.
A request must explain the student’s or applicant’s need for an accommodation and, if known, a description of any specific accommodations the student or applicant seeks. In order to ensure a full and timely review of their requests, students should submit with their requests all necessary supporting information regarding their disability, including all documentation described below.
Once a reasonable accommodation or auxiliary aide is approved, OAS will contact faculty members or other appropriate personnel about the approved accommodations. Students are encouraged to set up a private meeting with each of their teachers to discuss their personal situation and the individual protocol for accommodations.
VII. Documentation of Disability and Need for Accommodation
As a prerequisite for being granted any accommodations or provided with any auxiliary aides, students and applicants must identify themselves to the University and follow the processes described by this policy, including providing the University with adequate documentation in a timely manner. Such documentation must demonstrate the existence of the disability and the need for a reasonable accommodation. The Assistant Dean is responsible for determining whether the provided supporting documentation is appropriate and adequate. A complete list of what documentation will be required is provided in the appendices to this policy.
In all cases, a request should be supported by a report from a qualified professional. OAS can offer outside referrals for diagnostic services. All costs associated with diagnostic services are the responsibility of the student. Further information about documentation and verification of a disability is available on the OAS website and in the Disability Accommodation Request form.
The University shall consider all documentation submitted in support of an accommodation request. It may also require a student or applicant to provide supplementary materials when necessary. Failure to provide such documentation when requested may preclude the granting of an accommodation or auxiliary aide.
VIII. Timing and Renewal of Accommodation Requests
Students requesting accommodation should be mindful of the timeline of the request process, described further below. Submitting requests and all necessary documentation in a timely manner is the best way to ensure that the University is able to give each request a full review and provide necessary accommodations as soon as possible. As a general rule, new students should contact OAS as soon as possible after their application to the University has been accepted and they have made the necessary deposit. In other circumstances, students should submit their requests as soon as they become aware of the need for an accommodation. Requests should always be submitted at least six (6) weeks in advance of when the accommodation or auxiliary aide will be needed except in extraordinary circumstances.
Accommodation needs can vary depending upon a student's current course load, schedule, or course content, or the student’s disability status. Therefore, all students must renew their accommodation requests each semester (including summer sessions). If the accommodation request has not changed, the renewal process typically is a brief, online confirmation of continued need. In some instances, updated documentation or other information may be required.
NOTE CONCERNING HOUSING ACCOMMODATIONS: Housing accommodations may require additional time to review and to make. Therefore, requests for any housing-related accommodations generally should be made within time limits established by the housing assignment process. These are communicated in the University’s Housing Application. Housing accommodations may need to be renewed from year to year, depending on the nature of the accommodation and the student’s disability status. OAS communicates directly with students whose accommodation requires renewal.
IX. Accommodation Determinations
When reviewing requests for accommodations or auxiliary services, OAS will engage the student or applicant in an interactive and individualized inquiry. Students and applicants who request accommodations or auxiliary aides have a responsibility to actively engage in this process, including responding to requests from the University to provide supplemental information. Failure by the student or applicant to do so may result in delay of the University’s review of the request or denial.
The Assistant Dean will consider the request, the documentation provided by the student, information gathered during the inquiry, consult with faculty and/or other University officials or committees as needed, and determine whether and what reasonable accommodation(s) will be supported. The Assistant Dean also may seek advice or recommendations from the University’s health and wellness center staff in considering an accommodation request. In all such consultations and communications, the Assistant Dean and others involved in the review will maintain the confidentiality of student or applicant’s medical information, to the extent possible consistent with the need to conduct a full review of the request.
If OAS determines that the requesting student or applicant qualifies for an accommodation, it will identify a list of approved reasonable accommodations and share that list with the student. The student may then choose from among the options presented. Upon completion of its review and determination of appropriate accommodations, OAS will issue the student a letter and share that letter with appropriate faculty or other personnel concerning the accommodations or other auxiliary aides that the student must receive. OAS will also be available to the student to assist in questions or concerns related to implementation of any approved accommodations or auxiliary aides.
X. Service Animals
A Service Animal is an animal, usually a dog, which has been individually trained to do work or perform tasks for the benefit of an individual with a disability. In certain circumstances, miniature horses may also qualify as Service Animals. Animals whose sole function is to provide emotional support, comfort, or companionship do not qualify as Service Animals.
Qualified students will be permitted to bring service animals to campus and throughout all University buildings except in exceptional circumstances. The University may exclude Service Animals from certain restricted access areas if it determines that the presence of a Service Animal fundamentally alters the nature of a program or activity, or creates an unacceptable risk to the health and safety of any individuals associated with the University or to the animal. Examples of restricted access areas include but are not limited to the following:
· Research and teaching laboratories and clinics;
· Greenhouses and crop production areas;
· Outdoor wildlife research areas;
· Small animal facility (vivarium);
· Mechanical rooms and maintenance closets;
· Areas where protective clothing is necessary;
· Food preparation areas;
· University farms, barns and equine center (Farm View Road); and
· Other areas where a legitimate danger or risk to an animal is present.
Students are encouraged but not required to register Service Animals with OAS through the Service Animal Registration Form. Pre-registration allows the University to make any appropriate accommodations for other students, faculty or staff who may have allergies, phobias or service animals of their own.
When it is not readily apparent that the animal is a Service Animal, the student may generally only be asked the following by those responsible for the facilities that students wish to access:
- Is the animal a Service Animal required because of a disability?
- What work or task has the animal been trained to perform?
Owners of Service Animals in University facilities have the following responsibilities:
· Care and supervision of the Service Animal at all times;
· Ensuring the cleanup and disposal of the Service Animal’s waste and that the Service Animal toilets only in appropriate outdoor areas;
· Compliance by both the owner and the Service Animal with all applicable city, county, and state ordinances, laws, and/or regulations pertaining to licensing, vaccination, and other requirements for animals; and
· Ensuring that the Service Animal does not unduly interfere with the activities of the University or cause difficulties for students who reside in housing with the Service Animal.
Students who do not comply with the above may be required to pursue other forms of accommodation.
Owners of Services Animals are financially responsible for the actions of the Service Animal including, bodily injury to the student or others or property damage. The owner of a Service Animal will be required to reimburse the University for any costs or expenses incurred by the University as a result of the Service Animal. As applicable, the University may post these costs to the owner’s student account.
Service Animals may not be left overnight in University housing to be cared for by another student. A Service Animal’s owner leaving campus for a prolonged period must remove the Service Animal from campus.
The University is not responsible for a Service Animal during a fire alarm, fire drill, or natural disaster.
Students who may wish to have a service animal live in campus housing are required to make an accommodation request using the process described above.
Students with a medical condition(s) that are affected by animals (e.g., respiratory diseases, asthma, severe allergies) should contact OAS if they have a health or safety-related concern about exposure to a Service Animal.
XI. Emotional Support Animals
An Emotional Support Animal (“ESA”) is an animal that provides emotional support that alleviates one or more identified symptoms or effects of a person’s disability. It is not a pet. The University will permit ESAs to accompany qualified students in campus when approved using the process described above. Qualified students who may need the assistance of an ESA should submit a request for accommodation under the terms of this policy and review the University’s Emotional Support Animal Information and Agreement Form.
ESAs will generally not be permitted to accompany students elsewhere on campus, including classrooms or other non-residential facilities.
Because there is no official federal or state registry for support or assistance animals or agencies that provide such approval, the University does not recognize certifications or credentials of assistance animals.
XII. Privacy of Disability Records
All information submitted to or developed by the University related to the requests, diagnosis, documentation, or accommodation of a disability is considered private and will not become part of any other student record at Delaware Valley University. Disability information may be released to instructors or other appropriate University personnel who are involved with implementing one or more reasonable accommodation identified for a student only to the extent necessary to determine the appropriateness of a request and in order to implement approved accommodations.
The Institutional Research Office may collect non-identifying accommodation data for reporting purposes as well as quality control.
All documents supporting a disability on file with the Office of Accessibility Services will be retained and destroyed in accordance with applicable law.
XIII. Appealing Accommodation Determinations
Students may request a review of any determinations made by OAS, including whether a student is entitled to an accommodation or auxiliary aide or service and whether reasonable accommodations identified are appropriate, under the University’s Section 504 Grievance Procedures. Under those procedures, students are encouraged, as a preliminary step, to discuss their concern with the Assistant Dean. If the requested review cannot be resolved informally, then the student can submit an appeal for a review to be completed by the Dean of Students. The deadlines or other procedural requirements imposed by the Section 504 Grievance Procedures shall apply to any such appeals.
XIV. Interpretation; Section 504 Coordinator
Questions concerning the application of this policy and the application of the ADA or Section 504 of the Rehabilitation Act to students may be made to the Assistant Dean of Students for Accessibility Services or to the University’s Section 504 Coordinator:
Name: Timothy Poirier
Title: Dean of Students
Address: Student Center – 2nd Floor
700 East Butler Ave
Doylestown, PA 18901
Phone: 215.489.2215
Email: timothy.poirier@delval.edu