Policy on Student Accessibility Services - under revision

I. Introduction

II. General Principles

III. Services for Students with Disabilities

A. Documentation and Certification of Eligibility for Student Accommodations

B. Determining Reasonable Accommodations

C. Obtaining Academic Accommodations

D. Confidentiality and Release of Information

E. Student Grievances

F. Service Animals

I. INTRODUCTION

St. Olaf College strives to make its programs accessible to all individuals, in compliance with Section 504 of the Rehabilitation Act of 1973 and Title III of the Americans with Disabilities Act of 1990. Its purpose is to create and maintain an environment in which students may achieve their fullest potential, limited to the least extent possible by individual disabilities. Such disabilities include physical or mental impairment that substantially limit major life functions. All faculty, staff, and students of the College are expected to adhere to this philosophy of equal access to educational opportunity and to assume broad responsibility for its implementation.

Disclosure of a disability is not required, but if disclosed, it is the responsibility of the individual to seek available assistance and make needs known.

Student Accessibility Services is the designated office at St. Olaf College that maintains disability-related documents, certifies eligibility for services, and determines and provides reasonable accommodations for students with disabilities. It is located in Buntrock Commons 108. All requests for accommodation, documentation reports, and inquiries should be forwarded to:

Coordinator, Student Accessibility Services
St. Olaf College
1520 St. Olaf Avenue
Northfield, MN 55057-1098
507-786-3288


During the months of September through May, any guest on campus who may need special accommodations should contact the department sponsoring the event. From June through August, the Office of Conferences and Events manages such needs. Please make requests at least two weeks in advance of the event to:


Office of Conferences and Events
147 Buntrock Commons
Northfield, MN 55057-1098
507-786-3043


II. GENERAL PRINCIPLES

1. St. Olaf College strives to provide people with disabilities with:


a. equal access to courses, programs, services, activities, and facilities offered through the College;

b. an equal opportunity to learn and to receive reasonable accommodations, academic adjustments, and/or auxiliary aids and services;

c. appropriate confidentiality of all information regarding their disability and to choose to whom, outside of the College, information about their disability will be disclosed, except as disclosures are required or permitted by law;

d. essential information, reasonably available in accessible formats.


2. Students with disabilities at St. Olaf are asked to:

a. meet course prerequisites and essential institutional standards for courses, programs, services, activities, and facilities, with reasonable accommodations if necessary;

b. identify themselves as individuals with a disability when an accommodation is needed and seek information, counsel, and assistance as necessary;

c. demonstrate and/or document (from an appropriate professional) how the disability limits their participation in courses, programs, services, activities, and facilities;

d. follow published procedures for obtaining reasonable accommodations, academic adjustments, and/or auxiliary aids and services.


3. St. Olaf College shall endeavor to:

a. identify and establish essential functions, abilities, skills, knowledge, and standards for courses, programs, services, activities, and facilities and shall strive to evaluate faculty, staff, and students on this basis;

b. request and receive, through Student Accessibility Services ('SAS'), current documentation that supports requests for accommodations, academic adjustments, and/or auxiliary aids and services;

c. provide information to students and guests with disabilities in accessible formats upon request;

d. review courses, programs, services, activities and facilities, and strive to make them available and usable in the most integrated and appropriate settings;

e. evaluate students and applicants on their abilities as demonstrated with or without reasonable accommodations if necessary;

f. provide or arrange reasonable accommodations, academic adjustments, and/or auxiliary aids and services for students and guests with disabilities in courses, programs, services, activities, and facilities;

g. maintain appropriate confidentiality of records and communication, except where disclosure is permitted or required by law.

h. recognize that some students have academic or behavior problems but do not have a disability and do not qualify for reasonable accommodations;

i. confirm what the essential requirements in courses and programs are as stated on the course syllabus. This will help in determining the appropriateness of accommodation requests and will focus discussions on defined information.


4. St. Olaf College may:

a. deny a request for accommodations, academic adjustments, and/or auxiliary aids and services if the documentation reveals that the request is not warranted, or if the individual fails to provide appropriate documentation;

b. refuse an unreasonable accommodation, adjustment, and/or auxiliary aid and service that imposes a fundamental alteration on a program or activity or constitutes undue hardship to the College.


5. Faculty at St. Olaf College shall participate in the managing of disability- related issues by:

a. determining course content and general methods of teaching;

b. making informed decisions in conjunction with SAS about whether and how best to adapt teaching and assessment methods to accommodate students;

c. seeing that the standards in their courses are not lowered or compromised;

d. requiring students to meet the essential requirements of the course in order to obtain an appropriate passing grade;

e. questioning SAS (not the student) about a specific accommodation request if it is either inappropriate for the course, or if the nature of the request would alter the essential requirements of a course;

f. determining the most appropriate ways in conjunction with SAS to adapt courses to the needs of particular students.

g. understanding that when he/she receives a notification from SAS of a request for accommodation for a student, that the student has provided adequate and appropriate documentation of his/her disability, and that accommodation requests are based on this documentation;

h. knowing that alternative ways to assist students with disabilities may be discussed with SAS;

i. realizing that some students with disabilities have academic or behavior problems unrelated to their disability, and that these issues should be confirmed or discussed with SAS. Faculty are not obligated to treat such problems any differently than they would for a non-disabled student.


III. SERVICES FOR STUDENTS WITH DISABILITIES

Student Accessibility Services ('SAS') is the designated office on the St. Olaf College campus that acts as a resource/advocate for students with disabilities, verifies and files documentation, certifies eligibility for services, and establishes reasonable accommodations. Any student who has need for accommodations should contact SAS.

To be eligible for services, students must have a disability - a physical or mental impairment that substantially limits one or more of the major life activities: walking, seeing, hearing, speaking, learning, breathing, working, taking care of oneself, performing manual tasks.

SAS seeks to provide equal access to students with disabilities through accommodations and support, and to inform and enlighten the entire college community about disability concerns.


A. Documentation and Certification of Eligibility for Student Accommodations


1. Documentation Purposes. Eligibility for accommodations at the College is dependent on the nature of the disability and its impact on learning. Therefore, Student Accessibility Services ('SAS') and the ADA Coordinator requests disability-related documents from the appropriate licensed professional(s) to verify a student as having a disability and to determine the need for reasonable accommodations. Documentation serves two purposes. It establishes existence of a disability (a physical or mental impairment that substantially limits a major life activity) that affords protection under the law, and it demonstrates a need for accommodations to insure equal access to courses, programs, services, activities, and facilities.

2. Elements of Documentation. Documentation from a licensed professional legitimizes a student's request for accommodations and should include the following information:

  • A clear statement of the diagnosed disability;
  • A description of the functional limitations resulting from the disability;
  • A list of the accommodations recommended;
  • A statement of why the disability qualifies the applicant for accommodations requested;
  • Documentation of educational, developmental, and medical history, and a list of all test instruments used in the documentation and relevant scores may be necessary.

These documents should be current (ordinarily within the last three years), must appear on official letterhead of the licensed professional, and must be signed by a qualified professional not related to the student.

3. Costs. The cost of obtaining student documentation is borne by the student. If the initial documentation is incomplete or inadequate in determining the extent of the disability and reasonable accommodations, SAS has the discretion to require additional documentation. Any cost of obtaining additional documentation is also borne by the student.

Students reporting learning or attention difficulties may be given referrals for comprehensive and diagnostic testing in the community. The student is responsible for testing costs.

4. Certification. SAS certifies that a student has a disability and registers disabled students for services provided through SAS. Students who do not meet the legal requirements for disability accommodations are referred to other campus and community resources for assistance. Pending receipt of documentation, SAS reserves the right to deny services or accommodation.


B. Determining Reasonable Accommodations

A reasonable accommodation is a modification or adjustment to a course, program, service, activity, or facility that enables a qualified student with a disability to have an equal opportunity. An equal opportunity means an opportunity to attain the same level of performance or to enjoy equal benefits and privileges as are available to a similarly situated student without a disability. St. Olaf College is obligated to make a reasonable accommodation only to the known limitations of an otherwise qualified disabled student. To determine reasonable accommodations, Student Accessibility Services ('SAS') may seek information from appropriate college personnel regarding essential standards for courses, programs, services, activities, and facilities. Final determination of reasonable accommodations is made by SAS. Reasonable accommodations are determined by examining:

  • the barriers resulting from the interaction between the documented disability and the campus environment;
  • the possible accommodations that might remove the barriers;
  • whether or not the student has access to the course, program, service, activity, or facility without accommodations; and
  • whether or not essential elements of the course, program, service, activity, or facility are compromised by the accommodations.


C. Obtaining Academic Accommodations


1. Procedures. Students who request accommodations are responsible for initiating the eligibility determination process and must seek assistance from Student Accessibility Services ('SAS'), Buntrock Commons 108, in a timely manner, at least two weeks prior to the beginning of classes or when a disability becomes known. Official notification is considered to be visits, phone calls, email, or letters from the student, parent, transfer institution, or an interested party (e.g., Division of Vocational Rehabilitation). Untimely requests may result in delays.

Students with a disability must provide a complete, adequate documentation of their disability from an appropriate source before they can be recognized and given consideration as a student with a disability. When this is submitted, SAS staff and the student will discuss the interaction of the disability and the academic environment and determine what reasonable accommodations may be appropriate. Consultation with faculty, staff and outside professionals regarding essential elements and reasonable accommodations will occur in situations that are new, complex, or sensitive. SAS will file the official documentation and ensure that all disability-related documents are kept confidential and shared with College personnel on a limited and need-to-know basis only.

SAS will supply individualized letters to faculty members certifying that the student has a disability and listing the appropriate accommodations. The letter also invites faculty to contact SAS if there are concerns or questions about the accommodations. Instructors will be expected to assist with the provision of accommodations when reasonable and necessary. They are not expected to compromise essential elements of the course or evaluation standards.

The student with the disability will be responsible for delivering the letters to appropriate faculty and are encouraged to discuss with their professors the functional limitations on each discipline.

Most accommodations such as accessible classrooms, assistive technology, note-takers, readers, interpreters, course substitutions, document conversion, priority registration, study strategies, and taped lectures will be arranged by SAS. Some accommodations such as advance notice of assignments, alternative ways of completing assignments, early syllabus, examination modifications, and time extensions will be arranged between student and faculty with SAS providing help if necessary.

Students with disabilities will be responsible for contacting SAS if reasonable accommodations are not implemented in an effective or timely way. SAS will work with College personnel and the student to resolve disagreements regarding recommended accommodations. Students may also register a complaint by following grievance procedures specified under 'Grievances' in this publication.

Due to the uniqueness of each class, students must apply for accommodation letters each semester.

2. Common Academic Accommodations. Students with disabilities have been admitted to St. Olaf College through the same process as other students in that they are 'otherwise qualified' to attend. Accommodations do not provide a different set of standards but seek to 'level the playing field' or remove barriers that would prohibit an accessible educational environment. While St. Olaf College desires all of its students to achieve favorable academic outcomes, and affords accommodations to provide access, it does not guarantee success in its offerings and activities. The College and its faculty are not required to waive essential elements of courses or make fundamental alterations to programs or services. Students with disabilities are not entitled to the accommodation they may prefer or have received in other educational settings, but their requests will be considered on a case-by-case basis, supported by the documentation they provide. A partial list of common academic accommodations follows:

  • Accessible classroom/location/furniture;
  • Advance notice of assignments;
  • Alternative ways of completing assignments (e.g., oral presentation vs. written paper);
  • Assistive computer technology;
  • Assistive listening devices to listening-impaired students through SAS;
  • College visitors attending events should check with ushers at those events for access;
  • Auxiliary aids and services:

Note-takers: Note-takers are selected by SAS from students enrolled in the class. After each session, the student with a disability and the note-taker go to a nearby photocopy machine specified by SAS to copy the notes. SAS pays for copying. The student with a disability must be present in class to receive notes or have previously received approval from SAS.

Readers: Students with disabilities should request readers and/or scribes at the beginning of a semester or at least one week before an examination or paper.

Interpreters: Students needing interpreters should contact SAS as soon as they are admitted to the College and when registering for ensuing semester classes.

Library Assistants: For general assistance, students with disabilities may contact the reference desk in Rolvaag Memorial Library. If more extensive help is needed, they may contact SAS in advance.

Course or program modifications - Substitutions: Such accommodations are made only when it is clear that the student's disability makes completion of the requirement impossible, and that such an accommodation does not alter the integrity of the academic program. Any requests will be considered on an individual basis. One established substitution is for foreign language study. All students must attempt a foreign language. If after strict adherence to course requirements, appropriate class attendance, and work with a tutor assigned by the Academic Support Center the student receives a D or F, he/she may petition to satisfy all or any remaining portion of the foreign language requirement by taking classes in foreign culture and civilization or literature in English translation.

A student experiencing difficulty in a language should first consult with the instructor of the course and SAS (In a limited number of cases involving students with specific learning disabilities, a faculty member or a student may initiate the procedure to request an alternative to the requirement before the student completes the course, as detailed in guidelines approved by the faculty on May 10, 1988.).

He/She must then fill out a petition available in the Registrar's office that includes a statement describing the difficulties faced in learning the language along with an unofficial transcript and an account of the effort expended in this class.

The Foreign Language Subcommittee, comprised of three language professors and the SAS Coordinator, evaluate the request, along with a statement from current and/or previous instructors in the discipline and background information from SAS concerning disability documentation, evidence of disability-related need for substitution, and justification for regarding the request as reasonable. They make a recommendation to the Curriculum and Educational Policies Committee of the College, which makes the final decision.

Those granted the substitution receive information about courses that will satisfy what remains of the foreign language requirement. Those who are denied receive study strategies and are asked to work with SAS as they continue their language study. If they are still unsuccessful, they may petition again.

Document conversion (alternative print formats: Braille, large print, text-to-speech):

  • Early syllabus
  • Examination modifications:
  • Alternative test formats (short answer, multiple choice, oral, essay)
  • Computer or basic calculator for examinations
  • Examination administered in two parts
  • Private, quiet examination room
  • Readers and scribes
  • Extra time on tests
  • Priority registration for the first semester
  • Study strategies training
  • Time extensions
  • Recorded lectures


D. Confidentiality and Release of Information

The office of Student Accessibility Services ('SAS') is committed to maintaining as confidential student disability-related information. Information collected may include test data, grades, biographical history, disability information, performance reviews, and case notes. Guidelines about such information include the following:

  1. Student files at SAS shall be made available to SAS staff. Any information regarding disability gained from medical examinations or appropriate post-admissions/hiring inquiry shall be considered confidential and will be shared with those school officials of the College who have legitimate educational interests. Disability-related information is to be treated as medical information is treated. Generally, faculty and staff need not have access to diagnostic or other information regarding a student's disability; they do need to know what accommodations are necessary or appropriate to meet the student's disability-related needs. If a student has requested an accommodation, and upon request, the student will be informed as to what information is being provided to the faculty or staff regarding the request.
  2. A separate confidential file is established which contains documentation of a disability and any on-going changes in the student's condition.
  3. Records will be kept for seven years after the date of graduation or the year the student was expected to graduate.
  4. Information in files will not be released except as permitted by law, including the Family Educational Rights and Privacy Act (FERPA). FERPA allows the release of student information to other school officials for legitimate educational purposes and in emergency situations where the release of information is necessary to protect the health or safety of others. It also allows release in certain other limited circumstances. For more information on FERPA, please see the College's annual notice of FERPA rights.
  5. A student's file may be released pursuant to a court order or subpoena.
  6. A student may give written consent for the release of information when she or he wishes to share it with others. Before giving such consent, the student should understand the information being released, the purpose of the release, and to whom the information is being released. Information will not be released without consent unless required by federal or state law.
  7. SAS may charge a reasonable fee for costs incurred in connection with the copying of information.
  8. SAS will retain a copy of all information provided. If a student wishes to have a record expunged, he or she must make a written request to the coordinator who will decide whether it is necessary for the office to retain the record.
  9. A student has the right to review his or her own file.


E. Student Grievances

The purpose of these procedures is to attempt to resolve internally all types of student disability-related grievances at the level where they occur and in a timely manner. It is advantageous to students, faculty, staff, and administration to keep communications open and to contact someone immediately if a situation is escalating.

Students with disabilities are asked to contact Student Accessibility Services ('SAS') immediately if reasonable accommodations are not implemented in an effective or timely way. Faculty who wish for reconsideration of an accommodation should also contact SAS. This should be done no later than one week after the accommodation is scheduled to be implemented.

If an agreement cannot be reached informally, an individual may file a written complaint with SAS who will conduct a thorough investigation that allows interested persons an opportunity to submit evidence relevant to the complaint.

At least three members of the OnPar Committee will review the gathered evidence, meet with all parties in the dispute with their permission, and decide upon an appropriate plan of action. A written determination as to the validity of the complaint and a description of the resolution, if any, will be issued by SAS to the complainant and other concerned parties no later than 10 workdays after the filing of the grievance.

If the grievance is against SAS, the above procedures will be followed except that the initial complaint should be made with the Director of the Academic Support Center.

If dissatisfied with the resolution, the complainant may request reconsideration by contacting the College's ADA Coordinator within 10 workdays of the resolution. Accommodations in question generally will continue to be provided until a final decision is made.

While it is hoped the student can resolve a grievance within the campus process, he/she has the right to file any grievance directly to the U.S. Office of Civil Rights at any time. The Statute of Limitations for filing a complaint with OCR is 180 days from the time the incident occurred.