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Student Disability Accommodation

Title: Student Disability Accommodation Policy and Procedure
Effective Date: October 1, 2011
Responsible Office: Compliance & Equity, Dean of Students
Last Updated: February 5, 2021

I. Scope  

This is the policy and procedure for all qualified students with a disability to obtain reasonable accommodations at William & Mary, including the Virginia Institute of Marine Science (the university). It is for all types of students - undergraduate, graduate, degree-seeking and non-degree seeking, full-time and part-time. Only students who identify themselves as having a disability and seek accommodation using these procedures are eligible. Students who have been accepted but have not yet enrolled may also access this policy. Applicants are also covered by this policy for accommodations needed in the admissions process.

This policy defines the process for eligible students to seek reasonable accommodations in any of the university's programs and activities. Students engaged in academic work off-site (such as internships for course credit and study away) should contact the Office of Student Accessibility Services to determine whether William & Mary or the other entity (such as the business where the student is interning) is responsible for making accommodations. (The ability to accommodate a student with a disability should be a precondition to any business, agency, or organization that wants to participate in an internship or externship agreement with the university.)  Typically, accommodation requests for internship sites should be made directly with the site. SAS can assist students with this process. In the case of academic coursework taken at another institution of higher learning, the Director of Student Accessibility Services will serve as a consultant and information source for students arranging accommodations at these locations.

This policy generally does not apply to student employees who are seeking accommodation relating to their jobs; the Office of Student Accessibility Services may coordinate with the Office of Human Resources, which processes employee accommodation requests, to assist student employees. See Employee Reasonable Accommodation Policy and Procedure

II. Purpose 

This policy and procedure enable the university to comply with the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973, which require reasonable accommodations 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. They help satisfy William & Mary's Code of Ethics, Statement of Rights and Responsibilities, and Policy on Discrimination, Harassment, and Retaliation.

III. Definitions

Note: The following terms are applied by the university in accordance with and by using the definitions supplied by federal law and regulations, which are summarized here.

  • Accommodations are defined as any reasonable adjustment required for a student to have equal access to the university's programs and activities, inside or outside the classroom. Examples of potential accommodations include:
    • Extended time for completion of exams or other assignments for a student with a learning disability
    • Ability to use speech-to-text software for a student with dysgraphia
    • Provision of a private, distraction-free testing environment for a student with ADHD
    • A class being moved to a space accessible to a student with a specific mobility impairment
    • Provision of air conditioning for a residential student with a respiratory condition
    • Permitting a visually impaired student to bring their service animal to class.
    • Accommodations do not include:
      • Substantial modifications to academic standards,
      • Personal aids/devices,
      • Modification or adjustment of requirements essential to any program of instruction, program or activity, or essential to any directly related licensing requirement, or
      • Modifications or adjustments that result in undue hardship, considering the nature, cost, and impact of the accommodation and other factors.
  • Disability is a physical or mental impairment that substantially limits one or more major life activities.
    • A student is "qualified" if they "meets the academic and technical standards requisite to admission or to participate in the educational program or activity, with or without reasonable modifications to rules, policies, or practices; the removal of architectural, communication, or transportation barriers; or the provision of auxiliary aids and services."
IV. Policy

It is the policy of William & Mary to provide qualified students who have disabilities with reasonable accommodation based upon relevant law, the university's educational standards, and sound ethical practice in Student Accessibility Services.   Retaliation against an individual with a disability for requesting or using accommodations is prohibited. The university takes strong action to protect individuals from retaliation and to address any retaliatory behavior that occurs.

Decisions about whether a student is a qualified student with a disability and what constitutes reasonable accommodation typically are made by the Director of Student Accessibility Services or the designee.   Accommodations are considered on a case-by-case as well as a class-by-class (or program or activity) basis. In addition to academic accommodation, the Director, or designee, makes accommodation determinations for other university programs and activities, such as residential and athletics programs, and works with other university departments, such as Facilities Management, Parking & Transportation Services, Residence Life, Office of the Registrar, Athletics, Auxiliary Services, and Student Activities to address special access and service issues related to a student's educational experience. Certain requests relating to medical or health issues may arise as disability accommodation requests or may be processed through other university processes, specifically:

The Director of Student Accessibility Services, or designee, may be involved in these determinations and can answer questions or help address any ADA-related concerns that students may have. 

V. Procedure for Requesting Accommodations

In order to receive an accommodation, a student (or applicant) must submit a request to the Office of Student Accessibility Services by completing the accommodation request form. The request must explain the need for the accommodation and may include a specific accommodation request. The request must be submitted with adequate time for it to be considered and a determination made. In most cases, and as discussed further below, the student will need to provide evidence of their disability through documentation by a medical care provider.  

Student Accessibility Services does not grant accommodations retroactively. If a student chooses not to disclose a disability to Student Accessibility Services or if a student requests that letters of accommodation are not sent to faculty members, retroactive accommodations cannot be granted. In these instances, a student's belief that the work they have submitted, or exam scores received, do not accurately reflect their academic capabilities will not form the basis for a grade change through the applicable grade appeal process.  

If an accommodation is granted, the Office of Student Accessibility Services will issue a letter to the professor and/or others who must be aware of the accommodation in order to implement it. 

Documentation of Disability & Need for Accommodation

Students may always choose whether or not they want to identify themselves as having a disability, but students who want the university to provide an accommodation must do so. If a student's disability is not obvious, they are responsible for providing medical documentation to support the existence of the disability and the need for accommodation.    

The student is responsible for providing all diagnostic information to sufficiently support the existence of a disability and the need for reasonable accommodation. An accommodation is not needed if the student would still have meaningful access to the program, service, or activity without it. The Director of Student Accessibility Service, or designee, is responsible for deciding whether a disability or need for accommodation(s) has been adequately documented.

Information regarding a student's disability provided by someone other than a university professional must be in writing and provided by a qualified professional, most often a physician, educational diagnostician, learning disability specialist, or mental health professional who is not a blood relative. Student Accessibility Services can offer outside referrals for diagnostic services not provided by the university. All costs associated with diagnostic study incurred off campus are borne by the student. Further information about documentation and verification of a disability is available on the Student Accessibility Services website.

Professional documentation may be relevant for several aspects of a disability accommodation process. It is most relevant for determining whether a student has a medical condition; the university will defer to a medical diagnosis provided that documentation is adequate. Professional documentation is also used to determine whether that condition constitutes a disability, but that is a decision based on the legal definition of a disability and is not solely a medical diagnosis. Professional documentation is often relevant for determining whether accommodation is needed, but depending on the nature of the disability, a physician or other professional may not be as well-equipped as the university to determine what modifications to programs, policies, or services are appropriate or the effect of such modifications. 

Timing; Need to Renew Accommodation Requests 

Students should make accommodation requests as far in advance as practicable of the relevant course, exam, activity, or program to allow for appropriate consideration and planning.

When possible, students entering the university for the first time should submit information related to disability at least six weeks prior to enrollment so that reasonable accommodation can be arranged and delivered in a timely fashion.

Requests for housing-related accommodations generally must be made within the time limits established by the housing selection process. Additional guidance regarding housing-related accommodations is provided on the Residence Life website.

Students must renew certain accommodation requests each semester (including summer sessions).[1]  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. Student Accessibility Services will alert students who have an accommodation that requires renewal.

Accommodation Determinations

Student Accessibility Services will consider the request and the information (documentation) provided by the student, consult with faculty and/or other university officials or committees as needed, and determine whether and what accommodation(s) to approve. (See Section III for a definition of accommodation.)  The Director or designee also may seek advice or recommendations/guidance from the ADA/Rehabilitation Act Coordinator and/or the Medical Review Committee in considering an accommodation request. 

Student Accessibility Services will identify a list of approved accommodations in accordance with the manifestations of the disability, a copy of which will be shared with the student. For academic accommodations, Student Accessibility Services will prepare individual letters for each professor or for the appropriate school official[2] summarizing the approved accommodations relevant to their course. Students are responsible for communicating with faculty members regarding their desired accommodations; students who need assistance with such communication due to their disability should speak with Student Accessibility Services staff. Faculty and other university officials are then required to provide reasonable accommodation(s) in accordance with the Student Accessibility Services' letter(s) as requested by the student. If a student encounters any problems with the implementation of an accommodation, the student should contact Student Accessibility Services.

Disability & the Foreign Language Requirement

Students with conditions that adversely affect the learning of a foreign language may request reasonable accommodation within the structure of required foreign language courses. If accommodation proves unworkable, however, students may petition the Committee on Degrees for authorization to substitute select courses for foreign language courses. They should petition as soon as possible but no later than the pre-registration period of the first semester of their senior year.

To ensure that modification is considered only when truly needed, students must provide documentation of disability meeting specific criteria. Students experiencing exceptional difficulty with foreign language course should also consider approaching any current foreign language instructor to discuss concerns.

Service & Emotional Support Animals

Service animals are trained dogs (or dogs in training) and miniature horses. Students have a right to bring service animals to campus. Students are encouraged to register service animals with Student Accessibility Services. This will allow William & Mary to make any appropriate accommodations for other students, faculty, or staff who may have allergies, phobias, or service animals of their own. Students wishing to have a service animal live in campus housing must contact Student Accessibility Services.[3]

Emotional Support animals are animals that provide comfort or emotional support to people or that assist someone but do not meet the definition of a service animal. Emotional support animals can be any type of animal. Decisions about emotional support animals living in campus housing are made on a case-by-case basis; students must make a request for accommodation through Student Accessibility Services. Emotional support animals are not permitted in other campus buildings unless a separate accommodation request has been approved. These decisions are also made on a case-by-case basis. 

No animals will be permitted to live in campus housing unless approved by Student Accessibility Services. Students are required to sign an animal agreement/contract, which will be provided by Accessibility Services.

Limited Mobility Transportation Services

Students with temporary or permanent mobility-limiting condition may be eligible for limited mobility transportation services. Applicable students must have their diagnosed condition registered with Student Accessibility Services to be considered for this accommodation. Once a student is approved by SAS, transportation services will be arranged by Parking & Transportation Services. Please contact [[sas]] for more information.

VI. Confidential Handling of Disability Records

All information submitted to or developed by the university related to the diagnosis, documentation, or accommodation of a disability is considered confidential and will not become part of any other student record at William & Mary. The staff of the Dean of Students Office and the ADA/Rehabilitation Act Coordinator have access to all disability records and may arrange access for other authorized university officials in the event of an emergency or other unusual necessity. Disability information may be released in confidence to faculty members or other members of the community who have an educational need to know. The Compliance & Equity Office may collect accommodation data for reporting purposes as well as quality control.

All documents supporting a disability on file in the Student Accessibility Services Office will be retained and destroyed in accordance with Virginia law. 

VII. Appealing Accommodation Determinations 

Students may petition for a review of Student Accessibility Services' determinations under the university's ADA/Rehabilitation Act Grievance Procedure. Under that procedure, students are first encouraged to discuss their concerns with the Director. The next step in the process is a review by the Dean of Students or designee.

VIII. Approvals & Amendment

This policy and procedure are approved by the Provost; the ADA/Rehabilitation Act Coordinator is authorized to make minor, technical revisions to this policy and procedure. 

Revisions to this policy and procedure were approved by the Provost, effective October 1, 2011; further amendments were approved effective July 28, 2017, to improve the readability of the document, to add examples of accommodations, to add and update references, to clarify the use of medical documentation in the accommodation process, to add provisions regarding the use of golf carts and regarding service and comfort/therapy animals, and to authorize the ADA/Rehabilitation Act Coordinator to make minor, technical revisions. Additional amendments were approved effective August 21, 2018, to add provisions regarding limited mobility transportation, to update the role of the ADA/Rehabilitation Act Coordinator, and to update contact information. A clarification regarding the procedure for requesting accommodations was made on December 18, 2018. Additional technical amendments were approved effective February 5, 2021, to update retaliation prohibitions and contact information.

IX. Interpretation; ADA/Rehabilitation Act Coordinator  

Questions concerning the application of this policy and the application of the ADA or the Rehabilitation Act to students may be made to the office of Student Accessibility Services or the university's ADA/Rehabilitation Act Coordinator:

Student Accessibility Services
181 Sadler Center P.O. Box 8795
Williamsburg, VA 23187

Carla Costello, Ed.D. ’15
ADA/Rehabilitation Act Coordinator
Deputy Compliance Officer
108 James Blair Hall
William & Mary
P.O. Box 8795
Williamsburg, VA 23187

X. Related Policies & Other Documents

[1] Accommodation needs can vary depending on a student's current course load, schedule, course content, or the student's disability status. Accommodation requests and renewals are subject to review and approval by Student Accessibility Services.

[2] Specifically, in the Law School, to protect blind grading, accommodation letters typically are provided to a designated dean. 

[3] SAS may consult with Residence Life staff regarding the types of assistance animals suitable for a residence hall.