Student Disability Accommodation

Title: Student Disability Accommodation Policy and Procedure
Effective Date: October 1, 2011
Responsible Office: Compliance & Equity, Student Affairs
Last Updated: August 25, 2025

I. Scope

This policy and procedure is for all qualified students with a disability to request and obtain reasonable accommodations at William & Mary, including the Virginia Institute of Marine Science (the university). Students must self-identify and register with Student Accessibility Services (SAS) as an individual with a disability and provide relevant and appropriate documentation to request and obtain reasonable accommodations. Applicants for admission are also covered by this policy for accommodations needed during the admissions process.

Students engaged in academic work off-site, including internships and study-abroad programs, should contact SAS for assistance. Student employees seeking accommodations related to their jobs should contact SAS, who will coordinate with University Human Resources as appropriate to provide reasonable accommodations in the context of student employment.

II. Purpose and Policy Statement

This policy and procedure enable the university to comply with the Americans with Disabilities Act (ADA), as amended (ADAA, 2008), and Section 504 of the Rehabilitation Act of 1973, as amended, which require equal access to educational programs, activities and services, as well as the provision of reasonable accommodations made for qualified students with disabilities. Students seeking religious accommodations should follow the process in that policy.

Student Accessibility Services (SAS) is the office designated by the university to work with qualified students with disabilities to determine reasonable accommodations through an individualized, collaborative, and interactive process. Accommodations do not guarantee student success, rather they seek to provide equal access and participation in educational programs and activities.

Reasonable accommodations are not determined based solely on student preferences; rather they are determined through an interactive process and based upon information and documentation received

regarding the functional limitations of a student’s disability. When making determinations about reasonable accommodations, it may be necessary for SAS to consult with faculty or other staff as appropriate.

Reasonable accommodations do not include:

Fundamental alterations, or substantial modifications/adjustments, to academic standards essential components to any program of instruction or other university program or activity, or modifications of any essential program component directly related to a licensing requirement.
Personal use items or devices, including but not limited to personal care attendants, mobility devices, eyeglasses or hearing aids.
Modifications or adjustments that result in an undue financial or administrative burden to the university, considering the nature, cost, and impact of the accommodation and other factors.

Faculty and staff may not make independent determinations about fundamental alterations or undue burden and must contact SAS with questions or concerns about any requested or approved accommodation.

III. Definitions

Disability means a physical or mental impairment that substantially limits one or more major life activities including, but not limited to

Breathing
Hearing
Learning
Lifting
Seeing
Speaking
Walking
Caring for oneself

Documentation means information that must be submitted to SAS as part of the interactive process to request and receive reasonable accommodations. Documentation includes but is not limited to, a student’s self-report, medical information via the health-care provider form or other form that provides sufficient relevant information, assessments, and high school documentation (IEP/504 Plan). Documentation is intended to assist SAS personnel in determining a student’s eligibility for reasonable accommodations, as well as assisting in the determination of appropriate reasonable accommodations.

Emotional support animal (ESA)¹ means any animal with a primary role of providing a person with a disability emotional comfort. ESA’s may be allowed to live with a student in an on-campus housing if approved as a reasonable accommodation. ESAs are not permitted in other campus buildings unless a separate accommodation has been granted through SAS. All requests are reviewed on an individual case-by-case basis.

Fundamental Alteration² means an adjustment or modification that changes the nature of an academic program or curriculum, lower academic standards or fundamentally alter the requirements to complete a course, certification program or other activity.

Interactive Process means the process by which Student Accessibility Services engages with students on an individualized and collaborative basis, to determine appropriate reasonable accommodations. As part of the interactive process, SAS may consult with faculty or other staff as appropriate.

Qualified Student with a Disability means a student with a documented disability that meets the requirements for admission and the technical and behavioral standards for participation in an educational program, service, or activity, with or without reasonable accommodations.

Reasonable Accommodation means any reasonable adjustment or modification in policies, practices or procedures that enable a qualified student with a disability to have equal access to the university’s programs and activities, inside or outside the classroom.

Service Animal means a dog³, or dog in training⁴, individually trained to do work or perform tasks for an individual with a disability including, but not limited to, guiding individuals with impaired vision, alerting individuals who are hearing impaired to intruders or sounds, providing minimal protection or rescue work, pulling a wheelchair or fetching dropped items. The task(s) performed by the dog must be directly related to the individual’s disability.

Undue burden⁵ means an action requiring significant difficulty or expense when considering factors such as the university’s size, financial resources, and the nature and structure of its operations. Accommodations that are unduly extensive, substantial or disruptive may be an administrative burden for the university.

IV. Procedures for Requesting Reasonable Accommodations

Student Accessibility Services manages the interactive process for qualified students with disabilities to request reasonable accommodations, including, but not limited to, academic accommodations, housing accommodations, academic underloads for medical reasons, meal plan exceptions, and the Limited Mobility Shuttle Service.

SAS may speak with faculty or other appropriate staff to ensure requested accommodations are reasonable given course requirements, curricular expectations, academic standards, and other program requirements.

SAS also works with other university departments such as Facilities Management, Parking & Transportation Services, Residence Life, Care Support Services, Office of the Registrar, Athletics, Auxiliary Services and Student Activities to address special access and service needs related to a student’s educational experience. Students seeking either full or partial withdrawal from one or more courses should contact the Advising Center.

A. Disclosure of Disability, Timing of Requests, Renewals, Retroactive Requests

1. Disclosure. Students may choose whether they wish to identify themselves as having a disability and may choose whether they wish to request accommodations through SAS. To receive accommodations, students must follow the steps outlined in Section B below.

2. Timing. Students (new, continuing or transfer) are encouraged to submit information related to academic accommodation requests at least six (6) weeks prior to enrollment so that students may engage in the interactive process with SAS, provide the required documentation, and utilize approved accommodations within the current semester.

3. Retroactive Accommodations. The university does not provide retroactive accommodations. Students are responsible for requesting accommodations in a timely manner. If a student chooses not to register and request reasonable accommodations with SAS, or if a student chooses not to distribute approval letters to their faculty, retroactive accommodations will not be granted. In these instances, a student’s belief that the work they have submitted, or exam scores received, does not accurately reflect their academic capabilities will not form the basis for a grade change through the applicable grade appeal process.

4. Renewal. Students must renew certain accommodation requests each semester (including summer sessions).

a. If the accommodation request has not changed, the renewal process is typically a brief, online confirmation of continued need. In some instances, updated documentation or other information may be required. SAS will alert students who have an accommodation that requires renewal.

b. Requests for housing-related accommodations generally must be made within the time limits established by the housing selection process. Additional guidance regarding housing deadlines, housing options, and housing-related accommodations is provided on the Residence Life website. Students are placed in housing based on availability at the time of the approved accommodation request. Students will be placed on a priority housing waitlist if appropriate housing is not available at the time of the approval.

B. Steps in the Accommodation Process

1. Registration. Qualified students (or applicants) must register with Student Accessibility Services. As part of the registration process, students must identify the specific disability and explain the correlation between their functional limitations and program access. Registration information may include a specific accommodation request, but all requests are discussed with the student as part of the interactive process and are not automatically approved.

2. Documentation⁶ Qualified students must submit relevant, appropriate documentation to SAS. Documentation can include a student’s self-report, medical information from a health care provider via the health care provider form (or other health care form that provides sufficient and relevant information), assessments, as needed, and high school documentation (IEP/504 Plan)⁷.

SAS may request additional information as necessary to assist in determining eligibility for accommodations and what accommodations are appropriate and reasonable. Medical documentation is often relevant for determining whether accommodation is needed and for understanding a student’s functional limitations. Medical documentation may include the physician’s or other professional’s recommend accommodation. Primary consideration will be given to the requested or suggested reasonable accommodation however, the university has the right to choose among equally effective alternative accommodations and makes the final determination as to what accommodations are provided.

Student Accessibility Services accepts medical documentation from internal providers at the Student Health Center or the Counseling Center. SAS can offer outside referrals for diagnostic services not provided by the university. All costs associated with diagnostic study incurred off campus are the responsibility of the student.

3. Welcome Meeting. After the student registers and provides relevant documentation, SAS contacts the student to schedule a welcome meeting. SAS makes every attempt to schedule the welcome meeting within five (5) business days of the registration. The welcome meeting may take place in person or virtually. During the welcome meeting, SAS engages the student in the interactive process to discuss their functional limitations and potential reasonable accommodations. Students may receive verbal information about approved accommodations during the welcome meeting but depending on the need to interact with appropriate faculty or staff, the process may take additional time. Once an accommodation is formally approved, students receive a notification letter through the Accommodate System.

Approval Letters. If approved for accommodations, SAS prepares accommodation approval letters as noted in Section C. Only information related to the approved accommodation is contained in the letter for students to share with need-to-know faculty or staff.

C. Academic and Housing Accommodations

1. Academic Accommodations. Approval letters for academic accommodations, including testing accommodations, are sent to students through the Accommodate System. Students have discretion to determine which faculty members receive their accommodation approval letters. Students will receive information from SAS on how to share letters with their faculty.⁸

Students are strongly encouraged to communicate and/or meet with their faculty to discuss the implementation of the approved accommodations. This is an important step in the accommodation process. Students may seek assistance from SAS as needed to facilitate conversations with faculty. Students with questions or concerns regarding their approved accommodations and/or implementation of their accommodations should contact SAS as soon as possible.

Students approved for testing accommodations who wish to take their tests/exams in the Testing Center must notify their faculty members at least three (3) days prior to the scheduled test/exam date.

2. Housing Accommodations. Upon approval for a housing-related accommodation, SAS notifies the student and Residence Life via the Accommodate System. Students are placed in housing based on space and availability at the time of the approval. Students are placed on a priority waitlist if appropriate housing is not available at the time of approval. Juniors and Seniors are not guaranteed on-campus housing. Students without guaranteed on-campus housing may request on-campus housing as an accommodation. These determinations will be made on a case-by-case basis, through the interactive process.
a. Service Animals in university housing⁹. Students wishing to have a service animal live in campus housing must contact Student Accessibility Services to ensure appropriate housing and to allow the provision of accommodations for other students who may have allergies, phobias, or service animals of their own. Students must follow the requirements and guidelines which, per Virginia law, include proper licensure and vaccination.

b. Emotional Support Animals (ESA) in university housing¹⁰. ESAs may be allowed to live with a student in on-campus housing if approved as a reasonable accommodation.¹¹ These requests are considered on a case-by-case basis through the interactive process. Students with approved ESAs must follow the requirements and guidelines which include proper licensure and vaccination as appropriate. ESAs are not permitted in other campus buildings unless a separate accommodation request has been approved.

D. Service Animals on campus. Students are not required to request an accommodation to bring a service animal on campus. However, students are strongly encouraged to alert SAS to the presence of service animals, particularly in classrooms, to ensure that accommodations for other students, faculty or staff who may have allergies, phobias, or service animals of their own can be provided. Students must follow the requirements and guidelines which, per Virginia law, include proper licensure and vaccination.

Only two (2) questions are permitted relating to the presence of a service animal on campus: (1) Is the animal required because of a disability; (2) What work or tasks has the animal been trained to perform? Service animals are generally welcome to accompany individuals with disabilities in all areas of campus where the public is allowed to go. There may be areas where service animals are prohibited due to health and safety concerns.

Such areas may include, but are not limited to, research laboratories, mechanical rooms, custodial closets, food service preparation areas, areas where protective clothing is necessary, or areas where there is a danger to the service animal.

V. Accommodation Determinations and Implementation

A. Determinations. Determinations about whether a student is a qualified individual with a disability, and what accommodations are reasonable based on their functional limitations, are made by SAS. Where a requested accommodation is determined not to be reasonable, SAS will discuss equally effective alternative accommodations with the student that would support their disability-related needs. SAS analyzes the following when making reasonable accommodation determinations:

whether the requested accommodation is a fundamental alteration to a course, program, activity or certification;

whether the requested accommodation is an undue administrative or financial burden to the university;

whether the request is retroactive;

whether equally effective alternative accommodations are available.

Determinations regarding fundamental alteration and undue financial or administrative burden will be made in collaboration with SAS, Compliance & Equity, and other employees, including university counsel as appropriate.

B. Implementation. Once accommodation letters are distributed by the student, faculty and staff must implement accommodations approved by SAS. Students are strongly encouraged to engage with their faculty to discuss the implementation of approved accommodations. Students should notify SAS if they experience issues or have concerns about the implementation of their approved accommodations. Faculty or staff with questions about approved accommodations, or need assistance with implementation should contact SAS.

VI. Confidentiality and Retaliation

Records, whether electronic or paper, pertaining to a student’s disability and accommodations, are maintained separately from other education records by Student Accessibility Services. Records relating to a student’s disability and accommodations are considered education records under the Family Educational Rights and Privacy Act (FERPA) and William & Mary's Student Records Privacy Policy and Notification of Rights under FERPA.

Information from records held by SAS is shared only with the consent of the subject student except to the extent that FERPA authorizes disclosure without consent, such as disclosures to school officials with a legitimate educational interest to fulfill their professional responsibilities for the university pursuant to §99.31(a)(1) of FERPA.

Documents relating to a disability on file with Student Accessibility Services will be retained and destroyed in accordance with the Library of Virginia’s Records Retention Schedules.

Retaliation against a student for requesting or receiving disability-related accommodations is prohibited. Concerns about retaliation should be directed to the Office of Compliance & Equity at [[reportconcern]]

VII. Grievance of Accommodation Determination/Disability Discrimination

Students may request a review of Student Accessibility Services' determinations under the university's Student Disability ADA/Rehabilitation Act Grievance Procedure. Under that procedure, students first request a review from the Director of Student Accessibility Services. The next step is a review by the Assistant Vice President for Student Success.

Students may contact the ADA Coordinator for assistance at [[compequity]].

Students who believe they have been discriminated against based on their disability may file a report with the Director of Title IX and Civil Rights Compliance at [[reportconcern]]

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.

Amendments to this policy and procedure were made to align with current Student Accessibility Services practices, to provide clarification and transparency of the steps in the accommodation process and to update contact information. These revisions were approved by the Provost on August 25, 2025.

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 Director of Student Accessibility Services or the university's ADA/Rehabilitation Act Coordinator

Contact Information

Kara Fifield, Director of Student Accessibility Services

181 Sadler Center

P.O. Box 8795 Williamsburg, VA 23187

757-221-2512

[[sas]]

Carla Costello, Ed.D. ’15 ADA/Rehabilitation Act Coordinator

102 James Blair Hall

P.O. Box 8795 Williamsburg, VA 23187

757-221-1254

[[compequity]]

Jenelle Job, Ph.D.

Director of Title IX and Civil Rights Compliance

108 James Blair Hall

P.O. Box 8795

Williamsburg, VA 23187

757-221-4977

[[reportconcern]]

Wilmarie Rodriguez, Ed.D.

Assistant Vice President for Student Success

184 Sadler Center

P.O. Box 8795

Williamsburg, VA 23187

[[studentsuccess]]

X. Related Policies & Other Documents

[1] Virginia Law Requires all dogs to be licensed. Proof of vaccination is required to obtain a license. See Virginia Code Title 3.2, Chapter 65, Article 5.

[2] Faculty and staff may not make independent determinations about fundamental alterations and must contact SAS with any questions or concerns about an approved or requested accommodation.

[3] Revised ADA regulations have a separate provision about miniature horses, where reasonable. The regulations set out four assessment factors to assist entities in determining whether miniature horses can be accommodated in their facility. The assessment factors are (1) whether the miniature horse is housebroken; (2) whether the miniature horse is under the owner’s control; (3) whether the facility can accommodate the miniature horse’s type, size, and weight; and (4) whether the miniature horse’s presence will not compromise legitimate safety requirements necessary for safe operation of the facility.

[4]Virginia law contains a provision that includes service dogs in training that are at least six months of age.

[5] Faculty and staff may not make independent determinations about undue burden and must contact SAS with any questions or concerns about an approved or requested accommodation.

[6] While SAS generally requires medical documentation of a disability before accommodations can be finalized, students may schedule an informational session at any time by either calling the office at (757) 221.2512 or emailing [[sas]]. SAS may provide provisional accommodations (typically for a semester) to ensure equitable access while awaiting documentation, or for other extenuating circumstances, which can be discussed at an informational session.

[7] Individual Education Plans or Section 504 Plans may have helpful information for SAS and are accepted as documentation. However, this documentation may not be sufficient to establish eligibility in a higher education setting. In these instances, SAS will review the information with the student and explain what other documentation is necessary.

[8] In the Law School, to protect blind grading, accommodation letters are typically provided to a designated dean.

[9] See footnote 1.

[10]See footnote 1.

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