Provost Memorandum


OF RECORD

Guidelines for Addressing Academic Issues of Students with Disabilities

Policy Statement
The University of Pennsylvania is committed to providing equal educational opportunities to all students, including students with disabilities. Penn does not discriminate against students with disabilities and provides reasonable accommodation to a student’s known disability in order to afford that student an equal opportunity to participate in University-sponsored programs.

Reason for Policy Guidance
This Policy Guidance, known as the Provost’s Memorandum, serves two purposes:

  • To provide guidance to faculty and academic support staff so that they may reasonably accommodate students with disabilities without compromising academic standards and requirements.
  • To assure students with disabilities that the University will provide access to all University-sponsored programs, benefits and activities through reasonable accommodation and program accessibility as required under the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990 (ADA).

Protection from Discrimination
The Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990 prohibit discrimination against people with disabilities by institutions like Penn that receive or benefit from Federal financial assistance. The ADA further protects from discrimination persons who are associated with an individual disability.

Definitions
Disability–Under the law, a person with a disability is defined as an individual who (1) has a physical or mental impairment that substantially limits one or more major life activities (2) has a history or record of such an impairment, or (3) is regarded as having such an impairment. Examples of recognized disabilities under the law include, but are not limited to, blindness, deafness, paralysis, cystic fibrosis, lupus, mental illness, HIV/AIDS and specific learning disabilities including Attention Deficit Hyperactivity Disorder (ADHD).

Reasonable Accommodation– a modification or adjustment to an academic program that enables an otherwise qualified individual with a disability full access to participation in University-sponsored programs. These modifications should not alter the fundamental purpose of the course.

Reasonable accommodation is determined on an individual basis and will reflect the functional impairment so that accommodation(s) may vary from class to class depending upon course content and format. Accommodations are intended to be effective and reasonable; they may not be exactly what the student wishes or requests.

Appropriate Documentation – a written evaluation or report provided by a clinician in a specific profession or area of expertise who is considered qualified to make the diagnosis. The documentation must be current, comprehensive and may include clinical and social histories from parents, counselors and specialists. A diagnosis must be included. Accommodations must relate to the student’s specific functional limitations within the academic setting. The documentation must conform to well-established practices in specific areas/fields.

Responsible University Office
Since January 2002, all students with disabilities are served by the Office of Student Disabilities Services, located in the Weingarten Learning Resources Center under the Office of the Vice Provost of University Life.

The Office of Student Disabilities Services is available to assist faculty, academic support staff, and students in reaching a joint determination of academic accommodations, where needed.

Weingarten Learning Resources Center
Office of Learning Resources
Office of Student Disabilities Services

3702 Spruce Street, Suite 300
(Stouffer Commons)
Philadelphia, PA 19104-6027

For additional information on this Memorandum, contact the above responsible University office.

Accommodation Procedure

The Role of Students
All students with disabilities who seek an accommodation at Penn have the responsibility to identify themselves to SDS. Identification may take place at admissions or at any time during the student’s course of study.

All students with disabilities have the responsibility to provide documentation at their own expense in order to be considered for accommodations. SDS may request additional documentation from students if the determination of a disability is inconclusive, or if the documentation does not support the accommodations requested.

The request for accommodation and supporting documentation must be provided in a timely manner.

After documentation of disability has been approved and accommodations have been proposed, students must give permission for letters to be sent to all instructors in whose classes accommodations are being requested. Instructors should review the proposed accommodations (see below). After there is agreement on the appropriate accommodation, students are encouraged to introduce themselves to professors directly and to initiate a dialogue about their particular needs.

Role of Faculty and Academic Support Staff
Faculty members and academic support staff have a responsibility in ensuring equity in their programs and classrooms. However, the modifications offered should not fundamentally alter the academic requirements essential to a program of study or to licensing prerequisites.

Once faculty members have been notified officially, through presentation of a verification letter from SDS, that a student has a disability and that accommodations are being requested, instructors should review the proposed accommodations. If an accommodation is found to alter fundamentally the academic structure or essential nature of a course the instructor should contact SDS as quickly as possible to request modification of the proposed accommodation, as the presence or absence of an accommodation may affect the students’ ability to take the course.

It is also important to recognize that students with disabilities must reach the same performance standards to fulfill degree requirements as their non-disabled peers. Accommodation provides the student with a disability with equity, not unfair advantage.

Faculty and academic support staff are required to consider accommodations only for students who are registered with SDS through presentation of a verification letter from that office. If faculty have not received verification letters, they should instruct students to contact SDS.

Confidentiality
All documentation provided by the student resides with the Office of Student Disabilities Services, which will assess the need for accommodations. This information will be kept as confidential as practical while the accommodations are being considered and thereafter.

Having presented appropriate documentation of disability to SDS, the student is not required to present it to individual professors, programs, or schools.

Faculty should refrain from discussing a student’s issues regarding disabilities and accommodations for them in front of the class, in the presence of other students, or to faculty or staff not directly involved in the accommodation process.

Examples of Suggested Accommodations
The following suggestions represent some, but not all, of the ways faculty and academic support staff may be asked to accommodate students:

  • Providing students with course information such as reading lists, textbooks and syllabi in advance of the start of classes where alternate formats for print material are necessary so that the student can obtain audio recordings of reading material or make textbook enlargements before the start of classes. This gives students with reading disabilities the opportunity to begin their reading early, and the advanced time required for those who rely on recordings.
  • Submitting course information to the Registrar in a timely fashion. If a particular classroom is inaccessible to a student registered for the class, the classroom may have to be modified or the class moved to another location that is accessible. (Inaccessible laboratory areas will be modified, as needed.)
  • Allowing students to record lectures or use assistive listening devices.
  • Allowing Oral or American Sign Language interpreters to attend classes to translate lectures or permitting stenographers to transcribe lectures.
  • Reproducing reading materials, exams, charts and graphs in large print.
  • Allowing students additional time to complete exams.
  • Allowing alternate test formats (e.g. oral exams in lieu of written ones.)
  • Permitting students to take exams in alternate locations.
  • Permitting students to use equipment to take examinations (e.g., closed circuit television that enlarges print, or a word processor).

The appropriateness of any one or more of these or any other accommodations must be determined on an individual basis giving due regard to the available medical documentation and the essential nature and integrity of the academic program or course of study involved.

Concerns and Complaints
The Office of Affirmative Action and Equal Opportunity Programs is responsible for overseeing the University’s implementation of its equal opportunity and nondiscrimination obligations arising under federal, Commonwealth, and local laws. Any concerns or complaints relating to perceived violations of the Provost’s Memorandum should be addressed to this office.

To register a concern or file a complaint if there is uncertainty about whether a request is reasonable or if there is disagreement about an accommodation, contact this office.

Educational Resources and Publications
There are several helpful educational and resource publications available through the Office of Student Disabilities Services and the Office of Affirmative Action and Equal Opportunity Programs:

  • Office of Affirmative Action Fact Sheet and other printed information describes the network of services, policies and procedures.
  • ADA Compliance Guide published by Thompson, a complete index.
  • Section 504 Compliance Handbook, a complete index.
  • Guidelines for Communicating About People with Disabilities.

This Memorandum is available in alternate format upon request.