The Provost's Office periodically issues guidelines for addressing academic issues of students with disabilities. These are intended to remind the University community of Federal requirements that prohibit discrimination against people with disabilities and to describe the resources available to faculty and students regarding accommodations, procedures, and support services. Last revised in 1994, the Guidelines that follow below were updated this year by the Committee on Learning Disabilities, chaired by Professor John Richetti, working closely with Alice Nagle, Associate Director for the Program for People with Disabilities, and Dr. Judith Nathanson, the University's Learning Disabilities Specialist.
The Guidelines have been reviewed and approved by the Council of Undergraduate Deans, the President and me.
--Robert Barchi, Provost
Guidelines for Addressing Academic Issues of Students with Disabilities
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:
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 against persons who are associated with an individual disability.
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 Offices
Since August 1998, all students with Learning Disabilities and/or ADHD are served by the Office of the Learning Disabilities Specialist in Counseling and Psychological Services. All students with motor or sensory disabilities are served by the Program for People with Disabilities located in the Office of Affirmative Action and Equal Opportunity Programs.
Each responsible University office is available to assist faculty, academic support staff, and students in reaching a joint determination of academic accommodations, where needed.
For additional information on the Memorandum, contact one of the above responsible University offices.
The Role of Students
All students with disabilities who seek an accommodation at Penn have the responsibility to identify themselves to the responsible University office. 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. Either disability office 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 the appropriate University office, 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 structure of a course the instructor should contact as quickly as possible the appropriate University office 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 the appropriate University office, through presentation of a verification letter from that office. If faculty have not received verification letters, they should instruct students to contact the appropriate office.
All documentation provided by the student resides with the Learning Disability Specialist or the Associate Director, Program for People with Disabilities, who 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 the responsible University office, 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:
Concerns and Complaints
The Office of Affirmative Action and Equal Opportunity is responsible for overseeing the University's implementation of its equal opportunity and nondiscrimination obligations arising under federal, state and Commonwealth 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 Affirmative Action and Equal Opportunity Programs:
This Memorandum is available in alternate format upon request.
Almanac, Vol. 46, No. 14, December 7, 1999