I. Purpose. The purpose of this Procedure is to implement the College’s Disability Accommodations Policy (“Policy”) as it pertains to Visitors, as defined in the Policy.
II. Scope and Applicability. This Procedure applies to any Visitor who is seeking a Disability Accommodation in order to access a Service.
III. Definitions
A. All capitalized terms in this Procedure have the meanings provided in the Policy.
B. All other capitalized terms in this Procedure have the following meanings:
1. Accommodation File means the Accommodation Request, any communications with the Visitor, the decision of the Fundamental Alterations Review Committee, if any, and the written decision of the Manager to the Visitor.
2. College-sponsored event is an event hosted by the College or College department for College Employees, Students or Visitors on College Property. It does not include events sponsored by third parties on College Property pursuant to a facilities use agreement or other contractual agreement.
3. DSS means Disability Support Services.
4. Event Services means the Office of Event Services.
5. Manager means the Event Services Manager, or designee.
6. VP LRM means the Vice President for Learning Resources Management.
IV. Types of Accommodations that May Be Considered
A. A Visitor with a Disability may be eligible for a Disability Accommodation, based on the circumstances.
B. Examples of Disability Accommodations that may be provided if they do not create an Undue Hardship, cause or fail to mitigate a Direct Threat, and/or cause a Fundamental Alteration to a Service, include but are not limited to, the following:
1. Arranging for Auxiliary Aids and Services at College events;
2. Providing food labeling for allergies in dining facilities; and/or
3. Providing accessible seating arrangements or space at College events.
C. If a requested Disability Accommodation would impose an Undue Hardship on the College, cause or fail to mitigate a Direct Threat, and/or cause a Fundamental Alteration to a Service, the College will reasonably accommodate the Visitor’s Disability to the extent that it can do so without causing an Undue Hardship, Direct Threat to the College, or Fundamental Alteration, even though such a Disability Accommodation would be partial in nature.
D. Where there is more than one reasonable Disability Accommodation that would not pose an Undue Hardship, Direct Threat, or cause a Fundamental Alteration, the College is not obligated to provide the Disability Accommodation that is preferred by the Visitor.
E. The College is responsible for covering the cost of approved Disability Accommodations, not the Visitor receiving the Disability Accommodations. Costs will be charged to the department hosting the Activity for which the accommodation is provided.
F. Visitors are not required to request permission to bring Service Animals or Service Animals in Training onto College Property where members of the public are allowed to go, including Buildings that are open to the public and areas in which they access College Services or engage in College Activities. Visitors are subject to the provisions of the Service Animal Procedure and should direct any questions to the Office of Public Safety & Police (410-777-2440 Office; 410-777-1329 TTY; 443-336-3144 Text).
V. Accommodation Request
A. A Visitor who is seeking a Disability Accommodation in connection with accessing a College Service or attending a College-sponsored event must submit an online Accommodation Request Form to Events Services using the link available on the College website.
B. A Visitor who is seeking a Disability Accommodation for an event that is not a College-sponsored event but that occurs on College Property, should contact the event host directly to request accommodations.
C. If a Visitor is unable to submit the Accommodation Request online, the Visitor can contact Events Services by telephone at 410-777-2614; via email at [email protected]; or in person at Student Union Building 158.
D. Timing of Accommodation Requests
1. An Accommodation Request from a Visitor will only be granted through Event Services and must be made in an adequate amount of time prior to the desired onset of the Service.
2. A Visitor should make the Accommodation Request as early as possible to provide the College with a reasonable amount of time to provide the requested Disability Accommodation.
3. Visitors seeking sign language interpreter services and/or assistive technology must submit an Accommodation Request at least thirty (30) days prior to the date of the Service; otherwise, the College cannot guarantee the requested Disability Accommodations will be available by date of the Service.
E. In the Accommodation Request, the Visitor must describe:
1. The Visitor’s name, email address, and phone number;
2. The Service for which the Visitor needs an Accommodation;
3. The Visitor’s Disability; and
4. How the Disability prevents them from accessing a Service.
VI. Communications regarding Accommodation Requests
A. All communications with the Visitor and decisions will be sent to the Visitor, with a copy to the Authorized Employee, using the email address provided by the Visitor.
B. The Visitor is responsible for responding to communications in a timely manner, and failure to do so may result in the Accommodation Request not being granted prior to the need for the Disability Accommodation.
VII. Consideration of Accommodation Requests
A. Upon receipt of an Accommodation Request from a Visitor, the Manager, in consultation with the ADA & Accessibility Compliance Officer, if needed, will determine appropriate Disability Accommodations. If the Manager has questions about whether the Visitor has a Disability, the Accommodation Request is reasonable, or the Accommodation Request would result in an Undue Hardship, Direct Threat, and/or Fundamental Alteration, the Manager may consult with the Office of General Counsel.
B. If both the Visitor’s Disability and the need for a Disability Accommodation are readily apparent and the Accommodation Request does not constitute an Undue Hardship, pose a Direct Threat, or otherwise result in a Fundamental Alteration of the College’s Service, the Manager will approve the Disability Accommodation.
C. If both the Visitor’s Disability and the need for a Disability Accommodation are not readily apparent, the Manager will contact the Visitor to engage in an interactive dialogue regarding the Disability and the need for a Disability Accommodation.
D. The Manager may deny an Accommodation Request if, at the Manager’s sole discretion, provision of the Accommodation creates an Undue Hardship to the College or causes or fails to eliminate a Direct Threat.
E. The Manager may consult with the Authorized Employee(s) for a Service about whether the Accommodation Request can be granted without creating an Undue Hardship, Direct Threat, or Fundamental Alteration.
F. If the Manager believes that granting the Disability Accommodation will result in a Fundamental Alteration of the Service and an appropriate alternative Disability Accommodation cannot be determined, the Manager will refer the matter to the Fundamental Alteration Review Committee to determine whether granting the Disability Accommodation would result in a Fundamental Alteration.
G. If, after these consultations, the Manager determines that the Accommodation Request can be granted without creating an Undue Hardship, Direct Threat, or Fundamental Alteration, the Manager will notify the Visitor that the Accommodation Request has been granted.
H. If the Manager determines that the Visitor does not have a Disability, the Accommodation Request is not reasonable, or the Accommodation Request would result in an Undue Hardship, Direct Threat, and/or Fundamental Alteration, the Manager will consult with the Office of General Counsel before denying the Accommodation Request.
I. In general, primary consideration will be given to the Disability Accommodation requested by the Visitor unless there is another equally effective accommodation, or the Accommodation Request would cause an Undue Hardship, cause or fail to eliminate a Direct Threat, or result in a Fundamental Alteration. In such circumstances, the Manager will identify an effective alternative Disability Accommodation taking into consideration the timeliness, accuracy, and appropriateness of the alternative Disability Accommodation.
J. If the Visitor does not accept the alternate Disability Accommodation and no agreement can be reached, the Manager will deny the Disability Accommodation.
VIII. Decision on Accommodation Request
A. The Manager, after consultation with the Visitor and other individuals as necessary, will make the final determination whether to approve or deny the specific Disability Accommodations.
B. The Manager will send a written decision to the Visitor’s email address.
C. A decision to grant a Disability Accommodation applies only to the Service described in the Accommodation Request and does not constitute a policy or universal decision for future Accommodation Requests.
D. To the extent the Visitor seeks a Disability Accommodation to another Service, the Visitor is required to submit another Accommodation Request and follow this Procedure.
IX. Appeals
A. A Visitor may appeal a decision made by the Manager by submitting an Appeal Form in writing to the VP LRM no later than three (3) Business Days after the decision being sent to the Visitor.
B. No other individual, department, or office, including the Authorized Employee(s), may appeal the granting of a Disability Accommodation to a Visitor.
C. The VP LRM will review the Appeal Form and Accommodation File and decide whether to accept, reject, or modify the decision of the Manager on the Accommodation Request as soon as is reasonably practicable.
D. The VP LRM will send the decision to the Visitor, and if a Disability Accommodation is granted or modified, will send a copy of the decision to the Authorized Employee(s).
E. The decision of the VP LRM is final and may not be further appealed or grieved.
X. Implementation of Disability Accommodations
A. The Authorized Employee(s) and/or Event Services is responsible for implementing any Disability Accommodations granted to the Visitor.
B. Visitors are responsible for promptly notifying the Authorized Employee and/or the Manager if they believe an approved Disability Accommodation is not being provided or is being provided is not effective.
C. The Manager and any Employee responsible for implementing an Accommodation must make every attempt to respect the privacy of the Visitor when making or implementing a Disability Accommodation.
XI. Confidentiality of Records
A. The Manager will document in writing all Visitor Accommodation Requests and the conversations during the interactive process.
B. This information shall be kept in a secure location and shall be treated as confidential, except as necessary to administer the Disability Accommodation process or implement the Disability Accommodation.
C. The Manager will maintain a copy of Accommodation File for three (3) years after the decision is issued.
XII. Deadlines. Any deadlines set forth in this Procedure may be extended for good cause and with notice in writing to the Visitor.
XIII. External Complaints
A. Although Visitors are encouraged to attempt to resolve complaints using the College’s internal appeal procedures set forth above, Visitors have the right to file a complaint directly with the external agency authorized to accept such complaints or pursue other remedies available to them under state or federal law.
B. A Visitor may file complaints of violation of Section 504 of the Rehabilitation Act with the following agencies:
U.S. Department of Education
Office for Civil Rights
Lyndon Baines Johnson Department of Education Bldg
400 Maryland Avenue, SW
Washington, DC 20202-1100
Telephone: 800-421-3481
FAX: 202-453-6012; TDD: 800-877-8339
Email: [email protected]
Philadelphia Office
Office for Civil Rights
U.S. Department of Education
The Wanamaker Building
100 Penn Square East, Suite 515
Philadelphia, PA 19107-3323
Telephone: 215-656-8541
FAX: 215-656-8605; TDD: 800-877-8339
Email: [email protected]
C. A complaint regarding violation of Americans with Disabilities Act may be submitted to the U.S. Department of Justice www.ada.gov/complaint/ or at:
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Civil Rights Division
Disability Rights Section 1425 NYAV
Washington, D.C. 20530
Fax: (202) 307-1197
1. The Department of Justice complaint process is described at www.ada.gov/filing_complaint.htm.
2. For questions about filing an ADA complaint, a Visitor may call the
ADA Information Line at 800-514-0301 (voice) or 800-514-0383 (TTY) or 202-307-0663 (voice and TTY).
Procedure Title: Visitor Disability Accommodations Procedure
Policy Category: General
Policy Owner: President
Policy Administrator: Event Services Manager
Contact Information: Peter Kaiser; [email protected]; 410-777-2821
Approval Date: January 8, 2024
Effective Date: September 16, 2024
History: N/A
Applies to: All Visitors
Related Policies: Disability Accommodations Policy
Related Procedures:
Forms/Guidelines:
Relevant Laws: