Policies and Procedures for Students with Disabilities

Pittsburgh Theological Seminary recognizes disability as an aspect of diversity, the inclusion of which is vital to the seminary community and to society. The Academic Affairs Office makes available to all students disability resources intended to bolster success and make the learning environment accessible and inclusive. Students with disabilities can begin the collaborative process of accessibility by contacting the Associate Dean for Students and Formation to develop a partnership, generate solutions, and implement reasonable accommodations.

Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990 prohibit discrimination against individuals with disabilities. The seminary’s Associate Dean for Students and Formation (“Dean of Students”) shall serve as the institution’s ADA Coordinator for students with disabilities.

STUDENT RIGHTS AND RESPONSIBILITIES

Students with disabilities have both rights and responsibilities which include the following:

  • RIGHT to equal opportunity to learn and participate in their chosen academic program, through the provision of reasonable accommodations, academic adjustments, and/or auxiliary aids and services.
  • RIGHT to confidentiality of information regarding their disability, except as disclosure is necessary to acquire accommodations, facilitate services, and/or is required by law.
  • RIGHT to accessible formats of content and documents.
  • RIGHT to file a complaint, in accordance with the seminary’s Section 504/ADA Grievance Procedures and without fear of retaliation, if in good faith they believe they have been subjected to discrimination on the basis of disability or have been denied access to accommodations as required by law.
  • RESPONSIBILITY to meet and maintain essential qualifications and standards for the seminary’s courses and programs.
  • RESPONSIBILITY to follow published procedures for obtaining reasonable accommodations at the seminary.
  • RESPONSIBILITY to provide documentation that (a) provides sufficient detail of the manner in which their disability may impact their participation in the seminary’s academic programs or their ability to share equally in the benefits and privileges of the seminary’s programs and (b) supports each accommodation request.

SEMINARY RIGHTS AND RESPONSIBILITIES

The seminary also has rights and responsibilities which include the following:

  • RIGHT to identify essential functions, abilities, skills, knowledge and standards for courses and programs and to evaluate all students equally on these bases.
  • RIGHT to request and receive current documentation that supports accommodation requests.
  • RIGHT to select among equally effective accommodations to provide for students, and to do so in a timely manner.
  • RIGHT to refuse an unreasonable accommodation or a request that imposes a fundamental alteration to a program or course or lowers the seminary’s academic or conduct standards.
  • RIGHT to deny a request for an accommodation if documentation does not support the request, or if documentation is not provided.
  • RESPONSIBILITY to provide content and documents to students in accessible formats.
  • RESPONSIBILITY to provide and facilitate reasonable accommodations for students in courses and programs.
  • RESPONSIBILITY to ensure programs, courses, and facilities are available in the most integrated and accessible settings possible.
  • RESPONSIBILITY to maintain appropriate confidentiality of records and communications.

DEFINITIONS AND QUALIFYING CONDITIONS

Section 504 of the Rehabilitation Act and the Americans with Disabilities Act defines a disability as “a mental or physical impairment that substantially limits a major life activity.” Recognized conditions that are eligible to receive disability services, for example, include but are not limited to:

  1. Learning Disabilities (e.g., dyslexia, ADD);
  2. Physical Disabilities (e.g., visual impairment, deafness, cerebral palsy); and
  3. Psychological Disabilities (e.g., anxiety, depression, PTSD).

SUMMARY OF STEPS FOR OBTAINING SERVICES

These are the steps that shall be followed when a student seeks services from the seminary in dealing with a disability. Detailed explanations for each step follow.

  1. The student contacts the Associate Dean for Students and Formation (“Dean of Students”) and requests assistance in walking through the following steps to secure disability resources.
  2. After conversation, the student submits a written petition to the Dean of Students, requesting a “Plan of Accommodation” including documentation to support the request.
  3. The petition is reviewed by the Associate Dean for Students and Formation and appropriate faculty (e.g., academic adviser, current instructors).
  4. A “Plan of Accommodation” is drafted by the Dean of Students and sent to the Dean of Faculty and Vice President for Academic Affairs for approval and signature. The plan is then presented in writing to the student for acceptance and a signature.
  5. After the “Plan of Accommodation” is accepted by the student, the signed copy is submitted to the student’s instructors and adviser and is sent to the Registrar for placement in the student’s confidential student file.
  6. Normally, the student is responsible for initiating conversation with each professor prior to the beginning of each semester concerning implementation of the “Plan of Accommodation.”  In some instances, and after conferring with the student’s advisor and/or the Dean of Students, the student may create a different means of implementing academic accommodations with any or all of the student’s professors.
  7. The “Plan of Accommodation” is reviewed before each subsequent academic year.
  8. A students who believes they have been denied a requested academic accommodation or service required by law has the right to file a grievance seeking review of the denial. Please refer to the ADA Grievance Procedure.

STEP #1: INITIAL CONTACT

The Dean of Students welcomes the opportunity to talk with students who wish to seek Disability Resources and to assist them in walking through the process outlined below. Students may make a meeting request by phone or email. Conversations can take place by phone, Zoom, or in person.

STEP #2: PETITION FOR SERVICES AND REQUIRED DOCUMENTATION

Once admitted to Pittsburgh Theological Seminary and at least 4 weeks prior to matriculation, entering students requesting accommodations should petition the Dean of Students in writing requesting accommodations. Current students should petition as early as possible, but at least 4 weeks prior to the beginning of each semester in which accommodations are requested. Students who choose not to self-identify when they enter the seminary do not forfeit their right to receive accommodations at a later date. However, late submission of documentation may result in a delay in implementing any accommodation plan. Accommodations cannot be retroactive. The written petition submitted to the Dean of Students should include a description of the student’s needs/disabilities, a list of services requested, and appropriate documentation to support the accommodations being requested. Once in place, the “Plan of Accommodation” can be used by students throughout their enrollment at the seminary.

REQUIRED DOCUMENTATION

In support of the written petition, students must submit relevant and current documentation of a disability from a qualified health professional(s). Documentation of previously provided accommodations from other educational settings can also be submitted in support of the petition for accommodation. Appropriate documentation should not be more than 3 years old and should include:

  • A description of the disability, specifying duration and severity
  • Test scores and interpretation, if relevant
  • Information concerning prescribed medications and their potential side effects
  • Assessment of substantial disability-based limitations and how they relate to the educational environment
  • Recommendations concerning educational accommodations

Documentation must be on official letterhead and signed by the doctor or health care professional. The seminary reserves the right to request additional documentation, if needed. No documentation will result in a waiver of Pittsburgh Theological Seminary’s admissions policies, regulations regarding acceptable behavior, or course objectives and requirements, including the attendance policy. Accommodation requests that fundamentally alter the nature of the curriculum or a course’s learning objectives are not considered reasonable under the applicable federal laws. All costs for testing and assessment in support of the petition are the responsibility of the student, although testing costs may be reimbursed by health insurance companies. Documentation is also required for the use of service animals on campus. Please see Appendix I. Documentation can be submitted to the Dean of Students via fax, email, or hard copy.

STEP #3: PETITION REVIEW

The Dean of Students shall review the student’s petition for services and respond within 5 business days.

STEP #4: PLAN OF ACCOMMODATION

The Dean of Students, in consultation with appropriate faculty members, will craft a “Plan of Accommodation” that will be submitted to the Academic Dean for approval. The Plan will then be presented in writing to the student for acceptance and a signature. The “Plan of Accommodation” need not include specific diagnostic information. The student may request to have information removed from the Plan of Accommodation, if the student believes that the Plan discloses more information than is necessary.

Students who believe they have been denied a requested academic accommodation or service required by law has the right to file a grievance seeking review of the denial. Please refer to the ADA Grievance Procedure. Class format, i.e., online, on-campus, intensive, shall be taken into consideration when crafting the “Plan of Accommodation.”

STEPS #5 and #6: PLAN IMPLEMENTATION

After the “Plan of Accommodation” has been crafted, submitted to the student, approved, and signed, a final copy of the plan will then be submitted to the student’s academic adviser, all instructors, and, if applicable, the Director of Field Education. Information about a student’s disability diagnosis will only be provided to individuals on a need-to-know basis. Normally, it is the student’s responsibility to communicate with each instructor about implementation of the “Plan of Accommodation” prior to the beginning of the semester. If a student requests accommodation directly from a faculty member without communicating with the Dean of Students, the faculty member must counsel the student to contact the Dean of Students. Accommodations for reported disabilities should not be provided without notification from the Dean of Students. In some instances, and after conferring with the student’s advisor and/or the Dean of Students, the student may create a different means of implementing academic accommodations with any or all of the student’s professors. A faculty member is not responsible for any academic accommodations until a copy of the “Plan of Accommodation” has been issued by the Dean of Students, approved by the student, issued in writing to instructors, and a conversation between the student and instructor has occurred concerning implementation (unless the Dean of Students advises the instructor of a different approach).

STEP #7: REVIEW

The “Plan of Accommodation” for each student shall be reviewed by the Dean of Students before each academic year.

OTHER IMPORTANT INFORMATION ABOUT DISABILITY SERVICES

ADA GRIEVANCE PROCEDURE

This Grievance Procedure shall be effective on August 31, 2021. The seminary reserves the right to amend such procedures. Any seminary student who believes that he or she has been subjected to discrimination on the basis of disability or has been denied access or accommodations required by law shall have the right to invoke this Grievance Procedure. In general, this Grievance Procedure is designed to address the following types of concerns:

  • Disagreements or denials regarding requested services, accommodations, or modifications to curriculum requirements;
  • Alleged harassment or discrimination on the basis of a disability; and
  • Any other alleged violations of the ADA and/or Section 504.

FILING A GRIEVANCE

Regardless of the specific grievance procedure invoked by a student, all grievances must be filed within 30 days of the event or action giving rise to the student’s complaint(s). As an initial matter, all grievances shall be reviewed to determine whether they are submitted within a timely manner and/or whether they contain all required information. The seminary shall not review a grievance that is untimely or fails to contain all required information, including a clear statement of all grounds for the grievance. To facilitate a clear and prompt resolution; once initiated, a grievance shall not be expanded beyond the issues presented in the student’s initial complaint. This grievance procedure is intended to be the sole and exclusive process for challenging any decision relating to a disability-related academic accommodation through internal seminary procedures. In particular, the PTS Anti-Discrimination Policy and Procedures do not apply to disability-related academic accommodations and are not designed to assess or change any determination rendered under this policy. A failure to invoke any part of the grievance process does not mean that the student has lost any legal right to challenge the seminary’s failure to provide a requested accommodation.  This process is offered as a voluntary means to address quickly and efficiently a failure to provide an accommodation, in the hope that the situation can be resolved internally and early in the semester in which the accommodation was requested.

GRIEVANCE PROCEDURE

1. An otherwise qualified student with a disability, as defined by the ADA and the Rehabilitation Act, shall have the right to request that the Grievance Committee* review the denial of any requested academic accommodation or service by fully complying with the procedures detailed below. This provision shall also apply to a student requesting an academic accommodation who believes the seminary has wrongly denied certification of a disability.

*The Grievance Committee shall be led by the Dean of Students and shall include the following: the seminary’s Vice President of Finance and Administration (or his/her designee), a neutral staff person, an uninvolved faculty member, and a representative from the student body. The aforementioned list of individuals shall be selected by the Dean of Students.

2. The Student shall fully complete an “ADA Review Request Form” and submit it to the Dean of Students within 10 days following the date of the denial of the requested academic accommodation or service. A student may obtain a copy of the “ADA Review Request Form” from the Admissions and Student Services Office. The student’s completed form must clearly state:

  • The basis and rationale for the review
  • The specific facts and/or policies supporting the student’s position
  • The remedy and resolution desired by the student
  • All other information required on the form

3. An “ADA Review Request Form” is considered incomplete and not eligible for review if it does not contain all required information. The student is solely responsible to supply all required information on the form within the 10-day deadline from denial of the requested accommodation. Upon receiving a timely “ADA Review Request Form,” the Grievance Committee shall send a notice of acknowledgment of receipt to the student.  To the fullest extent practical, the members of the Grievance Committee shall keep both the existence of the review and the facts learned as a result of the review process confidential and shall not disclose or discuss the review or the facts learned as a result of the review with anyone other than the other Grievance Committee members.

4. The Grievance Committee shall assess the “ADA Review Request Form” and review all information necessary to render a written determination. If requested by the committee, the student shall supply any additional information pertaining to the grievance. The committee will issue a written “Letter of Determination” on the student’s “ADA Review Request Form” within 5 business days after receiving the student’s completed form, or as soon as possible thereafter. Further, the committee shall provide the student with a copy of the “Letter of Determination.”

5. Within ten (10) days following receipt of the committee’s written “Letter of Determination,” if the student disagrees with the determination, the student may seek a review with the Dean of Faculty & Vice President for Academic Affairs (“Dean of Faculty”). The student shall submit a written letter requesting a review of the committee’s “Letter of Determination.” The written request must identify the specific facts and grounds which form the basis for the student’s appeal. Upon receiving a timely letter seeking a review of the Dean of Student’s “Letter of Determination,” the Dean of Faculty shall, at the Dean’s sole discretion, gather additional information necessary for the consideration of the student’s appeal, including, but not limited to, interviewing individuals, including the student, who may possess relevant information. The Dean of Faculty shall complete this review within 10 days or as soon as possible thereafter.

6. No later than three (3) days after the end of the review period, the Dean of Faculty shall send a written “Letter of Review” in response to the student’s appeal, setting forth the Dean of faculty’s decision. The Dean of Faculty’s “Letter of Review” shall constitute the final decision of the seminary.

7. During the Grievance Process, the student will be entitled to receive the academic accommodations/services offered, if any, by the seminary. The seminary recognizes the importance of a student’s concerns and pledges to address issues promptly so as not to inhibit the student’s participation in the course or program.

NOTE: For purposes of calculating all time periods set forth in this Grievance Procedure, official seminary holidays and breaks set forth in the seminary’s academic calendar (such as Thanksgiving break, Christmas break, and Holy Week break) or dates the seminary officially closes (such as for inclement weather) shall be excluded in determining the time period for taking any required action. Moreover, the day of the act or event from which the designated period of time begins to run shall not be included. The last day of any time period provided in the Grievance Procedure shall be included, unless it is a Saturday or Sunday, and in such an event, the next business day shall be counted in the time period.

RECORDS

A student filing a grievance shall have the right to review all records maintained in the grievance file or relied upon by any decision-maker, unless any such review is prohibited by federal or state law. Upon a student’s request, the seminary shall establish a mutually acceptable time and location for the student to review the requested records.

NO RETALIATION

Retaliation against any person who files a bona fide complaint of discrimination, participates in an investigation, or opposes a discriminatory educational practice or policy is prohibited by seminary policy and federal and state law.

SELF REPRESENTATION

A student exercising his or her right to invoke this Grievance Procedure is free to consult with others but shall be expected to represent himself or herself directly in the grievance process. The expectation of self-representation does not, however, does not mean that a student cannot have reasonable support ensure communication during the Grievance Procedure; for example, a sign language interpreter for a hearing impaired student.

URGENT OR UNUSUAL MATTERS

Depending upon the specific circumstances and the urgency of any issue(s) raised by a student in his or her grievance, the seminary reserves the right (but shall not be required) to modify its procedures or conduct an expedited review.

OCR COMPLAINT

Although students are encouraged to attempt to resolve complaints pertaining to disabilities by utilizing this Grievance Procedure, they have the right to file a complaint directly with the U.S. Department of Education, Office for Civil Rights (OCR) (Mid-Atlantic regional office). Information regarding applicable timelines and procedures is available from OCR. https://www.hhs.gov/civil-rights/filing-a-complaint/index.html

APPENDIX I

SERVICE ANIMALS

If a disabilities qualified student has a service animal, the following shall apply:

A service animal is defined as a guide dog or signal dog trained to work or perform tasks for the benefit of an individual with a disability. (At the current time, only dogs are recognized as service animals under Titles II, III, and the ADA.) Pets and therapy animals whose primary purpose is to provide comfort and emotional support do not qualify as service animals under the ADA.

The care and supervision of a service animal is the responsibility of the owner using the animal’s services. The owner must ensure that the animal is in good health and has been vaccinated against diseases as recommended by the American Veterinary Medical Association. Further, service dogs must wear rabies vaccination tags.

Service animals must be kept on a leash or lead at all times when the animal is in a public area. The owner must also be in full control of the animal at all times. The owner is responsible for the cost to repair any damage done by the service animal to seminary property.

Appropriate documentation must be on file in the Academic Affairs Office before a service animal enters the seminary.

APPENDIX II

SAMPLE DISABILITY SUPPORT SERVICES PLAN OF ACCOMMODATION

 

Name    Avery Smith                                                      Date    August 1, 2021                              

Degree Program    Master of Divinity                            Academic Term    Fall, 2021                   

The student has requested that the following description/explanation of his/her condition be disclosed: Avery has been legally blind since age 5. Avery has made arrangements to obtain reading materials in braille and/or audio.

Professor:    Dr. Jones                                      Course    CH120                                      

Students with disabilities may experience barriers to their full and meaningful participation in an academic setting. The above noted student is enrolled in your class and has been determined eligible to receive disability support services. The student has requested academic accommodations as outlined below and should be held to the same attendance and academic standards as students who do not have a disability. In order to provide equal access to the course and all course materials, the following accommodations are necessary:

  • Reader if written materials be presented in class and unavailable in braille form
  • Interpreter if PowerPoint or other images be displayed during class lecture
  • Permission to sit near the classroom exit door
  • The accompaniment of a seeing-eye dog
  • Reader/Scribe* for all tests, quizzes, and exams (Student possesses computer technology capable of translating audio to text for the purpose of paper writing and understands he is responsible for following all footnoting requirements.)

*The scribe has been instructed to record answers verbatim without alteration.

 

___________________________________________________   _____________________

Student’s Signature                                                                         Date

 

___________________________________________________   _____________________

Signature of Associate Dean for Students and Formation               Date

 

NOTE TO PROFESSOR:

If appropriate, discuss with the student his or her perceived barriers should there be an emergency evacuation and develop a plan of action. Accommodations should not fundamentally alter the nature of any course or program of study. It is not always possible to anticipate how each student’s disability will be impacted in a course. As a result, it may be necessary to amend the above approved accommodations. Should you require clarification regarding this, please contact the Associate Dean for Students and Formation. The information contained in this document is CONFIDENTIAL and should not be disclosed to a third party without written permission from the student.

 

PETITION FOR DISABILITY SUPPORT SERVICES

 

Name____________________________________  Date ____________________________

 

Degree Program____________________________ Academic Term ___________________

 

Description/explanation of condition:                                                                                                                             

 

[   ] I have attached supporting documentation from a professional heath care provider to support this request and certify that it is not more than three years old.

[   ] I have requested supporting documentation and it is forthcoming.

Please provide an itemized list of the accommodations you wish to request. Include a statement explaining how and why said accommodation will increase your academic performance. (NOTE: Accommodations cannot reduce the attendance or academic standards set forth by the seminary, nor can they fundamentally alter the nature of any course or program of study.)

1)

2)

3)

I understand that the information contained on this form will be held in confidence and only shared with others on a “need to know” basis. I expect it to be utilized for the sole purpose of assisting me in achieving academic success. Further, I understand that I will in no way be discriminated against for the disclosure of this information.

___________________________________________________   _____________________

Student’s Signature                                                                          Date

INSTRUCTIONS: Please submit this petition to the seminary’s Associate Dean for Students and Formation at least 4 weeks prior to the beginning of an academic term. The Associate Dean for Students and Formation will review the petition and respond within 5 business days.