SA-4102 Disability Assessment and Accommodation

1.0        Purpose

VTCSOM welcomes and embraces diversity in all forms, including individuals with disabilities. This policy provides guidelines for the VTCSOM community to assure compliance with the Americans with Disabilities Act of 1990 (ADA) (as amended) and the Rehabilitation Act of 1973 (as amended) during the interactive process of requesting and implementing accommodations for individuals with disabilities. 

Please note that this document is subject to change and can be revised as required.  

For more information on how to request accommodations, review Procedures for Requesting Accommodations.

Information about appeals and grievances can be found in Appeals and Grievances.

2.0        Policy

VTCSOM is committed to fostering a community that welcomes and embraces diversity in all forms, including the inclusion of individuals with disabilities. Medical students with disabilities are encouraged to access all of the resources available to them, including registering and requesting accommodations (see Procedures for Requesting Accommodations for step-by-step instructions).

To ensure an accessible educational experience, VTCSOM will work with Virginia Tech’s designated Services for Students with Disabilities, located on the Blacksburg campus, to provide accommodations and support to VTCSOM medical students with documented disabilities. In partnership with SSD and in the interest of minimizing barriers, VTCSOM has identified a VTCSOM Services for Students with Disabilities (SSD) liaison who will guide individual students with disabilities through an interactive process, which includes the documentation of disabilities, the determination of appropriate accommodations, and implementation of approved accommodations. Effective collaboration will garner the expertise of university partners to ensure that medical students with disabilities receive high-quality accommodations and support.

Accommodations will be determined and approved on a case-by-case basis to meet the needs of each individual medical student, ensuring that accommodations do not require fundamental alterations to the curriculum, while meeting the technical standards for medical students.

During the interactive process, information about a student’s accommodations request and disability-related needs may be provided to VTCSOM deans, faculty, administrators, clinical preceptors, and/or ad hoc consultants on a need-to-know basis as deemed necessary for the determination of appropriate accommodations. However, medical students’ information will be held in the strictest confidence during the process and specific student disability information is not shared. Once accommodation requests that are approved, the VTCSOM SSD liaison will work closely with the student, the Associate Dean for Student Affairs, the Senior Associate Dean for Medical Education, course directors, clerkship directors, and faculty members as appropriate to insure implementation.

There are three central themes for registering and requesting disability accommodations at VTCSOM:

• VTCSOM’s commitment to protecting the privacy of all learners. 
• All candidates for the degree of Doctor of Medicine attest to the ability to meet the Technical Standards for Medical School Matriculation, Promotion, and Graduation, with or without reasonable accommodation. 
• Early communication with relevant disability service providers (dsp), administrators, and faculty is critical to a successful partnership in determining and implementing accommodations.

It is VTCSOM’s responsibility in the process to:

• Refer students to the VTCSOM SSD liaison when appropriate;
• Participate in the interactive process;
• Designate a liaison to work with appropriate parties in documenting, determining, and approving accommodations;
• Assist with implementation of reasonable accommodations; and
• Hold the student accountable to academic and technical standards. 

It is the VTCSOM SSD liaison’s responsibility to:

• Maintain appropriate documentation and ensure that medical student’s privacy is upheld;
• Engage the appropriate individuals in the interactive process;
• Assist student with notifying and communicating with faculty about implementation of approved accommodations;
• Assist student when approved accommodations are not being properly implemented;

It is SSD’s responsibility in the process to:

• Maintain appropriate documentation and ensure that medical student’s privacy is upheld;
• Engage the appropriate individuals in the interactive process; and
• Assist student when approved accommodations are not being properly implemented;

It is the student's responsibility in the accommodation process to:

• Self-identify as having a disability;
• Schedule a meeting with the Disability Advocacy & Student Support liaison to discuss accommodations;
• Provide appropriate documentation;
• Request accommodations and participate in the interactive process;
• Attest to the ability to meet the Technical Standards for Medical School Matriculation, Promotion, and Graduation, with or without reasonable accommodation;
• Follow procedures for requesting and implementing accommodations;
• Notify the VTCSOM SSD liaison and/or SSD if accommodations are not being implemented and/or if adjustments or additional accommodations are needed.

3.0        Procedures

VTCSOM students with disabilities and students who suspect they may have a disability are encouraged to access all available resources as early as possible. Your inquiry is confidential, and students can obtain general information without registering. The process of requesting and receiving accommodations is an interactive one and you are strongly encouraged to participate.

1. Meet with VT’s Services for Students with Disabilities or VTCSOM SSD Liaison to register for services and discuss potential accommodations. As part of the registration process, you will need to provide documentation of your disability. For more information about documentation, visit the SSD website. 
   1. Copies of documentation may be presented in person, by mail, and/or by fax.
   2. Please note, accommodations during undergraduate medical education may vary from those received previously and accommodations provided in the didactic setting are determined separately from those in the clinical setting. Thus, it is important to discuss your needs with the liaison and make a request for clinical accommodations as early as possible, even if you are considering not utilizing accommodations. 
   3. Review the Doctor of Medicine Technical Standards for Medical School Matriculation, Promotion, and Graduation.
   4. If you register through VTCSOM SSD liaison, then your registration form and documentation will be shared with Virginia Tech’s SSD.
2. SSD will assess the documentation to determine if the documentation supports the presence of a disability and demonstrates the need for accommodations. 
3. SSD notifies VTCSOM SSD Liaison whether or not documentation meets criteria.
   1. If the documentation does meet criteria, go to Step 4.
   2. If the documentation does not meet criteria, the student has the option to discuss this with the VTCSOM SSD liaison and/or SSD staff and/or present new documentation. In some cases, students can register with the SSD office, but will not receive classroom accommodation until appropriate documentation is provided.
4. Meet with SSD, the VTCSOM SSD liaison, and other faculty, as appropriate, to discuss accommodations and services that will assist you with meeting the technical standards.
5. Virginia Tech’s SSD and the VTCSOM SSD Liaison will work with the Associate Dean for Student Affairs and the VTCSOM Medical Student Performance and Promotion Committee (MSPPC) to verify that the requested accommodations are reasonable and do not alter an essential feature of the curriculum or technical standards. The MSPPC does not have a role in approving or denying requested accommodations.
6. Once you have registered and your request has been approved, SSD will provide you with an accommodation letter that describes your eligibility for services. Once your letter is received, send it to the VTCSOM SSD Liaison.
7. Upon receiving your letter, the VTCSOM SSD liaison will schedule a meeting to discuss with you any necessary details to implementing accommodations, such as:
   1. Including determination of who else needs to be aware of your accommodation needs (e.g., Associate Dean for Assessment and Program Evaluation, course directors, clerkship directors, coordinators, other instructors) in order to facilitate the accommodation. 
   2. Notify those identified instructors and other members of the teaching team who need to be aware of your accommodations. 
   3. Other needs as determined on a case-by-case basis.
8. The VTCSOM SSD liaison will follow up with you on an ongoing basis to:
   1. Ensure that approved accommodations are being implemented and to help address any issues that may arise. 
   2. Provide you with guidance on how to request adjustments and/or additional accommodations, if needed. 
   3. Prepare for future accommodations request, including certification, licensing, and board exams, which are made directly to the agency that administers the exam, such as the National Board of Medical Examiners. 
9. You are responsible for notifying the VTCSOM SSD Liaison if your approved accommodations are not being implemented or if you need adjustments to your accommodations.

4.0        Appeals and Grievances

VTCSOM seeks to determine disability accommodations through an interactive process involving disability services professionals, appropriate members of the university community, and the individuals with disabilities themselves.

We recognize that in any deliberative process and with the best efforts of everyone involved with your service delivery at VTCSOM, disagreements may occur. VTCSOM offers a range of options to resolve concerns about accommodation and eligibility decisions, services received, treatment by university staff and faculty, and University policies related to students with disabilities.

Throughout the resolution process, you may expect to receive timely responses and have your concerns addressed in a respectful manner. Disability-related law and University policy prohibit retaliation in any form against persons who file complaints.

We strongly encourage you to let the VTCSOM SSD liaison know about any concerns as soon as possible and provide clear and detailed information so that we can work together to solve the problem as quickly as possible. If you wish to know more about your rights as an individual with a disability under Federal and State law and University policy, VTCSOM SSD can refer you to the appropriate entity.

5.0        Appeals and Grievance Procedure

Students have many options to resolve issues using VTCSOM’s grievance processes. An individual who believes that they have been discriminated against on the basis of their disability is encouraged to work with VTCSOM to resolve their concerns. While attempts at internal resolution are always recommended first, external means for resolving concerns are also available, and may be exercised at any time.

VTCSOM has a complaint procedure to deal promptly and fairly with concerns and complaints about discrimination based on disability as well as other areas of discrimination. The procedure may be used by any student who believes that they have been discriminated against or harassed based on race, color, religion, gender, sexual orientation, national origin or citizenship status, age, disability, or veteran’s status.

Anyone may bring forth information or a concern about discrimination or harassment. Complaints are handled as confidentially as possible to protect the rights of both the complainant and the person accused. Retaliation against anyone who makes a complaint or participates in a complaint process will not be tolerated.

Option 1

Informal Resolution - This first step is an informal process where VTCSOM SSD works to resolve accommodation concerns between the student and faculty, or staff through the interactive process. VTCSOM does not conduct investigations, but rather works with SSD to promptly identify an agreeable solution.

• VTCSOM Services for Students with Disabilities Liaison, Christie Neal, at cdneal1@vt.edu
• Contact Associate Dean of Student Affairs, Amanda Murchison, MD, at amandabm@vt.edu

Option 2

Per Virginia Tech Policy 4075, appeals of any decisions made or actions taken, including complaints of discrimination on the basis of a disability should be directed to the university’s Director of Compliance and Conflict Resolution at (540) 231-2010 

Option 3

Discrimination Complaint - Any person who believes he or she has been subjected to discrimination on the basis of a protected category may contact the Office of Civil Rights (OCR), U.S. Department of Education. OCR advises that a potential complainant may want to explore and utilize the institution’s grievance process to resolve the complaint prior to filing a complaint against an institution. However, individuals are not required by law to use the institutional grievance process before filing a complaint with OCR.

Seek resolution by contacting the
Office of Civil Rights (OCR),
U.S. Department of Education at
Voice: (415) 486-5555,
TTY: (877) 521-2172

OR

The student may file a complaint with the Department of Education Office of Civil Rights

OR, by writing to:
District of Columbia Office
U.S. Department of Education
1100 Pennsylvania Ave., NW, Rm. 316
P.O. Box 14620
Washington, D.C. 20044-4620

Telephone: 202-208-2545
FAX: 202-208-7797; TDD: 202-208-7741
E-mail: OCR_DC@ed.gov

VTCSOM developed this information in accordance with these references: Public Law 101-336; the Americans with Disabilities Act of 1990, as amended (ADA AA); Section 504 of the Rehabilitation Act of 1973; applicable regulations; and the Virginia Polytechnic Institute and State University Policy 4075.

6.0        References

• Technical Standards for Medical School Matriculation, Promotion, and Graduation
• University Accommodations of Persons with Disabilities Policy 4075
• Virginia Tech Services for Students with Disabilities website
• Virginia Tech Director of Compliance and Conflict Resolution
• Department of Education Office of Civil Rights
• Office of Student Affairs
• Assistant Director and VTCSOM Services for Students with Disabilities Liaison
• Associate Dean of Student Affairs
• Office of Educational Affairs
• Senior Associate Dean for Medical Education
• Associate Dean for Assessment and Program Evaluation

7.0        Approval and Revisions

Approved by Student Affairs