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Fwd: [ICUlist] ADA Coordinators & Access Plans


Joy Deleon <[log in to unmask]>


Open Forum for Learning Assistance Professionals <[log in to unmask]>


Fri, 4 Feb 2011 14:54:39 -0600





text/plain (637 lines) , Unknown Name (637 lines) , Unknown Name (637 lines) , ADA and Section 504 Coordinator.docx (637 lines)

Nancy and all,

This was recently discussed on a listserve for folks who work with students
with disabilities at Independent Colleges and Universities (ICU).  I have
forwarded these conversations.  I am sorry for the "junk" that comes with
it, but I didn't have time to edit it down.

I hope that this helps,


Forwarded conversation
Subject: [ICUlist] ADA Coordinators & Access Plans

From: *Copney-Okeke, Linda* <[log in to unmask]>
Date: Mon, Jan 31, 2011 at 9:37 AM
To: "[log in to unmask]" <[log in to unmask]>

 First, I know where ADA Coordinator positions are located on our campuses
was recently discussed back in October, and most schools who responded
pointed out that the position was located either under VP Administration or
in HR.  We have been without  an ADA Coordinator for a few months due to
changing personnel, and we are considering or have asked our HR person if
they would be willing to be the Coordinator.  I have a meeting tomorrow in
regard to this and would like feedback from my peer institutions  about the

1)      I know that Section 504 requires a coordinator & that ADA supports
but does not directly require one for private institutions.  Can you point
me to where in both laws it states this requirement.

2)      Do you have a job description for an ADA Coordinator at your school
that I can look at?

3)      What specific responsibilities does your ADA Coordinator have?  Is
it just hearing grievances or are they responsible for the overall
coordination of compliance efforts across campus including entities such as
facilities and construction.

I do not want for this responsibility to fall into my lap for the sole
reason that while I can point out problems with compliance, I do not have
any authority to make compliance happen.  I would like to ensure that we
have someone in place who actually has a voice at the table where decisions
are being made.

Second, we have not done an access plan in quite a while (our former ADA
Coordinator had planned to conduct one, but left), and I am wondering if
others are redoing one now that the ADAAA amendments have been passed.  Is
there a template of some kind to look at?

Thanks in advance for any input you can give me.

Linda Copney-Okeke

Director, Campus Access

University of New Haven

"*A Leader in Experiential Learning*"

300 Boston Post Road

West Haven, CT 06516

Phone: (203) 932-7332

Fax: (203) 931-6082

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From: *Shirley Tucker* <[log in to unmask]>
Date: Mon, Jan 31, 2011 at 10:01 AM
To: "[log in to unmask]" <[log in to unmask]>

 Please post to list.

 *Shirley E. Tucker, Ed.D., Director, *
*Disability Services Office *
*& **Academic Resources Center*
*Lancaster Bible College*
*901 Eden Road*
*Lancaster PA 17601*
*(717) 560-8200, ext. 5383*
*[log in to unmask]*
information that is privileged, confidential and exempt from disclosure
under applicable law. If you are not the intended recipient of this message,
please do not disclose, forward, distribute, copy, or use this message or
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notify me immediately by return e-mail and delete the original message from
your e-mail system. Thank you.

>>> "Copney-Okeke, Linda" <[log in to unmask]> 1/31/2011 10:37 AM

From: *Steiger, Gavin* <[log in to unmask]>
Date: Mon, Jan 31, 2011 at 10:22 AM
To: [log in to unmask]

Hi Linda,

I can't answer your first 2 questions, but I may be able to help with the
3rd. I believe the ADA coordinator will have a wide range of
responsibilities. Along with the one's you mentioned, the ADA coordinator
would also be responsible for all other aspects of campus compliance (e.g.,
web accessibility and accessible technology [remember the Penn State case],
perhaps overseeing visitor requests, assisting in emergency planning, and
employment issues). Ideally, I would wish the ADA Coordinator to be someone
outside of HR so that if an employee files a grievance it would go to a
third party. However, I recognize that this typically does not happen at
small universities and colleges, including Trinity.


Gavin Steiger, M.Ed.

Coordinator, Disability Services for Students

Trinity University

One Trinity Place, Box 85

San Antonio, TX 78212-7200

Phone: 210-999-7411

Fax: 210-999-7848

Office: 215 Coates University Center

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From: *Joy Deleon* <[log in to unmask]>
Date: Mon, Jan 31, 2011 at 1:31 PM
To: [log in to unmask]

Hi all!

I found an old string of emails relevant to this question.  The
discussion/question was initiated when I read an article in *Disability
Compliance in Higher Education* (Vol 15, Issue 7, February 2010) which I
would recommend.

We had been operating under "ADA Coordinator by Committee" and as a result
of these discussions designated our VP for Administration (who is over HR
and physical plant) as our ADA Coordinator - because he had the power to get
some things done and was over 2 of 3 of the main areas (and we would work
together on areas that overlapped).

I am also attaching some information that I copied from various sources to
prepare for that decision.

I hope that this is ultimately helpful.



Email string starts here:

 Hi Joy, both 504 and ADA require us to do so!

35.107 Designation of responsible employee and adoption of grievance

(a) Designation of responsible employee. A public entity that employs 50 or
more persons shall designate at least one employee to coordinate its
efforts to comply with and carry out its responsibilities under this part,
including any investigation of any complaint communicated to it alleging
its noncompliance with this part or alleging any actions that would be
prohibited by this part. The public entity shall make available to all
interested individuals the name, office address, and telephone number of
the employee or employees designated pursuant to this paragraph.

(b) Complaint procedure. A public entity that employs 50 or more persons
shall adopt and publish grievance procedures providing for prompt and
equitable resolution of complaints alleging any action that would be
prohibited by this part.

ADA Coordinator by Committee

Three years ago, I was working at another institution where my role was that
of an ADA Coordinator. At Trinity and my former institution, the ADA
Coordinator role was kept separate from HR and DS. I think there can be a
number of advantages to this organizational structure.

At Trinity (since we are a small private liberal arts school), the ADA
Coordinator is also the VP for Fiscal Affairs. This structure is nice
because she controls the pot of money we have for ALL accommodations (HR,
DS, visitor, and campus renovation). Having a central pot of ADA-specific
money means that individual departments donít have to scrounge for money to
pay for an interpreter, or purchase an expensive piece of AT. At my other
institution (a large public land-grant school), the position was housed
under the Office of Institution Equity. This, too, was a very good fit since
one role of the ADA Coordinator is to ensure campus compliance with the ADA
and non-discrimination (the heart of the ADA!) The DS and HR offices can
usually address their own issues and deal with them appropriately. Sometimes
it is nice to get a second opinion from another person on campus though.

Along with ensuring campus compliance with all aspects of the ADA
(employment; public access for employees, students, and visitors; education;
technology; etc.), the ADA Coordinator will often be the person who will
deal with grievances. If the ADA Coordinator is also the DS provider or the
HR staff person, then the ADA Coordinator may not have an objective
third-party analysis of the grievance because of the vested interest they
may already have with the case. This is where it is nice to have one
specific person who makes the final decision.

I most often contact the ADA Coordinator at Trinity when I am dealing with
an expensive accommodation request (e.g., CART) or if I have a vested
interest in campus construction/renovations (e.g., new science building).
This is not to say, though, that you cannot or should not have more contact
with *your* ADA Coordinator. I donít have a job description to pass along,
but you may want to contact Scott Lissner at Ohio State. He is the ADA
Coordinator there and may be able to provide you with more information about
his role. Please let me know if I can help further.

San Antonio, TX 78212-7200

215 Coates University Center

Hi Joy, problem i see is that this person and office and phone have to be
prominently displayed and advertized as the place to go, difficult when
there are 3 of you to consider.   With us the ADA officer is also the vp
for ADA/504/equity/diversity and used to be AA, but NE voted AA out this
year.  But his name is prominently listed on everything as the ADA, then we
are his little toadies and minions :-)


Considering that most of the settlement agreements and both ADA title II and
the 504 regulations state that the college must provide notice of its
designated an ADA Coordinator and include the person's name and the
disability grievenace procedures in publications, I don't think having a
committee act as ADA Coordinator  would be sufficient.  The October 2009
issue of DCHE discusses this in the "OCR Finds Fault with Disability
Coordinator's Lack of Training" article.  Section 504 section 104.7 is
entitled "Designation of  responsible employee and adoption of grievance
procedure".    You may want to get these two sources and present them to
your college.


I agree with Linda. Also, I have 2 other questions: 1) Who is responsible
for providing accommodations to visitors? 2) Hypothetically, if an employee
or student wishes to file a complaint because they want to challenge an
accommodation request that was denied, to whom do they make this complaint?
Who is responsible for responding to grievances filed against either office?
(BTW, I hope you never have to deal with this issue, and I guess I asked 3

In my experience, I believe there should be an ADA coordinator who is
responsible for campus-wide disability compliance, responding to visitor
requests, and addressing grievances should they be filed. I believe this
person can wear hats outside the ADA coordinator role and should be someone
outside HR and DS to maintain objectivity.


Teresa said:

 << Have you ever heard of such a split? I havenít, I assume the 504
coordinator is the 504 coordinator, and isnít normally just for students or
just of employees. Right? Or possibly right? >>

The problem is that the split you are describing is NOT that unusual.  It is
not unusual for there to be very separate folks handling employees and
students, with no middle ground between them.  The problem is that there is
NO ONE assigned to handle a big chunk of things that fall under neither the
"student" or "employee" realm.  The school needs to clearly designate
someone (and give them a budget) to do what is generally considered to be
the COORDINATION aspects of 504/ADA for the campus.

Try asking this question: "If a student who was graduating had a parent who
was Deaf and needed an interpreter, who would be responsible for gathering
that information, making arrangements for the interpreter, and paying for
it?"  Once they answer THAT question, they have identified who they want to
be TRULY in charge of 504/ADA coordination (beyond the things you and
what's-his-name are doing now).  If they want that to be YOU, I would be
inclined to accept the responsibility IF it came with both the authority and
some additional budget to make things happen.

We have had this situation.  A parent contacted the registrar because the
registrar sends out information about graduation and a note indicating she
should be contacted if there are special needs.  The registrar contacted me
and I told her that the department responsibile (financially) for the
graduation ceremony should hire an interpreter--and then I gave her several
names of interpreters.  The registrar's office paid for the interpreter fee.
We have had similar situations with orientation week, when parents are on
campus.  The orientation budget picks up the costs and coordinates the
service and I help with that part if they want it.

(We are a small school of about 1300 students.)


Fellow Listers-

I have been asked by the woman who was just made the ADA Coordinator to find
out what exactly that entails.what duties and responsibilities does that
title typically include?

Could anyone recommend a good resource/manual/etc for her?

Many thanks in advance-


Lynn M. Walden

Coordinator, Disability Services

Northern Michigan University

2001 C.B. Hedgcock

1401 Presque Isle Ave.

Marquette, MI  49855

(906) 227-1737

FAX (906) 227-1714


Scott's website has his job description which I think is very helpful.

LRP also puts out a very good book on ADA Coordinators responsibilities.  It
was written by three ADA Coordinators who are members of AHEAD.

Emily Singer
Disability Support Services
The Catholic University of America
620 Michigan Ave NE
207 Pryzbyla Center
Washington, DC 20064
202-319-5211 phone
202-319-5126 fax
[log in to unmask]

Hi Lynn,

Here's a description of our ADA's (Human Rights Compliance Officer)
duties. This is from the website, not the job description, but it gives
you an idea. BTW, our previous ADA asked me the same question. There is
a job description, but how it plays out is different for every
institution. Also, some duties vary. Here ya go:

"Reporting directly to the President, the Director of Human Rights,
Access & Inclusion provides professional and authoritative advice with
respect to University matters that concern discrimination, diversity,
equity and harassment issues.  The position serves as the University's
Affirmative Action/Equal Opportunity Officer by ensuring compliance,
reporting and enforcement in the areas of discrimination and harassment
for students, faculty and staff.

As such, the Director of Human Rights, Access & Inclusion audits
practices and advises university managers, supervisors and employees on
compliance with University policies related to diversity and human
rights, including equal employment opportunity, affirmative action,
harassment (including sexual), disability discrimination and other forms
of discrimination; undertakes necessary related investigations and
prepares recommendations and written reports; assists in carrying out
policies and strategies that integrate diversity and human rights into
the University's strategic goals and its Diversity Plan by coordinating
and collaborating with other UI offices; provides guidance and support
to the Dean of Students, who is responsible for investigating incidents
of discrimination in which a student is the alleged perpetrator; serves
as the university's Americans with Disabilities Act coordinator,
monitoring ADA activities for compliance with University, state and
federal policies; develops and delivers training regarding
discrimination, diversity and sexual harassment prevention."

I hope this is helpful.

-----Original Message-----
From: Disabled Student Services in Higher Education
[mailto:[log in to unmask]] On Behalf Of Lynn Walden

Sent: Friday, August 28, 2009 8:34 AM
To: [log in to unmask]
Subject: ADA Coordinators

There are a couple of Thompson publications that I really appreciate, The
Guide to Workplace Accommodations, and the ADA Compliance Guide. The former
gives nice ideas about processes, updates, regs, etc. and the latter gives a
monthly newsletter and keeps me updated on where things are at and headed.
For those that get Disability Compliance for Higher Ed, it has that feel but
comes at it from a more employer/employee perspective. There are a couple of
great conferences that they could attend that may help as well, although I
don't think there's one for a while (might be one in Oct.). I went to one in
June in KC that was quite good. They gave TONS of handouts that I'd be
willing to share she'd like to contact me.

Wish her luck, I feel her pain,


Edward A. Martinelli, Jr., Ph.D.
Director, Accessibility Services
ADA Coordinator
LC 312
Utah Valley University
800 W. University Parkway MS-190
Orem, UT 84058-5999
(801) 863-8747
(801) 863-8377 (fax)

This is what DOJ has to say about the job

ADA Best Practices Tool Kit for State and Local Governments <http://www.ada
Chapter 2 <>  Addendum:
Title II Checklist <>

(ADA Coordinator, Notice & Grievance Procedure)
L. Scott Lissner, University ADA Coordinator
Office Of The Provost, The Ohio State University
1849 Cannon Drive
Columbus, OH 43210-1266
(614) 292-6207(v); (614) 688-8605(tty)
(614) 688-3665(fax); Http:// <>
This email communication is confidential.  If you are not the intended
recipient, please do not read, copy, use, or disclose the contents of this
communication to others.  Please notify the sender that you have received
this email in error by replying to the email or by telephoning (608)
363-2572.  Please then delete the email and any copies of it.  Thank you.


Joy de Leon
Assistant Dean of Students
Director, Learning Enrichment and Disability Services
Beloit College
700 College Street
Beloit, WI 53511
(608) 363-2572 (office)
(608) 363-7059 (fax)
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Joy de Leon
Assistant Dean of Students
Director, Learning Enrichment and Disability Services
Beloit College
700 College Street
Beloit, WI 53511
(608) 363-2572 (office)
(608) 363-7059 (fax)
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