Reasonable Accommodation Policy

Policy number11-08
Responsible officeOffice of the Vice President of Diversity and Inclusion (students)
Office of Institutional Equity (employees)
Housing and Residence Life (housing)
Enforcement officialOffice of the Vice President of Diversity and Inclusion (students)
Office of Institutional Equity (employees)
Housing and Residence Life (housing)
ClassificationBoard of Trustees-delegated Policy
Category11. Federal and State Civil Protections

Statement of policy

Western Michigan University (WMU) is committed to ensuring that faculty, staff, employees, job applicants, students, and others have equal access to its programs, will not be discriminated against based on having an actual or perceived disability, and will have the same opportunity to be successful in education, housing, and employment as those individuals who do not have disabilities.  WMU complies with requests for accommodations under the Americans with Disability Act, including the Amendments Act, (hereinafter ADA), Section § 504 of the Rehabilitation Act (§ 504), the Fair Housing Standards Act (FHSA), the Michigan Persons with Disabilities Civil Rights Act, and other related laws and guidance.

Summary of contents/major changes

This Policy combines into one University Policy information that was previously stated in the Human Resources Manual; on the Office of Institutional Equity’s (OIE), Residence Life’s, and the Disability Services for Students’ (DSS) webpage; and other legal and regulatory requirements.

1. Purpose of Policy

WMU is committed to ensuring that individuals who identify as having disabilities are fully included in University life and receive the accommodations necessary for making education, employment, and University Programs accessible in compliance with federal and state laws.  This Policy describes how WMU implements that commitment and sets standards that the University must meet when responding to requests for or providing reasonable accommodations. 

2. Stakeholders Most Impacted by the Policy

The Policy applies to employees, students, and members of the public who participate in University Programs and who either provide or require reasonable accommodations so individuals with disabilities may have equal access to those programs. 

3. Key Definitions

3.1.  Auxiliary Aid: accessible or alternative texts aiding those with print-related disabilities including visual, learning, or hand dexterity challenges; interpreters or other effective methods of making orally delivered materials available to individuals with hearing impairments; scribes and/or qualified readers that make learning environments accessible

3.2.         Essential Functions of a Program, Position, or Instruction:  those functions that are fundamental to the course of education, program, or position that the individual holds or desires.  The phrase "essential functions" does not include marginal functions.  

3.3.         Housing:  any residential housing facility that is located on campus, owned, operated, licensed, leased, or under the control of the University, including apartments and residence halls

3.4.         Interactive Process:  a process through which employers and employees with disabilities who request accommodations work together to develop reasonable accommodations; at WMU this process includes the employee, the employee’s supervisor, and the Office of Institutional Equity (IE)

3.5.  Major Bodily Functions: include, but are not limited to, functions of the immune system, normal cell growth, digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine, and reproductive functions

3.6.  Major life activities: include, but are not limited to, caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, and working

3.7.  Marginal functions: those instructional or positional duties that are less important or not critical to the success or failure of the specific program or position 

3.8.         Non-Apparent or Invisible Disability: a disability that is not readily apparent upon casual interaction with a person

3.9.         Person with a disability: a person who has a physical or mental impairment that substantially limits one or more major life activities or bodily functions; a record of such impairment; or who is regarded as having such impairment

3.10.      Qualified Employee:  an employee (faculty or staff) with a disability who, with or without a reasonable accommodation, can perform the essential functions of the position  

3.11.      Qualified Individual:  Qualified Student, Qualified Employee, or other Person with a Disability 

3.12.      Qualified Student:  a student with a disability who, with or without a reasonable accommodation, meets the academic and technical standards requisite to admission or participation in a University program or activity

3.13.               Reasonable Accommodation: any change in the workplace, course of instruction, program, or the way things are customarily done, that provides Qualified Individuals with an equal opportunity to participate and that does not impose undue hardship on the University or fundamentally alter the workplace, education, or other University Program

3.14.      Semester Request:  form students complete to have DSS send official notification of approved reasonable accommodations to relevant faculty member(s) for a specified semester 

3.15.      Temporary Disability: a short-term acute illness or injury that temporarily impacts an individual’s ability to access academic programs, housing, or employment

3.16.      Undue Hardship: significant difficulty or expense to the University.  Factors to consider include, but are not limited to, the nature and cost of the accommodation, the impact of the accommodation upon the nature and operation of the department, course of instruction, or employment position and how the request affects the health and safety of other employees or students.  When considering cost, Undue Hardship is viewed based on the resources of the University as a whole, not based on an individual unit or department.

3.17.      University Program:  an official program or event operated by or sponsored by the University, such as commencement or graduation

3.18.      Other relevant terms are defined as set forth in the Department of Health and Human Services’ Regulations implementing Section 504 of the Rehabilitation Act of 1973, the ADAAA, the FHSA, or other relevant law.  45 C.F.R. § 84.1, et seq. 

4. Full Policy Details

4.1.     The University is committed to providing Reasonable Accommodations to students, employees, and members of the public who seek to participate in University Programs, services, activities, and employment. 

4.2.  Federal and state anti-discrimination laws extend civil rights protection to education, employment, and housing of individuals with disabilities.  Under these laws, WMU may not discriminate against any otherwise qualified individual because of a disability, perceived disability, record of a disability, or a relationship to someone with a disability.  WMU must ensure such individuals have the same access to programs and employment as do individuals without disabilities unless doing so would pose an undue hardship to the University or fundamentally alter the workplace, education, or other University Program.  

4.3. The University is not required to provide a Qualified Individual’s desired accommodation.  Instead, the University and the Qualified Individual must participate in the interactive process to identify a reasonable accommodation that will allow the Qualified Individual to equally participate in University employment, education, Program, or event without placing undue hardship on the University or fundamentally altering the workplace, education, or other University Program.  

4.4.   As part of the Interactive Process for evaluating accommodation requests, WMU will consider individual preferences; however, WMU makes the ultimate determination as to the accommodation provided, which may not be the Qualified Individual’s desired accommodation.  Qualified Individuals may appeal that determination or file a complaint with an outside agency as discussed below.

4.5.  A Qualified Individual is not required to identify themselves as a Person with a Disability or to request an accommodation. However, all individuals seeking a Reasonable Accommodation must submit a request because the University must be informed of the disability and need for accommodation in order to begin the Interactive Process.  

4.6.     Student Accommodation Requests

4.6.1.     Academic Accommodations requirements may be adjusted, as necessary, to ensure that the courses or programs do not discriminate against Qualified Students. Academic adjustments may be required unless the change requested would eliminate requirements that are essential to the program of instruction or to any directly related licensing requirement (e.g., CPR, lifeguard, or health care provider certifications).  Academic adjustments may include, but are not limited to:

                 i.         Changes in the length of time permitted for the completion of degree requirements;

                ii.         Substitution of specific courses required for the completion of degree requirements; or

               iii.         Adaptation in the manner in which specific courses are conducted.  Students must provide their own Auxiliary Aids for use outside of class, such as personal attendants, individually prescribed devices, readers for personal use or study, or other devices or services of a personal nature.  The University will provide Auxiliary Aids for in-class use and test-taking.  Qualified Students may still participate in Educational Programs or activities if they do not elect to use such aid(s).

4.6.2.     Housing Accommodations

At the Qualified Student’s request, WMU will provide convenient, accessible Housing that is comparable to that provided to students without disabilities at the same cost it provides the same or similar housing to students without disabilities.  WMU will not discriminate in providing such housing.  WMU will not limit room assignments for Qualified Students with accommodations to any particular building.  Qualified Students who have been granted an accommodation will not be required to pay a fee or surcharge for an approved accommodation.  The University reserves the right to assign a Qualified Student with an accommodation to a single room or a room without a roommate.  If the University assigns a Qualified Student with an accommodation to a single room as part of the interactive process, it will not require the student to pay additional housing costs associated with having a single room.

4.6.3.     Financial and Employment Assistance for Students

WMU will not discriminate against any Qualified Students when providing financial assistance, assisting them obtain outside employment, or obtaining WMU employment.

4.6.4.     Non-Academic Services

WMU will not discriminate against any Qualified Individual when providing access to non-academic services including access to physical education, athletics, counseling, placement services, or social organizations.

4.7.     Employee Accommodation Requests

4.7.1.     A Qualified Employee may be entitled to an accommodation if they are able to perform the essential functions of the position with or without reasonable accommodations.  

4.7.2.     WMU will provide a Reasonable Accommodation, which may include a change in work environment, for employees or applicants that will allow an otherwise Qualified Employee to apply for a position or perform the essential functions of the position, so long as the accommodation does not impose an undue hardship upon the University or threaten the health or safety of coworkers.

4.7.3.     A function may be "essential" if, among other characteristics, the position exists to perform the function; a limited number of other employees are available to perform the function; or the function is highly specialized, and the individual was hired based on them having those specialized skills.

4.7.4.     A written job description and the associated Job Content Tool (JCT) will be considered evidence of the essential functions of an individual position.

4.7.5.     Accommodation requests from Student Employees will be handled according to the role for which the student is requesting an accommodation.  For example, if the student employee is requesting an accommodation for their employment position, the request will be adjudicated in the same manner as other employment accommodation requests. 

4.7.6.     Units are responsible for funding approved employee accommodations.  If a unit does not have the funding, it should elevate the issue through the department and the vice president overseeing the department as necessary.

4.8.     Accommodation Requests from Members of the Public 

Members of the public who are attending University Programs are entitled to accommodations upon reasonable notice and request to the University, so long as the accommodation does not fundamentally alter the Program or cause undue hardship to the University.  Requests from the public should be made to the event sponsor (e.g., the department or program).

4.9.     Confidentiality

4.9.1.     Medical or other individually identifying information submitted in relation to an accommodation request shall be kept confidential and secure.  Only those university individuals with a need to know will have access to such information.

4.9.2.     Confidential information must be kept separate from student educational records or employee personnel files.

4.9.3.     If an office or department receives a request to disclose such information, it should contact the Office of General Counsel for assistance in evaluating the University’s options.

4.10.  Appeals

4.10.1.  Appeals must be submitted in writing within 30 days of the final disability determination or denial of requested accommodation.

4.10.2.  Individuals who wish to appeal a Reasonable Accommodation determination must contact the Reasonable Accommodation Committee, which will consider the appeal in accordance with its standard procedures and guidelines.      The Reasonable Accommodation Committee shall include, at a minimum, at least one member from Human Resources, Environmental Health Services, Office of Institutional Equity, Disability Services for Students, and the Office of the General Counsel.      No one who was involved in the initial accommodation decision will take active part in the appeal determination.

4.10.3.  The Reasonable Accommodation Committee must publish appeal procedures and practices in a centralized location. 

4.10.4.  Individuals wishing to appeal may pursue other remedies such as filing a charge with a federal or state department or agency without it affecting their right to prompt, fair consideration of their appeal to the University.  Use of the University's internal procedure is not necessary in order to pursue other remedies.  

4.10.5.  Where a vice presidential area denies an accommodation request solely based on financial undue hardship, the University president, in consultation with the Office of the General Counsel, will make the final determination.

4.10.6.  Options for Filing a Complaint outside of the University

       a. For housing complaints, contact the Department of Housing and Urban Development (HUD) at housing_equal_opp/online-        complaint.
       b. For employment complaints, contact the Equal Employment Opportunity Commission (EEOC) at
       c. For non-housing-related student complaints, contact the Department of Education Office of Civil Rights (ED OCR) at
       d. For complaints of discrimination under state law, contact the Michigan Department of Civil Rights at,4613,7-138-70682_67734-153171--,00.html.

4.11.  Retaliation 

Retaliation against an individual who requests an accommodation is prohibited. Individuals who believe that they have been retaliated against may contact IE and/or file a complaint with any of the entities listed in Section 4.10.6, above.

4.12.  Implementation/Communication

The University Community will be notified of this Policy via its posting on the University’s Policy page and standard departmental communication processes.  Students who have questions about requesting an accommodation should contact Disability Services for Students.  Employees should contact the Office of Institutional Equity.  (Contact information below).  Members of the public should contact the event sponsor (i.e., Department or program) to discuss available accommodations.  

5. Accountability

5.1.  Failure to follow this Policy and any associated procedures may subject WMU employees to disciplinary action, up to and including dismissal from employment by the University, consistent with applicable procedures and Collective Bargaining Agreements.  Additional consequences of non-compliance include:

5.2.  The University could lose all or a portion of its state or federal funding for failure to follow this Policy and related procedures.

5.3.  The University and individuals could be subject to other legal consequences as set forth in applicable laws.

6. Related Procedures and Guidelines

6.1.1.     Disability Services for Students Registration Process, available at

6.1.2.     Office of Institutional Equity Reasonable Accommodation Request Process, available at

6.1.3.     Housing and Residence Life, Residence Life Policy Book

6.1.4.     Reasonable Accommodation Appeal procedures, available at [TBD].

7. Additional Information

AAUP Contract

8. FAQs

8.1.  I have an Individualized Educational Plan (IEP) from my high school.  Does that plan follow me to WMU?

Answer: No. If you require an educational accommodation, you must register with and request assistance from Disability Services for Students.  Your IEP ends when you graduate from high school.

8.2.   Whom do I contact to request an accommodation? 

      Answer: Students should contact the Disability Services for Students office at:

Woodlawn Place
2210 Wilbur Ave.
Western Michigan University
Kalamazoo MI 49008-5277 USA
(269) 387-2116

Employees should contact the Office of Institutional Equity at:

1220 Trimpe Building
Western Michigan University
Kalamazoo, MI 49008
(269) 387-6316

Members of the public should contact the event sponsor (i.e., Department or program) to discuss available accommodations.  

8.3.  Will my academic accommodations carry over to my clinical experiences?

Answer:  Yes.  However, you may need additional/revised accommodations given the difference between the academic setting and the clinical setting.  Contact DSS to evaluate whether any additional accommodations may be necessary. 



Effective date of current versionOctober 5, 2020
Date first adoptedOctober 5, 2020
Proposed date of next reviewOctober 5, 2023


Certified by

Vice President for Diversity and Inclusion

Director, Office of Institutional Equity

Vice President for Student Affairs

At the direction of

Edward M. Montgomery
University President