Student Accessibility Services

Americans with Disabilities Act of 1990

Prohibits discrimination against individuals with  physical and mental disabilities in all areas of public life, including jobs, schools, transportation, and access to all public and private places that are open to the general public. Institutes of higher education must provide reasonable accommodations to qualified students. Enforced by U.S. Civil Rights Division, Department of Justice (DOJ) and the Equal Employment Opportunity Commission (EEOC).

Section 504 of the Rehabilitation Act of 1973

Prohibits discrimination against an otherwise qualified individual with a disability, solely on the basis of the disability, in any program or activity that receives federal financial assistance. Enforced by Office of Civil Rights, U.S. Department of Education.

Fair Housing Act (Title VII of The Civil Rights Act of 1968)

Prohibits discrimination in housing based upon race, sex, religion, color, national origin, familial status, and disability. Prohibits refusal to make reasonable accommodations in rules, policies, etc. when such accommodations may be necessary to afford a person with disability the equal opportunity to use and dwell in the residence. Jointly enforced by Department of Housing and Urban Development and Department of Justice.

Keck Graduate Institute complies with Section 504 of the Rehabilitation Act of 1973 as amended, the Americans with Disabilities Act of 1990 as amended, and other applicable state and federal law prohibiting discrimination against individuals with disabilities. Under these laws, students have the privilege to confidentiality. Keck Graduate Institute recognizes that student health information is confidential information as per state and federal laws. It is the student's responsibility to communicate disability accommodations with their faculty.

The Americans with Disabilities Act states, a person with a disability is someone who:

• has a physical or mental impairment that substantially limits one or more major life activities,
• has a history or record of such an impairment (such as cancer that is in remission), or
• is perceived by others as having such an impairment.

Disabilities may include, but are not limited to, learning differences or disabilities, physical and mobility impairments, sensory impairments, psychological disorders, and/or chronic health impairments.

Note: Having received accommodations in high school through an Individualized Education Program (IEP) or a 504 plan does not automatically make a student eligible for services in college.The student must register for services and provide supporting documentation for review; IEPs are not acceptable forms of documentation. If it is determined that a student is eligible to receive accommodations, the recommended accommodations may be different from those the student received in high school. 

To establish eligibility for accommodations the student must provide documentation which identifies that the condition substantially limits performance in one or more major life activities. The student or guardian is responsible for submitting the documentation to the Associate Director of Student Wellness. If a parent or family member is serving in such a capacity consistent with the ethical guidelines of mental or medical health care professionals the documentation should state as such. Appropriate documentation must be provided by the treating health care professional on letterhead and should address the following guidelines:

• Licensure and experience of health care professional
• A specific diagnosis of limitations
• A description of how the diagnosis was reached; methods and procedures, test results and evaluation of test results
• A description of the specific changes that have occurred since the original report and recommendations were made that indicate a need to adjust accommodations as originally made
• What and how any major life activities are limited by the impairment
• How the disability causes any academic difficulties
• A list of all accommodations, which might be needed to facilitate the student’s participation in the academic program 

The student must complete the following intake process:

1. Please contact student.accessibility@kgi.edu to schedule an in- person intake appointment.
2. The student must submit the following forms:
   1. FERPA Student Release Form
   2. Information Release Form
   3. Physician Verification Form
   4. Student Release Form from KGI to SDRC
3. The Associate Director of Student Wellness will review accommodation intake packet and approve or decline. If Application is denied, the coordinator will schedule a follow up meeting to discuss.
4. If the Associate Director of Student Wellness approves, they will send a Letter of Accommodation to the student.
5. The student is responsible for submitting their Letter of Accommodation to the faculty member/course coordinator. Accommodations will not be active until the Letter of Accommodation is sent (via email) and reviewed by the faculty member. Please note that accommodations are not retroactive. Approved accommodations will be provided to the student.

Self-identification is voluntary. All students with a disability who are seeking accommodations must be registered with Student Accessibility Services and provide documentation of the disability, if accommodations are desired. Please note that information will be kept strictly confidential.

• Please email student.accessibility@kgi.edu to schedule an intake appointment
• Digital forms will be provided via email and will be required to be completed prior to the scheduled appointment
• Intake registration appointments for accommodations may begin as promptly as admittance into the Institution

Required Documentation: All students seeking accommodations must provide documentation of their disability.

All documentation should:

• Be current
• State clearly the diagnosed disability and educational or medical documentation
• Describe the functional limitations resulting from the disability
• For learning disabilities, provide all psychological and education testing instructions used in the evaluation report and relevant subtest scores used to document the stated disability

A student needs official authorization from KGI Student Accessibility Services before receiving accommodations. The student is responsible for providing the Associate Director of Student Wellness with current documentation from qualified professionals regarding the disability. After meeting with the student, the Associate Director of Student Wellness determines appropriate accommodations based on the nature and extent of the disability described in the documentation. Per the Americans with Disabilities Act (ADA), federal institutions are mandated to provide reasonable accommodations to students registered with KGI Student Accessibility Services. To provide reasonable accommodations, it is recommended that accommodations be requested at least 14 business days in advance to provide adequate timing to review and approve the accommodation intake packet and schedule the appropriate accommodations. Under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973, universities are required to make reasonable accommodations for qualified students with disabilities. Keck Graduate Institute will provide reasonable accommodations for qualified students with disabilities to facilitate equal access to educational programs, student activities, and other campus facilities. Students must be aware that it may also take up to six business weeks to schedule and implement appropriate accommodations. Once accommodations have been approved, they are applied proactively and not retroactively. Please note that students can register for accommodations as soon as they are accepted into KGI.

Examples of Reasonable Accommodations, which students with disabilities may require:

• Use of interpreters, scribes, readers, and/or note takers
• Audio record courses
• Enlarged copies of notes, required readings, handouts and exam questions
• Extended time on exams
• Quiet, distraction-reduced environment for taking exams
• Preferential seating in the classroom
• An accessible website

The Associate Director of Student Wellness creates a Letter of Accommodation specifying authorized accommodations. The student is responsible for delivering the letters (via email) to the instructors and discussing accommodations based on the contents of the letter. The process of requesting and receiving accommodations is interactive; all people involved—the student, the instructor and the Associate Director of Student Wellness— have a responsibility to make sure the process is easily communicated and transparent. Students who receive initial approval are encouraged to send their Letter of Accommodation directly to the professor in which they chose to have course accommodations. Accommodations are not active until the course coordinator/professor has received the Letter of Accommodation. The Associate Director of Student Wellness is not responsible for communicating accommodations with the faculty member, however recognizing that under extreme circumstances a disability may inhibit this interaction - the Associate Director of Student Wellness will connect with the faculty member. Any disability related issues that may arise should be communicated to the Associate Director of Student Wellness immediately.

Per the Americans with Disabilities Act (ADA), federal institutions are mandated to have instructional media with closed captioning (videos, recorded lectures, and presentations). This includes any items posted on Canvas. KGI Student Accessibility Services has researched free resources for faculty members to conduct their own free captioning. It is encouraged that faculty members complete their own captioning for their instructional media. If faculty members need KGI Student Accessibility Services to assist with captioning, videos must be submitted to the Associate Director of Student Wellness at least six business weeks prior to the student view date and in mp4 file format. It is the responsibility of the student registered with KGI Student Accessibility Services to request captioning accommodations with the Associate Director of Student Wellness. For more information on requesting captioning on videos please email the Associate Director of Student Wellness.

If students are approved for exam accommodations, the student will need to schedule the exam with Student Accessibility Services at least ten business days prior to the exam. Students can opt-out of using their exam accommodations by submitting a written request at least five (5) business days prior to the exam. Once their written request has been acknowledged, the student will be expected to sit in the main classroom for the exam. Students approved for exam accommodations must sign the Testing Guidelines and Procedures for the Accommodated Exams. All students are required to abide by the Testing Guidelines and Procedures. Violation of any of these guidelines may subject the student in question to the Student Conduct Committee in violation of the Honor Code.

In accordance with section 504 of the Rehabilitation Act of 1973, KGI will assist in providing reasonable accommodations for students during internships, experiential education rotations, and other educational activities on and off campus. Students seeking accommodations must:

• Inform the Associate Director of Student Wellness at least 45 business days before their internship submission to provide a reasonable amount of time to organize accommodations. Students should be prepared to provide appropriate physician documentation for the requested accommodation(s) to the Associate Director of Student Wellness. If accommodations are approved, the student will receive a letter of accommodation.
• Communicate and provide their letter of accommodation to their KGI clinical/experiential/internship coordinator, Team Master’s Project Director (Riggs School), or Program Director at least 30 business days in advance before their internship submission.
• Communicate with their site clinical/internship supervisor/instructor their letter of accommodation and requested accommodations once they are placed.

All academic accommodations must be registered with KGI Student Accessibility Services in order to use the accommodations in the classroom. It is important to make an intake appointment with the Associate Director of Student Wellness as soon as possible, to determine reasonable accommodations. Documentation is required and will be requested for specific accommodations. It is the students’ responsibility to meet with the Associate Director of Student Wellness in order to receive approved accommodations. Students who have been granted the accommodation of Audio Recording must abide by each accommodation’s provision. Audio recording outside of the classroom e.g. labs, clinical rotations, internships, etc. should be discussed on a case-by-case basis in collaboration with the instructors, programs, site and the Associate Director of Student Wellness.

Classes Involving Sensitive Material and an Instructors Right to Privacy

If there are open discussions in which the subject matter is not appropriate for any student to audio record, it is appropriate for the instructor to make a general announcement to ask students to stop recording devices. An instructor’s right to privacy or concern over copyright does not override the student’s right to accommodation. The Associate Director of Student Wellness is responsible for meeting with the instructor if there is any issue about privacy and copyright.

Rights of Students Approved for Audio Recording Lectures

Please see the Office for Civil Rights—Q & A Regarding Audio Recording and the California Education Code 78907 for more information on the rights of students.

Conditions of Agreement

• Instructor may make a general announcement without identifying the student that permission is granted for audio recording throughout class.
• Any audio recording as part of an accommodation may not be shared without consent of the instructor and the Associate Director of Student Wellness.
• Instructors may request audio recording be turned off during personal discussion if students are not asked to take notes during the same discussion.
• Audio recording is protected under copyright law and cannot be published, posted, reproduced, or quoted without consent from the Instructor and Associate Director of Student Wellness.
• The student is responsible for providing their own recording device that will be used or they may check out equipment from the Associate Director of Student Wellness.
• All audio recordings must be deleted at the end of the module or semester.
• A KGI Audio Recording Agreement must be completed by the student registered with KGI Student Accessibility Services.

In compliance with Section 504 of the Rehabilitation Act of 1973, Keck Graduate Institute does not discriminate on the basis of a disability and is committed to providing equal and reasonable accommodations to students who may need a service animal present with them.

Pet Animal

A ‘pet’ is a dog, cat, fish, or other animal kept for ordinary use and companionship. A pet is not considered a service or emotional support animal. Pets are not covered by Section 504 of the Rehabilitation Act of 1973. No pets are allowed on campus unless it is in the housing commons of Oasis. The owner of the pet should register their animal with Oasis Housing. A pet deposit and monthly pet fee will apply. Please contact Oasis Commons for pet fees and breed restrictions. Pets are only allowed on Oasis Commons property. No pets are allowed on the KGI campus including classrooms and laboratories.

DISRUPTIVE BEHAVIOR

Oasis Housing does not have to accept the animal if it has posed a threat to the safety and health of others or has demonstrated disruptive and harmful behavior to the community. The owner of the animal is financially responsible for the actions of the approved animal including bodily injury or property damage. The owner’s responsibility covers, but is not limited to, replacement of furniture, carpet, window, and wall covering. The owner is expected to cover these costs at the time of the repair.

WASTE

The owner is responsible for ensuring the cleanup of the animal’s waste and disposing it in the identified outside waste disposal containers. The owner, where appropriate, must toilet the animal in areas designated by the institution. Indoor animal waste, such as cat litter, must be placed in a sturdy plastic bag and securely tied up before being disposed of in outside identified waste disposal containers. Litter boxes should be placed on mats so that waste is not tracked onto carpeted surfaces.

Service Animal

A service animal is a dog that is individually trained to do work or perform specific tasks for the benefit of an individual with a disability, including physical, sensory, psychiatric, intellectual, or other mental disability. A service animal can also be a miniature horse that weighs between 70 to 100 pounds and is approximately 24 to 34 inches in height as measured to the shoulder of the horse. The need for service animals can be the following: guide dog or seeing eye dog, hearing or signal dog, sensory or social signals support, seizure response, psychiatric service. Service animals cannot be allowed in sterile labs due to safety and health concerns. Service animals are allowed on Oasis Commons property and KGI campus property, excluding labs. If a student needs to have their service animal inside a laboratory they must get confirmed access with the Associate Director of Student Wellness.

ACCOMMODATION

Students who use service animals are not required to register through KGI Student Accessibility Services. However, they may be asked to confirm with faculty, staff, and/or the Student Accessibility Services Coordinator if their animal is a service animal required because of a disability, and what work or task has the service animal been trained to perform.

DISRUPTIVE BEHAVIOR

KGI does not have to accept the animal if it has posed a threat to the safety and health of others or has demonstrated disruptive and harmful behavior to the community. The owner of the animal is financially responsible for the actions of the animal including bodily injury or property damage. The owner’s responsibility covers, but is not limited to replacement of furniture, carpet, window, and wall covering. The owner is expected to cover these costs at the time of the repair.

COMPLIANCE

Service animals must be under the control of their owner at all times and cannot be left alone on KGI property. If the owner designates another student to care for their animal, the owner remains solely responsible for the animal’s behavior.

WASTE

The owner is responsible for ensuring the cleanup of the animal’s waste and disposing it in the identified outside waste disposal containers. The owner, where appropriate, must release the animal in waste areas designated by the institution. Indoor animal waste, such as cat litter, must be placed in a sturdy plastic bag and securely tied up before being disposed of in outside identified waste disposal containers. Litter boxes should be placed on mats so that waste is not tracked onto carpeted surfaces.

Emotional Support Animal

An emotional support animal could be any type of animal, it is not limited to either a dog or miniature horse. Certain animal species will not be allowed, such as birds, reptiles, rodents, and skunks. The emotional support animal provides general therapy comfort to one’s physical, social, emotional or cognitive state as defined by Section 504 of the Rehabilitation Act and by the Fair Housing Act. Emotional support animals are only allowed at Oasis Commons if approved by Oasis Commons. Emotional support animals are not allowed on KGI campus property including classrooms and laboratories.

DOCUMENTATION

Students using emotional support animals can connect with KGI Student Accessibility Services to complete the appropriate documentation and recieve a letter of support to provide to Oasis Commons. Documentation must be in the form of a letter or report from a physician, psychologist, psychiatrist or other medical provider who is qualified to make the diagnosis and is currently treating the student for the disability for which they are requesting a service animal. The documentation must be signed and dated within the last year. The documentation must include the specific diagnosis, statement of current condition, the date and a summary of the most recent evaluation and the expected duration of condition.

VACCINATION AND HEALTH

In order for an emotional support animal to be approved by KGI Student Accessibility Services, 
the owner must provide the following documentation:

• Evidence of required vaccinations
• Evidence of licensing as required by state or local law

FOOD

Emotional support animals can be fed freeze dried or otherwise dead animals and still maintain their health. Owners of emotional support animals are not allowed to feed live animals to their emotional support animal. 
 
DISRUPTIVE BEHAVIOR

KGI does not have to accept the animal if it has posed a threat to the safety and health of others or has demonstrated disruptive and harmful behavior to the community. The owner of the animal is financially responsible for the actions of the approved animal including bodily injury or property damage. The owner’s responsibility covers, but is not limited to replacement of furniture, carpet, window, and wall covering. The owner is expected to cover these costs at the time of the repair.

COMPLIANCE

Emotional support animals must be under the control of their owner. If the owner designates another student to care for their animal, the owner remains solely responsible for the animal’s behavior.

WASTE

The owner is responsible for ensuring the cleanup of the animal’s waste and disposing it in the identified outside waste disposal containers. Owner, where appropriate, must toilet the animal in areas designated by the institution. Indoor animal waste, such as cat litter, must be placed in a sturdy plastic bag and securely tied up before being disposed of in outside identified waste disposal containers. Litter boxes should be placed on mats so that waste is not tracked onto carpeted surfaces.

Keck Graduate Institute (“Institute”) has adopted an internal grievance procedure for prompt and equitable resolution of complaints alleging any action prohibited by federal regulations implementing Section 504 of the Rehabilitation Act of 1973, as amended, Title III of the Americans with Disabilities Act of 1990 (ADA), and similar state laws. These laws provide that no otherwise qualified individual with a disability shall, by reason of such disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of the Institute, or be subjected to discrimination by the Institute. Issues that are grievable include, but are not limited to, a denial of a requested accommodation, the inadequacy of an accommodation, the inaccessibility of a program, benefit, service or activity (including those delivered through electronic and information technology) due to disability, or discrimination or harassment based on disability.

All such student grievances should be addressed to the attention of KGI’s Associate Director of Student Wellness.

The following steps explain the procedure:

• The grievance should be submitted in writing and include the Grievant’s name and contact information, a clear and concise description of the problem which is the basis for the grievance (including relevant facts, any steps taken to resolve the problem, the names of and contact information for persons who may have relevant information concerning the grievance), and a statement of the remedy requested.
• A grievance must be filed within ninety (90) days after the grievant becomes aware of the alleged problem. Grievances received later than ninety (90) days will be dismissed as untimely, unless exceptional circumstances prevented timely filing.
• An investigation, as may be appropriate, will follow the filing of a grievance. The investigation shall be conducted by the Institute’s Student Accessibility Services office, Director of Human Resources or other designee (“grievance officer”). These procedures contemplate a prompt and informal, but thorough investigation which affords the grievant, the party against whom the grievance or the proposed disposition is directed, and their representatives, if any, an opportunity to submit documents and information relevant to the consideration of and resolution of the grievance.
• A written determination as to the validity of the grievance and a description of the resolution, if any, shall be issued by the grievance officer and a copy forwarded to the grievant and the party against whom the grievance or the proposed disposition is directed no later than thirty (30) days after receipt of the grievance.
• The disposition proposed by the grievance officer will be put into effect promptly. The grievant or the party against whom the grievance or the proposed disposition is directed may appeal. An appeal will not suspend the implementation of the disposition proposed by the grievance officer, except in those circumstances where the appeal officer decides that good cause exists making the suspension of implementation appropriate.
• Within ten (10) days of the receipt of the grievance officer’s determination, the grievant or the party against whom the grievance or the proposed disposition is directed may appeal the grievance officer’s determination. The appeal, which must be in writing, should state the reasons why the person believes the determination should be changed and state the change(s) sought. All appeals are to be submitted to the Institute’s Student Accessibility Services office, who will direct the appeal and all appropriate records to the appropriate appeal officer (e.g., Dean of Students, Academic Dean, Director of Human Resources, or Vice President for Finance and Operations depending on the circumstances and issues involved) for review and disposition. A copy of the appeal officer’s written decision will be expected within 30 days of the filing of the appeal and will be sent to the parties, the grievance officer, Student Accessibility Services.
• Whenever the application of the deadlines or procedures set forth in this grievance procedure creates a problem due to the nature of the grievance, the urgency of the matter, or other circumstances (including for reasons relating to breaks in the academic calendar), the grievance or appeal officer will determine whether an appropriate expedited procedure can be fashioned or extensions of time are warranted, and the parties shall be advised.
• The Institute’s Student Accessibility Services Office shall maintain the files and records relating to grievances filed.

The availability and use of this grievance procedure does not prevent a person from filing a complaint of discrimination based on disability with a federal or state agency such as the United States Department of Education, Office of Civil Rights, 50 United Nations Plaza, San Francisco, CA 94102, Telephone: 415.486.5555, TDD: 800.877.8339; Email: ocr.sanfrancisco@ed.gov.

Retaliation against anyone who files a grievance or cooperates in the investigation under this grievance procedure is against the law and prohibited. Any concerns about retaliation related to this process should be disclosed immediately to the Institute’s Associate Director of Student Wellness or Director of Human Resources.

Inquiries concerning KGI’s Student Accessibility Services accommodations and discrimination policies, compliance with applicable laws, statutes and regulations (such as Section 504 and the ADA), and this grievance procedure (including requests for any accommodations needed to use this procedure) should be directed to the Institute’s Associate Director of Student Wellness or Director of Human Resources.

Forms are provided by the Associate Director of Student Wellness. Note, where in the judgement of the Institute it is more appropriate to do so, the Institute may administer or investigate a grievance regarding disability discrimination, harassment or retaliation through procedures set forth in other applicable Institute policies. Also, in the case of students, a dispute arising from a request for a modification or waiver of academic requirements or standards may, in the first instance, be referred to Academic Affairs.