Reasonable Accommodation Process Access

Michelle Day Project Manager Kim Jones Regional Disability Coordinator 2

Learning Objectives  Describe the required components of the reasonable accommodation process.  Discuss how documentation related to the reasonable accommodation process will be maintained.  Name 2 resources that can assist with identifying effective accommodations.  Name the best resource for obtaining tools/forms, tips, and resources to support the reasonable accommodation process for Job Corps students with disabilities. 3

REASONABLE ACCOMMODATION 4

What are Reasonable Accommodations? Any changes to the environment or in the way things are customarily done, that gives a person with a disability an opportunity to participate in the application process, job, program or activity that is equal to the opportunity given to similarly situated people without disabilities. 5

Examples of Reasonable Accommodations A modification to: Job Work/academic environment Policy, program, or procedure Examples: Modifying a facility, work or training schedules Acquiring or modifying equipment or devices Adjusting or modifying examinations, training materials, or policies Providing sign language interpreters 6

Who Can Request Reasonable Accommodations?  Applicant who requests accommodation to complete the admissions process  Applicant who requests accommodation to participate in the Job Corps program  Student who requests accommodation to participate in the Job Corps program or in work site activities  Applicant/student provides information indicating a disability is likely 7

REASONABLE ACCOMMODATION PROCESS CHALLENGE GAME 8

9 Accommodation Plan ProcessDocumentationRequests

Reasonable Accommodation Process You are writing the center’s required SOP describing the reasonable accommodation process. What is the best source of information about the required components of the reasonable accommodation process? 10

Reasonable Accommodation Process – Answer Appendix 605-describes each required component of the reasonable accommodation process and related policy. It also contains basic information about reasonable accommodation and disability. 11

Requesting an Accommodation You are the DC. A student comes to you and discloses she has a learning disability and that she had an IEP. She would like to use a calculator on her TABE test and have unlimited time. She would also like several other accommodations that she received in school that she thinks would help her in Job Corps? What should you do? 12

Requesting an Accommodation – Answer  If the student does not have her IEP, request a release from the student and obtain the IEP.  Document the request–A reasonable accommodation request can be communicated in any form (e.g., oral, written, sign language); however; the request must be documented on the Reasonable Accommodation Request Form (Appendix 605) 13

Documentation If an applicant/student submits a request for a reasonable accommodation, the AC or center may ask the applicant/student for reasonable documentation about his/her disability/functional limitations and past accommodations. Name 2 sources that may provide the necessary documentation? 14

Documentation – Answer In Job Corps documentation of a disability and information about past accommodations is most often provided by:  Schools-IEPs or 504 plans  Health care professionals (e.g., physicians, psychiatrists, psychologists)  Rehabilitation professionals (e.g., vocational rehabilitation specialists) 15

Reviewing the Request  Is the entire reasonable accommodation team required to meet with every applicant/student who may need accommodation? 16

Reviewing the Request– Answer NO!  If the accommodation request is straightforward and does not involve significant expense, the review can be an informal meeting (phone or face-to-face) between the DC(s) and the applicant/student (and parents, service providers, if applicable)  If the request involves complex accommodation issues and/or significant expense, a reasonable accommodation committee meeting may be required  The meeting must be documented and specific accommodations must be discussed 17

Evaluating the Request  Appendix 605 contains a list of accommodations that can be provided by Job Corps centers, so when you receive a request you should check this list to determine if the accommodation can be provided. True of False? 18

Evaluating the Request – Answer False!  There are many grey areas in the interpretation of what constitutes a reasonable accommodation; therefore, Job Corps has no specific list of accommodations that will or will not be provided.  Each request for accommodation should be evaluated individually and a determination made regarding whether it is reasonable.  Appendix 605 contains specific guidance on evaluating the reasonableness of a request 19

Developing an Accommodation Plan  You are a member of the reasonable accommodation committee. As part of the process for developing an accommodation plan, you are discussing a particular barrier to participation in the program with an applicant and cannot figure out any accommodations that would alleviate those barriers. Name the best resource for helping you with accommodation suggestions? 20

Developing an Accommodation Plan – Answer The Job Accommodation Network (JAN) is your best accommodation suggestion resource. Other accommodation resources include:  Job Corps Disability Website  Regional Disability Coordinators  Community resources (Centers for Independent Living, Division of VR, Universities, etc.) 21

Developing an Accommodation Plan (2)  When developing an accommodation plan who is the best resource for information about:  The functional limitations the individual may have as a result of the disability  The barriers to participation in Job Corps  The types of accommodations that have helped in the past 22

Developing an Accommodation Plan (2) – Answer  The applicant/student; always obtain his/her input and include him/her in the accommodation process 23

Developing an Accommodation Plan (3)  Name 3 common accommodations provided by Job Corps centers? 24

Developing an Accommodation Plan (3) – Answer  Extra Time  Use of a Calculator  Preferential Seating  Modified Schedule  Frequent Breaks  Noise Cancelling Headsets  Adaptive Equipment 25

Denying a Request  You are the DC. The reasonable accommodation committee has been through the accommodation process with an applicant and does not feel like the requested accommodation can be provided. No alternate accommodation can be agreed upon. What is the center’s next step? 26

Denying a Request – Answer  No accommodation can be denied at the center level; if the center feels that providing the accommodation would be an undue hardship or a fundamental alteration, and no alternate accommodation can be agreed upon, the decision must be forwarded to the Regional Director (RD) for a final decision  Applicants must not be denied admission based solely on the need to provide reasonable accommodation or modification 27

Notification  Once the necessary accommodations have been determined, an accommodation plan will be developed and should be in place before student arrives on center. What is the required process for notifying staff about accommodation plans? 28

Notification – Answer  DCs should staff weekly a list of students with new or updated plans  Managers are responsible for ensuring that approved accommodations are implemented in their areas of supervision  DCs should maintain copies of the notification s 29

Determining Accommodation Effectiveness As a student participates in Job Corps, new needs may be identified or accommodation adjustments may be required. What is the required process for evaluating the effectiveness of accommodation plans? 30

Determining Accommodation Effectiveness – Answer  As needed, but at least every 60 days as part of student performance panel.  Counselor should:  Check with student about effectiveness of plan at each meeting  Gather information from appropriate staff about the effectiveness of accommodation prior to panel  Forward information to DCs to update plan or resolve issues  Forms and additional guidance for supporting this process are available on Job Corps Disability website. 31

Recordkeeping  A separate accommodation file should be maintained for each student receiving accommodation. Name 3 pieces of information that could be found in this file? 32

Recordkeeping – Answer  Notes/Updates (documentation of accommodation process)  Documentation Supporting Provision of Accommodation  Signed Accommodation Plan  Accommodation Effectiveness Review Documentation  Reasonable Accommodation Request Form 33

CHALLENGE QUESTION 34

Resource  Who is your regional disability coordinator? 35

Resource – Answer  Lisa Kosh-Region 1  Nikki Jackson-Regions 2, 3  Laura Kuhn-Region 4  Kimberly Jones-Regions 5, 6 36

REASONABLE ACCOMMODATION PROCESS CHALLENGE GAME REVIEW 37

Reasonable Accommodation Process  The center’s SOP and process should include the following components: Request Documentation Reviewing Request Evaluating a Request Denying a Request 38

Reasonable Accommodation Process Developing an Accommodation Plan Notification Determining Accommodation Effectiveness Recordkeeping 39

RESOURCES 40

41 Job Corps Disability Website

42 JAN

Regional Disability Coordinators  Lisa Kosh-Region 1  Nikki Jackson-Regions 2, 3  Laura Kuhn-Region 4  Kimberly Jones-Regions 5, 6 43

WRAP UP 44

Learning Objectives  Describe the required components of the reasonable accommodation process.  Discuss how documentation related to the reasonable accommodation process will be maintained.  Name 2 resources that can assist with identifying effective accommodations.  Name the best resource for obtaining tools/forms, tips, and resources to support the reasonable accommodation process for Job Corps students with disabilities. 45

Questions? 46

Feedback 47 Thanks for participating! Please complete your evaluation and leave it with a room monitor.