Disability Accommodation Policy and Appeal Procedure
1.0 Policy Purpose
1.0.1 Commitment
Vassar College is committed to providing individuals with disabilities with equitable access to its academic programs, courses, and campus life. In alignment with the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, and applicable provisions of the Fair Housing Act, Vassar provides reasonable accommodations to support full participation in all aspects of the educational experience.
1.0.2 AEO Office
Through proactive planning and inclusive practices, the College reaffirms its commitment to creating a welcoming and accessible environment for all students. Individuals with disabilities are encouraged to work closely with the Office for Accessibility and Educational Opportunity (AEO) to identify suitable accommodations and utilize available campus resources to their full potential.
1.0.3 Process; No Retaliation
This policy and its accompanying procedures are designed to provide a transparent and fair process for students to raise concerns about decisions related to their disability status or accommodations. It is intended that such concerns are reviewed in a consistent, timely, and equitable manner. Additionally, individuals who exercise their rights under disability law or support others in doing so are protected from retaliation.
1.1 Office for Accessibility and Educational Opportunity
1.1.1 Self-Identified Disabilities
The Office for Accessibility and Educational Opportunity (hereafter, “AEO”) supports the College’s educational mission by providing services to students with disabilities who self-identify. Disabilities may include, but are not limited to, learning disabilities, ADHD, psychological disorders, chronic health conditions, mobility or orthopedic impairments, sensory loss, and substance use recovery needs. AEO coordinates accommodations for academic courses, residential life, meal plans, college-sponsored extracurricular activities, and college jobs.
1.1.2 Eligibility
Determinations of whether a student with a disability is qualified and eligible for accommodations are made on a case-by-case basis by the Office for Accessibility and Educational Opportunity. A “qualified student” meets the essential academic and technical standards required for admission to or participation in the College’s academic program or activity, with or without reasonable accommodations. The eligibility determination process considers documentation of the disability, the functional impact of the impairment, and whether reasonable accommodations can be provided without fundamentally altering the nature of a course, program, or service.
1.1.3 Grounds for Refusing Accommodations
Accommodations are not provided if:
- The student is not considered “qualified” as an individual with a disability as defined by Section 504, ADA, NYSHRL, or FHA.
- The accommodation request is made retroactively.
- The student failed to follow established College procedures.
- The accommodation requested constitutes a personal service that the College is not obligated to provide.
- The requested accommodation would fundamentally alter the nature of a service, program, or activity.1
1.1.4 Retroactive Accommodations
Students with disabilities are expected to initiate the accommodation process in a timely manner. This is important because the College is generally unable to offer retroactive accommodations or alter past academic performance or obligations. To ensure accommodations are provided effectively, students must follow the College’s academic policies and procedures, which include requesting accommodations in advance and formally self-identifying with the AEO office. By doing so, students can ensure they receive the necessary support to fully participate in their academic programs.
As explained in Section 2.4.1, modifications to disability-related accommodation decisions will only be considered in rare circumstances, such as when there has been a significant mistake in the interactive process that affected the outcome, when new and important information becomes available that could change the decision, or when bias or a conflict of interest from someone involved in the process may have adversely influenced the decision.
1.1.5 How to Request a Disability Accommodation
Students seeking disability-related accommodations must self-identify and initiate the accommodation request process. Students are encouraged to contact the Office for Accessibility and Educational Opportunity (AEO) to request a meeting or obtain additional information. AEO staff can be reached via email at aeo@vassar.edu or by phone at (845) 437-7584. The office is located on campus in the Old Laundry Building, Room 125, on the ground floor.
For more information, please visit the AEO website:
https://offices.vassar.edu/accessibility-and-educational-opportunity/
Detailed information on how to register with the Office for Accessibility and Educational Opportunity (AEO), including steps for disclosing a disability, requesting accommodations, and submitting required documentation, is available on the AEO website: https://offices.vassar.edu/accessibility-and-educational-opportunity/register/
1.2 ADA/Section 504 Coordinator
1.2.1 Vassar Resources
The Faculty Director for Institutional Equity serves as the College’s ADA/Section 504 Coordinator and, in consultation with the Assistant Vice President for Institutional Equity, oversees compliance with Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act (ADA). The Faculty Director for Institutional Equity oversees appeals related to disagreements or denials of disability-related accommodations, modifications, or auxiliary aids and services resulting in an inability to access the College’s education program or activity or that had a discriminatory effect. The ADA / Section 504 Coordinator may be reached at Vassar College, Office for Institutional Equity by email at equity@vassar.edu or by telephone at (845) 437-7924.
1.2.2 External Resources
Questions or concerns regarding the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act of 1973, and the New York State Human Rights Law, particularly as they relate to protections for individuals with disabilities, may also be directed to:
- Section 504 of the Rehabilitation Act of 1973
Office for Civil Rights
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202-1475
Phone: (202) 453-6020
Fax: (202) 453-6021
TDD: (800) 877-8339
Email: OCR.DC@ed.gov
Website: https://www.ed.gov/laws-and-policy/individuals-disabilities/section-504
- New York State Division of Human Rights Law
New York State Division of Human Rights
One Fordham Plaza, 4th Floor, Bronx, NY 10458.
General inquiries or inquiries about language access may also be directed to info@dhr.ny.gov. Toll-free: (888) 392-3644
TDD/TTY: (718) 741-8300
Division's Fair Housing toll-free hotline (844) 862-8703
Education Discrimination Complaint Form: https://dhr.ny.gov/system/files/documents/2024/06/nysdhr-education-complaint-form.pdf
- Americans with Disabilities Act
US Department of Justice
950 Pennsylvania Avenue, N.W.
Civil Rights Division
Disability Rights Section _ NYA
Washington, DC 20530
Phone: (800) 514-0301 (voice)
TDD/TTY: (800) 514-0383
2.0 Student Disability Appeal Policy
2.1 Scope
This policy applies to all students, including employees enrolled as special or matriculated students, and any individuals participating in or seeking to participate in the College’s educational programs or activities.
2.2 Exclusions and Exceptions
- Changing Needs. This appeal policy and procedures do not limit a student’s ability to request new or revised accommodations in response to evolving needs, such as changes in coursework, newly diagnosed conditions, or developments in existing disability-related conditions. Such requests should be directed to the AEO for review and consideration.
- Discrimination and Harassment Complaints. Complaints of alleged discrimination and harassment based on disability that are unrelated to the accommodation process are handled through the Interim Policy Against Discrimination, Harassment, and Sexual Misconduct, overseen by the Office for Institutional Equity.
- Employee Accommodation Requests. Employees (faculty, administrators, and staff) with disability-related appeals concerning their employment status and disability-related needs should first attempt to resolve the matter by contacting the Vassar College Benefits Office in Human Resources (HR). To learn more or schedule a meeting, call (845) 437-7761. If there are concerns about an accommodation decision or implementing a recommended accommodation, an Interactive Process through HR can be initiated.
2.3 Confidentiality
Individuals with disabilities have the right to privacy and discretion concerning all information related to their disabilities. All disability-related documentation or information shared with the College will be handled with privacy and discretion. This information will be used exclusively to support the College’s efforts in determining and implementing reasonable accommodations, modifications, and services that enable equal access to programs, services, and activities. The College is committed to maintaining confidentiality in all informal and formal proceedings unless otherwise specified in these procedural statements.
2.4 Formal Appeal Process
The formal appeal process is designed to provide a prompt, fair, and impartial review of decisions related to the approval or denial of reasonable accommodations for individuals with disabilities. The purpose of the appeal is to determine whether a procedural or substantive error occurred during the initial review or grievance process that materially affected the outcome. If such an error is identified, the appeal process provides appropriate direction for corrective action to resolve the issue in a timely and equitable manner.
2.4.1 Permissible Grounds for Appeal
A student (“Appealing Party”) may submit an appeal only on one or more of the following grounds. Appeals that do not meet one or more of these criteria will be rejected during the preliminary review process:
- Procedural Irregularity
A procedural error or deviation occurred during the review of the accommodation request that materially affected the outcome. This includes, but is not limited to, the College’s failure to follow established procedures or failure to provide the student with a meaningful opportunity to engage in the interactive process required to assess reasonable accommodations. - New Information
New, substantive information has become available that was not reasonably accessible or known to the student or the AEO Office at the time of the original determination. The new information must be relevant and have the potential to materially affect the outcome of the accommodation decision. The student must explain why this information was not previously submitted and how it supports the accommodation request. - Conflict of Interest
The presence of a conflict of interest or demonstrated bias on the part of one or more individuals involved in the review or determination of the accommodation request that may have materially affected the outcome of the matter. The student must identify the individual(s) alleged to have a conflict of interest or bias and provide a reasonable basis for the claim, including any supporting information or context that demonstrates how the impartiality of the process was compromised and how this may have impacted the decision.
2.4.2 How to File an Appeal Request
After reviewing the provisions outlined in Section 2.4, and, if applicable, the accompanying letter from the Office for Accessibility and Educational Opportunity (AEO) detailing the rationale for the accommodation denial, the student may submit a written appeal to the Office for Institutional Equity. The appeal must be directed to the Faculty Director of Institutional Equity.
The written appeal should include the following:
- A clear explanation of why the student believes the requested accommodation is reasonable and appropriate, including any relevant medical or psychological documentation the student wishes to provide in support of the appeal.
- A summary of prior resolution efforts undertaken through the interactive process with the Office for Accessibility and Educational Opportunity (AEO), including any communications or steps taken to address the request.
- A statement of the desired outcome, describing how the proposed accommodation would ensure equal access to the relevant academic course, program, activity, or residential life setting.
- The appeal must be signed by the student. Electronic signatures are acceptable.
2.4.3 When to File
Three Business Days. The written appeal must be submitted via email to the Office for Institutional Equity within three (3) business days of the student’s notice that their request for an accommodation, modification, or auxiliary aid has been denied.
Extension of Time. The Faculty Director for Institutional Equity may extend the standard timeframe if the nature or urgency of the issue, or the timing of an upcoming academic or programmatic event, presents a challenge to meeting the deadline. In such cases, the Faculty Director will consult with the student and relevant College officials to determine whether an expedited or adjusted review process is appropriate.
2.4.4 Where to File
The appeal request must be submitted in writing to the Faculty Director for Institutional Equity via email at equity@vassar.edu or mailed to the Office for Institutional Equity, Vassar College, Box 645, 124 Raymond Avenue, Poughkeepsie, New York, 12604-0645.
2.5 Review of Appeal Request
2.5.1 Preliminary Review by Faculty Director for Institutional Equity
- Establishing Grounds for Appeal. Upon receiving the written appeal, the Faculty Director for Institutional Equity and Assistant Vice President for Institutional Equity will conduct a preliminary review to determine whether the appeal meets the required criteria as outlined in Section 2.4.1: Permissible Grounds for Appeal. If the appeal does not clearly establish appropriate grounds, such as demonstrating a procedural or substantive error, presenting new relevant information, or identifying evidence of bias or conflict of interest, the Faculty Director may reject the appeal.
This decision concludes the appeal process and is not subject to further review. - Correctable Deficiency. If the deficiency is correctable, the appeal will be returned to the student with a written explanation of the issues that must be addressed. The student may be allowed to revise and resubmit the appeal within the timeframe specified in the return document. If the appeal is rejected outright, the student will receive written notice explaining the reason for the rejection. In either case, no further action will be taken until the appeal meets the required criteria for review.
2.5.2 Interim Accommodations
While an appeal is under review, the Faculty Director for Institutional Equity may consult with the Director of the Office for Accessibility and Educational Opportunity (AEO) to determine whether interim accommodations are appropriate or available. The authority to identify, approve, and implement any such temporary accommodations rests solely with the Director of AEO. The Faculty Director does not have the authority to initiate or authorize interim accommodations during the appeal process.
2.5.3 ADA/Section 504 Appeal Committee
The Faculty Director convenes the ADA/Section 504 Appeal Committee for Institutional Equity to review student appeals involving denied or disputed disability-related accommodations. The committee is responsible for conducting a thorough and impartial evaluation to determine whether the original decision was reasonable and consistent with Vassar College policies and applicable federal and state disability laws and regulations.
2.5.4 Composition of ADA/504 Appeal Committee
- Chair: The Faculty Director for Institutional Equity or their designee serves as chair of the committee.
- Faculty Member: One member of the faculty, bringing an academic perspective and familiarity with curricular demands.
- Accessibility Committee Member: One member of the Accessibility Committee, selected for their knowledge and experience in disability access and student support services at the College.
All members of the committee are required to participate in training on the College’s Student Disability Appeal Policy and have an understanding of the principles involved in evaluating accommodation appeals. This includes awareness of the rights of students with disabilities, the College’s responsibilities in providing access, and the broader context in which accommodation decisions are made.
2.5.5 Conflict of Interest or Bias
- Students who believe that a member of the ADA/Section 504 Appeal Committee, including the Faculty Director for Institutional Equity, has a conflict of interest or bias should submit a written statement to the Assistant Vice President for Institutional Equity at equity@vassar.edu. The statement should clearly describe the concern and include any relevant supporting information.
- The Assistant Vice President will review the concern and determine whether the individual should be recused, using an objective standard: whether a reasonable person, based on the information provided, would believe a conflict or bias exists. A perceived conflict or bias, without substantiating evidence, may not be sufficient.
- If recusal is deemed necessary, the individual will be removed from all aspects of the appeal process. A trained alternate will be appointed to ensure the committee remains impartial and able to conduct a fair review. The recused individual will not have access to any further materials, discussions, or decisions related to the appeal.
- A written explanation of the decision will be provided to both the student and the Faculty Director for Institutional Equity. The decision of the Assistant Vice President is final and not subject to appeal.
2.5.6 Appeal Review Process
Substantive Review. The committee will review the student’s written appeal, along with any supplemental information gathered by the Faculty Director, to determine whether the original accommodation decision was appropriate or whether it should be reconsidered and the requested accommodation, or a comparable and suitable alternative, should be granted.
Time Frame. All appeals will be resolved as promptly as possible, typically within five (5) to ten (10) college business days following receipt of all necessary information and completion of any related meetings. If additional time is required due to the complexity of the case or other extenuating circumstances, the Faculty Director may extend the timeline and will notify all parties in writing.
2.5.7 Possible Appeal Outcomes
- Appeal Request Granted
If the appeal is granted, the student will receive a written notification outlining the committee’s decision and the rationale supporting the outcome. The written outcome will indicate whether the interactive process should be reconvened to implement the requested initial accommodation or to explore and implement an equally effective alternative accommodation. The outcome may also identify any other necessary corrective actions, including steps to address procedural errors, clarify expectations for implementation, or ensure compliance with institutional obligations and applicable disability laws. The Director of AEO will coordinate with the student and relevant College personnel to promptly resume the interactive process and ensure that appropriate accommodations are put into place in a timely and effective manner. - Appeal Request Denied
If the ADA/Section 504 Appeal Committee determines that the original decision to deny the requested accommodation was reasonable and consistent with Vassar College policies and applicable disability laws and regulations, the appeal will be denied. The student will receive a formal written notification outlining the committee’s decision, including a clear explanation of the rationale and the criteria used in reaching the outcome.
A denial affirms the original determination made by the Office for Accessibility and Educational Opportunity (AEO), and the matter will not be subject to further internal review. Students are encouraged to consult with the AEO or the Office for Institutional Equity if they wish to better understand the decision or to explore alternative support strategies that may be available within the College’s existing resources and programs.
All decisions issued through this appeal process are final and cannot be further appealed within the College.
Copies of the decision will also be provided to the Director of the Office for Accessibility and Educational Opportunity (AEO), Dean of Studies, and, when appropriate, to the relevant faculty member (in cases involving academic accommodations) or appropriate College administrator (for non-academic or residential accommodations).
2.6 Record Retention
The Office for Institutional Equity and the Office for Accessibility and Educational Opportunity will maintain records related to each disability accommodation appeal, including all supporting documentation and the outcome, for a minimum of seven (7) years following the student’s graduation or date of last enrollment, whichever is later. These records will be securely stored and handled in accordance with applicable College privacy and institutional data management policies.
3.0 Glossary of Terms
Americans with Disabilities Act (ADA). The ADA, as amended, is a federal law that protects individuals with disabilities from discrimination in any program or activity in which they are qualified to participate. Title I prohibits discrimination based on disability in employment. Title III applies to private education facilities and the activities of places of public accommodation. The ADA is enforced by the U.S. Dept of Education, Office for Civil Rights, and the Department of Justice. Under the ADA, an individual with a disability means a person who has a physical or mental impairment that substantially limits a major life activity; has a record of having such an impairment; or is regarded as having such an impairment.
Appealing Party. A student who has standing to file an appeal concerning any action, inaction, or decision by the College related to the approval, denial, or failure to provide a reasonable accommodation for a documented disability.
Business Day. For the purposes of College procedures and timelines, a business day is defined as any day, Monday through Friday, on which the administrative offices of the College are open for regular operations. This excludes weekends, official college holidays, and any other days when the college is officially closed.
College Officials. College officials are individuals responsible for overseeing institutional policies, programs, and practices that support the College’s educational mission and residential life infrastructure.
Confidentiality. Information related to a student’s disability, including medical documentation, diagnoses, and accommodation requests, is protected under the ADA, Section 504 of the Rehabilitation Act, and FERPA. Such information is confidential and is shared only on a need-to-know basis with individuals directly involved in the accommodation process.
Conflict of Interest. In the context of this Policy, a conflict of interest or bias arises when an individual involved in evaluating or deciding on a disability accommodation request has a personal interest or prejudice that could compromise impartiality.
Fair Housing Act (FHA). FHA law applies to “dwellings,” including housing operated by colleges and universities. FHA makes it unlawful to discriminate based on disability in dwellings, as enforced by the U.S. Department of Housing and Urban Development. Under the Fair Housing Act, persons with a disability means “those individuals with mental or physical impairments that substantially limit one or more major life activities.”
FERPA (Family Educational Rights and Privacy Act). A federal law that protects the privacy of student education records, including disability-related information. FERPA gives students the right to access their records, request corrections, and control the disclosure of personally identifiable information, except as permitted by law.
Fundamental Alteration. A fundamental alteration is a change that would substantially modify the essential nature, academic standards, or objectives of a program, service, or activity. While institutions must consider reasonable accommodations under the ADA and Section 504, they are not required to implement changes that compromise the core components of an educational or institutional offering.
Interactive Process. The interactive process is an individualized and collaborative dialogue between the College and a student with a documented disability to determine appropriate reasonable accommodations. Required under the ADA and Section 504, this process involves timely and good-faith communication to assess the functional limitations caused by the disability and to identify accommodations that provide equal access to the College’s programs, services, and activities. It may include reviewing documentation, requesting additional information, consulting with relevant personnel, and exploring effective alternatives that do not fundamentally alter the nature of a program or impose undue burden on the institution.
Modification. A modification is an individualized change to the College’s policies, practices, or procedures made to provide access to individuals with disabilities. A reasonable modification does not fundamentally alter the nature of the College’s educational program, service, or activity, and is provided under the requirements of the ADA and Section 504.
New York State Human Rights Law. The New York State Human Rights Law protects students and applicants from unlawful discrimination by educational institutions. It prohibits discrimination based on disability and other protected characteristics, and requires schools to provide equal access and reasonable accommodations. Under the New York State Human Rights Law (NYSHRL) a disability as defined as a “physical, mental or medical impairment resulting from anatomical, physiological, genetic or neurological conditions which prevents the exercise of a normal bodily function or is demonstrable by medically accepted clinical or laboratory diagnostic technique, or; a record of such an impairment, or; a condition regarded by others as such an impairment.”
Qualified Individual. A qualified student with a disability is one who meets the essential academic and technical standards required for admission to, ongoing participation in, or completion of the College’s educational programs or activities, with or without reasonable accommodations.
Reasonable Accommodation. A reasonable accommodation is a modification or adjustment to a policy, practice, environment, or service that provides a qualified individual with a disability an equal opportunity to access and participate in the College’s programs or activities. Accommodations are not required if they impose an undue burden or fundamentally alter the nature of the program or service.
Section 504 of the Rehabilitation Act of 1973 (Section 504). Section 504 is a federal civil rights law that prohibits discrimination based on disability in any program or activity receiving federal financial assistance, including colleges and universities. It requires institutions to ensure that qualified students with disabilities have equal access to and benefit from academic programs, services, and activities. A qualified individual with a disability is defined under Section 504 as a person who has "a physical or mental impairment that substantially limits one or more major life activities," has a record of such an impairment, or is regarded as having such an impairment. Major life activities include, but are not limited to, walking, seeing, hearing, speaking, breathing, learning, working, and caring for oneself.
Undue Burden or Hardship. An undue burden (or undue hardship) refers to a proposed accommodation or modification that would impose significant difficulty or expense on the institution, in light of its overall resources and operations. Determining whether an undue burden exists is a fact-specific inquiry that considers factors such as the nature and cost of the accommodation, the College’s total financial and administrative resources, and the impact of the accommodation on the institution’s ability to carry out its programs or services.
4.0 Related Documentation
- Accessibility and Educational Opportunity (AEO) Accommodation Process
- Interim Policy Against Discrimination, Harassment, and Sexual Misconduct
- Section 504 of the Rehabilitation Act of 1973
- Americans with Disabilities Act of 1990
- New York State Human Rights Law
5.0 Responsible Department and Positions
- Faculty Director for Institutional Equity, Office for Institutional Equity
- Director, Accessibility and Educational Opportunity Office
6.0 Review History
- Adopted 1999
- 2008
- 2012
- 2025
7.0 Revision History
- Disability Accommodations and Support Services Policy (adopted 1999)
- Disability Accommodations and Support Services Policy (July 2008)
- Disability Accommodation and Support Services Policy (July 2012)
- Student Disability Accommodation Appeal Policy (August 2025)
- In cases where a disability-related accommodation request is denied because it would result in a fundamental alteration, the College will continue to engage the student in the interactive process to explore whether alternative accommodations that do not fundamentally alter the academic program can effectively address the student’s disability-related needs. Determining whether a student accommodation request constitutes a fundamental alteration will be made promptly to allow the student sufficient time to obtain alternative accommodations. ↩︎
Office for Institutional Equity
124 Raymond Avenue, Box 645, Poughkeepsie, New York 12604-0645
Main Building, South 182