Accessibility, Disability, and Reasonable Accommodation Policy
and Section 504 Grievance Procedures at Sterling College
I. Overview & Purpose
Variation is natural and vital to the development of dynamic human communities. Sterling College recognizes the spectrum of ability as a valued aspect of diversity that is integral to the campus community and society. Within the context of our mission of ecological thinking and action, our rustic and rural settings, experiential educational programs, and with a limited resource base, we aim to continually improve the design and condition of our built environments and enhance ways to safely navigate farm, field, and wild nature. The College strives to support welcoming, accessible, and inclusive conditions for our community members and visitors alike.
Importantly, Sterling College assists qualified, currently enrolled students with obtaining reasonable academic, work, and housing accommodations, including service and assistance animals. Reasonable accommodations are available to all currently enrolled students who have a documented disability that substantially limits them in one or more major life activities. Such accommodations are put in place to ensure equal access, not to guarantee success. Students with disabilities will be held to the same standard of achievement in academics and the work program as all other students.
Sterling College follows all the applicable provisions of state and federal law which prohibit discrimination on the basis of race, color, religion, ancestry, marital status, national origin, sex, sexual orientation, gender identity, place of birth, age, disability, HIV status, (as well as laws that prohibit retaliation against any person who exercises rights under these laws, such as complaining of discrimination) in the administration of its educational, admissions, financial aid, and employment policies and programs. Sterling College’s Full Non-Discrimination Policy can be found here. Steling College reiterates its specific commitment to:
Ensuring students and employees are not subjected to discrimination or harassment due to a disability;
Ensuring students and employees are not subjected to a hostile environment relating to a disability; and
Providing reasonable accommodations for students with documented disabilities as required by law.
This policy explains the process for documenting a disability and requesting reasonable accommodation(s), describes the standard for review of such requests, and explains the role of Sterling’s Accommodation & Accessibility Team (AAT) in both reviewing accommodation requests and working toward broader accessibility goals. Any questions about disability-related issues and accommodations that are not addressed in the policy below should be directed to the College’s 504 Coordinator, who is identified below.
II. ADA/Section 504 Coordinator
Sterling College’s ADA/Section 504 coordinator and compliance officer (the “504 Coordinator”) has responsibility for issues related to Section 503 and 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act.
Sterling College’s Section 504 Coordinator is:
Craig Wilson
Director of Learning Support
[email protected]
802-586-7711 ext. 157
A detailed description of the 504 Coordinator’s role and responsibilities can be found in the related document Section 504 Coordinator: Role, Responsibilities, and Training Requirements.
III. About The Accommodation & Accessibility Team
The Sterling College Accommodation & Accessibility Team (AAT) – a sub-committee of the College’s Student Engagement Committee – is composed of the Dean of Community, the Dean of Work-Learning (or another member of the faculty with involvement in both Academics and Work Program) and the Director of Learning Support. The AAT reviews requests from currently enrolled students with disabilities for reasonable accommodations. The AAT is chaired by the Director of Learning Support. All requests for accommodations, appeals to appeal requests, concerns for discrimination based on disabilities, denials of services/accommodation or policy grievances should be directed to the attention of the Director of Learning Support at the above contact information.
The AAT meets in closed session at the start of each semester and as needed thereafter to evaluate and act upon students’ documented requests for accommodation. This team meets during inter-semester breaks to process accommodation requests for the upcoming term.
The AAT also meets at least twice per semester in open session to advance aspirations, review and enact plans to enhance the accessibility and inclusiveness of the Sterling community, campus and instructional sites, and culture for all individuals with disabilities. All members of the College community, including students, are welcome and encouraged to participate in these open meetings, which are noticed in the Convener, announced in Community Meeting, and published on the Sterling Calendar.
IV. Shared Responsibility for Enhancing General Accessibility & Living Into Our Inclusivity Aspirations at Sterling College
Creating and maintaining usable, equitable, and inclusive learning environments is a shared responsibility of the entire campus community. To this end:
Sterling provides certain testing, assessment, and classroom accommodations to support students with some learning differences that do not rise to the level of a documented disability.
Sterling employees have undertaken and/or been provided access to professional development resources focused on better understanding the history and experiences of disability and neurodivergence in higher education, supporting neurodivergent students and others with executive function challenges (with support from Landmark College).
Faculty have begun implementing universal design for learning strategies in in-person courses and through the use of educational technology.
Nevertheless, due to the nature of Sterling’s locations and programs, creating and maintaining barrier-free environments can prove difficult – and recognizing that some barriers to access, particularly in wild nature, agricultural spaces, and outdoor spaces used for learning, work, and recreation, can be challenging to adapt or may not be readily removed – the Accommodation & Accessibility Team focuses on prioritizing working one-on-one with students to determine reasonable accommodations.
V. Disability Documentation & Determination
In accordance with the Americans with Disabilities Act (ADA) of 1990 (as amended in 2008), an individual with a disability is a person who has a physical or mental impairment that substantially limits one or more major life activities such as breathing, eating, sleeping, walking, talking, manual tasks, etc. Pursuant to the ADA, Sections 503 and 504 of the Rehabilitation Act of 1973, and other applicable state laws that prohibit discrimination on the basis of disability, students with a documented disability have a right to receive reasonable accommodations (defined below). In most cases, medical documentation will be required to identify a disability-related need for accommodations.
Building and using a toolkit for success in academics, work and community that includes self-advocacy skills, resources, and various study strategies is an important part of college learning for all students. Sterling neither imposes accommodations on its students nor preempts their responsibilities, as legal and social adults, to document their disabilities, request accommodations, and engage in a structured interactive process with the College to achieve accessibility.
Student Responsibilities
Students seeking reasonable accommodation for disabilities have the following responsibilities:Submit a confidential Disability Disclosure Form to the AAT.
Provide appropriate disability documentation (detailed below) to support any requested reasonable accommodations;
Cooperate and correspond in a timely manner with the AAT by responding to requests for additional information from the student or their healthcare provider(s), which may be needed to determine eligibility for accommodations.
Receive, read, and understand the written eligibility/denial determination letter from the AAT. Students who need assistance understanding this letter may consult with their advisor.
At the start of each term, provide a copy of their determination letter to the faculty member(s) instructing each course in which the student requires accommodation.
Appropriate Documentation
Disability documentation must adequately verify the nature and extent of the disability in accordance with current professional standards and it must clearly show the need for each of the requested accommodations. Documentation must be from a qualified professional who is licensed or certified to diagnose the disability in question. All tests used to document eligibility must be technically sound, and all documentation should be recent enough to reflect the student's current level of functioning.
Documentation is expected to contain the following:A specific diagnostic statement identifying the disability including severity and date of current diagnostic evaluation;
Specific findings which support this diagnosis including relevant history, tests administered, test results, and interpretation of those test results;
Length of condition(s) and expected duration;
Information concerning the impact of the disability on the educational setting including a description of the physical and/or cognitive functional limitations due to the disability;
Recommended accommodations or services to address the functional impact(s) of the disability; and
Any other helpful information for working with the student.
The documentation must be on letterhead, dated, and signed. It must also include the evaluator's name, address, telephone number and professional credentials. Alternatively, the student may ask their healthcare provider/qualified evaluator to fill out Sterling’s Disability Documentation Form.
If the documentation submitted is incomplete or inadequate to determine the extent of the disability or reasonable accommodation, the AAT may, at its discretion, require additional documentation.
The student is responsible for any costs related to obtaining initial documentation and any additional documentation requested.
Timing
Students who are disclosing and documenting their disability for the first time at Sterling should allow at least 4 weeks for documentation review and issuance of a determination.Confidentiality
Disability documentation will be treated confidentially. Limited information, when needed for legitimate educational interest, is released and/or discussed on a need-to-know basis and is subject to FERPA guidelines. Except as permitted by FERPA, no information will be released and/or discussed without consent from the student in question.
Reasonable Accommodations for Students with Disabilities
A reasonable accommodation is a modification or adjustment to a course, program, service, or activity that enables a qualified student with a disability to have an equal opportunity to attain the same level of achievement or enjoy the same benefits and privileges that are available to similarly-situated students without disabilities. The College has a legal obligation to provide accommodation(s) only to the known limitations of an otherwise qualified student with a documented disability (see above) and only to the extent that the requested accommodation meets the legal standard for reasonableness in a higher education context (as described further below).
Reasonable accommodations are determined by Sterling’s Accommodation & Accessibility Team (AAT). Whenever a student with a documented disability makes a timely request for a reasonable accommodation, the AAT examines, as appropriate on a case-by-case basis:
The barriers resulting from the interaction between the impact of the documented disability and the campus environment;
The possible accommodations that might ameliorate or remove the barriers;
Whether or not the student has access to the course, program, service or activity without an accommodation; and/or
Whether or not essential elements of the course, program, service, activity or facility are compromised by the accommodations.
To determine reasonable accommodations, the AAT may seek information from appropriate College personnel regarding essential standards for courses, programs, services, and activities (including but not limited to learning objectives, competencies, minimum requirements and prerequisites, safety and risk management standards, and assessments).
In reviewing reasonable accommodation requests, the following analysis is used
Does the student have a documented disability?
Is the student "otherwise qualified?"
Is the request reasonable?
To be considered a “reasonable” accommodation, the requested accommodation must not:
fundamentally alter the nature of the program or activity;
alter or remove essential requirements;
lower academic standards;
present an undue financial or administrative burden on the College; or
pose a direct threat to the safety of others or the public.
Sterling is not required to provide any requested accommodations that have any of the above-listed effects, as such requests do not meet the legal definition of a “reasonable accommodation.”
The College reserves the right to recommend accommodations that differ from the specific approaches suggested by the student or individuals documenting the student’s disability, so long as the accommodations proposed by the AAT achieve the objective of program accessibility as required by law.
If a student perceives a need for additional accommodations or for the modification of existing accommodations, the student must request, in writing, a revision of the accommodation plan. Such requests should be addressed to the AAT via the Director of Learning Support (contact information in Section II).
When to Request Accommodations
Advance notice is required to review accommodation requests and coordinate accommodations. Students with disabilities are advised to document their disability and begin the accommodation request process well in advance of a semester’s start, with no less than 4 weeks’ notice. While the AAT will make a good faith effort to accommodate students as quickly as possible, students should be aware that it takes time to document disabilities, consider accommodation requests, determine feasibility and reasonableness, and implement accommodation measures. Some types of accommodation requests require more lead time to process and coordinate than others. As a very small college with limited personnel, many of whom fill numerous roles, processing time is especially important. Even more time may also be required if additional information is required after review.
Students who request accommodations after the start of a term should not expect immediate accommodation. Also, in fairness to students who suddenly find themselves grappling with a new disability or temporary impairment mid-semester, requests related to conditions that emerged during the semester will be prioritized over mid-semester requests to address long-standing disabilities for which accommodation could have been sought earlier.Accommodation in the Work Program
Sterling offers a range of work program positions suited to a wide range of abilities, interests, and professional development goals. Students should review job vouchers carefully during the process of preferencing and signing up for work program positions. Job vouchers include a representative outline of duties and qualifications. Reasonable accommodations for students with documented disabilities are available in the Work Program. Students should only apply for jobs that they can perform with or without reasonable accommodation.
Students requesting disability accommodation in the Work Program, inclusive of chores and work crew positions, should follow the processes outlined above for documenting disability and requesting accommodation before the start of semester. If reasonable accommodations cannot be identified, a different, more suitably accessible type of work position or chore will be assigned.Accommodation in Some Experiential Endeavors and Field Programs
Conditions in some signature Sterling College programming, including but not limited to experiential endeavors, intensive field programs, and outdoor oriented course such as A Sense of Place are necessarily different than you would find on a typical college campus. Such studies offered through Sterling College are immersive learning experiences that can involve:
travel by multiple forms of transportation across long distances;
hiking, biking, paddling and other forms of human-powered movement through varied environments, over uneven terrain, and on moving water;
extended periods of time in the unsheltered outdoors;
limited, sporadic or no access to running water, flush toilets, showers, laundry and other facilities for hygiene;
extended periods of time during day and night without access to electricity;
no or limited access to electronic technologies, including cellular phones, internet, and similar communication devices and platforms;
navigation of unfamiliar environments and variable itineraries;
limited ability to accommodate some dietary restrictions and preferences;
intensive interaction with only a small group of peers and faculty;
close proximity to livestock, draft animals, and/or wildlife; and
sustained challenge.
In other words, such programs can be as physically, mentally, and emotionally taxing as they are rewarding. As such, some Sterling programs may have minimum physical and health requirements. Opportunities for accommodation within some Sterling Experiential Endeavors and Field Programs tend to be more limited than in classes or programs based on-campus or at a regular instructional site. Students with disabilities who are interested in participating in a program that may have the above-listed characteristics and/or has published minimum physical and health requirements should contact the faculty member leading the field program to learn more about its particular demands and are encouraged to confer with the Director of Learning Support about whether their requested accommodations may be feasible in these programs.
Minimum Requirements for Winter Expedition
Students interested in participating in Sterling’s Expedition II: Winter Outdoor Challenge (colloquially known as ‘Winter Expedition’) should be aware that in order to meet the learning objectives of this course the class will engage in field-based experiences in a wide range of weather conditions: temperatures in December can dip as low as -20 F, but also can be above freezing and raining. At times, the class will be walking up to 8 miles per day, mostly off-trail, over steep and uneven terrain, through deep snow, all while carrying a backpack that weighs about 40 lbs. Winter Expedition entails sleeping outside for 3 nights in a sleeping bag and tarp shelter that you build yourself, and all cooking is done on fires. Fires are made from firewood that you have to find, carry to your campsite, saw into lengths, and split; the campfire environment is usually smoky which can irritate your eyes and lungs.Accommodation in Internship Placements
& Other Off-Campus Work-Learning Experiences
Sterling College supports students with disabilities and encourages their robust participation in internships and other off-campus work-learning experiences (“Field Placements”) that may be required as part of a student’s academic program.
Field Placement accommodations are made on a case-by-case basis and require coordination with third-parties. As such, if a student requires accommodations during a field placement, it is the student’s responsibility to request accommodations as far in advance as possible – ideally when setting up the Field Placement, and with a minimum of 4 weeks’ notice before the student is scheduled to begin work-learning at an off-campus site. The Director of Learning Support will work with the student’s advisor, instructor of record, and Field Placement personnel to develop an appropriate accommodation plan.
Students are responsible for carefully vetting a proposed Field Placement before committing to work-learning in that setting. Students should engage Field Placement personnel in detailed conversation about the nature of the field placement and site, the work involved, and the accommodation possibilities. The Director of Learning Support is available to support students in such exploratory conversations, upon request, and will serve as the primary liaison between the College, the student with a documented disability, and field placement personnel when the student requests accommodations in a field placement.
When considering a field placement:
Students should work with their advisor(s) to identify the most critical factor(s) in determining appropriate Field Placement(s) that advance their personal learning goals, suit their learning styles, and can reasonably accommodate their documented disabilities.
Students are not required to use accommodations during their Field Placement(s). However, there can be no retroactive adjustments to grades or for performance.
It is the student’s responsibility to find transportation to the Field Placement site unless transportation is being provided for all students.
Students with disabilities are also strongly encouraged to tour potential Field Placement sites before committing to work-learning in a particular setting or program.
Accommodation Exploration During the Admissions Process
Sterling College does not discriminate against qualified individuals with disabilities in their admissions process. Disability disclosure is not required during the admissions process; disclosure of a disability is always voluntary. Nevertheless, some applicants may wish to explore the accommodation options ahead of matriculation. Sterling will work with applicants as needed to make sure that our programs are the right fit and that desired accommodations are possible. Applicants with disabilities also have the right to have reasonable accommodations in the admissions process, upon a request and demonstration of a relationship between their disability and the need for accommodation.
Temporary Impairment
While not required by applicable law, the AAT may be able to arrange limited assistance for students who are experiencing a temporary impairment. Temporary impairments such as short-term medical conditions, infections, injuries, surgeries, or acute illnesses can happen at any time and seriously affect a student’s ability to participate in, or complete, a course. These situations are highly variable in nature and effect, so the specific course of action followed will be tailored on a case-by-case basis. When the College voluntarily arranges or provides support for a student with a temporary impairment, such support does not mean the temporarily impaired student qualifies or is certified as an individual with a disability under applicable law. It does, however, represent the College attempting to support students through periods of unexpected, emergent or short-lead scheduled impairments or treatments.
Broadly speaking there are four scenarios:Unplanned Temporary Impairment Requiring More than Two Weeks or 20% Absence: If an unplanned temporary impairment occurs that will require more than two weeks (in the case of full long block courses) or 20% (in the case of intensive or shorter courses) absence from classes, then it is recommended that a student withdraw from classes for that semester.
Unplanned Temporary Impairment Requiring Less than Two Weeks Absence: If a temporary impairment was unplanned, but is foreseen to be resolved within two weeks, the general sequence of events would be as follows:
As soon as is safely possible, obtain a dated letter from your medical provider describing your condition, including the expected duration and limitations of your condition. Share this with the Director of Learning Support or who will communicate essentials only to those people who will need to know (e.g. academic advisor, instructors, student life, etc).
Discuss your situation with the course instructor who will work with you to make suitable accommodations which might include, but are not limited to:
Dropping an exam or assignment score;
Providing the opportunity for a makeup exam or an equivalent assignment;
Allowing extra-credit assignments to substitute for missed class work; and
Arranging for an increased flexibility in assignment due dates, etc.
If an unplanned temporary impairment arises less than two weeks before the end of the semester, it may be an option to take an Incomplete in that class, to be completed as soon as possible after the temporary impairment has been ameliorated.
Planned Temporary Impairment Requiring More than Two Weeks Absence: If a temporary impairment can be foreseen and will require more than two weeks absence from classes (e.g. significant scheduled surgery), it is recommended that a student take a Leave of Absence from the college for the semester in which that temporary impairment falls. However, alternative options do exist, for example, a student could enroll in a combination of options that are easily fitted around this temporary impairment - for example, taking an Intensive plus one independent study. Students who foresee this situation should initiate a planning conversation with their advisor and the Director of Learning Support as early as possible in the planning process. They are also encouraged to reach out to the Dean of Academics and Assistant Dean of Academics & Registrar for further support in the academic planning process, the Associate Dean of Work-Learning for support in identifying impacts to the Work Program, and the Dean of Community for any support relating to campus and residential accessibility.
Planned Temporary Impairment Requiring Less than Two Weeks Absence: If a temporary impairment can be foreseen and will require less than two weeks absence from classes (e.g. scheduled surgery), the general sequence of events would be as follows:
As far ahead as possible, but at least two weeks in advance, obtain a dated letter from your medical provider describing your scheduled condition, including the duration and limitations of your condition. Share this with the Director of Learning Support who will communicate essentials only to those people who will need to know (e.g. this could include one or more of the following: academic advisor, instructors, student life staff, etc).
Discuss your situation with the course instructor who will work with you to make suitable accommodations which might include, but are not limited to:
Dropping an exam or assignment score;
Providing the opportunity for a makeup exam or an equivalent assignment;
Allowing extra-credit assignments to substitute for missed class work; or
Arranging for an increased flexibility in assignment due dates, etc.
In some cases, both planned and unplanned temporary impairment can allow a student to continue participating in a class but with some element of reduced capacity. In such a situation, it is recommended that students meet with the Director of Learning Support to generate temporary accommodations that allow the student to get the most out of the classroom experience. Temporary accommodations might include, but are not limited to:
Reduced or no screen time
Voice to text software
Classmate(s) providing notes to student
Alternative assignments
Increased time on quizzes and exams
Remote attendance being permitted.
On-Campus Housing Accommodations
Students requesting accommodations in housing should do so at least one month before the start of the semester. Requests may require documentation from a medical provider. Opportunities to request accommodation are found in the New Student Housing Application and Returning Student Housing Preference Survey, and may also be made in writing to the Dean of Community. Accommodations could include, for example:
First-floor room
Access to single-use bathroom
Single room
Assistance or Service Animal (see full policy below)
Pets, Service & Assistance Animals
Students are not allowed to have animals on campus (that is, pets), including but not limited to: in classrooms, residence halls, Dunbarn, any kitchens, in College vehicles, or at College-sponsored events. Exceptions to this policy are listed below.
Service Animals and Assistance Animals
Sterling College recognizes that Service Animals and Assistance Animals can play an important role in facilitating the independence and successful college experience of some individuals with certain types of disabilities. Service Animals and Assistance Animals that meet the criteria described below will be exempt from the pet provision above.
The health and safety of Sterling College students, faculty, staff, and the Service Animal or Assistance Animal is an important concern. College community members who have questions about the presence of Service Animals or Assistance Animals on campus should direct those questions to the Office of the Dean of Community.Service Animals
A Service Animal is defined under the Americans with Disabilities Act (ADA) as any dog (or in some cases, a miniature horse) that is individually trained to do work or perform tasks for the benefit of an individual with a disability. The work or task must be directly related to the person’s disability. The provision of emotional support, well-being, comfort, or companionship does not constitute work or tasks for the purposes of this definition (see “Assistance Animals,” below). The ADA and US Department of Justice state that service animals in training are not considered service animals, however some state or local laws may cover animals that are still in training.
Service Animals in training who are with a member of the College community who has a disability, and with whom the animal will be working as a Service Animal, are provided the same rights as Service Animals under this policy.
Students with Service Animals are permitted generally to bring their Service Animals in all areas of a place of public accommodation, such as classrooms, residence halls (including the private residence assigned to the student), activities and events, and dining facilities. However, Service Animals are not permitted if they pose a direct threat to health or safety, if their presence constitutes a fundamental alteration to the nature of a program, service or physical space, if they cannot effectively be controlled, or if they are not housebroken.
Students planning to bring a Service Animal to campus should work closely with the Office of the Dean of Community, before arriving on campus. Students intending to keep a Service Animal in a residence hall should submit a request to the Office of the Dean of Community at least 30 days in advance. The Office of the Dean of Community may ask the student if the animal is required because of a disability, and what work or task the animal has been trained to perform, but will not ask about the nature of the student’s disability for this purpose.
Students are encouraged to provide identification (e.g., harness, backpack) that the animal is a Service Animal so that others are aware it is a working animal, however identification is not required.
See below for a description of the student’s responsibilities and the reasons for removal of Service Animals.Assistance Animals
An Assistance Animal provides emotional support, comfort, companionship or therapeutic benefits. A person qualifies for reasonable accommodation involving an Assistance Animal under the Fair Housing Act if:
the person has a documented disability;
the animal is necessary to afford the person with a disability an equal opportunity to use and enjoy the residence halls; and
there is an identifiable relationship between the disability and the assistance the animal provides.
Assistance Animals are allowed generally within designated residence halls, but not in other College buildings or college vehicles. Assistance animals may not accompany students to classes or on field trips. The College will not, however, permit Assistance Animals in residence halls if they pose a direct threat to the health or safety of others; would cause substantial physical damage to the property of others; would pose an undue financial and administrative burden; or would fundamentally alter the nature of the College’s operations.
Students planning to bring an Assistance Animal to campus must obtain approval from the Office of the Dean of Community by submitting a request at least 4 weeks in advance of arriving on campus. The College requires the Dean of Community to ask for the following documentation:
a letter from a licensed medical provider certifying that you have been diagnosed with a disability, and that the symptoms of your disability will be mitigated by the use of this assistance animal;
documentation from a veterinarian that your animal is up-to-date on vaccinations, is in good health, and can be appropriately and safely housed indoors;
a budget, prepared by you, indicating how you will financially provide for the needs of your animal. The budget can be a statement included in the personal statement stating that the student’s guardian will ensure the animal’s financial needs (food, vet bills, grooming) will be met; and
a personal statement written by you as to how the assistance animal will help you be successful at Sterling.
See below for a description of the student’s responsibilities and the reasons for removal of Assistance Animals.
Animal Care
Requirements for service animals, assistance animals and their owners include:
The owner of the animal must be in full control of the animal at all times.
All animals must be leashed while outside on campus.
Animals may not be left outside unattended, even while leashed.
Animals must be licensed in accordance with local regulations and, if appropriate, must wear a valid vaccination tag.
Animals must wear identification at all times.
Animals must be in good health. Any service/assistance animals occupying college housing must have an annual clean bill of health from a licensed veterinarian. Documentation must be submitted to the Dean of Community.
Students are encouraged to provide identification that the animal is a service animal so that others are aware it is a working animal, but service animals are not required to wear a vest, identification tag, or specific harness. Students will provide documentation of the continuing need for the assistance animal on an annual basis.
The owner is responsible for appropriate waste clean-up and overall cleanliness of the animal.
The owner is responsible for the appropriate management of their animal in all College facilities.
Disruptive and/or aggressive behavior on the part of the animal may result in the owner being asked to remove the animal from College facilities immediately and permanently.
The owner is responsible for any property damage or personal injury caused by the animal, or pest control (e.g., flea treatment) required because of the animal.
Any animal left unattended or abandoned will be removed from campus.
In the event that the owner leaves the College for any amount of time greater than 8 hours (dog) or 24 hours (cat), the owner must bring the animal with them or communicate to the Dean of Community the plan for the animal’s care.
Removal of an Animal
Sterling College maintains the right to remove an animal under certain circumstances if:
the animal is out of control of the handler,
it is not vaccinated or licensed,
it causes disturbances such as noise or excessive odors,
it poses a direct threat to any member of the Sterling community,
the service/assistance animal is left unattended without care, or
the animal displays disruptive and/or aggressive behavior, which may result in the owner being asked or required to remove the animal from College facilities immediately and permanently.
Etiquette with Service Animals and Assistance Animals
To support safe, respectful, and harmonious relations with service and assistance animals in the Sterling Community:
Do not pet a Service Animal or Assistance Animal without permission of the owner; petting a Service Animal when the animal is working distracts the animal from the task at hand. Service dogs typically wear a leather harness, scarf or sign to indicate they are working animals.
Do not feed a Service Animal or Assistance Animal. The animal may have specific dietary requirements.
Do not deliberately startle a Service Animal or Assistance Animal.
Do not separate or attempt to separate an owner from her or his Service Animal or Assistance Animal.
Allow a service animal to accompany the owner at all times and everywhere on campus except where service animals are specifically prohibited. Students with assistance animals are not afforded this right, and may only be present in the student’s housing if approved by the Dean of Community Office.
Problem Solving & Direct Communication Around Disability Accommodation
Clear communication between students, faculty/staff, and the AAT is vital to reducing barriers for and providing equal opportunity to students with disabilities.
When possible, students are encouraged to first address concerns about disability accommodation directly with the individuals involved in the situation such as:
the Director of Learning Support regarding eligibility for accommodations and specific accommodations;
the individual faculty or staff member, in the cases of implementation or lack of approved accommodations;
If a student is unable to discuss an issue with the Director of Learning Support, or if the complaint is about the Director of Learning Support, the student should contact the Dean of Community.
It is often possible that a simple misunderstanding can be cleared up via direct and respectful communication. If a student is hesitant about engaging in direct communication, they may reach out to the Director of Learning Support, the Dean of Community or their faculty advisor for support in preparing for or engaging in the direct communication and arriving at clarity.
Faculty and staff are encouraged to first address concerns about disability accommodation directly with their supervisor and/or the Section 504 Coordinator.
Appealing an Accommodation Determination
All students who submit documentation of disability and request accommodation will receive a written eligibility/denial determination letter from the AAT. Students who do not agree with the determination letter (in whole or part) may choose to engage in informal problem solving and direct communication with the Director of Learning Support and/or the Accessibility and Accommodations team. Students are not required to participate in informal problem-solving and may move directly to a formal appeal as outlined in Section XI, below. To be clear, the College makes this informal resolution option available, but parties are under no obligation to participate in informal resolution and can instead pursue the complaint process outlined below.
Because Sterling is such a small institution, we do not have a formal appeal process with a separate review panel for accommodation determinations. Instead, students who disagree with a decision made with respect to a requested accommodation may submit a written request for reconsideration to the Director of Learning Support and the AAT within five business days after receiving the written notice of the determination. The written request for reconsideration may be submitted via email to the 504 Coordinator/Director of Learning Support (contact information in Section II). It should include the specific aspects of the decision being challenged and supporting arguments and/or evidence.
All requests for reconsideration will be taken up as soon as possible and a determination will typically be issued within five business days of the AAT’s receipt of all information pertinent to the reconsideration request. The AAT may extend this time period, if necessary. If an extension of time is required, the 504 Coordinator/Director of Learning Support will provide an email acknowledgement that the review is in process and a request for additional information or time required for the review, in writing to the student’s official college email. It is incumbent upon the student to attend to their email for these communications and to respond to all AAT requests in a timely manner.
Faculty and staff who would like formal review of a disability-related decision may pursued the Section 504 Grievance Procedures outlined immediately below.
Section 504 Grievance Procedures
Sterling College is committed to promoting equal access to its programs, services, and activities. Sterling determines accommodations through an interactive process involving the student, the AAT, and appropriate community members. However, at times, a faculty or staff member or a student may disagree with a decision made with respect to a requested accommodation or other matter pertaining to disability, or be concerned about perceived discrimination or harassment on the basis of disability.
In addition to the above-stated optional problem-solving process and the opportunity for reconsideration of accommodation decisions, faculty or staff members or students who feel that they have been inappropriately denied accommodations, harassed or discriminated against on the basis of their disability by anyone affiliated with the College (inclusive of employees, other students, or third-party affiliates) in violation of Section 504 of the Rehabilitation Act of 1973, the ADA, or other applicable law, are encouraged to file a complaint under Sterling’s Section 504 Grievance Procedures, detailed below.While the College will address complaints when they are raised, to best facilitate timely resolution of disability-related grievances, complaints be submitted to the 504 Coordinator within 30 days of the date upon which the person filing the grievance becomes aware of the alleged discriminatory action.
If the grievance in question involves the 504 Coordinator/Director of Learning Support, the written grievance may be submitted to the Dean of Academic Affairs, who will work with the President to identify an appropriate person to review the complaint.
Grievances must be submitted in writing, containing the name and address of the person filing it. The written grievance must state the problem or action alleged to be discriminatory and the remedy or relief sought.
The 504 Coordinator (or their designee) shall conduct an investigation of the grievance. This investigation may be informal, but it must be thorough, affording all interested persons an opportunity to present witnesses and/or suggest that certain individuals be interviewed, and submit relevant evidence. The 504 Coordinator will maintain the files and records of Sterling College relating to such grievances.
The Section 504 Coordinator will acknowledge the written grievance within 48 business hours of receipt and seek additional information within the next 21 business days, unless extenuating circumstances (e.g., party and witness availability, college breaks) require a longer investigation period. Parties will be informed of any delay and the reasons for the delay.
The Section 504 Coordinator will typically issue a written decision on the grievance no later than 28 business days after its filing; if, however, extenuating circumstances (e.g., witness availability, college breaks) make it difficult to render a decision in this time period, the Section 504 Coordinator will, at a minimum, provide a written update within the first 28 business days and detail any additional steps that will be taken to reach a resolution within a timeframe that is reasonable under the circumstances. Written notice will be shared with the person who filed the grievance, any person(s) accused of participating in or enabling discrimination or harassment, and the President of the College. Parties will receive notice of the outcome of a complaint and the basis for the decision.
If the written decision contains a finding that discrimination or harassment occurred, the College will take steps to stop the discrimination or harassment, prevent recurrence, and remedy discriminatory effects on the complainant and others, as necessary and appropriate.
The person filing the grievance may appeal the decision of the 504 Coordinator (or designee) by writing to the President of the College (or their designee) within 15 days of receiving the Section 504 Coordinator’s decision. The President of the College shall issue a written decision in response to the appeal no later than 30 days after its filing.
The availability and use of this grievance procedure does not prevent a person from filing a complaint of discrimination on the basis of disability with the U. S. Department of Health and Human Services, Office for Civil Rights.
Sterling College will make appropriate arrangements to ensure that individuals with disabilities are provided other accommodations, if needed, to participate in this grievance process. Such arrangements may include, but are not limited to, providing interpreters for the deaf, providing taped cassettes of material for the blind, or assuring a barrier-free location for the proceedings. The Section 504 Coordinator will be responsible for such arrangements.
Sterling College does not retaliate against anyone because they have filed a grievance or cooperated in the investigation of a grievance.
Additional Support for Students with Learning Differences
Sterling endeavors to provide an inclusive learning environment and may be able to offer support for some learning differences that do not rise to the level of a documented disability. Such students are encouraged to avail themselves of the learning support structures and programming at Sterling College. The following types of limited learning supports may be available to support academic success without moving through the full disability documentation process:
extended time on tests;
quiet space for testing;
spelling-related accommodation;
use of a calculator;
use of music or noise-canceling headphones during testing; and
use of manipulatives (e.g., fidget spinners, tactile apparatuses, or knitting) in class.
If provided without the student’s being recognized by the AAT as a student with a disability, such supports are being provided at the discretion of the College, and not because they are required by law, and accordingly they may be modified or discontinued as deemed appropriate by the College.
The Director of Learning Support is available to work with individual returning and newly admitted students each semester to assess and support learning and development including coordination and development and implementation of individualized academic support plans for students. Students should schedule an appointment with the Director of Learning Support whenever they are curious about available support, at the recommendation of an advisor, or as soon as an academic struggle or the need for support becomes apparent.
Students with a history of learning differences and hindrances that affect learning are encouraged to forward their current and comprehensive documentation to the Director of Learning Support during the months before the beginning of their first semester. Students with learning differences are then asked to meet with the Director of Learning Support at the start of the academic semester in order to discuss course planning and strategies for success.
Of course, any student who wishes to seek reasonable accommodations on the basis of a documented disability are welcome and encouraged to submit in the AAT documentation and accommodation process detailed above. Students may do so at any time, without regard to whether they have received such supports without doing so in the past.