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Purpose and Scope

The ºÚÁÏÍø±¬³Ô¹Ï (ºÚÁÏÍø±¬³Ô¹Ï) is committed to ensuring that all members of its community have equitable access to its programs, services, activities, and operations. These procedures establish a consistent process for raising and resolving complaints related to disability discrimination, denial of reasonable accommodations, or other accessibility concerns.

The procedures apply to all members of the ºÚÁÏÍø±¬³Ô¹Ï community, including applicants, students, employees, contractors, and visitors, across all university settings—whether in person, online, or at partner or off-site locations.

Formalizing this process supports ºÚÁÏÍø±¬³Ô¹Ï’s compliance with federal and state laws, as well as University System of Maryland (USM) policies. Specifically, the procedures are guided by the Americans with Disabilities Act of 1990 (as amended), Section 504 and Section 508 of the Rehabilitation Act of 1973, and related state and federal accessibility regulations. Establishing a step-by-step complaint process also demonstrates ºÚÁÏÍø±¬³Ô¹Ï’s institutional responsibility to address concerns promptly, fairly, and transparently, while maintaining accountability in its accessibility efforts.

1. Accessibility: Ensuring that individuals with disabilities have equitable, independent access to ºÚÁÏÍø±¬³Ô¹Ï’s programs, services, activities, technologies, and environments, in compliance with federal and state law.
2. Disability: A physical or mental impairment that substantially limits one or more of the person’s major life activities, taking into consideration any mitigating measures, a record of such an impairment, or being regarded as having such an impairment. 
3. Discrimination: Unequal treatment based on a disability that interferes with an individual’s ability to participate in ºÚÁÏÍø±¬³Ô¹Ï’s programs, services, or activities.
4. Essential Job Functions: The fundamental, basic job duties performed in a position. A function may be essential because: the position exists to perform that function; there are a limited number of employees available who could perform that function; and/or the function is highly specialized, and the incumbent is hired for special expertise or ability to perform it. 
5. External Technology or Vendors: External platforms, applications, or services used by the university that are not developed in-house. These must be evaluated for accessibility before adoption. 
6. Fundamental Alteration: Any change to an essential requirement of a course or program and is determined on an individual basis. Deliverables, methods of instruction, or methods of assessment can be analyzed to determine if an alternative method, strategy, or assignment format would alter the essential objectives and components of a course or program or job requirement. 
7. Reasonable Accommodations for Students: Any changes to a course, program, the classroom environment, or the way things are usually done that allow an individual with a disability to participate in educational activities or enjoy equal access to benefits available to other individuals in the school environment. Modifications must address prospective or current student’s particular disability(ies) and should not fundamentally alter course, program, or degree requirements. 
8. Reasonable Accommodations for Staff and Faculty and Student Employees: Any changes to a job, the work environment, or the way things are usually done that allow an individual with a Disability to apply for a job, perform job functions, or enjoy equal access to benefits available to other individuals in the workplace. Modifications must address the Disability and should not fundamentally alter employees’ Essential Job Functions. 
9. Retaliation: Action that is taken against an individual because they reported discrimination, filed a complaint of discrimination, or participated in an investigation or proceeding concerning a discrimination complaint; or intimidating, threatening, coercing, or discriminating against any individual for the purpose of interfering with any right or privilege secured by law or policy promulgated by USM and/or the University relating to Discrimination, or because an individual has made a report, testified, assisted, or participated in any manner in an Investigation or proceeding related to Discrimination. Retaliation includes retaliatory harassment. 

Procedures

The following steps outline the process for filing, reviewing, and resolving complaints of Disability Discrimination, denial of Reasonable Accommodations, or other Accessibility-related concerns at ºÚÁÏÍø±¬³Ô¹Ï.

1. A complaint may be submitted by any applicant, student, employee, contractor, or visitor who believes they have experienced inaccessibility—whether physical, digital, or denial of reasonable accommodation at ºÚÁÏÍø±¬³Ô¹Ï or through any vendor, partner, or service affiliated with the University. Complaints should be submitted in writing through the ADA complaint portal or to the ADA Compliance Officer at adacompliance@umgc.edu.

   A complaint must include:

   1. The complainant’s name and contact information (phone and/ or email)
   2. A description of the issue, including relevant dates, locations, and individuals involved
   3. Any supporting documentation
   4. The remedy or resolution sought, if known
2. The ADA Compliance Officer (or designee) will acknowledge receipt of the complaint within five (5) business days. The complainant will be informed of the next steps and provided with a copy of these procedures.
3. The ADA Compliance Officer will review the complaint to determine whether the complaint falls within the scope of ºÚÁÏÍø±¬³Ô¹Ï Policy on Access for Individuals with Disabilities; and additional information is required from the complainant. If the complaint is outside the ADA Officer’s jurisdiction, the complainant will be referred to the appropriate office (e.g., Human Resources, Title IX, etc.) and the complainant must follow up with the respective office. If the complaint falls within scope, the ADA Compliance Officer (or designee) will initiate an investigation. The investigation may include interviews, review of documents, and consultation with relevant offices or individuals. Both the complainant and the respondent will have the opportunity to provide information.
4. Following the investigation, the ADA Compliance Officer will issue a written determination within thirty (30) business days of receiving the complaint, unless additional time is required. The determination will include: a summary of findings, any corrective actions or remedies to be implemented, and information about the right to appeal. If new information become available after a decision is made, the complainant should resubmit another complaint.
5. At any time, individuals also have the right to file a complaint with external agencies, including:
   • The U.S. Department of Education, Office for Civil Rights (OCR)
   • The Equal Employment Opportunity Commission (EEOC)
   • The Maryland Commission on Civil Rights (MCCR)
   • The U.S. Department of Justice (DOJ), Civil Rights Division

1. VI-1.01 ºÚÁÏÍø±¬³Ô¹Ï Policy on Access for Individuals with Disabilities
2. P-V-1.30: Procedures for ºÚÁÏÍø±¬³Ô¹Ï Policy on Student Reasonable Accommodation
3. VI-1.00 ºÚÁÏÍø±¬³Ô¹Ï Policy on Non-Discrimination and Anti-Harassment
6. Federal Laws: ADA, Rehabilitation Act (Sections 504 & 508) State Accessibility Regulations