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Operational policy regarding event accessibility

  1. Purpose. This policy provides the requirements for administrative offices and instructional units of the university in planning events that consider the accessibility of participants, including those with disabilities, in accordance with the university’s duties under Section 504 of the Rehabilitation Act of 1973 (Section 504), 29 U.S.C. 794, and its implementing regulation at 34 C.F.R. Part 104, and Title II of the Americans with Disabilities Act of 1990 (Title II), 42 U.S.C. 12131 et seq., and its implementing regulation at 28 C.F.R. Part 35.
  2. Definitions. For the purposes of this rule only, the following definitions shall apply:
    1. Assistive listening devices (ALDs). Personal devices that help those with hearing loss or a voice, speech, or language disorder to communicate.
    2. Event coordinator. A university employee of the administrative office, instructional unit, or office of university events and protocol who is primarily responsible for organizing the event on behalf of the administrative office or instructional unit.
    3. Section 504/title II coordinator: A university employee responsible for overseeing the university’s compliance with the above-noted disability non-discrimination and accommodation laws. The section 504/title II coordinator position is within the office of compliance, equal opportunity and affirmative action.
    4. Speech-to-text services. Technology that enables human speech to be converted automatically to text; includes real-time captioning or transcribing, a method of using specialized software to convert spoken language into visual text onto a screen.
  3. Requirements. The administrative offices and instructional units of the university are responsible for ensuring that any events they sponsor are accessible to those individuals with disabilities that need and request a reasonable accommodation, in accordance with the laws noted in paragraph (A) of this policy. The event coordinator must solicit, review, and respond to requests for accommodations in the manner described below. It is the responsibility of the administrative office or instructional unit sponsoring the event to ensure the event is held in compliance with this policy.
  4. Implementation.
    1. Event planning and production. Event coordinators shall consider the accessibility of the event at all stages of event planning and production. Any costs incurred in complying with this policy are the responsibility of the administrative office or instructional unit sponsoring the event. The event coordinator may consult with the Section 504/Title II coordinator, the office of student accessibility services (SAS), and other campus resources in planning an accessible event.
    2. Invitations, advertising, and event website. Any invitations, advertising, websites, or registration sites for events shall contain language notifying the intended audience that they can obtain information as to the existence and location of accessible services, activities, and facilities, and if they require a reasonable accommodation to attend the event, they should contact the event coordinator (or designee) as soon as possible. The notice shall also provide the contact information for the event coordinator or designee.
    3. Requests for accommodations. The event coordinator shall review any requests for disability accommodations to determine if they are reasonable. No accommodation shall be required if the accommodation would fundamentally alter the nature of the event or result in undue financial and administrative burdens. Event planners must consult the section 504/title II coordinator prior to denying any accommodation request.
    4. Assistive listening devices (ALDs). If the event will have a speaker, presentation, or performance where audible communication is integral to the program (and particularly if audio amplification will be used), an ALD shall be provided. The event coordinator shall discuss the availability and usage of an ALD system with the employees responsible for audio, visual, and technical support for the space. Some university event spaces are equipped with permanent ALDs. The student center has permanent ALDs in some spaces and portable ALDs that can be reserved ahead of an event. Classroom technology and university event support can also be contacted for portable ALD systems.
    5. Speech-to-text services. If the event will have a speaker, presentation, or performance where audible communication is integral to the program, particularly if the event is large and public-facing, the event coordinator should consider utilizing speech-to-text services to proactively address any accessibility issues, disability or otherwise.
    6. Training. Event coordinators are responsible for familiarizing themselves with this policy. The event coordinator shall also ensure that other staff (including volunteers and student assistants) with responsibility for planning events or interacting with attendees, receive training regarding this policy. Training should occur on a regular basis, at least biannually, and be conducted with assistance from the section 504/title II coordinator. New event coordinators should be trained shortly after hire or designation.
  5. Violation. Any person who believes they were denied a reasonable accommodation in violation of this policy may utilize the grievance procedure provided for in rule 3342-5-16.1 of the Administrative Code. The section 504/title II coordinator may be contacted at aa_eeo@kent.edu for more information regarding this process.
Policy Effective Date:
Apr 02, 2021
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