(University of California, Los Angeles January 26, 1993)
©1993 Regents of the University of California
The landmark Americans with Disabilities Act of 1990 (ADA) provides comprehensive civil rights protections to qualified individuals with disabilities in the areas of employment, public services, public accommodations, transportation, and telecommunications. Title II, subtitle A, of the ADA took effect on January 26, 1992 and covers all programs, activities, and services of public entities, including the University of California.
The ADA defines a "disability" as a physical or mental impairment that substantially limits one or more major life activities (such as walking, hearing, seeing, speaking, breathing, learning, and working); a record of having such an impairment; or being regarded as having one. "Disability" covers a wide range of conditions and includes mobility, vision, hearing, or speech impairments, learning disabilities, chronic health conditions, emotional illnesses, HIV disease (symptomatic or asymptomatic), and a history of drug addiction.
A "qualified individual with a disability" is further defined as a person who, with or without reasonable modifications to the University's policies or practices; removal of architectural, communication, or transportation barriers; or provision of auxiliary aids and services, meets the University's essential eligibility requirements to receive services or participate in its programs. For the purposes of employment, a "qualified individual with a disability" is a person who can perform the essential functions of the job, either held or sought, with or without reasonable accommodation.
Under Title II of the ADA, a public entity must operate each program, activity, or service so that it is, when viewed in its entirety, readily accessible to and useable by individuals with disabilities, unless doing so would result in a fundamental alteration in the nature of the program, activity, or service; would result in undue financial and administrative burdens; or threaten or destroy the historic significance of an historic property. This standard, known as "program accessibility", can be achieved by a number of methods. These include but are not limited to: redesign of equipment, reassignment of services to accessible buildings, assignment of aides to beneficiaries, home visits, delivery of services at alternate accessible sites, alteration of existing facilities and construction of new facilities, and use of accessible rolling stock or other conveyances. When choosing a method of providing program access, a public entity must give priority to the one that results in the most integrated setting appropriate to encourage interaction among all users, including individuals with disabilities.
Section 35.105 of Title II of the ADA requires all public entities to conduct a Self-evaluation by January 26, 1993. However, public entities are liable for any discriminatory policies or practices in effect after January 26, 1992. Through the Self-evaluation, the University must:
Areas that need careful examination in the Self-evaluation process include, but are not limited to: general policies and practices, communications, auxiliary aids, eligibility and admission requirements, evacuation from buildings, written and audio-visual materials, employment, training programs, building and construction policies, and physical barriers. (An extensive review of physical barriers to program accessibility was completed July 24, 1992, for the campus ADA Transition Plan).
This report sets forth the findings of the Self-evaluation that UCLA conducted in accord with Title II, subtitle A of the ADA. A Chancellor's ADA Self-evaluation Task Force, in conjunction with a group of ADA Coordinators representing a broad array of campus programs and organizations, carried out the Self-evaluation. The report is comprised of five principal sections. Following this introduction and executive summary, Section II describes the background of, and enumerates the organizations and the processes that deal with, the ongoing campus effort to provide program access. Section III details the establishment of the Chancellor's ADA Self-evaluation Task Force, the development and conduct of the Self-evaluation Survey, the designation of ADA Coordinators, the individuals with disabilities and organizations representing individuals with disabilities that participated in, and were consulted during, the Self-evaluation process, and the areas examined by the Self-evaluation Survey. Section IV enumerates the Self-evaluation Survey's findings and provides a description of problems identified and modifications made.
The Self-evaluation findings, based on surveys of over one hundred major administrative and academic entities encompassing several hundred discrete programs, indicate that there is a significant level of awareness of, and commitment to, the general precepts of Title II of the ADA at UCLA. This would be expected in light of the University's long established efforts to ensure compliance with the provisions of Section 504 of the Rehabilitation Act of 1973 - many provisions of which form the basis for, and closely parallel, the ADA requirements. Areas, however, were identified in which modifications are appropriate. Some of these areas include: methods to inform faculty and staff periodically about the ADA requirements, effective telephone communication for individuals who are deaf or hard-of-hearing, appropriate portrayal of individuals with disabilities in written and audio-visual materials, advertisement that programs are architecturally and programmatically accessible and that accommodations are made upon request, emergency evacuation procedures, grievance procedures, "significant assistance" and assurance of compliance through contracts or other arrangements, ADA training sessions, and reasonable accommodation in employment.
Consistent with the Chancellor's 1986 commencement address pledge to improve campus accessibility, UCLA has had an active effort underway to remove barriers to its programs, services, and activities for individuals with disabilities. The following is a description of University organizations to create a more hospitable campus environment for individuals with disabilities.
In 1986 the Chancellor created a full-time office to oversee compliance with Section 504. In January 1992 its duties were expanded to include coordination of both ADA and 504 compliance. The Coordinator of ADA & 504 Compliance has the charge to:
This Committee was established in 1982 as an advisory group by the Chancellor to create and maintain a more accessible campus environment for individuals with disabilities. The CACD is comprised of student, faculty, staff, alumni, community, and ex-officio members. The Committee's charge is to analyze and identify problems, propose solutions, and make recommendations on matters of particular concern to persons with disabilities.
The USD is committed to the precept that students with disabilities should be fully integrated into the mainstream of University life and have access to all academic and extracurricular activities. The USD serves as a voice for students with disabilities as an under-represented group on campus, and seeks to educate the non-disabled community about their needs, concerns, and abilities. The USD participates in the CACD as a subcommittee and advocates for improved services and physical and program accessibility for all students with disabilities at UCLA. The USD was granted status as a Student Advocacy Group (SAG) in the Fall of 1989. As such, USD receives institutional funding, administrative support, office space, and telephone privileges to carry out its goals.
The OSD is mandated by the State to deliver core academic support services to students with permanent and temporary disabilities. The mission of the Office is to assist students with disabilities in their endeavor to be fully integrated into the mainstream of all academic and extracurricular activities on campus. The OSD strives to fulfill this charge by safeguarding the rights of students with disabilities, educating the campus community regarding disability related issues, and facilitating the elimination of physical, transportation, program, and attitudinal barriers. OSD has addressed needs such as procuring adaptive equipment, establishing and co-sponsoring a disability awareness month with the USD, and alerting the Chancellor's ADA & 504 Compliance Office of information regarding barriers that impede students' access to campus facilities and programs.
The DCP is part of the Microcomputer Support Office and provides computer support services to UCLA faculty, students, and staff with disabilities. The program's services involve: support for all disabilities, including physical and learning disabilities, visual and hearing impairments; one-on-one training on IBM and Macintosh computers; technical support and consulting to users and computing facility support staff; and several campus public-access microcomputer workstations that are available for use by anyone with a disability, and are equipped with the latest access technology such as voice synthesis, voice recognition, optical scanning and reading machines, braille print and screen display, and alternate-input keyboards and switches. In addition to the public access workstations, the DCP staff provide consulting support to computer facilities on campus with their own accessible workstations. These enable access to networks and course software in the Division of Social Sciences, the School of Public Health, and the School of Law. The DCP serves as the campus liaison with vendors, other universities, and organizations regarding advanced microcomputer technology and support strategies for persons with disabilities. It works closely with other campus offices in providing an accessible computing environment at UCLA.
The SAAO provides assistance to staff with disabilities in dealing with complaints of discrimination. This includes investigating and mediating internal discrimination complaints filed with state and/or federal agencies. The SAAO conducts diversity awareness training focusing on the area of disability. In addition, SAAO periodically carries out self-identification surveys to determine the number of employees with disabilities working at UCLA.
Medical Center Human Resources offers a range of specialized vocational rehabilitation services designed for staff and faculty with disabilities in achieving optimal career potential. Services include: consultation and counseling in worksite modification, job analysis, identification and assessment of assistive technological equipment/devices and compliance with the reasonable accommodation provision of the ADA.
Following the completion of the campus ADA Transition Plan in July of 1992, a Chancellor's ADA Self-evaluation Task Force, encompassing a diverse group of individuals and constituencies, was instituted to coordinate the development and conduct of the Self-evaluation Survey, as well as to undertake the planning and analytical work required to produce a Self-evaluation report. The group was established and carried out its charge with the participation and/or support of the following individuals:
At its initial meeting, the ADA Self-evaluation Task Force created a Steering/Survey Committee and formed working committees on Employment, Communications, and Policies and Procedures. At a subsequent meeting of the Steering/Survey Committee it was decided to augment the resources of the Task Force by the designation of a group of ADA self-evaluation Coordinators to assist with the task of administering the Self-evaluation Survey. In addition, it was determined that the Coordinators would serve as a resource to their respective campus entities on ADA issues during the self-evaluation process, and would possess a high degree of familiarity with their own programs; consequently, they would be able to identify appropriate individuals within these programs to respond to the Survey. (In this regard, at one point in the survey process, Task Force members acted as Coordinators for their specific areas by assisting with the distribution, completion, and collection of the Survey instruments.) The Steering Committee further resolved that to ensure representation from a comprehensive cross-section of campus programs, a Coordinator would be sought from all major organizational areas. Based on information from the Office of Academic Planning and Budget, a review of the current UCLA Administrative and Academic Organizations was conducted and the designation of a Coordinator was requested from each principal entity. During the selection process all Task Force members and Coordinators were provided with key materials including: The University of California Guidelines for Facilities Compliance with Title II of the ADA dated May 8, 1992, and Assistant Vice President Bocchicchio's letter and accompanying materials of August 31, 1992, regarding the ADA Self-evaluation requirement. (These materials have been widely distributed as part of the overall ADA compliance effort.)
The resulting group of ADA Self-evaluation Coordinators functioned with the support and/or participation of the following individuals:
Concurrent with the identification of the ADA Coordinators, the Task Force Steering/Survey Committee undertook the development of a survey instrument. The Coordinator of ADA & 504 Compliance developed and distributed an initial draft survey for comment by members of the Committee, as well as by Paula Lutomirski, Assistant Vice Chancellor, Information Management and Institutional Research, Eve Fielder, Director, Survey Research Center, Institute For Social Science Research, and Thomas Skewes-Cox, Senior Administrative Analyst, Student Affairs Information Research Office.
The draft was based in part on a variety of materials, including: the University of California Guidelines for Facilities Compliance with Title II of the ADA, dated May 8, 1992; the Universitywide Guidelines for Implementing the Employment Provisions of the ADA, dated May 12, 1992; the Federal Register of July 26, 1991 (28 CFR, Part 35); the U.S. Department of Justice's Americans with Disabilities Act Title II Technical Assistance Manual of January 24, 1992; the Guide to the Section 504 Self-evaluation for Colleges and Universities of January 1978 by G. Richard Biehl prepared by the National Association of College and University Business Officers (NACUBO) under a subcontract with the American Council on Education (ACE); and the two documents enclosed in Assistant Vice President Bocchicchio's letter of August 31, 1992 regarding the ADA Self-evaluation requirement, namely, the Federally Required Self-evaluation which was the process the University of California used in 1978 for completing the Section 504 Self-evaluation, and ADA Self-evaluation and Transition Plans prepared by Evan Terry Associates for Title II covered entities. In addition, with permission of the University of Michigan, Ann Arbor, selected portions from their Self-evaluation were adapted for use in the campus Survey instrument. U.S. Department of Justice's ADA Self-evaluation technical assistance materials were not available in time to use in the development of the campus Self-evaluation Survey.
It was also taken into account during the Survey development process that the University, as a recipient of Federal financial assistance, is concurrently covered by Section 504 of the Rehabilitation Act of 1973 and Title II of the ADA. The ADA Title II regulations closely parallel those of Section 504, including the requirement for a Self-evaluation. In view of the fact that most Section 504 Self-evaluations were done many years ago and because Section 504's coverage has been broadened by statutory amendment and provides more specific guidance with respect to issues of academic adjustment and accommodation than Title II of the ADA, selected items from the U.S. Department of Education's Section 504 regulation (34 CFR 104) specifically covering postsecondary education were incorporated into Sections II, III, and V of the Self-evaluation Survey.
After comment on the first draft of the Survey was complete, a second iteration was produced for additional comment. The draft was distributed for review to members of the Chancellor's Advisory Committee on Disability (CACD) at its November 10, 1992, meeting. As a result of this process, a third draft emerged and was refined into a final version shortly thereafter. In addition, an ADA Self-evaluation Survey Guide was developed to assist the various campus entities in understanding salient ADA principles and in completing the Survey instrument. With permission of the University of California, Berkeley, selected portions of their ADA Self-evaluation Instructions were adapted for use in the UCLA Guide.
Throughout this procedure opportunities were provided for the submission of comments from interested individuals with disabilities and organizations representing individuals with disabilities.
The resulting Self-evaluation Survey form consists of seven general sections covering 94 specific items. Design of the Survey and the accompanying Guide took into account not only the need to provide an instrument that would function as an evaluative tool but would, as a natural consequence of its administration, also be informative and impart a degree of knowledge about the ADA requirements as they relate to the campus community. All programs were instructed to retain copies of their completed Survey form and Guide for future reference.
In order to provide a rational structure for ADA programmatic reviews at UCLA, each organization was asked to examine its own internal structure and identify those discrete areas which are responsible for specific "programs." This examination, designed to avoid an unmanageable multiplicity of reviews, attempted to group programs which were related in nature or scope. As an example, among its many programs, the Department of Cultural and Recreational Affairs (CRA) offers a full range of intramural sports activities for students. To conduct a review of each sport would be time-consuming and duplicative. A review of CRA's organization revealed that the specific area of intramural sports activities is managed by one operational unit with several subunits. Thus, it was deemed appropriate that the operational unit could rationally be selected as the entity to prepare a "programmatic review" of intramural sports activities.
The following is an overview of the areas examined by the various sections comprising the final Self-evaluation Survey instrument (University of California systemwide policies were not included):
- This section was required to be completed by all programs. It deals with the general requirements of the ADA Title II program accessibility standard and covers communications, emergency telephone services, written and audio-visual materials, evacuation from buildings, significant assistance, grievance procedures, advisory boards, building and construction policies, historic preservation programs, physical barriers and the Transition Plan, and non-structural means of achieving program access. The development of this section was assisted by members of the Policies and Procedures Committee.
- Only those programs with a responsibility for determining who is allowed to participate in an activity or service were required to complete this section. The section largely deals with the general Section 504 postsecondary education requirements regarding admissions and recruitment, including: pre-admission and admission tests, validity studies, accommodated testing, pre-admission inquiries, post-admission inquiries and confidentiality.
- Only those programs which provide or oversee instruction or training were required to complete this section. The section largely deals with the general Section 504 postsecondary education requirements regarding academic adjustments, including: relocation of classes, modification of degree requirements, accommodated testing, course substitution, field placement assignments, access to course registration, access to library materials, and access to orientation programs.
- This section was designed to gather preliminary data to help plan for computer access by individuals with disabilities, as well as to be generally informative regarding computing technology. This section was included because the widespread use of computers throughout the University environment underscores the need to provide adaptive computing and support services to faculty, staff, and students with disabilities to ensure their equal access to this technology. In addition, the requirement to furnish materials in alternative accessible formats, as well as to provide effective means of communication further emphasizes the importance of computer access. The section covered the major areas of computing technology and the accommodations and modifications necessary to make them accessible, including: input issues, output issues, documentation formats, and environmental and structural adaptations. This section was adapted from "Computers and Students with Disabilities: New Challenges for Higher Education", ©1991 by EDUCOM's Project EASI with the assistance of members of the Communications Committee.
- This section was required to be completed only by those programs that include housing or other overnight accommodations not UCLA owned and/or operated. UCLA Housing Administration was required to complete this section for all campus owned and/or operated residences. The section largely deals with the general Section 504 postsecondary education requirements regarding housing, including: comparability, convenience, and accessibility, equivalency of cost, sufficiency of quantity and variety, similarity in scope of choices, and nondiscrimination in off-campus housing.
- This section was required to be completed only by those programs that provide or arrange transportation for any of their activities using vehicles not UCLA owned and/or operated. UCLA Fleet and Transit Services was required to complete this section for all campus owned and/or operated vehicles. This section includes selected transportation provisions from Title II, subtitle B, of the ADA. This was done in view of the program access requirements of Section 504, as well as the citation accessible rolling stock as a method of achieving program access in Section 35.150 of Title II, subtitle A, of the ADA. In addition, it was deemed appropriate given the key role transportation services can play in providing access on a large campus with varied terrain. The following items were included: transportation provided through contractual arrangements, fixed route service, accessible format schedules, signage indicating accessibility, driver training and announcement of primary stops, and paratransit services.
- This section was required to be completed by those programs that make employment decisions. The section deals with the general employment requirements of Title I of the ADA as cross-referenced in Title II of the ADA and includes: training materials, reasonable accommodations, job descriptions, job postings, employment tests, interviews, worksite accessibility, and nondiscrimination in association with an individual with a disability. The development of this section was assisted by members of the Employment Committee.
With the assistance of members of the Policies and Procedures Committee, School of Dentistry Dean Dr. Stephen Blain, On-Campus Housing Administrator Martha Dorward, Office of Residential Life Assistant Director Jack Gibbons, School of Medicine Dean Dr. Ray Eden, Dean of Students Ray Goldstone, Registrar's Office Publication Manager Leann Hennig, Center for Student Programming Director Berky Nelson, and Academic Personnel Office Director Jean Stewart, the following campus documents were subsumed under the Self-evaluation process: UCLA Policy Manual, UCLA Standard Procedures Manual, Academic Personnel Policy and Procedure Manual ("The Call"), Student Conduct Code of Procedures, Academic Apprentice Personnel Manual, Medical School Conduct Code of Procedure, Dental School Conduct Code of Procedure, UCLA Activity Guidelines, UCLA Housing Handbook, UCLA General Catalog, and UCLA Schedule of Classes. NOTE: Although these are campus documents; certain provisions, such as the nondiscrimination statements, originate from the University of California Office of the President (UCOP). In such instances, when revised materials from UCOP become available they will be incorporated in campus documents at reprinting.
With the completed development of a Self-evaluation instrument, the next step was to distribute the Surveys to all Task Force members and Coordinators. To facilitate a more thorough understanding of the requirements of Title II of the ADA among those who would assist with the distribution, completion, and return of the Survey from their respective entities, workshops were held to inform Task Force members and Coordinators about the objectives of the Self-evaluation. The workshops were organized by the Coordinator of ADA & 504 Compliance with presentations from a panel consisting of the following:
At the workshops held the first week of December 1992, Self-evaluation Survey instruments were distributed, as well as resource materials which related to specific Self-evaluation provisions such as: evacuation policies and procedures, preferred terms to be used when referring to individuals with disabilities, the California Relay Service (CRS), copies of the ADA Title II, subtitle A, regulations, the ADA Title II Technical Assistance Manual, and the UCLA ADA Self-evaluation Survey Guide.
After the workshops, the Task Force members and Coordinators circulated the Surveys to their various programs. The completed Survey forms were returned in late December 1992 and early January 1993 and were analyzed to produce a summary of problems identified and modifications made.
The results of the ADA Self-evaluation Survey, completed January 26, 1993, reveal that substantial headway has been made by the campus in furthering program access. The Survey examined current services, policies, and practices in over one hundred major administrative and academic entities offering hundreds of programs. While much of this progress is attributable to the long-standing and diligent efforts of the campus to foster Section 504 compliance, areas were identified in which additional adjustments are needed. Ensuing is a summary of findings derived from the completed Self-evaluation Survey forms. The problems identified and the modifications described in these Surveys centered on the following items:
Note: This document is available in accessible formats (Braille, large print, or computer disk) upon request from:
Douglas Martin, Ph.D. (dmartin@saonet.ucla.edu)
Chancellor's ADA & 504 Compliance Office
A-239 Murphy Hall
University of California, Los Angeles
Box 951405
Los Angeles, CA 90095-1405
(310) 825-2242
(Voice), (310) 206-3349 (TTY), (310) 825-3688 (FAX)
Chancellor's ADA and 504 Compliance Office
Last updated: 01/19/99;
