Rule 3342-6-02.103 | University policy regarding equal opportunity.
(A) Policy statement. Pursuant to paragraph (K)(5) of rule 3342-6-02.1 of the Administrative Code, Kent state university establishes the following interactive procedures to assist employees and visitors to campus seeking to request an accommodation for a disability as defined under the Americans with Disabilities Act (ADA as amended). The office of equal opportunity and compliance (EOC) will be responsible for the administration of this policy.
(B) Scope. This policy is limited to university employees, including staff, faculty members, and student employees seeking a disability accommodation in order to perform the duties of their job or enjoy the benefits and privileges of their employment; and to visitors to the extent addressed in paragraph (D) of this rule. This policy does not address the accommodation process in place for students as administered through the office of student accessibility services (SAS). Job applicants for employment may request a reasonable accommodation from the hiring manager or the contact person listed on the job posting, who may then confer with EOC in reviewing such requests for reasonableness and assistance with implementation.
(C) Confidentiality. All information related to accommodation requests will be maintained as confidential to the extent permitted by law. It may be necessary for EOC to confer with an employee's supervisor regarding the requested accommodation, the employee's limitations in performing job duties, and to notify their supervisor of an approved accommodation. However, medical diagnoses will not be disclosed to their supervisors without the employee's consent.
(D) Visitors to campus. Pursuant to rule 3342-5-12.401 of the Administrative Code, EOC collaborates with university event coordinators to provide reasonable accommodations for visitors and guests with a disability or impairment to participate in a university program or activity. Visitors and guests seeking an accommodation are encouraged to contact the event coordinator prior to the event to ensure the requested accommodation is reviewed and implemented in a timely manner if the accommodation is determined to be reasonable. Event coordinators are encouraged to keep accessibility at the forefront when planning events. Visitors to campus not attending a specific event are encouraged to visit https://www.kent.edu/accessibility, or to contact EOC for accessibility needs or requests. Visitors who believe this policy has been violated may file a complaint in accordance with rule 3342-5-16.1 of the Administrative Code by visiting https://www.kent.edu/people-and-culture/discrimination-and-harassment. Failure to provide reasonable notice of an accessibility request may delay the process or result in denial of accommodation.
(E) Definitions
(1) Disability. For purposes of providing an accommodation under this policy, "disability" refers to a physical or mental condition that substantially limits a major life activity (e.g., caring for one's self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working); or a record of physical or mental impairment.
(2) Interactive process. An interactive process allows employees and the university to provide input and feedback in determining a reasonable accommodation. The goal of the interactive process outlined in this policy is:
(a) Determine if an employee has a disability
(b) Identify the precise limitations resulting from the disability as related to the employee's job functions, benefits or privileges;
(c) Identify potential reasonable accommodations that could address those limitations; and
(d) Determine whether a reasonable accommodation will be granted.
The interactive process may involve consultation with the employee, the employee's supervisors, the employee's healthcare provider, and other relevant university staff or departments as necessary to complete the process.
(3) Reasonable accommodation. For the purposes of this policy, "reasonable accommodation" refers to modifications or adjustments to the work environment, policies, or practices that enable an employee with a disability to perform the duties of their job or enjoy the benefits and privileges of their employment. An accommodation is not reasonable if it would result in an undue burden to the university, such as fundamentally altering an essential function of an employee's job. There may be several reasonable accommodations that could address the limitations arising from an employee's disability; the university may provide, at its discretion, an alternative to the accommodation requested by the employee or recommended by the employee's healthcare provider if another reasonable accommodation is sufficient.
(4) Assistive technology. Assistive technology refers to any technology that provides assistance to individuals with disabilities in order to maintain or improve their functional capabilities in their environment, such as Braille displays, modified keyboards, FM assistive hearing units, or screen readers.
(5) Undue hardship. Undue hardship refers to a significant difficulty or expense and focuses on the resources and circumstances of the particular employer in relation to the cost or difficulty of providing a specific accommodation. Undue hardship refers not only to financial difficulty, but to reasonable accommodations that are unduly extensive, substantial, or disruptive, or those that would fundamentally alter the nature or operation of the business.
(6) Major life activity. Major life activities include, but are not limited to, caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, and working.
(7) Substantially limited. Substantially limited include, but are not limited to, an impairment that may limit someone's ability to perform some aspect of their job, but otherwise not substantially limit any other major life activity.
(F) Interactive process.
(1) To initiate the interactive process and to formally request an accommodation, the employee should obtain and complete the electronic accommodation request forms available on the division of people, culture and belonging website at: https://www.kent.edu/people-and-culture/employee-accommodation-request
If a disability or impairment prevents the employee or visitor from completing the online electronic form, please contact EOC for assistance at compliance_equalopp@kent.edu or by phone at 330.672.2038.
(2) Documentation.
(a) After reviewing the request form, EOC may then require documentation of the employee's impairment, including information about how that impairment substantially limits the employee's major life activities, and specifically what limitations the impairment creates for the employee regarding their employment and what reasonable accommodations might be appropriate. EOC may provide a form to be completed by a healthcare provider and returned directly to EOC. The employee requesting the accommodation should also provide their healthcare provider with a copy of their current official job description (classified and unclassified positions: https://apps.kent.edu/JobDescriptions/; faculty positions: https://www.onetcodeconnector.org. It is the employee's responsibility to give the documentation of disability or impairment form and the job description to their healthcare provider for completion.
(b) The healthcare provider form must be completed by a healthcare professional that has treated or evaluated the employee for the impairment for which the accommodation has been requested.
(c) EOC may request additional documentation and/or information for further clarification from the employee and/or the healthcare provider.
(d) Incomplete forms may delay the process and may be returned to the employee for full completion. Failure to return a properly completed form or provide additional needed information may delay the interactive process or result in the denial of the accommodation request for the employee.
(e) The EOC office is the only office authorized to formally approve or deny accommodations for employees. Supervisors are expected to refer any employee requesting a disability accommodation to EOC for assistance. Supervisors should not request medical documentation from employees regarding an accommodation request.
(3) Reasonable accommodation discussion. Once all requested documentation is received and reviewed and EOC has determined that the employee has a disability as defined by this policy, the interactive process continues to determine what, if any, reasonable accommodations would be appropriate. This process may include discussions with the employee, the employee's healthcare provider (with employee's consent), the employee's supervisors, and other relevant university staff as necessary.
(4) Determination.
(a) An EOC representative will review the information provided through the interactive process and may approve or deny the request or propose an alternative accommodation. The EOC representative will inform the employee and the employee's supervisors of the determination as soon as reasonably possible.
(b) If the employee feels any approved accommodation is insufficient, the employee may request that EOC reengage in the interactive process at any time with the goal of determining an alternative reasonable accommodation.
(c) If an approved accommodation requires the procurement of any auxiliary aide(s), assistive technology, equipment and/or services that may be necessary to achieve the reasonable accommodation, the employee and/or the employee's supervisor will work with their department's appointed designee, typically a business manager, to purchase the equipment or services specified in the determination letter issued by EOC. If the approved accommodation requires a purchase of any equipment, furniture, product, or service, etc., and the department plans to request reimbursement from EOC, EOC may require that three quotes be submitted for consideration and approval. EOC may select from the three quotes, complete an authorization fund expenditure form, and submit the form to the employee's supervisor for a signature of approval. The department is required to submit to EOC a paid receipt or documentation showing proof of purchase for EOC to request reimbursement to the department's index and account number.
(d) EOC will not reimburse for any equipment, furniture, product, or service purchased prior to an approved accommodation implemented by this office. All purchases approved through the EOC accommodation process shall be made by the employee's department. Individual employees will not be reimbursed for purchases made using the employee's personal assets. Certain expenses associated with the shipment/delivery or assembly of new equipment, or the removal or storage of existing furniture/equipment (e.g., desks, chairs, monitors, etc.) are not eligible for reimbursement from the office of equal opportunity and compliance.
(e) Any equipment, furniture, product, or service that is purchased by the university for accommodation purposes is the property of the university. If the employee separates from the university for any reason, the item(s) purchased will remain at the university. If the employee transfers to another department and/or campus, the equipment, furniture, product or service may go with the employee to the new location, if the need for the accommodation still exists and the accommodation is still reasonable. Any fees or delivery charges associated with the relocation of equipment, furniture, product or services will be the responsibility of the employee's new department.
(5) Supervision or job changes. If an employee is granted a reasonable accommodation, and is subsequently under new supervision for any reason, it is the employee's responsibility to inform the new supervisor of the existing accommodation. If an employee accepts a different position at the university, or if the employee's current job duties change significantly, the employee should contact EOC to evaluate the reasonableness and effectiveness of their accommodation in light of their new position or new job duties. This may require the employee to reengage in the interactive process.
(6) Changes in accommodations. If an employee is granted a reasonable accommodation, it is their responsibility to keep EOC informed of any changes or updates, or when the reasonable accommodation is no longer needed. Moreover, any implemented accommodation may be reevaluated at the discretion of EOC to determine if it continues to be feasible and appropriate for the department or the university.
(G) Appeal.
(1) If the employee wishes to appeal the final determination made by EOC, the employee may make such appeal to the vice president of people, culture and belonging (or designee), within seven business days of the receipt of the determination letter.
(2) The employee may also contact EOC to discuss filing an internal complaint of discrimination if the employee feels they have been unlawfully discriminated against on the basis of disability. University policies regarding unlawful discrimination can be found in rules 3342-5-16 and 3342-5-16.1 of the Administrative Code.
(3) The employee may at any time file a complaint with an external agency such as the Ohio civil rights commission and/or the U. S. equal employment opportunity commission.
Last updated August 29, 2025 at 7:51 AM
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