What is reasonable accommodation?

1. Background

People with disabilities face many difficulties in their lives. The traditional view of disability was that these difficulties stemmed from a person’s medical abnormality or dysfunction (sometimes referred to as impairment). In contrast, in the U.K. and the U.S., there emerged the idea that disability is caused by the structure of society and that one is disabled because of social barriers (this is a disability in the sense that one cannot do something). The old view of disability is called the “medical model,” and the new one is called the “social model.

In the medical model, it is treatment through which disability is overcome. However, in the social model, changes in the structure of society and the removal of barriers are the means to overcome disabilities. In reality, both of these perspectives are used together, but reasonable accommodation is required from the standpoint of the social model.

In other words, “reasonable accommodation” is “a measure to restore the rights that a disabled person, due to the existence of a social barrier, would have deserved to enjoy.

2. Definition

According to a report by the Ministry of Education, Culture, Sports, Science and Technology (MEXT), reasonable accommodation at universities is defined as follows.

The “necessary and appropriate changes and adjustments to be made by universities and other institutions to ensure that persons with disabilities enjoy and exercise their ‘right to education’ on an equal basis with other persons, and which are individually required of students with disabilities when they receive education at universities and other institutions by their circumstances” and which “do not impose an unbalanced or excessive burden on universities and other institutions in terms of systems and finances.”

Report of the Study Group on Support for Students with Disabilities in Higher Education, MEXT, 2012

To make this more specific, reasonable accommodation consists of the following elements.

• Purpose: To guarantee the “right to education”. All education or educational services available to other students will be guaranteed.
• Measure (1): Make necessary and appropriate changes and adjustments. Changes and adjustments are made to how classes are provided for the above purposes. For specific details, please refer to the typical support menu and the collection of examples
• Limitations：
  • Individualized requirements for education. The necessary measures will be considered on a case-by-case basis, regardless of the existence of precedents. On the other hand, it guarantees the rights enjoyed and exercised by other students and nothing more.
  • Not out of balance. Changes and adjustments are kept within certain limits. The criteria are that the change should not detract from the purpose or essence of the class and that it should not be to the detriment of other students.
  • Not excessive strain. Financial, systemic, and human impact will be taken into consideration. Not all changes and adjustments that are necessary to respond to the disability can be made.
• Measure (2): Constructive dialogue. In order to implement the necessary measures, the applicant and the parties concerned discuss issues and aim to reach an agreement. This is called constructive dialogue. Even when the necessary adjustments or changes are not feasible, the next best thing will be devised through constructive dialogue.

3. Points

Suppose, for example, that a person is blind and requests that materials be rewritten in Braille. This is reasonable. However, the burden of converting the material to Braille may also be taken into consideration, and measures such as providing a service that reads the material aloud or preparing a formatted PDF file so that the material can be read aloud on a PC or other device may be taken. Also, verbally reporting answers to questions or having someone write them for that person can be a reasonable accommodation. However, asking to make a question easier for the person because of the hardship is not a reasonable accommodation. This is because the purpose of reasonable accommodation is to guarantee the right to education, not to compensate for the result of earning credits.

The criterion for considering whether or not a case falls under the right to education is “whether or not the student has access to or can use the classes, content, materials, and information that other students are obtaining (this is called accessibility).”

Accommodation Menus

The specific support menu includes the following. Note that not all of these are listed here, nor are those listed here available on an optional basis.

[ mobility assistance ]

• assisted in moving around
• For private car use, a parking space close to the classrooms is secured.

[ support for learning process ]

• Assigning an assistant unless the essential requirements of the experiment are not changed
• Send a note-taker because of difficulties with note-taking.
• Permission of photographs of the board, provision of copies of lecture notes.
• Dispatch for acquiring materials in the library and organizing and copying the collected materials.
• For assistance with daily living activities related to academic activities, travel expenses for attendants should be paid to the extent possible for the necessary trips.
• Due to difficulties of hearing, utilize PowerPoint transcripts, provide captioning, or use assistive devices such as Face Talk or UD Talk.
• According to hearing problems, evaluation of foreign language listening should be done in an exempted or alternative manner.
• Conveying important matters such as submission of assignments or schedule changes related to lectures, etc., by text information that can be referenced later, such as use of the TACT or e-mail.
• Uploads of slides, materials, etc., regarding the content of the lecture whenever possible to the TACT.
• Allowing to bring in PCs and tablets to view textbooks, materials, etc. in electronic format.
• Permission to use alternative means (e.g., projecting a typed text instead of speaking, using chat in a videoconferencing system, etc.) when oral statements are necessary.
• One-on-one individual presentations to the faculty member, use of pre-recorded video
• For difficulties in understanding the implicit rules, group discussions, etc., should be clearly defined with rules such as having a moderator, raising hands before speaking in turn, etc.
• Instructions about tasks and work associated with the class should be specific to the extent that they do not detract from the essence of the tasks and works (e.g. unless they end up teaching the answers, etc.). Rules and standards should similarly be specific about what should be done (and what should not be done), or the criteria for evaluation should be clearly stated.
• For difficulties in concentrating, doing something else (e.g., reading an unrelated book during a lecture or exercise) is allowed.
• Permission of an extension of the deadline for submitting reports and other assignments unless it does not change the essential requirements, informing as early as possible about the assignment.
• Clearly state what is required by when or provide a model or template ( of plan, schedule, content, etc.).

[ Conversion of lecture materials ]

• Adding subtitles and supplementary audio to video materials in the course.
• Conversion of textbooks, handouts, and other teaching materials to electronic data when necessary.
• For difficulties of viewing computer screens, printed copies of handouts should be provided.

[ Examination accommodation ]

• Accommodations for tardiness to the exam (e.g., allowing them to take the exam, not penalizing points, extending time, etc.) unless the essential requirements of education and evaluation are changed.
• Extension of the examination time for difficulties in writing.
• For problems with sweaty hands, permission to use handkerchiefs or towels during the exam.
• Reservation of a seat near the doorway of the classroom, a toilet, or a seat easy to sit on.
• Taking rest in an available classroom, entry, and exit of classrooms accordingly.
• Use of a separate room for the exam.
• According to difficulties, altering methods of evaluation, such as a report, unless the essential requirements of education and evaluation are changed.

[ Accommodation in classrooms ]

• Setting a laboratory table that fits the height of the wheelchair for the experiment.
• Consideration of tardiness to a class (e.g., not penalizing points, alternative evaluation for quizzes, uploading lecture materials to the TACT, etc.) unless the essential requirements of education and evaluation are changed.
• Reservation of the front seat, seat near the speaker, etc.
• For difficulties in performing multiple tasks, considerations for absences associated with job hunting, and delays in communication of such absences.
• Reservation of a seat near the doorway of the classroom, a toilet, or a seat easy to sit on.
• Taking rest in an available classroom, entry, and exit of classrooms accordingly.
• Permission of the use of noise-canceling earphones (headphones) in classes and exams.
• Participation in class online unless the essential requirements of education and evaluation are changed.

Request for reasonable accommodation

1. Flow of procedure

The request for reasonable accommodation has a prescribed procedure. It proceeds in the following order.

2. Key points of the procedure

The key point here is that examination of the request for reasonable accommodation is initiated after the request is made. This is important as a protection of rights from another perspective, which is not to treat the student differently from other students without their consent. Conversely, it also means that parents, family members, faculty, staff, or friends cannot make a request (although consultation is possible).

However, in order to request an accommodation, the student must understand what reasonable accommodation is and what they need. They may not know how to fill out the form. Or they may have doubts or hesitations about the request itself. Therefore, we encourage them to take advantage of our preliminary consultation.

It is also possible to submit a request without a preliminary consultation. In that case, we will set up a meeting to reaffirm what we would ask in the preliminary consultation.

3. Expected duration for the procedure

It takes approximately one month for the above process. If they wish to use reasonable accommodation from the beginning of each semester, they should come consult with us in advance one month prior to the start of the semester. The specific deadline for submitting the request form will be announced in August or February via Notice (however, this deadline is for the provision of reasonable accommodation in time for the start of the semester, and the request can be submitted even after this deadline has passed).

4. Validity period

Reasonable accommodation is valid until graduation (undergraduate) or completion (graduate). During this period, there is no need to resubmit a request. However, if there is a change in the requested accommodations due to an advance in grade or a change in circumstances, please make a request for an addition or modification.

Also, it is necessary to submit the request again when graduating from an undergraduate course and entering a graduate course (because the educational system is different).

Request form and other documents

To request reasonable accommodation, the following prescribed documents must be submitted.

Submit to: The Ability Support Center (mail, email, hand delivery)

When requesting additions or changes, please change the column “ Requested accommodation” in the “Request form for reasonable accommodation” and submit the new form.

Complaint

If there is any disagreement regarding the determination of reasonable accommodation, please contact the Abilities Support Center. We will readjust the situation. If the issue is still not resolved, please contact the following department for an appeal.

Office for the Disability Support