
Equal Access and Non-Discrimination Policy
To report a grievance or complaint, see the ADA/Section 504 Grievance Policy.
Americans with Disabilities Act / Section 504 / Web Content Accessibility Guidelines / Fair Housing Act
Purpose
The purpose of this policy is to affirm Northern Michigan University’s intent and commitment to comply with all federal and state laws concerning persons with disabilities.
Several laws ensure equal access and prohibit discrimination in higher education. The Americans with Disabilities Act (ADA) of 1990 and Section 504 of the Rehabilitation Act of 1973 protect the rights of individuals with disabilities and prohibit discrimination on the basis of disability in any program or activity receiving federal financial assistance. The ADA prohibits discrimination and guarantees protection of equal access to programs and services. Section 504 requires that reasonable accommodations be provided so that students with disabilities have equal access to education. In addition, the Fair Housing Act of 1968 prohibits disability-based discrimination in all forms of housing, including university housing. The Web Content Accessibility Guidelines (WCAG), used by the U.S. Department of Justice, inform ADA compliance for digital content.
Applicability
This policy applies to all students, faculty, staff, and applicants for employment.
Policy Statement
Northern Michigan University (NMU) reaffirms its commitment to prohibiting discrimination against individuals with disabilities, including persons with mental health disabilities, across all aspects of university life. This includes, but is not limited to, access to physical facilities, employment, services and the academic process. Northern Michigan University declares its intention to comply with the Americans with Disabilities Act (ADA), the Rehabilitation Act of 1973, and all other applicable federal and state disability laws and accessibility standards.
The University is committed to providing equal opportunities for applicants, students, and employees with disabilities to participate in or benefit from all university programs, services, and activities. This includes making reasonable accommodations, when appropriate, to support full participation by individuals with disabilities.
Northern Michigan University will not impose eligibility criteria that screen out, or tend to screen out, an individual with a disability or any class of individuals with disabilities from fully and equally enjoying any program, service, or activity unless such criteria can be shown to be essential to the nature of the program, service, or activity being provided.
To support this commitment, the University provides consultation, assistance, and problem resolution through designated oversight units. These oversight units develop and communicate processes to implement and uphold this policy.
Northern Michigan University will make reasonable modifications to its policies, practices and procedures when the modifications are necessary to avoid discrimination on the basis of a disability, unless making the modifications would fundamentally alter the nature of the service, program or activity. When a person requests a reasonable modification, the University will conduct an individualized, case-by-case assessment to determine what accommodations can be made to enable the person to participate in university programs, services, and activities. The assessment will also consider accommodations that allow the person to continue to participate in and benefit from these programs, services, and activities while receiving treatment for a mental health condition. NMU's Reasonable Accommodation Policy
Northern Michigan University has adopted an internal grievance policy and procedure to provide prompt and equitable resolution of complaints alleging any action prohibited by this policy. Any person who believes they have been subjected to discrimination on the basis of disability may file a grievance. ADA/Section 504 Grievance Policy
Retaliation against anyone who files a grievance or participates in the investigation of a grievance is strictly prohibited. NMU's Retaliation Policy
Northern Michigan University encourages the reporting of all incidents of harassment, discrimination, retaliation, and sexual misconduct. Clear guidance on how to report complaints is available through University policies. Questions may always be directed to the Title IX Coordinator. For concerns involving high-level administrators or members of the Board of Trustees, complaints may be reported to the Title IX Coordinator (who reports to the University President), the University’s General Counsel (who reports to the Board of Trustees), or directly to the Chair or Vice Chair of the Board of Trustees. All will fulfill their fiduciary duty to ensure a thorough investigation and appropriate action based on the facts, investigation findings, and circumstances.
Equal Access and Non-Discrimination, Procedure
In order to provide the necessary resources to comply with the full intent and scope of equal access and nondiscrimination laws, as well as support Northern Michigan University’s core values of opportunity, inclusion, and wellbeing, the University has assigned oversight units to administer the requirements of the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, the Fair Housing Act of 1968, and the Web Content Accessibility Guidelines. Specifically, these oversight units are assigned to support the goals listed below:
Oversight Unit: NMU Facilities
Includes the physical plant, infrastructure, buildings, grounds, and equipment.
- New construction and alterations will comply with the current standards for accessible design.
- Existing facilities will support services, programs, and activities with a goal to be readily accessible to persons with disabilities. When barriers cannot be readily adapted, NMU will work to make other accommodations to grant access to students with disabilities.
- Service animals supporting community members, meaning the University community who are not students, faculty, or staff, will be afforded the same access allowed to their handlers, unless the presence of a service animal would create a safety hazard or a fundamental alteration of the program or service.
To ask a question, or report a concern about facility accessibility, contact the Safety Department at safety@nmu.edu.
Accommodation requests for employees are accepted by NMU Human Resources.
Accommodation requests for students are accepted by NMU Disability Services.
For grievances, see the NMU ADA/Section 504 Grievance Policy at nmu.edu/policies/1090
Oversight Unit: NMU Disability Services
- Academic accommodation, including auxiliary aids and adjusted services, will be provided in a timely manner to enable participation by students with disabilities.
- Student housing accommodation, including physical housing accommodation, service and support animal accommodations and other reasonable accommodations, will be processed through NMU Disability Services. Accommodations granted will be coordinated with and implemented by NMU Housing. See NMU’s Reasonable Accommodation Policy at nmu.edu/policies/1262.
Accommodation requests for students are accepted by NMU Disability Services.
For grievances, see the NMU ADA/Section 504 Grievance Policy at nmu.edu/policies/1090
Oversight Unit: NMU Human Resources
- Auxiliary aids and services will be provided in a timely manner to enable participation by job applicants, faculty, and staff with disabilities. See NMU’s Reasonable Accommodation Policy at nmu.edu/policies/1262.
- Service animals will be afforded the same access allowed to their faculty or staff handlers unless the presence of a service animal would create a safety hazard or a fundamental alteration of the program or service.
Accommodation requests for employees are accepted by NMU Human Resources
For grievances, see the NMU ADA/Section 504 Grievance Policy at nmu.edu/policies/1090
- Student housing accommodation, including physical housing accommodation, service and support animal accommodations and other reasonable accommodations, will be processed through NMU Disability Services. Accommodations granted will be coordinated with and implemented by NMU Housing. See NMU’s Reasonable Accommodation Policy at nmu.edu/policies/1262.
- Service animals will be afforded the same access to housing allowed to student, faculty, staff, or community, handlers.
- Fair Housing Act (FHA) provisions for service and assistance animals will be appropriately adopted.
Accommodation requests for student housing are accepted by NMU Disability Services.
For grievances, see the NMU ADA/Section 504 Grievance Policy at nmu.edu/policies/1090
Oversight Unit: NMU Academic Affairs
- Faculty are afforded academic freedom by contractual agreement and/or a strong tradition of shared governance. Students are afforded equal access to educational opportunities through federal law, state law, national compliance standards, and NMU core values. Faculty will make necessary modifications to the academic requirements of a course of study if these requirements have a discriminatory impact on a student with a disability. Faculty, however, do not have to waive or change the requirements if they are essential to the course or if the changes would fundamentally alter the program. At NMU, the Disability Services office will work with faculty to address student accommodation requests. Requests not resolved in a timely manner will be referred to the relevant Dean, or if necessary, the NMU Provost, where the accommodation request and the course description will inform the resolution.
Accommodation requests for students are accepted by NMU Disability Services.
For grievances, see the NMU ADA/Section 504 Grievance Policy at nmu.edu/policies/1090
Oversight Unit: NMU Executive Council
- NMU will strive toward the goal of providing digital content that is accessible to all users, including those with disabilities. The current target for digital accessibility is WCAG version 2.2, level AA. Using this standard as a guide, The NMU Executive Council will direct NMU resources toward development of:
- Accessible online course and class materials: NMU will work toward presenting all course and class materials posted online in an accessible format.
- Accessible physical course materials: Class handouts or readings will be accessible or readable with assistive technology. Materials distributed in class should be available in accessible electronic or alternate formats at the same time they are given to the class as a whole.
- Accessible videos: Videos posted by the University will have closed captioning sufficient to ensure that people with hearing loss or auditory processing disorders can understand the information.
- Accessible public digital content: Websites and other public communication will be developed and published using the University’s current accessibility standards.
- Accessible internal digital content: Websites and other digital media content that is accessible to an NMU audience will be developed and published using the University’s current accessibility standards.
- Software, including mobile apps, will be internally developed or externally purchased utilizing a review process that evaluates accessibility; software that does not meet the University’s current accessibility standards will be implemented with a mitigation process that affords reasonable accommodation upon request.
- Legacy digital content, meaning digital content purchased or developed prior to implementation of the University’s current accessibility standards, will be migrated to formats adhering to accessibility standards. Legacy course and class materials as well as other digital content will be updated to adhere to accessibility standards as resources permit, but with the allowance that upon request, legacy materials are made accessible and usable to students with disabilities in a timely manner in order to provide equitable education opportunities.
- Archived digital content, meaning content created before the policy compliance date and used only for reference, research, or recordkeeping, will be stored and identified as archival. Archival digital content will be moved to dedicated archival storage in a risk-based process and migrated as resources permit.
To ask a question about, or report a concern about digital accessibility, [we are developing a digital accessibility form that will be posted widely throughout NMU’s web and digital content - it is not quite ready yet.]
Accommodation requests for employees are accepted by NMU Human Resources.
Accommodation requests for students are accepted by NMU Disability Services.
For grievances, see the NMU ADA/Section 504 Grievance Policy at nmu.edu/policies/1090
Oversight Unit: NMU ADA/Section 504 Coordinators
The Section 504 Coordinators receive and address any report of discrimination and/or harassment on the basis of disability. For the full grievance policy and process, see the NMU ADA/Section 504 Grievance Policy at nmu.edu/policies/1090
For students, the ADA/Section 504 Coordinator is:
The Dean of Students
NMU Dean of Students Office
2001 Hedgcock
(906) 227-1700
For faculty, staff, and 3rd party complaints, the ADA/Section 504 Coordinator is:
The Executive Director of Equal Opportunity and Title IX/ Equal Opportunity Officer
NMU Equal Opportunity Office
105 Cohodas Hall
(906) 227-2420
For issues related to physical access to facilities, the ADA/Section 504 Coordinator is:
The NMU Police Chief
NMU Police Department
1401 Presque Isle Avenue
(906) 227-2151
In addition, the University offers consultation, assistance, and problem resolution to the University community through the ADA Coordinators. The ADA Coordinators will provide information regarding other applicable University processes. Some responsibilities of the ADA/Section 504 Coordinators include:
- Develop and implement policies: Create and maintain policies, procedures, and forms that comply with Section 504 and ADA Amendments and the laws of the State of Michigan
- Train faculty and staff: Ensure staff understand their responsibilities under Section 504
- Investigate complaints: Ensure that designates assigned to investigate complaints of disability discrimination and harassment are properly trained and have appropriate resources to execute their duties
- Manage grievances: Ensure that designates assigned to manage grievances related to disability are properly trained and have appropriate resources to execute their duties. Ensure that escalation procedures are in place to address resolution disputes
- Monitor compliance: Ensure that all programs, services, activities, and facilities are accessible to people with disabilities
- Liaison to internal and external reviewers: Reviewers include but are not limited to the Office of Civil Rights and the Michigan Department of Civil Rights. The Coordinator will serve as the liaison between the University and regulatory agencies assessing equal access as for persons with disabilities.
- Advise: Advise administrators, faculty, and other professional personnel.
- Develop professional development: Develop professional development opportunities for faculty and staff.
Date Approved: | 4-20-2011 |
Last Revision: | 5-2-2025 |
Last Reviewed: | 5-2-2025 |
Approved By: | Board of Trustees |
Oversight Unit: | EQUAL OPPORTUNITY |