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App Culture: Set on Mindfulness of Mental Health

Never before have we seen such a surge in apps focused specifically on mental health, mindfulness, and stress reduction.
The popular meditation app Headspace and our Apples App of the Year, Calm, both had major updates this year that expanded their breadth considerably, taking on topics such as mindfulness for children and better sleep. The creators of the new app Lake: Artists’ Coloring Books tackle destressing a bit more actively. It offers an ever-changing selection of drawings, created by burgeoning illustrators and artists, that you can color in—which is perhaps the most accessible meditation of all.
Several apps leverage the latest research on cognitive behavioral therapy to help address larger issues. Although the apps are not a substitute for professional treatment, they do put a host of resources at your fingertips. Pacifica provides a self-help toolkit and access to a support group whenever you need it, while Joyable lets you work with a trained coach via text, email, or phone.

 

Letter from our Executive Director

2017 has been a dynamic year in mental health. For some, it feels like both a lifetime and a single second has passed since the year started back in January.

Thanks to you, some big steps have been made in bringing mental health care in the United States into the 21st Century.

We couldn’t have made progress happen within Higher Education without your generous support.

We maintained coverage for mental health and substance use benefits thanks to the thousands of you who called, emailed, and sent letters to your legislators telling them to make mental health a priority.

Our high student affairs policy standards let peers show their expertise and experience, which opens new career paths and more opportunities to transform lives and services.

This is all thanks to you – with you, we can change the trajectory of thousands of young lives.

We cannot thank you enough for your support. Griffin Ambitions Ltd and Vital Time will not settle for the answers of the past in mental health care and treatment.

With your help, we can take charge of a brighter future—where there is always hope.

To all those preparing for the celebrations, happy holidays from all of us here at Griffin Ambitions!

Be well,

 

Jacob M. Griffin

 

Most Y’all Missed This ’13 Reasons Why’ Detail & It Sheds Insight Into Alex’s Story

If you haven’t finished 13 Reasons Why, exit out of this post right now because I am about to end all debates about the last episode.

Based on the best-selling novel of the same name, 13 Reasons Why is proving to be one of the best and most socially aware young adult series in recent memory. It accurately shows what high school parties are like, using the kind of language high schoolers truly use (yes, F-bombs come out in droves), and not pulling any punches on more sensitive material. From almost everyone who has seen the show (many critics excluded), it is a poignant, incredibly well-done series that hits home pretty hard.

Seeing as it’s been several weeks since the show aired, you’ve probably either finished the series or got most of the way through it, which is what brought you here. It was a compelling show that made you want to get to the end just because of what it was talking about. For the same reasons, you probably had a hard time finishing it. However, if you weren’t paying enough attention while watching, you’ll not have noticed this one moment that changes the show’s entire narrative completely.

'13 Reasons Why' [Credit: Netflix]
’13 Reasons Why’ [Credit: Netflix]

It’s All In The Little Details

Unlike Clay Jensen, I’m not going to drag this out and make you wait 13 hours to know the whole story of what happened to Hannah Baker. During the 13th and final episode of the series, the Baker family finally has their deposition against the school. Several of the students from the tapes are called in and we get to see a few of their recordings as they’re sitting there being interviewed.

If you look to the bottom left corner of the screen, you’ll see the date that the tapes were recorded. Taking into account that the show was released on March 31st, 2017, this date changes everything about the show.

Zach Dempsey's deposition. '13 Reasons Why' [Credit: Netflix]
Zach Dempsey’s deposition. ’13 Reasons Why’ [Credit: Netflix]

November 10th, 2017: None of this has happened yet. OK, well some of it has.

The Story So Far

Hannah went to the park with Justin Foley, sparking that ill-fated picture of her on the slide. Hannah met Jessica Davis and Alex Standall; they started going to Monet’s every day to get hot chocolate and whatever the hell Alex was drinking. The three of them had their falling out due to Alex’s stupid list. Hannah and Courtney Crimson found out that Tyler Down was Hannah’s stalker. Courtney painted Hannah as a lesbian to salvage her own reputation. Hannah went on a pretty crummy date with Marcus Cole, after which Zach tried to make things better, but it ended poorly for both Hannah and him.

The rest of it probably hasn’t happened yet, however. Now, I’m not entirely sure about whether Ryan Shaver’s tape happened, but the rest of it certainly hasn’t.

This means that Bryce Walker hadn’t raped Jessica, Sheri Holland hadn’t knocked over the stop sign that led to Jeff Atkins’s fatal car crash, Clay and Hannah hadn’t hooked up — resulting in Hannah being unable to show her true feelings for him out of past traumas, Bryce hadn’t raped Hannah yet, and Mr. Porter hadn’t told Hannah to just let go of what happened to her and act like it never happened.

Giving life one last chance. '13 Reasons Why' [Credit: Netflix]
Giving life one last chance. ’13 Reasons Why’ [Credit: Netflix]

But the biggest, most important takeaway from knowing this is that Hannah is still here. We still have the chance to help her and prevent this from happening. We can still save Hannah. There is still time.

When it comes to suicide, at any age, those closest to the victim wished they had seen the signs and had the time to stop it. This theme is very evident throughout the series, as every character wishes they had only known what could cause Hannah to want to end her life. As the show points out, it can be obvious that someone is depressed and looking to find a way to put an end to their pain (evident from both Hannah and Alex). However, it is difficult to see it in those closest to you, which is why everyone was so blindsided by what had happened.

The biggest message that the show is trying to push is that we don’t know what’s going on in each other’s lives. We just have to be there for each other and support each other not matter what rumors we hear. There’s too much hate in the world, especially in high school. We need to overcome it and learn to appreciate each other for who we are.

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A worthy share for social media! Don’t forget to tag @GriffAmbitions

We often don’t know if someone is depressed, no matter how evident the signs may be. However, if we can be there for each other, we can prevent something like this from happening again. And, in the case of Hannah Baker, we can prevent it from happening altogether.

With this in mind, it’s interesting to note that Jay Asher’s original ending included Hannah Baker actually surviving her suicide attempt. This original ending was actually included in the 10th anniversary edition of the novel released last December. Which was coincidentally released mere months before the Netflix series aired.

Now I’m not saying that’s suspicious or anything, but maybe, just maybe, it was released around the same time as the Netflix series with the intent to continue the series for a second season – or maybe in another format altogether. Assuming the series does well (as most Netflix series do) and with this small little detail snuck in the finale, the creators could easily turn around and say that Hannah never did kill herself and instead give us a sequel following Hannah and company in a plotline in which she’s still alive.

College Faculty: Are You Being Rigorous or Just Intolerant?

I always took pride in being “a hard teacher.” I was rigorous but fair; my students

…didn’t need to be geniuses to succeed, they just needed to be “good students.” A good student attends class, sits attentively, participates in discussions, and meet deadlines. But after more than a decade of teaching, I realized that my idea of the good student was standing in the way of good teaching.

My awakening began one day in my required composition course, when three students sat in class wearing ear buds. Trying to stifle my annoyance, I grumbled to myself: “How could they think this was appropriate classroom behavior?” A week later, another student got up and walked out of class in the middle of a writing exercise. One of her peers later told me she had deemed the work “unproductive.” Hearing that I felt the familiar heat of anger: “Why come to college if you don’t want to learn?”

  • I’ve learned to push past those initial flashes of frustration, thanks to fresh data on the mental health of college students and to recent research on teaching. One concept in particular that has changed my interactions with students is the “ladder of inference,” presented in Peter Senge’s The Fifth Discipline Fieldbook: Strategies and Tools for Building a Learning Organization. The ladder of inference reveals the steps we take to create our beliefs about the world. The first five rungs of the ladder are:
  • (1) observing a person’s behavior; (2) selecting data from what we observe; (3) interpreting that data through the lens of previous experience; (4) making assumptions; and (5) drawing conclusions about that person.

We tend to run up that ladder so fast that we unconsciously draw conclusions based on scant data. To make matters worse, once we’ve drawn our conclusions, we only entertain data that confirm them. If a student is late, we might assume he doesn’t respect our time, and every time he is late, our judgment is confirmed. But if we gather more data, we might discover that the latecomer has OCD and struggles to get out of the house. Of course, the student could just be inconsiderate or a slacker, but we don’t know unless we seek out more information.

I decided to take the information-seeking route. “So, tell me about the ear buds,” I asked one day, and the story of this 18-year-old’s struggles emerged: He had been in multiple car accidents; he is on pain medication but has trouble sleeping and staying focused; the background noise of the music helps him to concentrate. People with ADHD confirm this: They need something in the background to crystallize their attention on the foreground.

As for the student who walked out midclass, I invited her to my office where I learned that she had left because of a panic attack. After a short conversation, I was satisfied that she had the necessary mental-health support, but when I asked about her other courses, she told me she was at risk of failing due to excessive absences. “Easy solution,” I said. “Communicate with these professors.”

But that was not an easy solution. The last time she had divulged to an instructor that she suffered from anxiety, the instructor’s response was, “Yes, we all have anxiety.” In the student’s words, this teacher “shut me down.”

According to data from the 2013 National College Health Assessment, nearly half of 123,078 respondents from 53 colleges and universities across the country felt overwhelming anxiety over the previous year and a third had problems functioning because of depression.

‘Thou shalt not’ directives do not work, and when we fill our classrooms with them, we are not treating students as adults. Still, we hold up the syllabus on the first day of class

like a crucifix to ward off the ‘students from hell.’

While some students arrive with diagnoses and legal accommodations, many begin experiencing mental-health problems during college; the average age of onset of depression and anxiety is 18 to 24. Whether these conditions are permanent or temporary, they are usually accompanied by learning challenges, such as impaired memory and decreased ability to focus and make connections, inhibited curiosity, diminished creativity, and limited flexibility.

To be clear, I have known students with psychiatric conditions who perform the role of the good student, but for others, conforming to that script can be impossible at times.

Despite our students’ struggles, many of us to continue to teach the way we were taught. We continue to lecture and produce syllabi that have the threatening tone of the Ten Commandments: Thou shalt not eat in class, thou shalt not be late, thou shalt not use cellphones. These rigid documents reflect good intentions. We want our students to learn how to behave professionally so that they succeed in the “real world.”

But there are a few problems with that approach: It doesn’t work. Banning cellphones, for example, doesn’t stop students from using them. And in the real world, successful people sit in meetings texting and eating food, or are routinely late. When we fill our classrooms with “don’t” directives, we are not treating students as adults.

Still, we hold up the syllabus on the first day of class like a crucifix to ward off the “students from hell.” In his classic The Courage to Teach: Exploring the Inner Landscape of a Teacher’s Life, Parker Palmer draws the veil from the “student from hell” to reveal a student “full of fear.” According to Palmer, teachers are also driven by fear: “We collaborate with the structures of separation because they promise to protect us against one of the deepest fears at the heart of being human — the fear of having a live encounter with alien ‘otherness,’ whether the other is a student, a colleague, a subject, or a self-dissenting voice within.”

That resonates with me. As a writing instructor I rarely lecture, but I do have a tendency to choreograph every step of class, leaving little space for “live encounters.” If, as Palmer suggests, we are protecting ourselves, it makes sense that our syllabi are stringent. It also makes sense that we are more likely to rely on stereotypes of students rather than seek more data about them — because when we gather more information, what we find can be unsettling. They are not whom we envisioned. Rather thanknowledge-thirsty, carefree adolescents, our students are complex people with complicated lives.

It is tempting to say, “We should leave mental health to the experts.” I have said that myself. But now I recognize that asking students to leave their mental-health issues at the door is not only unreasonable, it’s unjust. It’s akin to asking students to leave their race or gender at the door. Of course, we should direct students to the experts when they are in crisis, but there’s much we can do without positioning ourselves as therapists or saviors.

The work of promoting mental health shouldn’t always be outsourced to the counseling center; it must be part of the fabric of our institutions, including our classrooms. Too often when faculty discuss students with mental-health conditions, the conversation ends in the same place: Either we establish rigorous standards or we coddle students. But that is a false binary.

 

The student who left in the middle of my class told me she felt comfortable talking about her personal struggles with me because in my class we had read an article about mental health. She is smart and hardworking, but she was at risk of failing due to excessive absences. During our 15-minute conference, I gave her my computer to email her other professors and spell out the problem. She needed a nudge to trust that this was her best shot at succeeding at college.

  • Admittedly this is harder to do in a large-sized class. But even in such classes, we can acknowledge mental health by being open to “live encounters,” by ditching rules that don’t enhance learning, by responding to students with flexibility and caring, and by being informed about how mental illness affects learning and behavior.

    Outside of the classroom, even something as simple as organizing a panel where faculty and staff members discuss how they manage their psychiatric conditions can be helpful. Such an event had a profound effect on one of my students who had been diagnosed with depression in high school. Hearing the stories of these successful professors and staffers in her first semester, she said, made her think, “I can do this. I’m going to make it.”

    Reconsidering my notion of “the good student” has improved my pedagogy and my well-being. I spend more time getting to know my students and less time being frustrated. My courses are rigorous, and I have created a space for young adults with complicated lives. In this space, a diversity of perspectives and experiences allows us to learn together and from one another.

    Author, Catherine Savini is an associate professor of English.

College Counseling Center: The preeminent nationwide campus crisis

The Rise of Mental Health

The amount of young adults seeking higher education has been growing, and with it the amount of young adults who are ill prepared for higher education (Mowbray et al.,2006). Along with all this growth, colleges and Universities are finding higher and higher rates of mental illness on campus (Mowbray et al.,2006). A variety of studies has shown the rate of mental illness for college students to be somewhere around 12-18% compared to 10 years ago when it was closer to 5% (Mowbray et al.,2006).

It should be noted that while this rate is high it does not even touch the total amount of increase College Counseling Centers are seeing, in that this percentage only reflects the amount of students with a diagnosable mental health issue (Mowbray et al.,2006). In line with this, 68% of College Counseling Centers in a national survey reported that they are seeing a sharp increase in the need for counseling based services (Kitzrow, 2009); Columbia University reported a 40% increase, MIT a 50% increase, and University of Cincinnati reported a 55% increase during a survey of counseling center directors (Kitzrow, 2009).

In addition, more students are seeking psychological services, and the type of needs students report are diverse and growing more complex in nature (Kitzrow, 2009). For example in 1994 only 9% of clients seeking mental health services on college campuses reported psychiatric medication usage where as this rate is now closer to the 20% range (Kitzrow, 2009). But students that have medication issues or whose needs are more complex aren’t all College Counseling Centers must deal with, they also must cope with the fact that around 28% of freshman polled in a natural survey report feeling overwhelmed; with subsets of the students polled developing clinical levels of distress that continued through college (HERI, 2000). This statistic demonstrates that in some respects the growing need of students seeking to utilize college counseling centers are represented by two tiers; tier 1: students needing assistance in “lower-level” needs of anxiety, distress, family of origin issues, and tier 2: students with clinical disorders or high suicide idealization needing intense and often prolonged treatment.

Mental Health: Why Care?

An important question needs to be asked about the mental health services that are offered on college campuses: why should colleges or universities invest? Providing mental health services costs MIT over $838,000 per year, the cost of mental health is not cheap (Healy, 2002).

While the services are not cheap, the benefits that they bring to colleges are not small either. Brackney and Karabenick (1995) found that academic performance finds a significant correlation to high levels of psychological distress. This means that in providing mental health services to students, the likelihood that those students will do better overall at school are significantly strengthened, which brings about a higher chance of that student completing their program. It has been estimated that 4.29 million people in the United States are in a state in which they have been unable to graduate from college due to psychiatric disorders, so the amount of students and therefore the amount of money they could bring to institutions is by no means small (Kitzrow, 2009).

In addition, a six year longitudinal study found that emotional adjustment is one of the most important factors in retention of students, so the amount of impact mental health services provides to colleges is profound (Gerdes & Mallinckrodt, 1994). That impact is operationalized in a study of students that used University of Idaho’s Student Counseling Center, which found that not only did 77% students report that counseling allowed them to stay in school, 90% reported that counseling helped them achieve their overall goals (University of Idaho, 2000). While counseling centers have a great amount of impact on the campuses they service, the coming crisis in terms of higher demand will be something unlike counseling centers were ever designed for or could ever prepare for, as we will see in a review of their history.

Counseling Center History

Counseling has always existed in some way, shape or form within higher education, but was handled by the office of dean of women or the dean of men (Hodges, 2001). Then during the 1930’s and 1940’s, an argument arose in higher education that faculty should be providing counseling, especially the faculty that expressed interesting in the helping profession (Hodges, 2001). Thus some educators fought for faculty to take over the “normal” academic concerns, while other trained professionals handled more of the concerns deemed psychological (Hodges, 2001).

However, there was much confusion over the credentials, duties, and specialization needed in order to be offering psychological services (Hodges, 2001). Then, with the end of World War II, veterans began coming to college in droves, thanks to the financial assistant the Veterans Administration was offering (Hodges, 2001). This movement sparked a change in mindset for higher education because Federal funds were provided to make sure veterans were offered vocational preparations. This eventually set in motion the expanding role of counselors and created Counseling Centers on college campuses (Hodges, 2001).

Then as the civil rights movement started, social barriers to higher education were challenged and older students began to enroll, creating even more diversity on campuses (Aubrey, 1977). This drastic influx of students, combined with additional pressures for college personnel, provided counseling the right to move out of the faculty housing into it’s own profession (Hodges, 2001). This move into it’s own profession also created responsibilities for the counseling profession, in the need to develop standard of practice, ethics, and specialized training (Hodges, 2001).

In all of this, the American Psychological Association or APA grew in prestige, and created it’s own accreditation guidelines, training programs, and credentialing, moving what was a “generalist” movement into a highly specialized field (Hodges, 2001). With this specialization comes competition, between a variety of degrees, something that very much continues to this day (Hodges, 2001).

In a sense, College Counseling Centers have come out of a history that has required a defense, in that it is extremely special in nature and that sense of specialty must be preserved. If not, it could easily fall back into the sense of generalized mindset it worked so hard to come out of. As stated before the argument of faculty handling advising, counseling and other services has been around since the 1940’s and is still very much alive to this day (Mowbray et al.,2006). Even still there are those with the attitude that a university’s role was to teach, not to treat the students it served on campus (Mowbray et al.,2006). So, those who provide counseling on college campuses face a battle of being able to offer counseling to a growing diversity of students while maintaining that they provide a service that can’t just be handled by any faculty member (Mowbray et al.,2006).

The Law

Colleges obtained a majority of funding via the Federal Government in the form of loans that students take out in order to attend intuitions (McPherson, 2010). Due to this the law, in the sense that the government and therefore funding is directly tied to current law, law is critical in the discussion of College Counseling Centers.

First line in this consideration is the possibility that College Counseling Centers can be sued by the students and community they serve. Lawsuits do happen, not just to larger schools but also to smaller ones (Affsprung, 2010). That said: the larger the campus, the greater likelihood that the College Counseling Center can be sued (Affsprung, 2010). In fact, in an analysis of survey results from 1994-2008 of counseling directors found that once enrollment at a University or College reaches around 7,500 they become 3 ½ times more likely to be the target of a lawsuit or some sort of legal challenge (Affsprung, 2010).

It is important to note that during this same analysis of legal action taken against college counseling centers a variety of reasons for lawsuits were found (Affsprung, 2010). These reasons ranged from malpractice in the form of inappropriate medication being prescribed by the psychiatrist to the most common related to student suicide (Affsprung, 2010). Therefore Counseling Centers find themselves most at risk in relation to suicide idealization of students (Affsprung, 2010).

This brings up the important case of Elizabeth Shin versus MIT, in which the student committed suicide and her parents sued for $27 million. On top of the high monetary amount, legal opinion is Shin’s parents could have won but elected for a settlement of ‘undisclosed amount’ (Hodges, 2001). Shin’s parents were able to sue MIT for their daughter’s suicide because it was ruled that the University had a ‘special relationship’ with Elizabeth and because of this had a higher responsibility to her than just a normal bystander (Massie, 2008). This case, among others, should be noted in higher education in that prior to cases of this nature, Universities had no “duty to rescue.” However, a revision of Torts section 314A revised the student and University or College relationship to be included under “special relations” (Massie, 2008).

This is important within the discussion of the rising mental health issues on college campuses, in that these changes in law will impact the likelihood of Universities winning future cases to the ever growing requirement that colleges take “reasonable steps” to prevent students from harm (Massie, 2008).

In light of this lawsuit, MIT increased its mental health significantly, in order to have an outreach campaign to students seeking counseling as well as to build policy that would provide better counseling systems to students (Kitzrow, 2009). This is critical in that around 41% of counseling directors report that they do have formal follow-up procedure to assist students, which could easily give way to “high-risk” students being lost in the college counseling system (Kitzrow, 2009). However, when it comes to the legal issues, additional outreach is only part of the way to defend against lawsuits.

The Way Forward

As stated before, “reasonable steps” are a key point when considering the outcomes to lawsuits in College Counseling Centers. While outreach is a key component of “reasonable steps,” MIT, in the steps taken after Shin’s suicide, found that the importance of additional staff could not be left out (Hodges, 2001). These findings have been generalized, in the increasing literature looking at students who have entered or are currently in college, their demands as well as their parent’s demands of timely mental health service (Brunner et al., 2014). In fact, in review of the coming generation, Howe and Strauss (2007) provide the advice that counseling centers must “staff up” if they will keep even close to the pace of demands for services.

This insight is directly opposite of where most counseling centers stand today, in that most counseling center director’s report that they have waiting lists for counseling services (Brunner et al., 2014). In fact, estimates are even as high as to state that one third of college centers are unable to meet the demands for counseling service (Brunner et al., 2014).

The importance of additional staff is critical, but where is this staff to come from? Central Michigan University decided to address this issue with the design and implementation of Counselor-in-Residence program (Orchowski et al., 2011). The Director of Residence Life and the director of the counseling center came together to promote increased collaboration between the two departments (Orchowski et al., 2011). Counselors-in-Residence or “CR’s” worked in conjunction with the Residence Advisors, or “RA’s”, in that RA’s would refer students to the CR’s at provided student-friendly counseling times of 5 pm to 10 pm, which is after the normal counseling center business hours (Orchowski et al., 2011). The program at Central Michigan University was staffed with licensed Master-level Professionals Counselors and Social Workers (Orchowski et al., 2011). The University reported that such extension of the college counseling center provided a cost-effective solution to the increased demands for college counseling on their campus (Orchowski et al., 2011).

While a wonderful example of what departments can do when they work together, programs of said nature also carry certain risks with them. Blacklock (2003) caution against multiple locations for students to seek counseling, in that this may force students to drift from office to office until they locate the correct entry point. In addition, it is important to consider how the CRs must be balanced between dorms, in that certain dorms could command more robust attention than others.

That being said, the Counselor-In-Resident program was wonderful in that it brought an additional option to the professionals that currently serve students on college campuses: that of master’s level counselors (Orchowski et al., 2011). A survey of counseling center directors report that around 94% of counseling center staff either have their doctorate in counseling or clinical psychology (Kitzrow, 2009). While the amount of masters-level clinicians working within counseling centers is small, the importance of said clinicians is growing (Kitzrow, 2009). In talking in-depth with counseling directors, one study, which sought to focus on the challenges college counseling centers face, reported that graduate interns and peer counselors are extremely important in allowing their centers to serve additional students (Kitzrow, 2009).

So why aren’t masters-level clinicians being better utilized to serve students on college campuses? The answer is rather complex and once again comes with an important historical context of how masters-level practitioners are viewed. As stated before, the competition for professional opportunities within college counseling centers is competitive and the APA holds a lot of support (Jackson & Scheel, 2013). The APA’s attitude for more than 60 years has been the predominant stance that master’s-level counselors should practice under supervision of doctoral level psychologists (Jackson & Scheel, 2013).

In fact, in 1947 the APA even recommended the discontinuation of masters degrees for “lower level” psychology work, only shifting their stance in 1955 as master’s level curriculum was promoted to support the need for psychological services following World War II (Jackson & Scheel, 2013). While the APA’s history has been one that has sought to fight the independent licensing of masters-level counselors, it finds itself arguing a moot point on this issue, as all 50 states currently allow for master-level counselor to practice via state license (Jackson & Scheel, 2013). Yet the stance of higher education seems stuck within APA’s viewpoint of the 1940’s and 50’s. Masters-level counselors are allowed to practice in all 50 states, are used in social services programs, and allowed to be placed on medical insurance boards (Jackson & Scheel, 2013). It seems the state, social services, and even the general medical community has accepted the use of master’s level counselors, so why not higher education? Even the APA has changed it’s stance in some regards, as a 2006-2010 study by a board created within the organization came to the stance of not opposing independent practice by master’s-level counselors or promotion of supervisors of said counselors by doctoral-level psychologists (Jackson & Scheel, 2013).

In addition to the APA’s changes in regards to masters-level counselors, another important factor in their inclusion is the requirements promoted by the International Association of Counseling Services or IACS, which is important for counseling centers at a university or four year level in order to maintain their accreditation (Danger et al.). IACS standard indicates that professionals with a master’s degree from counseling disciplines can provide psychological services to students and even allow for trainees, provided that they are supervised by qualified staff (Danger et al.).

With all of these changes, it seems higher education has been left behind in its mindset of hiring mainly doctoral-level counselors, as seen by the statistic of 94% of centers having doctoral-based staff (Kitzrow, 2009). Perhaps the perspective is that because doctoral-level staff are allowed to prescribe medication, they are in a sense a better deal for the University than masters-level clinicians who currently don’t have that ability (Kitzrow, 2009). However, as stated before, the coming crisis in mental health isn’t just about the increased diversity in students’ mental health needs, but also about the increased demand (Mowbray et al.,2006). Simply having Universities or Colleges focus on the greatest diversity of services clinicians are able to provide will not stop lawsuits that focus on the American with Disabilities act or the ever increasing need to provide “reasonable steps” in preventing student suicide (Massie, 2008).

So the future of mental health must accommodate two-levels of service: in-depth need, as such is the case with medication, and quality need, as will be the case with the increase in anxiety and depression based disorders (HERI, 2000).

While other members on college campuses can provide some support, the important need of confidentiality and division of mental health services from academic based services must be noted (Mowbray et al., 2006). Students must feel that they are able to present their mental health needs without fear of these needs creating some sort of division on campus (Mowbray et al., 2006). An important part of meeting this need of confidentiality must come from those who are licensed to enforce it, both from a client-centered perspective and from the legal perspective (Mowbray et al., 2006).

The increased usage of masters-level clinicians is a natural solution to this issue of confidentiality and meeting of needs, as they are currently utilized within a variety of other sectors within society. In following with the model of Central Michigan University, these masters-level clinicians could be used in order to fill the extensive need of students, assigning “lower risk” students to them. This would follow the model that most mental health providers use in their coordination, in that students would receive an intake and off of said intake they would be set up with doctoral-level or masters-level clinicians (Schulberg et al., 2002). Masters-level clinicians would receive the students that do not currently need medication support or adjustment, and whose needs are more in line with general anxiety or depression based disorders. Once again, this follows the model of most mental health services and has been shown to be effective in managing cost and providing quality services (Schulberg et al., 2002).

As the masters-level clinicians or practicum students are working with termed “lower-risk” students, doctoral-level clinicians would be assigned “higher-risk” students. These students would be needing more extensive mental health issues or could be needing assistance with management of medication. The use of said system, along with the coordination of support groups and the use of peer counselors, could provide the quality and quantity needed to meet mental health services on campus. This model has been found to work in social services, as well as hospital and private services, showing to be both cost-effective and able to handle the diverse needs associated with providing mental health to a community (Schulberg et al., 2002).

Conclusion

The upcoming crisis on college campuses in terms of mental health has been growing for years and currently does not show signs of slowing down (Brunner et al., 2014). Instead of reverting to the faculty centered model of the 1940’s or simply continuing as planned could easily result in disaster or even worse: more lawsuits. Other solutions must be explored. Yet the cost must be handled in such a way that the already rising cost of tuition does not take another huge climb, as mental health services are expensive to any institution (Kitzrow, 2009).

The recommendation of more inclusion of masters-level clinicians must be explored, as current society has already adjusted to allow for their inclusion (Schulberg et al., 2002). There is already extensive research on how higher education interacts with general society, and how the two are correlated (Komives & Woodard, 2003). This correlation must not be dismissed when it comes to mental health, as higher education has fallen behind in this regard, and must consider a diverse range of opportunities that above all else does not focus on the spaded history of the past. Instead, the focus needs to be on the coming college student’s mental health needs and how to best meet those needs.

References

Affsprung, E. H. (2010). Legal Action Taken Against College and University Counseling Centers 1986-2008. Journal Of College Student Psychotherapy, 24(2), 130-138. doi:10.1080/87568220903558711

Asidao, C., & Sevig, T. (2014). Reaching In to Reach Out: One Counseling Center’s Journey in Developing a New Outreach Approach. Journal Of College Student Psychotherapy, 28(2), 132-143. doi:10.1080/87568225.2014.883881

Aubrey, R. F. (1997). Historical development of guidance and counseling and implications for the future. The Personnel and Guidance Journal, 55, 288-295.

Blacklock, B., Benson, B., Johnson, D., & Bloomberg, L. (2003). Needs assessment project: Exploring barriers and opportunities for college students with psychiatric disabilities. Minneapolis: University of Min- nesota, Disability Services.

Brackney, B., & Karabenick, S. (1995). Psychopathology and aca- demic performance: The role of motivation and learning strategies. Journal of Counseling Psychology, 42(4), 456–465.

Brunner, J. L., Wallace, D. L., Reymann, L. S., Sellers, J., & McCabe, A. G. (2014). College Counseling Today: Contemporary Students and How Counseling Centers Meet Their Needs. Journal Of College Student Psychotherapy, 28(4), 257-324. doi:10.1080/87568225.2014.948770

Danger, I. C. I., Records, I. F. C., Director, I. V. A., Trainees, I. V. D., Workload, V. D., Compensation-Salary, V. E., … & Insurance, L. Standards for University and College Counseling Services.

Gerdes, H., & Mallinckrodt, B. (1994). Emotional, social, and aca- demic adjustment of college students: A longitudinal study of reten- tion. Journal of Counseling and Development, 72, 281–288.

Healy, P. (2002, April 25). MIT to improve mental health ser- vices. The Boston Globe.

Higher Education Research Institute, University of California, Los Angeles (HERI, UCLA). (2000). The American freshman: National norms for fall 2000. Los Angeles: HERI, UCLA.

Hodges, S. (2001). University Counseling Centers at the Twenty-First Century: Looking Forward, Looking Back. Journal Of College Counseling, 4(2), 161.

Howe, N., Strauss, W., & LifeCourse Associates. (2007). Millennials go to college: Strategies for a new generation on campus: Recruiting and admissions, campus life, and the classroom (2nd ed.). Great Falls, VA: LifeCourse Associates.

International Association of Counseling Services: Standards for University and College Counseling Services. (2011). Journal of College Student Psychotherapy, 25(2), 163-183.

Jackson, M. A., & Scheel, M. J. (2013). Quality of Master’s Education: A Concern for Counseling Psychology?. Counseling Psychologist, 41(5), 669-699.

Kitzrow, M. A. (2009). The Mental Health Needs of Today’s College Students: Challenges and Recommendations. NASPA Journal (National Association Of Student Personnel Administrators, Inc.), 46(4), 646.

Komives, S. R., & Woodard Jr, D. B. (2003). Student services: A handbook for the profession. John Wiley & Sons.

Massie, A. M. (2008). Suicide on campus: the appropriate legal responsibility of college personnel. Marquette Law Review, (3),

McPherson, M. S. (2010). Keeping college affordable: Government and educational opportunity. Brookings Institution Press.

Mowbray, C. T., Megivern, D., Mandiberg, J. M., Strauss, S., Stein, C. H., Collins, K., & … Lett, R. (2006). Campus mental health services: recommendations for change. The American Journal Of Orthopsychiatry, 76(2), 226-237.

Orchowski, L. M., Castelino, P., Ng, H. M., Cosio, D., & Heaton, J. A. (2011). The Design and Implementation of a Counselor-in-Residence Program. Journal Of College Student Psychotherapy, 25(3), 241-258.

Schulberg, H. C., Raue, P. J., & Rollman, B. L. (2002). The effectiveness of psychotherapy in treating depressive disorders in primary care practice: clinical and cost perspectives. General Hospital Psychiatry, 24(4), 203-212.

University of Idaho Student Counseling Center. (2000). [Client satisfaction survey]. Unpublished raw data.

Eligible Colleges and Universities of Intervention in America

 

 

 Listing of Membership-eligible institutions for the Student Mental Health Policy Alliance
– A –
Abilene Christian University
Abraham Baldwin Agricultural College 
Academy of Art University 
Adams State College 
Adelphi University 
Adrian College 
Agnes Scott College 
Air Force Institute of Technology 
Air University 
Alabama A&M University
Alabama State University 
Alaska Bible College 
Alaska Pacific University 
Albany State University 
Albertson College of Idaho 
Albertus Magnus College 
Albion College 
Albright College 
Alcorn State University 
Alderson-Broaddus College 
Alexandria University 
Alfred State College, State University of New York College of Technology 
Alfred University 
Allegheny College 
Allen College 
Allen University 
Allentown College 
Alliant International University 
Alma College 
Alvernia College 
Alverno College 
Amberton University 
American Bible College and Seminary 
American Coastline University 
The American College 
American Global University 
American Graduate School of International Management 
American Institute for Computer Sciences 
American InterContinental University 
American International College 
American Military University 
American Public University 
American Schools of Professional Psychology 
American University 
American University of Hawaii 
Amherst College 
Anderson College 
Anderson University 
Andrew Jackson University 
Andrews University 
Angelo State University 
Anna Maria College 
Antioch College 
Antioch New England Graduate School 
Antioch University Los Angeles 
Antioch University Santa Barbara 
Antioch University Seattle 
Antioch University Yellow Springs OH 
Apache University 
Appalachian School of Law 
Appalachian State University 
Aquinas College 
Arcadia University 
Arizona International College 
Arizona State University 
Arizona State University West 
Arkansas State University 
Arkansas Tech University 
Arlington Baptist College 
Armstrong State University 
Art Center College of Design 
The Art Institute of Phoenix 
The Art Institute of Southern California 
The Art Institute of Washington 
Asbury College 
Ashland University 
Assumption College 
Athena University 
Athens State College 
Atlantic Union College 
Auburn University 
Auburn University, Montgomery 
Audrey Cohen College 
Augsburg College 
Augusta State University 
Augustana College, Rock Island Illinois 
Augustana College, Sioux Falls South Dakota 
Aurora University 
Austin College 
Austin Peay State University 
Averett College 
Avila College 
Azusa Pacific University
– B –
Babson College 
Baker College 
Baker University 
Baldwin-Wallace College 
Ball State University 
Baltimore Hebrew University 
Bank Street College of Education 
Baptist Bible College and Seminary 
The Baptist College of Florida 
Bard College 
Barclay College 
Barnard College 
Barrington University 
Barry University 
Barton College 
Bastyr University 
Bates College 
Bay Path College 
Baylor College of Dentistry 
Baylor College of Medicine 
Baylor University 
Belhaven College 
Bellarmine College 
Bellevue University 
Belmont Abbey College 
Belmont University 
Beloit College 
Bemidji State Univeristy 
Benedict College 
Benedictine College 
Benedictine University 
Bennett College 
Bennington College 
Bentley College 
Berea College 
Berkeley College 
Berklee College of Music 
Berry College 
Bethany Bible College 
Bethany College, West Virginia 
Bethany College, Lindsborg, KS 
Bethany College, Scotts Valley, CA 
Bethany Lutheran College 
Bethel College and Seminary, Saint Paul Minnesota 
Bethel College, McKenzie, Tennessee 
Bethel College, Mishawaka, Indiana 
Bethel College, Newton, Kansas 
Bethune-Cookman College 
Bienville University 
Biola University 
Birmingham-Southern College 
Black Hills State University 
Blackburn College 
Bloomfield College 
Bloomsburg University 
Bluefield College 
Bluefield State College 
Bluffton College 
Bob Jones University 
Boise State University 
The Boston Architectural Center 
Boston College 
Boston Conservatory 
Boston University 
Bowdoin College 
Bowie State University 
Bowling Green State University 
Bradford College 
Bradley University 
Brandeis University 
Brenau University 
Brewton-Parker College 
Briar Cliff University 
Bridgewater College 
Bridgewater State College 
Brigham Young University 
Brigham Young University Hawaii 
Brigham Young University Idaho 
Brooklyn College 
Brooklyn Law School 
Brown University 
Bryant College 
Bryn Mawr College 
Bucknell University 
Buena Vista University 
Buffalo State 
Butler University
– C –
C. R. Drew University of Medicine and Science 
Caldwell College 
California Baptist University 
California Coast University 
California College of Arts and Crafts 
California College for Health Sciences 
California College of Podiatric Medicine 
California Institute of the Arts 
California Institute for Human Science 
California Institute of Integral Studies 
California Institute of Technology 
California Lutheran University 
The California Maritime Academy 
California National University for Advanced Studies 
California Pacific University 
California Polytechnic State University, San Luis Obispo 
California State Polytechnic University, Pomona 
California State University, Bakersfield 
California State University, Channel Islands 
California State University, Chico 
California State University, Dominguez Hills 
California State University, Fresno 
California State University, Fullerton 
California State University, Hayward 
California State University, Long Beach 
California State University, Los Angeles 
California State University, Monterey 
California State University, Northridge 
California State University, Sacramento 
California State University, San Bernardino 
California State University, San Marcos 
California State University, Stanislaus 
California University of Pennsylvania 
Calumet College of St. Joseph 
Calvin College 
Cambridge College 
Cameron University 
Campbell University 
Campbellsville University 
Canisius College 
Canyon College 
Capella University 
Capital University 
Cardinal Stritch University 
Carleton College 
Carlow College 
Carnegie Institution of Washington 
Carnegie Mellon University 
Carroll College, Helena, MT 
Carroll College, Waukesha, WI 
Carson-Newman College 
Carthage College 
Case Western Reserve University 
Castleton State College 
Catawba College 
The Catholic University of America 
Cazenovia College 
Cedar Crest College 
Cedarville University 
Centenary College of Louisiana 
Centenary College of New Jersey 
Center for Creative Studies College of Art and Design 
Central College 
Central Connecticut State University 
Central Methodist College 
Central Michigan University 
Central Missouri State University 
Central State University 
Central Washington University 
Centre College, Danville Kentucky 
Century University 
Chadron State College 
Chadwick University 
Chaminade University of Honolulu, Hawaii 
Champlain College 
Chapman University 
Charles R. Drew University of Medicine and Science 
Charleston Southern University 
Charter Oak State College 
Chatham College 
Cheyney University of Pennsylvania 
Chicago-Kent College of Law 
Chicago School of Professional Psychology 
Chicago State University 
Chowan College 
Christendom College 
Christian Bible College and Seminary 
Christian Brothers University 
Christopher Newport University 
Circleville Bible College 
The Citadel 
City Colleges of Chicago 
City University, Bellevue Washington 
City University of Los Angeles 
City University of New York 
Claflin College 
Claremont Graduate University 
Claremont McKenna College 
Clarion University 
Clark Atlanta University 
Clark College 
Clark University 
Clarke College 
Clarkson University 
Clayton College and State University 
Clayton College of Natural Health 
Clemson University 
Clear Creek Baptist Bible College 
Cleary College 
Cleveland Chiropractic College 
Cleveland Institute of Art 
Cleveland Institute of Music 
Cleveland State University 
Clinch Valley College 
Coastal Carolina University 
Coe College 
Cogswell Polytechnical College 
Coker College 
Colby College 
Colby-Sawyer College 
Colgate University 
Coleman College 
College of Aeronautics 
College of the Atlantic 
College of Charleston 
College of Eastern Utah 
College of the Holy Cross 
The College of Insurance 
College for Lifelong Learning 
The College of Metaphysical Studies 
College Misericordia 
College of Mount Saint Joseph 
The College of New Jersey 
College of New Rochelle 
College of Notre Dame of Maryland 
College of the Ozarks 
College of Saint Benedict 
College of Saint Catherine 
College of Saint Elizabeth 
College of Saint Mary 
College of Saint Scholastica 
The College of Saint Thomas More 
The College of Saint Rose 
The College of Santa Fe 
College of the Southwest 
College of William and Mary 
The College of Wooster 
Colorado Christian University 
Colorado College 
Colorado School of Mines 
Colorado State University 
Colorado Technical University 
Columbia College 
Columbia College of Missouri 
Columbia International University 
Columbia Southern University 
Columbia Union College 
Columbia University 
Columbus State University 
Concord College 
Concordia College, Ann Arbor Michigan 
Concordia College, Austin Texas 
Concordia College, Bronxville, New York 
Concordia College, Moorhead Minnesota 
Concordia College, Saint Paul Minnesota 
Concordia College, Selma Alabama 
Concordia College, Seward Nebraska 
Concordia University, Irvine California 
Concordia University, Mequon Wisconsin 
Concordia University, Portland Oregon 
Concordia University, River Forest Illinois 
Connecticut College 
Converse College 
Cooper Union for the Advancement of Science and Art 
Coppin State College 
Cornell College, Iowa 
Corcoran College of Art + Design 
Cornell University 
Cornerstone University 
Cornish College of the Arts 
Cottey College 
Covenant College 
Creighton University 
Crichton College 
Crown College 
Culver-Stockton College 
Cumberland College 
Cumberland University 
Curry College 
Cypress College
– D –
Daemen College 
Dakota State University 
Dakota Wesleyan University 
Dallas Baptist University 
Dallas Theological Seminary 
Dana College 
Daniel Webster College 
Dartmouth College 
Davenport College 
Davidson College 
Davis and Elkins College 
Dawson College 
Dean College 
Deep Springs College 
Defiance College 
Delaware State University 
Delaware Valley College 
Delta College 
Delta State University 
Denison University 
Denver Seminary 
DePaul University 
DePauw University 
DeSales University 
DeVry University 
DeVry University, Columbus 
Diablo Valley College 
Dickinson College 
Dickinson State University 
Dillard University 
Dixie State College 
Doane College 
Dominican College 
Dominican University 
Dominican University of California 
Dordt College 
Dowling College 
Drake University 
Drew University 
Drexel University 
Drury University 
Duke University 
Duquesne University 
D’Youville College
– E –
Earlham College 
East Carolina University 
East Central University, Ada Oklahoma 
East Stroudsburg State University 
East Tennessee State University 
East Texas Baptist University 
East-West University 
Eastern College 
Eastern Connecticut State University 
Eastern Illinois University 
Eastern Kentucky University 
Eastern Mennonite University 
Eastern Michigan University 
Eastern Nazarene College 
Eastern New Mexico University 
Eastern Oregon University 
Eastern Washington University 
Eckerd College 
Edgewood College 
Edinboro University of Pennsylvania 
Edward Waters College 
Elizabeth City State University 
Elizabethtown College 
Elmhurst College 
Elmira College 
Elms College 
Elon University 
Embry-Riddle Aeronautical University 
Emerson College 
Emmanuel College 
Emmaus Bible College 
Emory University 
Emory & Henry College 
Empire State College 
Emporia State University 
Endicott College 
Erskine College 
Eureka College 
Evangel University 
Everglades College 
Evergreen State College 
Excelsior College
– F –
Fairfield University 
Fairleigh Dickinson University 
Fairmont State College 
Faith Baptist Bible College and Theological Seminary 
Faulkner University 
Fayetteville State University 
Felician College 
Ferris State University 
Ferrum College 
Fielding Graduate Institute 
Finch University of Health Sciences/The Chicago Medical School 
Fisk University 
Fitchburg State College 
Flagler College 
Florida A & M University 
Florida Atlantic University 
Florida Christian College 
Florida Gulf Coast University 
Florida Institute of Technology 
Florida International University 
Florida Memorial College 
Florida Metropolitan University 
Florida Southern College 
Florida State University 
Fontbonne College 
Fordham University 
Forest Institute of Professional Psychology 
Fort Hays State University 
Fort Lewis College 
Fort Valley State University 
Framingham State College 
Francis Marion University 
Franciscan University of Steubenville 
Franklin and Marshall College 
Franklin College 
Franklin Pierce College 
Franklin Pierce Law Center 
Franklin University 
Freed-Hardeman University 
Freewill Baptist Bible College 
Fresno Pacific University 
Friends University 
Frostburg State University 
Fuller Theological Seminary 
Fullerton College 
Furman University
– G –
Gallaudet University 
Gannon University 
Gardner-Webb University 
Geneva College 
George Fox University 
George Mason University 
George Washington University 
Georgetown College 
Georgetown University 
Georgian Court College 
Georgia College and State University 
Georgia Institute of Technology 
Georgia Perimeter College 
Georgia Southern University 
Georgia Southwestern State University 
Georgia State University 
Georgian Court College 
Gettysburg College 
Glenville State College 
Globe Institute of Technology 
Goddard College 
Golden Gate University 
Golden State Baptist College 
Goldey-Beacom College 
Gonzaga University 
Gooding Institute of Nurse Anesthesia 
Gordon College 
Gordon-Conwell Theological Seminary 
Goshen College 
Goucher College 
Governors State University 
Grace College 
Grace University 
Graceland University 
The Graduate Center, City University of New York 
Grambling State University 
Grand Canyon University 
Grand Valley State University 
Grand View College 
Grantham University 
Green Mountain College 
Greenleaf University 
Greensboro College 
Greenville College 
Greenwich University 
Grinnell College 
Grove City College 
Guilford College 
Gustavus Adolphus College, Saint Peter, Minnesota 
Gwynedd-Mercy College
– H –
Hamilton College 
Hamilton University 
Hamline University 
Hampden-Sydney College 
Hampshire College 
Hampton University 
Hannibal-LaGrange College 
Hanover College 
Hardin-Simmons University 
Harding University 
Harris-Stowe State College 
Hartwick College 
Harvard University 
Harvey Mudd College 
Hastings College 
Haverford College 
Hawaii Pacific University 
Hebrew College 
Heidelberg College 
Henderson State Univerisity 
Hendrix College 
Henry Cogswell College 
Heritage College 
Hesser College 
Hesston College 
High Point University 
Hilbert College 
Hillsdale College 
Hillsdale Freewill Baptist College 
Hiram College 
Hobart and William Smith Colleges 
Hofstra University 
Hollins University 
Holy Cross College, Notre Dame Indiana 
Holy Family College 
Hood College 
Hope College 
Houghton College 
Houston Baptist University 
Howard Payne University 
Howard University 
Humboldt State University 
Hunter College 
Huntingdon College 
Huntington College 
Huron University 
Husson College 
Huston-Tillotson College
– I –
Idaho State University 
Illinois College 
Illinois Institute of Technology 
Illinois State University 
Illinois Wesleyan University 
Immaculata College 
Indiana Institute Technologyy 
Indiana State University 
Indiana Wesleyan University 
Indiana University 
Indiana University Northwest 
Indiana University of Pennsylvania 
Indiana University at South Bend 
Indiana University Southeast 
Indiana University – Purdue University, Columbus 
Indiana University – Purdue University, Fort Wayne 
Indiana University – Purdue University, Indianapolis 
Institute for Christian Works 
Institute of Computer Technology 
Institute of Paper Science and Technology 
Institute for Transpersonal Psychology 
Inter American University of Puerto Rico 
International College 
International Fine Arts College 
International Institue of the Americas 
International Reform University 
Iona College 
Iowa State University 
Iowa Wesleyan College 
Ithaca College
– J –
Jackson State University 
Jacksonville State University 
Jacksonville University 
James Madison University 
Jamestown College 
Jarvis Christian College 
Jewish Theological Seminary 
John Brown University 
John Carroll University 
John F. Kennedy University 
John Jay College of Criminal Justice 
The Johns Hopkins University 
Johnson Bible College 
Johnson and Wales University 
Johnson C. Smith University 
Joint Military Intelligence College 
Jones College 
Jones International University 
Judson College, Marion AL 
Judson College, Elgin IL 
The Julliard School 
Juniata College
– K –
Kalamazoo College 
Kansas City Art Institute 
Kansas Newman College 
Kansas State University 
Kansas Wesleyan University 
Kean University 
Keck Graduate Institute 
Keene State College 
Keiser College 
Kennedy-Western University 
Kennesaw State University 
Kent State University 
Kentucky Christian College 
Kentucky State University 
Kentucky Wesleyan College 
Kenyon College 
Kettering University 
Keuka College 
King College 
King’s College, Wilkes-Barre, PA 
The King’s College, New York City, NY 
Knox College 
Knox Theological Seminary 
Kutztown University of Pennsylvania
– L –
La Roche College 
La Salle University 
La Sierra University 
Lafayette College 
LaGrange College 
Lake Erie College 
Lake Forest College 
Lake Superior State University 
Lakeland College 
Lamar University 
Lambuth University 
Lancaster Bible College 
Lancaster Theological Seminary 
Lander University 
Landmark College 
Langston University 
Lane College 
Lasell College 
Lawrence Technological University 
Lawrence University 
Le Moyne College 
Lebanon Valley College 
Lee College 
Lee University 
Lees-McRae College 
Lehigh Univervsity 
LeMoyne-Owen College 
Lenoir-Rhyne College 
Lenox Institute of Water Technology 
Lesley University 
LeTourneau University 
Lewis & Clark College 
Lewis-Clark State College 
Lewis University 
Liberty University 
Life University 
Limestone College 
Lincoln Christian College and Seminary 
Lincoln College 
Lincoln Memorial University 
Lincoln University, Jefferson City Missouri 
Lincoln University, San Francisco California 
Lincoln University of Pennsylvania 
Lindenwood College 
Lindsey Wilson College 
Linfield College 
Lipscomb University 
Lock Haven University 
Logan College of Chiropractic 
Loma Linda University 
Long Island University 
Longwood College 
Loras College 
Louisburg College 
Louisiana Baptist Universty 
Louisiana College 
Louisiana State University at Baton Rouge 
Louisiana State University Health Sciences Center New Orleans 
Louisiana State University at Shreveport 
Louisiana Tech University 
Loyola College, Baltimore 
Loyola Marymount University 
Loyola University, Chicago 
Loyola University, New Orleans 
Lubbock Christian University 
Luther College 
Luther Seminary 
Lutheran Bible Institute 
Lutheran Theological Seminary at Gettysburg 
Lycoming College 
Lyme Academy of Fine Arts 
Lynchburg College 
Lyndon State College 
Lynn University 
Lyon College
– M –
Macalester College 
MacMurray College 
Madonna University 
Maharishi University of Management 
Maine College of Art 
Maine Maritime Academy 
Malone College 
Manchester College 
Manhattan College 
Manhattanville College 
Mansfield University 
Maranatha Baptist Bible College 
Marian College 
Marietta College 
Marlboro College 
Marist College 
Marquette University 
Mars Hill College 
Marshall University 
Mary Baldwin College 
Mary Washington College 
Maryland Institute, College of Art 
Marylhurst University 
Marymount College 
Marymount Manhattan College 
Marymount University 
Maryville College 
Maryville University of Saint Louis 
Marywood University 
Massachusetts College of Art 
Massachusetts College of Liberal Arts 
Massachusetts College of Pharmacy and Allied Health Sciences 
Massachusetts Institute of Technology 
Massachusetts Maritime Academy 
Massachusetts School of Professional Psychology 
The Master’s College 
The Mayo Foundation 
Mayville State University 
The McGregor School of Antioch University 
McKendree College 
McMurry University 
McNeese State University 
MCP Hahnemann University 
McPherson College 
Medaille College 
Medical College of Georgia 
Medical College of Ohio 
Medical College of Pennsylvania and Hahnemann University 
Medical College of Wisconsin 
Medical University of South Carolina 
Meharry Medical College 
Menlo College 
Mercer University 
Mercy College 
Mercy College of Health Sciences 
Mercyhurst College 
Meredith College 
Merrimack College 
Mesa State College 
Messiah College 
Methodist College 
Methodist Theological School in Ohio 
Metropolitan College 
Metropolitan State College of Denver 
Metropolitan State University 
Miami Christian University 
Miami University of Ohio 
Michigan State University 
Michigan Technological University 
Mid-America Nazarene University 
Middle Georgia College 
Middle Tennessee State University 
Middlebury College 
Midwestern Baptist College 
Midwestern State University 
Miles College 
Millersville University 
Milligan College 
Millikin University 
Mills College 
Millsaps College 
Milwaukee School of Engineering 
Minneapolis College of Art and Design 
Minnesota State University Mankato 
Minnesota State University Moorhead 
Minot State University 
Minot State University–Bottineau 
Mississippi College 
Mississippi State University 
Mississippi University for Women 
Mississippi Valley State University 
Missouri Baptist College 
Missouri Southern State College 
Missouri Tech 
Missouri Valley College 
Missouri Western State College 
Mitchell College 
Molloy College 
Monmouth College, Monmouth Illinois 
Monmouth University, West Long Branch New Jersey 
Monroe College 
Montana State University-Billings 
Montana State University-Bozeman 
Montana State University College of Technology, Great Falls 
Montana State University-Northern Havre 
Montana Tech 
Montclair State University 
Monterey College of Law 
Monterey Institute of International Studies 
Montreat College 
Moravian College 
Morehead State University 
Morehouse College 
Morehouse School of Medicine 
Morgan State University 
Morningside College 
Morris Brown College 
Morris College 
Mount Aloysius College 
Mount Holyoke College 
Mount Ida College 
Mount Marty College 
Mount Mary College 
Mount Mercy College 
Mount Olive College 
Mount St. Clare College 
Mount St. Mary’s College and Seminary, Emmitsburg Maryland 
Mount St. Mary’s College, Los Angeles California 
Mount Senario College 
Mt. Sierra College 
Mount Union College 
Mount Vernon Nazarene College 
Mountain State University 
Muhlenberg College 
Murray State University 
Muskingum College
– N –
Naropa University 
National American University 
National Defense University 
The National Graduate School 
National-Louis University 
National Technological University 
National University 
The Naval Postgraduate School 
Nazarene Bible College 
Nazareth College 
Nebraska Methodist College 
Nebraska Wesleyan University 
Neumann College 
New Brunswick Theological Seminary 
New College of Florida 
New England College of Optometry 
New England Conservatory of Music 
New England Institute of Technology 
New England School of Communications 
New Jersey City University 
New Jersey Institute of Technology 
New Mexico Highlands University 
New Mexico Institute of Mining and Technology 
New Mexico State University 
New School University 
New World School of the Arts 
New York Academy of Art 
New York Institute of Technology 
New York Law School 
New York University 
Newberry College 
Newport University 
Niagara University 
Nicholls State University 
Nichols College 
Norfolk State University 
North Carolina Agricultural and Technical State University 
North Carolina Central University 
North Carolina School of the Arts 
North Carolina State University 
North Carolina Wesleyan College 
North Central College 
North Central University 
North Dakota State University–Fargo 
North Georgia College and State University, the Military College of Georgia 
North Greenville College 
North Park University 
Northeastern Illinois University 
Northeastern University 
Northeastern State University 
Northern Arizona University 
Northern Illinois University 
Northern Kentucky University 
Northern Michigan University 
Northern State University 
Northland College 
Northwest Christian College 
Northwest College 
Northwest College of Art 
Northwest Missouri State University 
Northwest Nazarene University 
Northwestern Oklahoma State University 
Northwestern State University, Louisiana 
Northwestern College, Iowa 
Northwestern College, Saint Paul, MN 
Northwestern Michigan College 
Northwestern University 
Northwood University 
Norwich University 
Notre Dame College of Ohio 
Notre Dame de Namur University 
Nova Southeastern University 
Nyack College
– O –
Oakland University 
Oakwood College 
Oberlin College 
Occidental College 
Oglethorpe University 
Ohio Dominican College 
Ohio Northern University 
The Ohio State University 
Ohio University 
Ohio Valley College 
Ohio Wesleyan University 
Oklahoma Baptist University 
Oklahoma Christian University 
Oklahoma City University 
Oklahoma Panhandle State University 
Oklahoma State University 
Oklahoma State University Tulsa 
Oklahoma Wesleyan University 
Old Dominion University 
Olin College of Engineering 
Olivet College 
Olivet Nazarene University 
The Open University 
Oral Roberts University 
Oregon Graduate Institute of Science and Technology 
Oregon Health Sciences University 
Oregon Institute of Technology 
Oregon State University 
Otterbein College 
Ottawa University 
Ouachita Baptist University 
Our Lady of the Lake University 
Our Lady of Holy Cross College
– P –
Pace University 
Pacific College of Oriental Medicine 
Pacific Lutheran University 
Pacific Northwest College of Art 
Pacific States University 
Pacific Union College 
Pacific University 
Paine College 
Palm Beach Atlantic College 
Palmer College of Chiropractic 
Park University 
Parsons School of Design 
Patten College 
Patrick Henry College 
Paul Quinn College 
Paul Smith’s College 
Peace College 
Pennsylvania College of Technology 
The Pennsylvania State University 
Pennsylvania State University at Altoona 
Pennsylvania State University, Great Valley 
Pennsylvania State University at Harrisburg 
Pennsylvania State University, Worthington Scranton 
Pensacola Christian College 
Pepperdine University 
Peru State College 
Pfeiffer University 
Pickering University 
Piedmont College 
Pine Manor College 
Pittsburg State University 
Philadelphia Biblical University 
Philadelphia University 
Philander Smith College 
Phillips University 
Pitzer College 
Plymouth State University, Plymouth New Hampshire 
Point Loma Nazarene College 
Point Park College 
Polytechnic University of New York 
Polytechnic University of Puerto Rico 
Pomona College 
Portland State University 
Potomac College 
Prairie View A & M University 
Pratt Institute 
Presbyterian College 
Prescott College 
Preston University 
Princeton University 
Principia College 
Providence College 
Purdue University
– Q –
Queens College 
Quincy University 
Quinnipiac College
– R –
Radford University 
Ramapo College of New Jersey 
Randolph-Macon College 
Randolph-Macon Woman’s College 
Reed College 
Regent University 
Regis College 
Regis University 
Reinhardt College 
Rensselaer Polytechnic Institute 
Rhode Island College 
Rhode Island School of Design 
Rhodes College 
Rice University 
The Richard Stockton College of New Jersey 
Rider University 
Ringling School of Art and Design 
Ripon College 
Rivier College 
Roanoke College 
Robert Morris College, Illinois 
Robert Morris College, Pittsburgh, PA 
Roberts Wesleyan College 
Rochester Institute of Technology 
Rochester College 
The Rockefeller University 
Rockford College 
Rockhurst University 
Rocky Mountain College 
Roger Williams University 
Rogers State University 
Rollins College 
Roosevelt University 
Rose-Hulman Institute of Technology 
Rosemont College 
Rowan University 
Rush University 
Russell Sage College 
Rust College 
Rutgers University 
Rutgers University-Camden 
Rutgers University-Newark 
Ryokan College
– S –
Sacred Heart University 
Sacred Heart University, Puerto Rico 
The Sage Colleges 
Saginaw Valley State University 
Saint Ambrose University 
Saint Andrews Presbyterian College 
Saint Anselm College 
Saint Anthony College of Nursing 
Saint Augustine’s College 
Saint Bonaventure University 
Saint Cloud State University 
Saint Edwards University 
Saint Francis College, Brooklyn Heights, New York 
Saint Francis College, Fort Wayne, Indiana 
Saint Francis College, Loretto, Pennsylvania 
St. Gregory’s University 
Saint John Fisher College 
Saint John’s College 
Saint John’s University, Collegeville Minnesota 
Saint John’s University, Jamaica New York 
Saint Joseph College 
Saint Joseph’s College 
Saint Joseph’s College of Maine 
Saint Joseph’s University 
Saint Lawrence University 
Saint Leo University 
Saint Louis University 
Saint Martin’s College 
Saint Mary College 
Saint Mary-of-the-Woods College 
Saint Mary’s College 
Saint Mary’s College of California 
Saint Mary’s College of Maryland 
Saint Mary’s University of Minnesota 
Saint Mary’s University of San Antonio 
Saint Meinrad’s School of Theology 
Saint Michael’s College 
Saint Norbert College 
Saint Olaf College 
Saint Paul’s College 
Saint Peter’s College 
Saint Rose College 
Saint Thomas Aquinas College 
Saint Thomas University 
Saint Vincent College 
Saint Xavier University 
Salem College 
Salem International University 
Salem State College 
Salisbury State University 
The Salk Institute for Biological Studies 
Salve Regina University 
Sam Houston State University 
Samford University 
Samuel Merritt College 
San Diego State University 
San Francisco Art Institute 
San Francisco Law School 
San Francisco State University 
San Joaquin College of Law 
San Jose Christian College 
San Jose State University 
Santa Clara University 
Sarah Lawrence College 
Saratoga University School of Law 
Sarah Lawrence College 
Savannah College of Art and Design 
Savannah State University 
Saybrook Graduate School and Research Center 
Schiller International University 
School for International Training 
School of the Art Institute of Chicago 
School of Islamic and Social Sciences 
School of the Museum of Fine Arts, Boston 
School of the Visual Arts 
Schreiner College 
Scripps College 
The Scripps Research Institute 
Seattle Pacific University 
Seattle University 
Seton Hall University 
Seton Hill College 
Shasta Bible College 
Shawnee State University 
Shaw University 
Sheffield School of Interior Design 
Sheldon Jackson College 
Shenandoah University 
Shepherd College 
Sherman College of Straight Chiropractic 
Shimer College 
Shippensburg University of Pennsylvania 
Shorter College 
Siena College 
Siena Heights University 
Silver Lake College 
Simmons College 
Simon’s Rock College 
Simpson College, Redding California 
Simpson College, Indianola Iowa 
Skidmore College 
Slippery Rock University 
Smith Chapel Bible College 
Smith College 
Soka University of America 
Sonoma State University 
South Carolina State University 
South Dakota School of Mines and Technology 
South Dakota State University 
South Pacific University 
South Texas College of Law 
Southampton College 
Southeast College of Technology 
Southeast Missouri State University 
Southeastern College 
Southeastern Louisiana University 
Southeastern Oklahoma State University 
Southeastern University 
Southern Adventist University 
Southern Arkansas University 
Southern California University of Health Sciences 
Southern California University of Professional Studies 
Southern Connecticut State University 
Southern Illinois University at Carbondale 
Southern Illinois University at Edwardsville 
Southern Illinois University Medical School at Springsfield 
Southern Methodist University 
Southern Nazarene University 
Southern New Hampshire University 
Southern Oregon State College 
Southern Polytechnic State Univerisity 
Southern Vermont College 
Southern Virginia University 
Southern Wesleyan University 
Southern University, Baton Rouge 
Southern University, New Orleans 
Southern University, Shreveport-Bossier City 
Southern Utah University 
Southwest Baptist University 
Southwest Bible College and Seminary 
Southwest Missouri State University 
Southwest State University 
Southwest Texas State University 
Southwestern Adventist University 
Southwestern Assemblies of God University 
Southwestern College 
Southwestern Oklahoma State University 
Southwestern University 
Southwestern University School of Law 
Spalding University 
Spartanburg Methodist College 
Spelman College 
Spertus College 
Spring Arbor College 
Spring Hill College 
Springfield College 
Stamford International College 
Stanford University 
State University of New York at Albany 
State University of New York at Binghamton 
State University of New York at Buffalo 
State University of New York at Oswego 
State University of New York at Stony Brook 
State University of New York College of Agriculture and Technology, Cobleskill 
State University of New York College of Agriculture and Technology, Morrisville 
State University of New York College at Brockport 
State University of New York College at Buffalo (Buffalo State College) 
State University of New York College at Cortland 
State University of New York College of Environmental Science and Forestry 
State University of New York College at Farmingdale 
State University of New York College at Fredonia 
State University of New York College at Geneseo 
State University of New York College Maritime College at Fort Schuyler 
State University of New York College at New Paltz 
State University of New York College at Old Westbury 
State University of New York College at Oneonta 
State University of New York College at Oswego 
State University of New York College at Plattsburgh 
State University of New York College at Potsdam 
State University of New York College at Purchase 
State University of New York Institute of Technology at Canton 
State University of New York Institute of Technology at Delhi 
State University of New York Institute of Technology at Utica/Rome 
State University of West Georgia 
The Stefan University 
Stephen F. Austin State University 
Stephens College 
Sterling College, Sterling Kansas 
Sterling College, Kansas 
Sterling College, Vermont 
Stetson University 
Stevens-Henager College 
Stevens Institute of Technology 
Stillman College 
Stonehill College 
Strayer University 
Suffolk University 
Sul Ross State University 
Summit University of Louisiana 
Susquehanna University 
Swarthmore College 
Sweet Briar College 
Syracuse University
– T –
Tabor College 
Talladega College 
Tarleton State University 
Taylor University 
Teachers College 
Teikyo Marycrest University 
Teikyo Post University 
Temple University 
Tennessee State University 
Tennessee Technological University 
Tennessee Temple University 
Tennessee Wesleyan College 
Texas A&M International University 
Texas A&M University 
Texas A&M University, Commerce 
Texas A&M University, Corpus Christi 
Texas A&M University, Galveston 
Texas A&M University, Kingsville 
Texas A&M University, Texarkana 
Texas Christian University 
Texas Lutheran University 
Texas Southern University 
Texas Tech University 
Texas Wesleyan University 
Texas Woman’s University 
Thiel College 
Thomas Aquinas College, Santa Paula CA 
Thomas Edison State College 
Thomas College 
Thomas Cooley Law School 
Thomas More College 
Thomas Jefferson University 
Toccoa Falls College 
Tougaloo College 
Touro College 
Towson University 
The Transworld University 
Transylvania University 
Trevecca Nazarene University 
Trinity Baptist College 
Trinity Christian College 
Trinity College, Hartford Connecticut 
Trinity College of Florida 
Trinity College, Washington DC 
Trinity College of Vermont 
Trinity International University 
Trinity University 
Tri-State University 
Troy State University 
Troy State University – Dothan 
Truman State University 
Tufts University 
Tulane University 
Tusculum College 
Tuskegee University
– U –
Uniformed Services Universty of the Health Sciences 
Union College, Barbourville KY 
Union College 
Union Theological Seminary 
Union University 
The Union Institute 
United States Air Force Academy 
United States Coast Guard Academy 
United States Merchant Marine Academy 
United States Military Academy 
United States Naval Academy 
United States Open University 
United States Sports Academy 
Unity College 
University of Action Learning at Boulder 
University of Advancing Technology 
University of Akron 
University of Alabama 
University of Alabama, Birmingham 
University of Alabama, Huntsville 
University of Alaska, Anchorage 
University of Alaska, Fairbanks 
University of Alaska, Southeast 
University of Arizona 
University of Arkansas, Fayetteville 
University of Arkansas at Little Rock 
University of Arkansas at Monticello 
University of Arkansas at Pine Bluff 
University of the Arts 
University of Baltimore 
University of Bridgeport 
University of California, Berkeley 
University of California, Davis 
University of California, Hastings College of Law 
University of California, Irvine 
University of California, Los Angeles 
University of California, Merced 
University of California, Riverside 
University of California, San Diego 
University of California, San Francisco 
University of California, Santa Barbara 
University of California, Santa Cruz 
University of Central Arkansas 
University of Central Florida 
University of Central Oklahoma 
University of Charleston 
University of Chicago 
University of Cincinnati 
University of Colorado 
University of Colorado, Colorado Springs 
University of Colorado, Denver 
University of Connecticut 
University of Dallas 
University of Dayton 
University of Delaware 
University of Denver 
University of Detroit Mercy 
University of the District of Columbia 
University of Dubuque 
University of Evansville 
University of Findlay 
University of Florida 
University of Georgia 
University of Great Falls 
University of Guam 
University of Hartford 
University of Hawai`i 
University of Hawai`i, Hilo 
University of Hawai`i, West O`ahu 
University of Health Sciences College of Osteopathic Medicine 
University of Houston 
University of Houston, Clear Lake 
University of Houston, Downtown 
University of Houston, Victoria 
University of Idaho 
University of the Incarnate Word 
University of Indianapolis 
University of Illinois at Chicago 
University of Illinois at Springfield 
University of Illinois at Urbana-Champaign 
University of Iowa 
University of Judaism 
University of Kansas 
University of Kansas Medical Center 
University of Kentucky 
University of La Vernee 
University of Louisiana at Lafayette 
University of Louisiana at Monroe 
University of Louisville 
University of Maine 
University of Maine at Fort Kent 
University of Maine at Presque Isle 
University of Mary Hardin-Baylor 
University of Maryland Baltimore County 
University of Maryland at Baltimore 
University of Maryland at College Park 
University of Maryland Eastern Shore 
University of Maryland University College 
University of Massachusetts at Amherst 
University of Massachusetts at Boston 
University of Massachusetts at Dartmouth 
University of Massachusetts at Lowell 
University of Massachusetts Medical School 
University of Medicine and Dentistry of New Jersey 
University of Memphis 
University of Miami 
University of Michigan-Ann Arbor 
University of Michigan-Dearborn 
University of Michigan-Flint 
University of Minnesota-Crookston 
University of Minnesota-Duluth 
University of Minnesota-Morris 
University of Minnesota-Twin Cities 
University of Mississippi 
University of Missouri-Columbia 
University of Missouri-Kansas City 
University of Missouri-Rolla 
University of Missouri-Saint Louis 
University of Montana, Missoula 
University of Montevallo 
University of Natural Medicine 
University of Nebraska, Kearney 
University of Nebraska, Lincoln 
University of Nebraska, Omaha 
University of Nevada, Las Vegas 
University of Nevada, Reno 
University of New England 
University of New Hampshire, Durham 
University of New Haven 
University of New Mexico 
University of New Orleans 
University of Newport 
University of North Alabama 
University of North Carolina at Asheville 
University of North Carolina at Chapel Hill 
University of North Carolina at Charlotte 
University of North Carolina at Greensboro 
University of North Carolina at Pembroke 
University of North Carolina at Wilmington 
University of North Dakota 
University of North Dakota–Lake Region 
University of North Florida 
University of North Texas 
University of Northern Colorado 
University of Northern Iowa 
University of Northern Washington 
University of Notre Dame 
University of Oklahoma 
University of Oregon 
University of Orlando 
University of Osteopathic Medicine and Health Science 
University of the Ozarks 
University of the Pacific 
University of Pennsylvania 
University of Phoenix 
University of Pittsburgh 
University of Pittsburgh at Bradford 
University of Pittsburgh at Greenburg 
University of Pittsburgh at Johnstown 
University of Portland 
University of Puerto Rico, Mayaguez 
University of Puerto Rico, Rio Piedras 
University of Puget Sound 
University of Redlands 
University of Rhode Island 
University of Richmond 
University of Rio Grande 
University of Rochester 
University of St. Francis 
University of St. Thomas, Houston 
University of St. Thomas, Saint Paul 
University of San Diego 
University of San Francisco 
University of Sarasota 
University of Science and Arts of Oklahoma 
University of the Sciences in Philadelphia 
University of Scranton 
University of Sioux Falls 
University of the South 
University of South Alabama 
University of South Carolina 
University of South Carolina, Aiken 
University of South Carolina, Beaufort 
University of South Carolina, Spartanburg 
University of South Dakota 
University of South Florida 
University of Southern California 
University of Southern Colorado 
University of Southern Indiana 
University of Southern Maine 
University of Southern Mississippi 
University of Tampa 
University of Tennessee, Chattanooga 
University of Tennessee Health Science Center 
University of Tennessee, Knoxville 
University of Tennessee, Martin 
University of Texas at Arlington 
University of Texas at Austin 
University of Texas at Brownsville 
University of Texas at Dallas 
University of Texas at El Paso 
University of Texas Health Science Center at Houston 
University of Texas Health Science Center at San Antonio 
University of Texas Health Center at Tyler 
University of Texas Medical Branch 
University of Texas-Pan American 
University of Texas of the Permian Basin 
University of Texas at San Antonio 
University of Texas at Tyler 
University of Texas Southwestern Medical Center 
University of Toledo 
University of Tulsa 
University of Utah 
University of Vermont 
University of the Virgin Islands 
University of Virginia 
University of Washington 
University of West Alabama 
University of West Florida 
University of Wisconsin-Green Bay 
University of Wisconsin-Eau Claire 
University of Wisconsin-La Crosse 
University of Wisconsin-Madison 
University of Wisconsin-Milwaukee 
University of Wisconsin-Oshkosh 
University of Wisconsin-Parkside 
University of Wisconsin-Platteville 
University of Wisconsin-Stevens Point 
University of Wisconsin-Stout 
University of Wisconsin-Superior 
University of Wisconsin-River Falls 
University of Wisconsin-Whitewater 
University of Wyoming 
Upper Iowa University 
Urbana University 
Ursinus College 
Ursuline College 
Utah State University 
Utah Valley State College 
Utica College
– V –
Valdosta State University 
Valley City State University 
Valparaiso University 
Vanderbilt University 
Vanguard University 
Vassar College 
Vennard College 
Vermont Technical College 
Villa Julie College 
Villanova University 
Virginia Commonwealth University 
Virginia Intermont College 
Virginia International University 
Virginia Military Institute 
Virginia Polytechnic Institute and State University 
Virginia State University 
Virginia Union University 
Virginia University of Lynchburg 
Virginia Wesleyan College 
Viterbo College 
Voorhees College
– W –
Wabash College 
Wagner College 
Wake Forest University 
Warner Pacific College 
Wartburg College 
Walden University 
Walla Walla College 
Walsh University 
Warren Wilson College 
Washburn University 
Washington & Jefferson College 
Washington & Lee University 
Washington Bible College / Capital Bible Seminary 
Washington College 
Washington State University 
Washington University in Saint Louis 
Wayland Baptist University 
Wayne State College 
Wayne State University 
Waynesburg College 
Webb Institute 
Weber State University 
Webster University 
Webster University North Florida 
Wellesley College 
Wells College 
Wentworth Institute of Technology 
Wesley College 
Wesleyan College 
Wesleyan University 
West Coast University 
West Chester University of Pennsylvania 
West Liberty State College 
West Texas A&M University 
West Virginia State College 
West Virginia University 
West Virginia University Parkersburg 
West Virginia Wesleyan College 
Western Baptist College 
Western Carolina University 
Western Connecticut State University 
Western Governors University 
Western Illinois University 
Western International University 
Western Kentucky University 
Western Maryland College 
Western Michigan University 
Western Montana College 
Western New England College 
Western New Mexico University 
Western Oregon University 
Western State College 
Western State University College of Law 
Western States Chiropractic College 
Western University of Health Sciences 
Western Washington University 
Westfield State College 
Westminster College, Fulton Missouri 
Westminster College, New Wilmington Pennsylvania 
Westminster College, Salt Lake City 
Westminster Theological Seminary 
Westminster Theological Seminary in California 
Westmont College 
Westwood College of Technology 
Wheaton College, Wheaton Illinois 
Wheaton College, Massachusetts 
Wheeling Jesuit University 
Wheelock College 
Whitman College 
Whittier College 
Whitworth College 
Wichita State University 
Widener University 
Wilberforce University 
Wilkes University 
Willamette University 
William Howard Taft University 
William Carey International University 
William Jewell College 
William Mitchell College of Law 
William Paterson University 
William Penn College 
William Woods University 
Williams Baptist College 
Williams College 
Wilmington College, New Castle Delaware 
Wilmington College, Wilmington Ohio 
Wilson College 
Wingate University 
Winston-Salem State University 
Winona State University 
Winthrop University 
Wisconsin Lutheran College 
Wittenberg University 
Wofford College 
Woodbury University 
Woods Hole Oceanographic Institution 
Worcester Polytechnic Institute 
Worcester State College 
Wright Institute 
Wright State University
– X –
Xavier University, Cincinnati, OH 
Xavier University of Louisiana
– Y –
Yale University 
Yeshiva University 
York College, York Nebraska 
York College of Pennsylvania 
Youngstown State University
– Z –
Zion Bible Institute
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

– A –
Abilene Christian University
Abraham Baldwin Agricultural College
Academy of Art University
Adams State College
Adelphi University
Adrian College
Agnes Scott College
Air Force Institute of Technology
Air University
Alabama A&M University
Alabama State University
Alaska Bible College
Alaska Pacific University
Albany State University
Albertson College of Idaho
Albertus Magnus College
Albion College
Albright College
Alcorn State University
Alderson-Broaddus College
Alexandria University
Alfred State College, State University of New York College of Technology
Alfred University
Allegheny College
Allen College
Allen University
Allentown College
Alliant International University
Alma College
Alvernia College
Alverno College
Amberton University
American Bible College and Seminary
American Coastline University
The American College
American Global University
American Graduate School of International Management
American Institute for Computer Sciences
American InterContinental University
American International College
American Military University
American Public University
American Schools of Professional Psychology
American University
American University of Hawaii
Amherst College
Anderson College
Anderson University
Andrew Jackson University
Andrews University
Angelo State University
Anna Maria College
Antioch College
Antioch New England Graduate School
Antioch University Los Angeles
Antioch University Santa Barbara
Antioch University Seattle
Antioch University Yellow Springs OH
Apache University
Appalachian School of Law
Appalachian State University
Aquinas College
Arcadia University
Arizona International College
Arizona State University
Arizona State University West
Arkansas State University
Arkansas Tech University
Arlington Baptist College
Armstrong State University
Art Center College of Design
The Art Institute of Phoenix
The Art Institute of Southern California
The Art Institute of Washington
Asbury College
Ashland University
Assumption College
Athena University
Athens State College
Atlantic Union College
Auburn University
Auburn University, Montgomery
Audrey Cohen College
Augsburg College
Augusta State University
Augustana College, Rock Island Illinois
Augustana College, Sioux Falls South Dakota
Aurora University
Austin College
Austin Peay State University
Averett College
Avila College
Azusa Pacific University
– B –
Babson College
Baker College
Baker University
Baldwin-Wallace College
Ball State University
Baltimore Hebrew University
Bank Street College of Education
Baptist Bible College and Seminary
The Baptist College of Florida
Bard College
Barclay College
Barnard College
Barrington University
Barry University
Barton College
Bastyr University
Bates College
Bay Path College
Baylor College of Dentistry
Baylor College of Medicine
Baylor University
Belhaven College
Bellarmine College
Bellevue University
Belmont Abbey College
Belmont University
Beloit College
Bemidji State Univeristy
Benedict College
Benedictine College
Benedictine University
Bennett College
Bennington College
Bentley College
Berea College
Berkeley College
Berklee College of Music
Berry College
Bethany Bible College
Bethany College, West Virginia
Bethany College, Lindsborg, KS
Bethany College, Scotts Valley, CA
Bethany Lutheran College
Bethel College and Seminary, Saint Paul Minnesota
Bethel College, McKenzie, Tennessee
Bethel College, Mishawaka, Indiana
Bethel College, Newton, Kansas
Bethune-Cookman College
Bienville University
Biola University
Birmingham-Southern College
Black Hills State University
Blackburn College
Bloomfield College
Bloomsburg University
Bluefield College
Bluefield State College
Bluffton College
Bob Jones University
Boise State University
The Boston Architectural Center
Boston College
Boston Conservatory
Boston University
Bowdoin College
Bowie State University
Bowling Green State University
Bradford College
Bradley University
Brandeis University
Brenau University
Brewton-Parker College
Briar Cliff University
Bridgewater College
Bridgewater State College
Brigham Young University
Brigham Young University Hawaii
Brigham Young University Idaho
Brooklyn College
Brooklyn Law School
Brown University
Bryant College
Bryn Mawr College
Bucknell University
Buena Vista University
Buffalo State
Butler University
– C –
C. R. Drew University of Medicine and Science
Caldwell College
California Baptist University
California Coast University
California College of Arts and Crafts
California College for Health Sciences
California College of Podiatric Medicine
California Institute of the Arts
California Institute for Human Science
California Institute of Integral Studies
California Institute of Technology
California Lutheran University
The California Maritime Academy
California National University for Advanced Studies
California Pacific University
California Polytechnic State University, San Luis Obispo
California State Polytechnic University, Pomona
California State University, Bakersfield
California State University, Channel Islands
California State University, Chico
California State University, Dominguez Hills
California State University, Fresno
California State University, Fullerton
California State University, Hayward
California State University, Long Beach
California State University, Los Angeles
California State University, Monterey
California State University, Northridge
California State University, Sacramento
California State University, San Bernardino
California State University, San Marcos
California State University, Stanislaus
California University of Pennsylvania
Calumet College of St. Joseph
Calvin College
Cambridge College
Cameron University
Campbell University
Campbellsville University
Canisius College
Canyon College
Capella University
Capital University
Cardinal Stritch University
Carleton College
Carlow College
Carnegie Institution of Washington
Carnegie Mellon University
Carroll College, Helena, MT
Carroll College, Waukesha, WI
Carson-Newman College
Carthage College
Case Western Reserve University
Castleton State College
Catawba College
The Catholic University of America
Cazenovia College
Cedar Crest College
Cedarville University
Centenary College of Louisiana
Centenary College of New Jersey
Center for Creative Studies College of Art and Design
Central College
Central Connecticut State University
Central Methodist College
Central Michigan University
Central Missouri State University
Central State University
Central Washington University
Centre College, Danville Kentucky
Century University
Chadron State College
Chadwick University
Chaminade University of Honolulu, Hawaii
Champlain College
Chapman University
Charles R. Drew University of Medicine and Science
Charleston Southern University
Charter Oak State College
Chatham College
Cheyney University of Pennsylvania
Chicago-Kent College of Law
Chicago School of Professional Psychology
Chicago State University
Chowan College
Christendom College
Christian Bible College and Seminary
Christian Brothers University
Christopher Newport University
Circleville Bible College
The Citadel
City Colleges of Chicago
City University, Bellevue Washington
City University of Los Angeles
City University of New York
Claflin College
Claremont Graduate University
Claremont McKenna College
Clarion University
Clark Atlanta University
Clark College
Clark University
Clarke College
Clarkson University
Clayton College and State University
Clayton College of Natural Health
Clemson University
Clear Creek Baptist Bible College
Cleary College
Cleveland Chiropractic College
Cleveland Institute of Art
Cleveland Institute of Music
Cleveland State University
Clinch Valley College
Coastal Carolina University
Coe College
Cogswell Polytechnical College
Coker College
Colby College
Colby-Sawyer College
Colgate University
Coleman College
College of Aeronautics
College of the Atlantic
College of Charleston
College of Eastern Utah
College of the Holy Cross
The College of Insurance
College for Lifelong Learning
The College of Metaphysical Studies
College Misericordia
College of Mount Saint Joseph
The College of New Jersey
College of New Rochelle
College of Notre Dame of Maryland
College of the Ozarks
College of Saint Benedict
College of Saint Catherine
College of Saint Elizabeth
College of Saint Mary
College of Saint Scholastica
The College of Saint Thomas More
The College of Saint Rose
The College of Santa Fe
College of the Southwest
College of William and Mary
The College of Wooster
Colorado Christian University
Colorado College
Colorado School of Mines
Colorado State University
Colorado Technical University
Columbia College
Columbia College of Missouri
Columbia International University
Columbia Southern University
Columbia Union College
Columbia University
Columbus State University
Concord College
Concordia College, Ann Arbor Michigan
Concordia College, Austin Texas
Concordia College, Bronxville, New York
Concordia College, Moorhead Minnesota
Concordia College, Saint Paul Minnesota
Concordia College, Selma Alabama
Concordia College, Seward Nebraska
Concordia University, Irvine California
Concordia University, Mequon Wisconsin
Concordia University, Portland Oregon
Concordia University, River Forest Illinois
Connecticut College
Converse College
Cooper Union for the Advancement of Science and Art
Coppin State College
Cornell College, Iowa
Corcoran College of Art + Design
Cornell University
Cornerstone University
Cornish College of the Arts
Cottey College
Covenant College
Creighton University
Crichton College
Crown College
Culver-Stockton College
Cumberland College
Cumberland University
Curry College
Cypress College
– D –
Daemen College
Dakota State University
Dakota Wesleyan University
Dallas Baptist University
Dallas Theological Seminary
Dana College
Daniel Webster College
Dartmouth College
Davenport College
Davidson College
Davis and Elkins College
Dawson College
Dean College
Deep Springs College
Defiance College
Delaware State University
Delaware Valley College
Delta College
Delta State University
Denison University
Denver Seminary
DePaul University
DePauw University
DeSales University
DeVry University
DeVry University, Columbus
Diablo Valley College
Dickinson College
Dickinson State University
Dillard University
Dixie State College
Doane College
Dominican College
Dominican University
Dominican University of California
Dordt College
Dowling College
Drake University
Drew University
Drexel University
Drury University
Duke University
Duquesne University
D’Youville College
– E –
Earlham College
East Carolina University
East Central University, Ada Oklahoma
East Stroudsburg State University
East Tennessee State University
East Texas Baptist University
East-West University
Eastern College
Eastern Connecticut State University
Eastern Illinois University
Eastern Kentucky University
Eastern Mennonite University
Eastern Michigan University
Eastern Nazarene College
Eastern New Mexico University
Eastern Oregon University
Eastern Washington University
Eckerd College
Edgewood College
Edinboro University of Pennsylvania
Edward Waters College
Elizabeth City State University
Elizabethtown College
Elmhurst College
Elmira College
Elms College
Elon University
Embry-Riddle Aeronautical University
Emerson College
Emmanuel College
Emmaus Bible College
Emory University
Emory & Henry College
Empire State College
Emporia State University
Endicott College
Erskine College
Eureka College
Evangel University
Everglades College
Evergreen State College
Excelsior College
– F –
Fairfield University
Fairleigh Dickinson University
Fairmont State College
Faith Baptist Bible College and Theological Seminary
Faulkner University
Fayetteville State University
Felician College
Ferris State University
Ferrum College
Fielding Graduate Institute
Finch University of Health Sciences/The Chicago Medical School
Fisk University
Fitchburg State College
Flagler College
Florida A & M University
Florida Atlantic University
Florida Christian College
Florida Gulf Coast University
Florida Institute of Technology
Florida International University
Florida Memorial College
Florida Metropolitan University
Florida Southern College
Florida State University
Fontbonne College
Fordham University
Forest Institute of Professional Psychology
Fort Hays State University
Fort Lewis College
Fort Valley State University
Framingham State College
Francis Marion University
Franciscan University of Steubenville
Franklin and Marshall College
Franklin College
Franklin Pierce College
Franklin Pierce Law Center
Franklin University
Freed-Hardeman University
Freewill Baptist Bible College
Fresno Pacific University
Friends University
Frostburg State University
Fuller Theological Seminary
Fullerton College
Furman University
– G –
Gallaudet University
Gannon University
Gardner-Webb University
Geneva College
George Fox University
George Mason University
George Washington University
Georgetown College
Georgetown University
Georgian Court College
Georgia College and State University
Georgia Institute of Technology
Georgia Perimeter College
Georgia Southern University
Georgia Southwestern State University
Georgia State University
Georgian Court College
Gettysburg College
Glenville State College
Globe Institute of Technology
Goddard College
Golden Gate University
Golden State Baptist College
Goldey-Beacom College
Gonzaga University
Gooding Institute of Nurse Anesthesia
Gordon College
Gordon-Conwell Theological Seminary
Goshen College
Goucher College
Governors State University
Grace College
Grace University
Graceland University
The Graduate Center, City University of New York
Grambling State University
Grand Canyon University
Grand Valley State University
Grand View College
Grantham University
Green Mountain College
Greenleaf University
Greensboro College
Greenville College
Greenwich University
Grinnell College
Grove City College
Guilford College
Gustavus Adolphus College, Saint Peter, Minnesota
Gwynedd-Mercy College
– H –
Hamilton College
Hamilton University
Hamline University
Hampden-Sydney College
Hampshire College
Hampton University
Hannibal-LaGrange College
Hanover College
Hardin-Simmons University
Harding University
Harris-Stowe State College
Hartwick College
Harvard University
Harvey Mudd College
Hastings College
Haverford College
Hawaii Pacific University
Hebrew College
Heidelberg College
Henderson State Univerisity
Hendrix College
Henry Cogswell College
Heritage College
Hesser College
Hesston College
High Point University
Hilbert College
Hillsdale College
Hillsdale Freewill Baptist College
Hiram College
Hobart and William Smith Colleges
Hofstra University
Hollins University
Holy Cross College, Notre Dame Indiana
Holy Family College
Hood College
Hope College
Houghton College
Houston Baptist University
Howard Payne University
Howard University
Humboldt State University
Hunter College
Huntingdon College
Huntington College
Huron University
Husson College
Huston-Tillotson College
– I –
Idaho State University
Illinois College
Illinois Institute of Technology
Illinois State University
Illinois Wesleyan University
Immaculata College
Indiana Institute Technologyy
Indiana State University
Indiana Wesleyan University
Indiana University
Indiana University Northwest
Indiana University of Pennsylvania
Indiana University at South Bend
Indiana University Southeast
Indiana University – Purdue University, Columbus
Indiana University – Purdue University, Fort Wayne
Indiana University – Purdue University, Indianapolis
Institute for Christian Works
Institute of Computer Technology
Institute of Paper Science and Technology
Institute for Transpersonal Psychology
Inter American University of Puerto Rico
International College
International Fine Arts College
International Institue of the Americas
International Reform University
Iona College
Iowa State University
Iowa Wesleyan College
Ithaca College
– J –
Jackson State University
Jacksonville State University
Jacksonville University
James Madison University
Jamestown College
Jarvis Christian College
Jewish Theological Seminary
John Brown University
John Carroll University
John F. Kennedy University
John Jay College of Criminal Justice
The Johns Hopkins University
Johnson Bible College
Johnson and Wales University
Johnson C. Smith University
Joint Military Intelligence College
Jones College
Jones International University
Judson College, Marion AL
Judson College, Elgin IL
The Julliard School
Juniata College
– K –
Kalamazoo College
Kansas City Art Institute
Kansas Newman College
Kansas State University
Kansas Wesleyan University
Kean University
Keck Graduate Institute
Keene State College
Keiser College
Kennedy-Western University
Kennesaw State University
Kent State University
Kentucky Christian College
Kentucky State University
Kentucky Wesleyan College
Kenyon College
Kettering University
Keuka College
King College
King’s College, Wilkes-Barre, PA
The King’s College, New York City, NY
Knox College
Knox Theological Seminary
Kutztown University of Pennsylvania
– L –
La Roche College
La Salle University
La Sierra University
Lafayette College
LaGrange College
Lake Erie College
Lake Forest College
Lake Superior State University
Lakeland College
Lamar University
Lambuth University
Lancaster Bible College
Lancaster Theological Seminary
Lander University
Landmark College
Langston University
Lane College
Lasell College
Lawrence Technological University
Lawrence University
Le Moyne College
Lebanon Valley College
Lee College
Lee University
Lees-McRae College
Lehigh Univervsity
LeMoyne-Owen College
Lenoir-Rhyne College
Lenox Institute of Water Technology
Lesley University
LeTourneau University
Lewis & Clark College
Lewis-Clark State College
Lewis University
Liberty University
Life University
Limestone College
Lincoln Christian College and Seminary
Lincoln College
Lincoln Memorial University
Lincoln University, Jefferson City Missouri
Lincoln University, San Francisco California
Lincoln University of Pennsylvania
Lindenwood College
Lindsey Wilson College
Linfield College
Lipscomb University
Lock Haven University
Logan College of Chiropractic
Loma Linda University
Long Island University
Longwood College
Loras College
Louisburg College
Louisiana Baptist Universty
Louisiana College
Louisiana State University at Baton Rouge
Louisiana State University Health Sciences Center New Orleans
Louisiana State University at Shreveport
Louisiana Tech University
Loyola College, Baltimore
Loyola Marymount University
Loyola University, Chicago
Loyola University, New Orleans
Lubbock Christian University
Luther College
Luther Seminary
Lutheran Bible Institute
Lutheran Theological Seminary at Gettysburg
Lycoming College
Lyme Academy of Fine Arts
Lynchburg College
Lyndon State College
Lynn University
Lyon College
– M –
Macalester College
MacMurray College
Madonna University
Maharishi University of Management
Maine College of Art
Maine Maritime Academy
Malone College
Manchester College
Manhattan College
Manhattanville College
Mansfield University
Maranatha Baptist Bible College
Marian College
Marietta College
Marlboro College
Marist College
Marquette University
Mars Hill College
Marshall University
Mary Baldwin College
Mary Washington College
Maryland Institute, College of Art
Marylhurst University
Marymount College
Marymount Manhattan College
Marymount University
Maryville College
Maryville University of Saint Louis
Marywood University
Massachusetts College of Art
Massachusetts College of Liberal Arts
Massachusetts College of Pharmacy and Allied Health Sciences
Massachusetts Institute of Technology
Massachusetts Maritime Academy
Massachusetts School of Professional Psychology
The Master’s College
The Mayo Foundation
Mayville State University
The McGregor School of Antioch University
McKendree College
McMurry University
McNeese State University
MCP Hahnemann University
McPherson College
Medaille College
Medical College of Georgia
Medical College of Ohio
Medical College of Pennsylvania and Hahnemann University
Medical College of Wisconsin
Medical University of South Carolina
Meharry Medical College
Menlo College
Mercer University
Mercy College
Mercy College of Health Sciences
Mercyhurst College
Meredith College
Merrimack College
Mesa State College
Messiah College
Methodist College
Methodist Theological School in Ohio
Metropolitan College
Metropolitan State College of Denver
Metropolitan State University
Miami Christian University
Miami University of Ohio
Michigan State University
Michigan Technological University
Mid-America Nazarene University
Middle Georgia College
Middle Tennessee State University
Middlebury College
Midwestern Baptist College
Midwestern State University
Miles College
Millersville University
Milligan College
Millikin University
Mills College
Millsaps College
Milwaukee School of Engineering
Minneapolis College of Art and Design
Minnesota State University Mankato
Minnesota State University Moorhead
Minot State University
Minot State University–Bottineau
Mississippi College
Mississippi State University
Mississippi University for Women
Mississippi Valley State University
Missouri Baptist College
Missouri Southern State College
Missouri Tech
Missouri Valley College
Missouri Western State College
Mitchell College
Molloy College
Monmouth College, Monmouth Illinois
Monmouth University, West Long Branch New Jersey
Monroe College
Montana State University-Billings
Montana State University-Bozeman
Montana State University College of Technology, Great Falls
Montana State University-Northern Havre
Montana Tech
Montclair State University
Monterey College of Law
Monterey Institute of International Studies
Montreat College
Moravian College
Morehead State University
Morehouse College
Morehouse School of Medicine
Morgan State University
Morningside College
Morris Brown College
Morris College
Mount Aloysius College
Mount Holyoke College
Mount Ida College
Mount Marty College
Mount Mary College
Mount Mercy College
Mount Olive College
Mount St. Clare College
Mount St. Mary’s College and Seminary, Emmitsburg Maryland
Mount St. Mary’s College, Los Angeles California
Mount Senario College
Mt. Sierra College
Mount Union College
Mount Vernon Nazarene College
Mountain State University
Muhlenberg College
Murray State University
Muskingum College
– N –
Naropa University
National American University
National Defense University
The National Graduate School
National-Louis University
National Technological University
National University
The Naval Postgraduate School
Nazarene Bible College
Nazareth College
Nebraska Methodist College
Nebraska Wesleyan University
Neumann College
New Brunswick Theological Seminary
New College of Florida
New England College of Optometry
New England Conservatory of Music
New England Institute of Technology
New England School of Communications
New Jersey City University
New Jersey Institute of Technology
New Mexico Highlands University
New Mexico Institute of Mining and Technology
New Mexico State University
New School University
New World School of the Arts
New York Academy of Art
New York Institute of Technology
New York Law School
New York University
Newberry College
Newport University
Niagara University
Nicholls State University
Nichols College
Norfolk State University
North Carolina Agricultural and Technical State University
North Carolina Central University
North Carolina School of the Arts
North Carolina State University
North Carolina Wesleyan College
North Central College
North Central University
North Dakota State University–Fargo
North Georgia College and State University, the Military College of Georgia
North Greenville College
North Park University
Northeastern Illinois University
Northeastern University
Northeastern State University
Northern Arizona University
Northern Illinois University
Northern Kentucky University
Northern Michigan University
Northern State University
Northland College
Northwest Christian College
Northwest College
Northwest College of Art
Northwest Missouri State University
Northwest Nazarene University
Northwestern Oklahoma State University
Northwestern State University, Louisiana
Northwestern College, Iowa
Northwestern College, Saint Paul, MN
Northwestern Michigan College
Northwestern University
Northwood University
Norwich University
Notre Dame College of Ohio
Notre Dame de Namur University
Nova Southeastern University
Nyack College
– O –
Oakland University
Oakwood College
Oberlin College
Occidental College
Oglethorpe University
Ohio Dominican College
Ohio Northern University
The Ohio State University
Ohio University
Ohio Valley College
Ohio Wesleyan University
Oklahoma Baptist University
Oklahoma Christian University
Oklahoma City University
Oklahoma Panhandle State University
Oklahoma State University
Oklahoma State University Tulsa
Oklahoma Wesleyan University
Old Dominion University
Olin College of Engineering
Olivet College
Olivet Nazarene University
The Open University
Oral Roberts University
Oregon Graduate Institute of Science and Technology
Oregon Health Sciences University
Oregon Institute of Technology
Oregon State University
Otterbein College
Ottawa University
Ouachita Baptist University
Our Lady of the Lake University
Our Lady of Holy Cross College
– P –
Pace University
Pacific College of Oriental Medicine
Pacific Lutheran University
Pacific Northwest College of Art
Pacific States University
Pacific Union College
Pacific University
Paine College
Palm Beach Atlantic College
Palmer College of Chiropractic
Park University
Parsons School of Design
Patten College
Patrick Henry College
Paul Quinn College
Paul Smith’s College
Peace College
Pennsylvania College of Technology
The Pennsylvania State University
Pennsylvania State University at Altoona
Pennsylvania State University, Great Valley
Pennsylvania State University at Harrisburg
Pennsylvania State University, Worthington Scranton
Pensacola Christian College
Pepperdine University
Peru State College
Pfeiffer University
Pickering University
Piedmont College
Pine Manor College
Pittsburg State University
Philadelphia Biblical University
Philadelphia University
Philander Smith College
Phillips University
Pitzer College
Plymouth State University, Plymouth New Hampshire
Point Loma Nazarene College
Point Park College
Polytechnic University of New York
Polytechnic University of Puerto Rico
Pomona College
Portland State University
Potomac College
Prairie View A & M University
Pratt Institute
Presbyterian College
Prescott College
Preston University
Princeton University
Principia College
Providence College
Purdue University
– Q –
Queens College
Quincy University
Quinnipiac College
– R –
Radford University
Ramapo College of New Jersey
Randolph-Macon College
Randolph-Macon Woman’s College
Reed College
Regent University
Regis College
Regis University
Reinhardt College
Rensselaer Polytechnic Institute
Rhode Island College
Rhode Island School of Design
Rhodes College
Rice University
The Richard Stockton College of New Jersey
Rider University
Ringling School of Art and Design
Ripon College
Rivier College
Roanoke College
Robert Morris College, Illinois
Robert Morris College, Pittsburgh, PA
Roberts Wesleyan College
Rochester Institute of Technology
Rochester College
The Rockefeller University
Rockford College
Rockhurst University
Rocky Mountain College
Roger Williams University
Rogers State University
Rollins College
Roosevelt University
Rose-Hulman Institute of Technology
Rosemont College
Rowan University
Rush University
Russell Sage College
Rust College
Rutgers University
Rutgers University-Camden
Rutgers University-Newark
Ryokan College
– S –
Sacred Heart University
Sacred Heart University, Puerto Rico
The Sage Colleges
Saginaw Valley State University
Saint Ambrose University
Saint Andrews Presbyterian College
Saint Anselm College
Saint Anthony College of Nursing
Saint Augustine’s College
Saint Bonaventure University
Saint Cloud State University
Saint Edwards University
Saint Francis College, Brooklyn Heights, New York
Saint Francis College, Fort Wayne, Indiana
Saint Francis College, Loretto, Pennsylvania
St. Gregory’s University
Saint John Fisher College
Saint John’s College
Saint John’s University, Collegeville Minnesota
Saint John’s University, Jamaica New York
Saint Joseph College
Saint Joseph’s College
Saint Joseph’s College of Maine
Saint Joseph’s University
Saint Lawrence University
Saint Leo University
Saint Louis University
Saint Martin’s College
Saint Mary College
Saint Mary-of-the-Woods College
Saint Mary’s College
Saint Mary’s College of California
Saint Mary’s College of Maryland
Saint Mary’s University of Minnesota
Saint Mary’s University of San Antonio
Saint Meinrad’s School of Theology
Saint Michael’s College
Saint Norbert College
Saint Olaf College
Saint Paul’s College
Saint Peter’s College
Saint Rose College
Saint Thomas Aquinas College
Saint Thomas University
Saint Vincent College
Saint Xavier University
Salem College
Salem International University
Salem State College
Salisbury State University
The Salk Institute for Biological Studies
Salve Regina University
Sam Houston State University
Samford University
Samuel Merritt College
San Diego State University
San Francisco Art Institute
San Francisco Law School
San Francisco State University
San Joaquin College of Law
San Jose Christian College
San Jose State University
Santa Clara University
Sarah Lawrence College
Saratoga University School of Law
Sarah Lawrence College
Savannah College of Art and Design
Savannah State University
Saybrook Graduate School and Research Center
Schiller International University
School for International Training
School of the Art Institute of Chicago
School of Islamic and Social Sciences
School of the Museum of Fine Arts, Boston
School of the Visual Arts
Schreiner College
Scripps College
The Scripps Research Institute
Seattle Pacific University
Seattle University
Seton Hall University
Seton Hill College
Shasta Bible College
Shawnee State University
Shaw University
Sheffield School of Interior Design
Sheldon Jackson College
Shenandoah University
Shepherd College
Sherman College of Straight Chiropractic
Shimer College
Shippensburg University of Pennsylvania
Shorter College
Siena College
Siena Heights University
Silver Lake College
Simmons College
Simon’s Rock College
Simpson College, Redding California
Simpson College, Indianola Iowa
Skidmore College
Slippery Rock University
Smith Chapel Bible College
Smith College
Soka University of America
Sonoma State University
South Carolina State University
South Dakota School of Mines and Technology
South Dakota State University
South Pacific University
South Texas College of Law
Southampton College
Southeast College of Technology
Southeast Missouri State University
Southeastern College
Southeastern Louisiana University
Southeastern Oklahoma State University
Southeastern University
Southern Adventist University
Southern Arkansas University
Southern California University of Health Sciences
Southern California University of Professional Studies
Southern Connecticut State University
Southern Illinois University at Carbondale
Southern Illinois University at Edwardsville
Southern Illinois University Medical School at Springsfield
Southern Methodist University
Southern Nazarene University
Southern New Hampshire University
Southern Oregon State College
Southern Polytechnic State Univerisity
Southern Vermont College
Southern Virginia University
Southern Wesleyan University
Southern University, Baton Rouge
Southern University, New Orleans
Southern University, Shreveport-Bossier City
Southern Utah University
Southwest Baptist University
Southwest Bible College and Seminary
Southwest Missouri State University
Southwest State University
Southwest Texas State University
Southwestern Adventist University
Southwestern Assemblies of God University
Southwestern College
Southwestern Oklahoma State University
Southwestern University
Southwestern University School of Law
Spalding University
Spartanburg Methodist College
Spelman College
Spertus College
Spring Arbor College
Spring Hill College
Springfield College
Stamford International College
Stanford University
State University of New York at Albany
State University of New York at Binghamton
State University of New York at Buffalo
State University of New York at Oswego
State University of New York at Stony Brook
State University of New York College of Agriculture and Technology, Cobleskill
State University of New York College of Agriculture and Technology, Morrisville
State University of New York College at Brockport
State University of New York College at Buffalo (Buffalo State College)
State University of New York College at Cortland
State University of New York College of Environmental Science and Forestry
State University of New York College at Farmingdale
State University of New York College at Fredonia
State University of New York College at Geneseo
State University of New York College Maritime College at Fort Schuyler
State University of New York College at New Paltz
State University of New York College at Old Westbury
State University of New York College at Oneonta
State University of New York College at Oswego
State University of New York College at Plattsburgh
State University of New York College at Potsdam
State University of New York College at Purchase
State University of New York Institute of Technology at Canton
State University of New York Institute of Technology at Delhi
State University of New York Institute of Technology at Utica/Rome
State University of West Georgia
The Stefan University
Stephen F. Austin State University
Stephens College
Sterling College, Sterling Kansas
Sterling College, Kansas
Sterling College, Vermont
Stetson University
Stevens-Henager College
Stevens Institute of Technology
Stillman College
Stonehill College
Strayer University
Suffolk University
Sul Ross State University
Summit University of Louisiana
Susquehanna University
Swarthmore College
Sweet Briar College
Syracuse University
– T –
Tabor College
Talladega College
Tarleton State University
Taylor University
Teachers College
Teikyo Marycrest University
Teikyo Post University
Temple University
Tennessee State University
Tennessee Technological University
Tennessee Temple University
Tennessee Wesleyan College
Texas A&M International University
Texas A&M University
Texas A&M University, Commerce
Texas A&M University, Corpus Christi
Texas A&M University, Galveston
Texas A&M University, Kingsville
Texas A&M University, Texarkana
Texas Christian University
Texas Lutheran University
Texas Southern University
Texas Tech University
Texas Wesleyan University
Texas Woman’s University
Thiel College
Thomas Aquinas College, Santa Paula CA
Thomas Edison State College
Thomas College
Thomas Cooley Law School
Thomas More College
Thomas Jefferson University
Toccoa Falls College
Tougaloo College
Touro College
Towson University
The Transworld University
Transylvania University
Trevecca Nazarene University
Trinity Baptist College
Trinity Christian College
Trinity College, Hartford Connecticut
Trinity College of Florida
Trinity College, Washington DC
Trinity College of Vermont
Trinity International University
Trinity University
Tri-State University
Troy State University
Troy State University – Dothan
Truman State University
Tufts University
Tulane University
Tusculum College
Tuskegee University
– U –
Uniformed Services Universty of the Health Sciences
Union College, Barbourville KY
Union College
Union Theological Seminary
Union University
The Union Institute
United States Air Force Academy
United States Coast Guard Academy
United States Merchant Marine Academy
United States Military Academy
United States Naval Academy
United States Open University
United States Sports Academy
Unity College
University of Action Learning at Boulder
University of Advancing Technology
University of Akron
University of Alabama
University of Alabama, Birmingham
University of Alabama, Huntsville
University of Alaska, Anchorage
University of Alaska, Fairbanks
University of Alaska, Southeast
University of Arizona
University of Arkansas, Fayetteville
University of Arkansas at Little Rock
University of Arkansas at Monticello
University of Arkansas at Pine Bluff
University of the Arts
University of Baltimore
University of Bridgeport
University of California, Berkeley
University of California, Davis
University of California, Hastings College of Law
University of California, Irvine
University of California, Los Angeles
University of California, Merced
University of California, Riverside
University of California, San Diego
University of California, San Francisco
University of California, Santa Barbara
University of California, Santa Cruz
University of Central Arkansas
University of Central Florida
University of Central Oklahoma
University of Charleston
University of Chicago
University of Cincinnati
University of Colorado
University of Colorado, Colorado Springs
University of Colorado, Denver
University of Connecticut
University of Dallas
University of Dayton
University of Delaware
University of Denver
University of Detroit Mercy
University of the District of Columbia
University of Dubuque
University of Evansville
University of Findlay
University of Florida
University of Georgia
University of Great Falls
University of Guam
University of Hartford
University of Hawai`i
University of Hawai`i, Hilo
University of Hawai`i, West O`ahu
University of Health Sciences College of Osteopathic Medicine
University of Houston
University of Houston, Clear Lake
University of Houston, Downtown
University of Houston, Victoria
University of Idaho
University of the Incarnate Word
University of Indianapolis
University of Illinois at Chicago
University of Illinois at Springfield
University of Illinois at Urbana-Champaign
University of Iowa
University of Judaism
University of Kansas
University of Kansas Medical Center
University of Kentucky
University of La Vernee
University of Louisiana at Lafayette
University of Louisiana at Monroe
University of Louisville
University of Maine
University of Maine at Fort Kent
University of Maine at Presque Isle
University of Mary Hardin-Baylor
University of Maryland Baltimore County
University of Maryland at Baltimore
University of Maryland at College Park
University of Maryland Eastern Shore
University of Maryland University College
University of Massachusetts at Amherst
University of Massachusetts at Boston
University of Massachusetts at Dartmouth
University of Massachusetts at Lowell
University of Massachusetts Medical School
University of Medicine and Dentistry of New Jersey
University of Memphis
University of Miami
University of Michigan-Ann Arbor
University of Michigan-Dearborn
University of Michigan-Flint
University of Minnesota-Crookston
University of Minnesota-Duluth
University of Minnesota-Morris
University of Minnesota-Twin Cities
University of Mississippi
University of Missouri-Columbia
University of Missouri-Kansas City
University of Missouri-Rolla
University of Missouri-Saint Louis
University of Montana, Missoula
University of Montevallo
University of Natural Medicine
University of Nebraska, Kearney
University of Nebraska, Lincoln
University of Nebraska, Omaha
University of Nevada, Las Vegas
University of Nevada, Reno
University of New England
University of New Hampshire, Durham
University of New Haven
University of New Mexico
University of New Orleans
University of Newport
University of North Alabama
University of North Carolina at Asheville
University of North Carolina at Chapel Hill
University of North Carolina at Charlotte
University of North Carolina at Greensboro
University of North Carolina at Pembroke
University of North Carolina at Wilmington
University of North Dakota
University of North Dakota–Lake Region
University of North Florida
University of North Texas
University of Northern Colorado
University of Northern Iowa
University of Northern Washington
University of Notre Dame
University of Oklahoma
University of Oregon
University of Orlando
University of Osteopathic Medicine and Health Science
University of the Ozarks
University of the Pacific
University of Pennsylvania
University of Phoenix
University of Pittsburgh
University of Pittsburgh at Bradford
University of Pittsburgh at Greenburg
University of Pittsburgh at Johnstown
University of Portland
University of Puerto Rico, Mayaguez
University of Puerto Rico, Rio Piedras
University of Puget Sound
University of Redlands
University of Rhode Island
University of Richmond
University of Rio Grande
University of Rochester
University of St. Francis
University of St. Thomas, Houston
University of St. Thomas, Saint Paul
University of San Diego
University of San Francisco
University of Sarasota
University of Science and Arts of Oklahoma
University of the Sciences in Philadelphia
University of Scranton
University of Sioux Falls
University of the South
University of South Alabama
University of South Carolina
University of South Carolina, Aiken
University of South Carolina, Beaufort
University of South Carolina, Spartanburg
University of South Dakota
University of South Florida
University of Southern California
University of Southern Colorado
University of Southern Indiana
University of Southern Maine
University of Southern Mississippi
University of Tampa
University of Tennessee, Chattanooga
University of Tennessee Health Science Center
University of Tennessee, Knoxville
University of Tennessee, Martin
University of Texas at Arlington
University of Texas at Austin
University of Texas at Brownsville
University of Texas at Dallas
University of Texas at El Paso
University of Texas Health Science Center at Houston
University of Texas Health Science Center at San Antonio
University of Texas Health Center at Tyler
University of Texas Medical Branch
University of Texas-Pan American
University of Texas of the Permian Basin
University of Texas at San Antonio
University of Texas at Tyler
University of Texas Southwestern Medical Center
University of Toledo
University of Tulsa
University of Utah
University of Vermont
University of the Virgin Islands
University of Virginia
University of Washington
University of West Alabama
University of West Florida
University of Wisconsin-Green Bay
University of Wisconsin-Eau Claire
University of Wisconsin-La Crosse
University of Wisconsin-Madison
University of Wisconsin-Milwaukee
University of Wisconsin-Oshkosh
University of Wisconsin-Parkside
University of Wisconsin-Platteville
University of Wisconsin-Stevens Point
University of Wisconsin-Stout
University of Wisconsin-Superior
University of Wisconsin-River Falls
University of Wisconsin-Whitewater
University of Wyoming
Upper Iowa University
Urbana University
Ursinus College
Ursuline College
Utah State University
Utah Valley State College
Utica College
– V –
Valdosta State University
Valley City State University
Valparaiso University
Vanderbilt University
Vanguard University
Vassar College
Vennard College
Vermont Technical College
Villa Julie College
Villanova University
Virginia Commonwealth University
Virginia Intermont College
Virginia International University
Virginia Military Institute
Virginia Polytechnic Institute and State University
Virginia State University
Virginia Union University
Virginia University of Lynchburg
Virginia Wesleyan College
Viterbo College
Voorhees College
– W –
Wabash College
Wagner College
Wake Forest University
Warner Pacific College
Wartburg College
Walden University
Walla Walla College
Walsh University
Warren Wilson College
Washburn University
Washington & Jefferson College
Washington & Lee University
Washington Bible College / Capital Bible Seminary
Washington College
Washington State University
Washington University in Saint Louis
Wayland Baptist University
Wayne State College
Wayne State University
Waynesburg College
Webb Institute
Weber State University
Webster University
Webster University North Florida
Wellesley College
Wells College
Wentworth Institute of Technology
Wesley College
Wesleyan College
Wesleyan University
West Coast University
West Chester University of Pennsylvania
West Liberty State College
West Texas A&M University
West Virginia State College
West Virginia University
West Virginia University Parkersburg
West Virginia Wesleyan College
Western Baptist College
Western Carolina University
Western Connecticut State University
Western Governors University
Western Illinois University
Western International University
Western Kentucky University
Western Maryland College
Western Michigan University
Western Montana College
Western New England College
Western New Mexico University
Western Oregon University
Western State College
Western State University College of Law
Western States Chiropractic College
Western University of Health Sciences
Western Washington University
Westfield State College
Westminster College, Fulton Missouri
Westminster College, New Wilmington Pennsylvania
Westminster College, Salt Lake City
Westminster Theological Seminary
Westminster Theological Seminary in California
Westmont College
Westwood College of Technology
Wheaton College, Wheaton Illinois
Wheaton College, Massachusetts
Wheeling Jesuit University
Wheelock College
Whitman College
Whittier College
Whitworth College
Wichita State University
Widener University
Wilberforce University
Wilkes University
Willamette University
William Howard Taft University
William Carey International University
William Jewell College
William Mitchell College of Law
William Paterson University
William Penn College
William Woods University
Williams Baptist College
Williams College
Wilmington College, New Castle Delaware
Wilmington College, Wilmington Ohio
Wilson College
Wingate University
Winston-Salem State University
Winona State University
Winthrop University
Wisconsin Lutheran College
Wittenberg University
Wofford College
Woodbury University
Woods Hole Oceanographic Institution
Worcester Polytechnic Institute
Worcester State College
Wright Institute
Wright State University
– X –
Xavier University, Cincinnati, OH
Xavier University of Louisiana
– Y –
Yale University
Yeshiva University
York College, York Nebraska
York College of Pennsylvania
Youngstown State University
– Z –

‘Z’ HAS NO QUALIFIED SCHOOLS

“I am not my illness”

I am not my illness. 

Keira, 16 

I’ve had depression for three years, and I used to hate the way my illness had changed me. I thought I could never be the girl I used to be. But my psychologist helped me to see that my illness can never change the inner me. In the end, I will have changed – I will be stronger for this battle – but my central values and the things that make me ‘me’ will always remain the same.

I am not my illness. 

Mark, 23 

I have schizophrenia. People call me crazy, and avoid me, because I hear voices and talk to them. Maybe I am crazy sometimes, when I have an episode. But I’m not always crazy. I may be schizophrenic, but schizophrenic is not all I am.

I am not my illness. 

Jessie, 13 

The girls at school all tease me because I always stutter when I talk, and sometimes I try to speak but my mouth can’t form the words. They call me retarded, dumb. I’ve never really had any real friends, all because I have autism. They can’t look past my illness and see the real me, the ‘me’ who longs to be accepted like any normal person. I may be autistic, but I’m still human. I still have feelings.

I am not my illness. 

Chrissie, 30 

I have bipolar disorder, also known as manic depression. Many people consider me ‘unemployable’, because of my illness. They say I’m ‘unstable and unpredictable’. But just because I have bipolar, doesn’t mean I’m unstable. I take medication to stabilise my moods, and though I have to take care not to stress out too much, my condition doesn’t prevent me from working, and working well. I can actually be very efficient and organised with what I do. But people don’t see it, because they never give me the chance. Bipolar disorder may be part of my life, but it doesn’t define who I am or what I’m capable of doing.

I am not my illness. 

Patrick, 15 

The guys at school call me a wuss, because I freak out so much before exams I throw up and faint. They reckon I’m chicken. I can’t tell them I have an anxiety disorder. They reckon mental illnesses are for weaklings. They don’t understand. Anyone can be affected. Anxiety has been part of my life for a long time, and mostly I still manage to live normally. Why can’t they see that?

I am not my illness. 

Annie, 16 

I had a nervous breakdown two years ago, and it led to me slowly sliding into mental illness. I missed almost a whole year of school last year. Now I’m back, and even though I know I’m not meant to take things too fast, it bugs me that people treat me like I’m going to go crazy at a moment’s notice. I know I’m fragile, but why do they have to always make such a big deal of it? I’m still the same person I always was.

I am not my illness. 

Samantha, 17 

I have suffered from anorexia for my whole high school life. At first I got so many compliments on how skinny I was, which only pushed me further. Then people started to notice that I wasn’t just pretty skinny any more, I was skeletal. They call me crazy, that I can’t see myself for what I actually am. They say I’m delusional. I’m not delusional. I’m sick. I know what I’m doing is wrong, but I can’t stop it. It’s the illness. It’s not me.

I am not my illness. 

Lily, 14 

Ever since the girls at school noticed I had scars on my wrist, I have been the subject of merciless taunting. My friends have turned their backs to me; they say I’m crazy. They look at me with disgust. I’m not crazy though. Or at least, I’m not crazy all the time. I’m sick. It is an illness, this addiction. It’s paralysing. I still cope though. I’m still me, whatever my illness. I’m still me.

I am not my illness. 

I am not my illness. My illness is not me. I am above this. I am above my illness. I. Am. Not. My. Illness.

Trump signs executive order aimed at reducing veteran suicides

Trump signs executive order aimed at reducing veteran suicides
© Getty Images

President Trump signed an executive order Tuesday aimed at helping veterans get access to mental health care.

The order instructs the departments of Defense, Homeland Security and Veterans Affairs to develop a plan within 60 days to provide “seamless access to mental health treatment and suicide prevention resources” for uniformed service members in the year following military service.

“We want them to get the highest care and the care they so richly deserve,” Trump said at the signing ceremony Tuesday afternoon.

Within 180 days, the departments must update Trump on the implementation of the plan and outline further reforms to increase access to mental health services.

Administration officials said the suicide rate among veterans in the first year following service is twice the average among veterans overall. About 20 veterans die by suicide per day in the U.S., the government estimates.

“That is just an unacceptable number, and we are focused on doing everything we can to prevent these veterans’ suicides,” said Veterans Affairs Secretary David Shulkin.

“We will be covering all separating military members who are transitioning into civilian life. 100 percent will have a mental health benefit for 12 months.”

Shulkin said that, currently, only 40 percent of veterans have coverage that includes mental health.

“Now, 100 percent will have that coverage,” he said.

The program is worth hundreds of millions of dollars per year, officials said, with the money coming from the Defense and Veterans Affairs budgets.

Higher Education Disability Law Year in Review:Court Decisions, Settlements, and Guidance

For information only.
Public Access File. 

Paul D. Grossman, J.D.[2]

OCR Chief Regional Attorney, S.F., Retired

Adjunct Professor of Disability Law, Hastings College of Law, Univ. of Cal.

AHEAD Board Member; Expert Panel Member, Disability Rights Advocates

 

Edited with Ruth Colker, J.D.

 Distinguished University Professor

Heck-Faust Memorial Chair in Constitutional Law, Moritz College of Law, OSU

ACLU Board Member

Presented with Jo Anne Simon, J.D.

Adjunct Professor, Fordham University School of Law

New York State Assembly Member, District 52

Founding Member and General Counsel of AHEAD

Documentation and Definition of Disability

 

In 2014 DOJ issued an NPRM: DEPARTMENT OF JUSTICE, Office of the Attorney General, 28 CFR Parts 35 and 36, CRT Docket No. 124; AG Order No., RIN 1190–AA59, proposed application of ADAA to individuals with learning disabilities and AD/HD under titles II & III.  Dept. of Justice, Amendment of Americans with Disabilities Act title II and Title III Regulations to Implement ADA Amendments Act of 2008 (Jan. 22, 2014), available at http://www.ada.gov/ nprm_adaaa/ nprm_adaaa.htm.   The regulation in question has not been issued and it is not on the published regulation calendar for issuance in the near future.

 

Rawdin v. American Board of Pediatrics, 985 F. Supp. 2d 636, 2013 U.S. Dist. LEXIS 159458, 2013 WL 5948074 (E.D. Pa. 2013)

The Summer Reading List for last year reported that the District court had concluded that an acquired learning disability following treatment for brain cancer is not a disability, when the individual is academically and professionally successful, and has both IQ and performance scores higher than the average individual in the general population.

Subsequent to the last Reading List, the Third Circuit affirmed the judgment of the district court in favor of the ABP.  Rawdin v. American Bd. of Pediatrics, 582 Fed. Appx. 114, 2014 U.S. App. LEXIS 17002 (3d Cir. Pa. 2014).  However, the Circuit Court assumed without deciding that Dr. Rawdin was an individual with a disability.  Consequently, the Circuit Court’s opinion focused on whether Dr. Rawdin was entitled to accommodations that he was denied either on the examination or in an alternative to the examination.  This issue is discussed below.

Insert Colker and Grossman, Higher Education at p. 46 as first NOTE.

 

Consent Decree, Department of Fair Employment and Housing (DFEH) and the United States v. LSAC, No. CV 12-1830-EMC (N.D. Cal. May 20, 2014), available at http://www.ada.gov/defh_v_lsac/lsac_consentdecree.htm.  [Lexis cite is as follows: but it is not to the pertinent documents. Dep’t of Fair Empl. & Hous. v. Law Sch. Admission Counsel, 2013 U.S. Dist. LEXIS 84205 (N.D. Cal. June 14, 2013)]

Last year’s Reading List reported that on May 20, the parties to this matter, the LSAC, the California Department of Fair Employment and Housing, and the United States entered into a court-approved consent decree providing an end to flagging LSAT score reports of individuals who received extended time on the test, to establish a compensation fund of $7.73 million for the 6000 individuals (nation-wide) who applied for accommodations in the past five years, to “streamline” the process for evaluating accommodation requests including automatically approving accommodations that an applicant can show previously had been received on standardized tests related to post-secondary admissions, and implementing the DOJ title III “best ensure” accommodation standard for individuals with sensory, manual, or speaking skills. For persons who are required to submit documentation (for example, persons who were not previously accommodated on standardized exams), documentation developed within the past five years will be considered reliable.  A claims administrator will administer the compensation fund.

The federal court approved the consent decree on May 29, 2014.  Pursuant to the decree, a panel of five experts was assembled to develop “best practices” guidance for LSAC to follow prospectively, unless any of the parties objected to recommendations of the panel and convinced the court that the recommendations were inconsistent with or outside the scope of the decree.

The decree assigned the panel 10 specific questions to answer.   On January 31, 2015, the panel filed its report.  See http://www.justice.gov/opa/pr/2014/May/14-crt-536.html (last viewed on May 22, 2014). Included in the panel’s recommendation are less burdensome documentation requirements and review practices that are more likely to result in accommodation eligibility; a greater number of documentation reviewers with a wider range of knowledge; training for all reviewers to ensure consistency; and a quicker, more responsive appeal process.

On February 26, the LSAC filed a response to the panel’s recommendations, challenging most of them.  On July 31st, the matter will be heard before the district court magistrate judge that was involved with the entry of the consent decree.  A ruling is supposed to result expeditiously.

Insert Colker and Grossman, Higher Education at p. 57 before box and p. 204 before the first NOTE.

 

Academic Deference and Qualification

Walsh v. University of Pittsburgh,   Civil Action No. 13-00189, (W.D. Penn. 2015), 2015 U.S. Dist. LEXIS 2563, 2015 WL 128104 http://law.justia.com/cases/federal/district-courts/pennsylvania/pawdce/2:2013cv00189/208081/63 (last viewed, June 22, 2015).

Although only a district court opinion, this decision is helpful for laying out the analytical structure for several types of allegations.

 

Amy Walsh is an individual with a BS in nursing. She enrolled in a Masters degree program in anesthesia.  While in the program, she performed well in the classroom but encountered difficulties in the clinical rotation stages.   The student alleged that in her first rotation it became necessary to tell one of her instructors that breast cancer surgery had resulted in weakness, reduced range of motion, and stiffness in one of her arms. According to Walsh, her instructors subsequently began stating that she would be unable to perform essential skills because of her limitations. Her complaints about this treatment got little response. At the second site for rotation, Walsh was placed on a performance improvement plan (PIP). The student alleged that this PIP was required because staff from the first rotation site had told the second site that she was incompetent. She complained again about her treatment without receiving an effective response. In the third rotation, on the same day, Walsh made two “dangerous or potentially dangerous,” errors in administering medication. Following three levels of due process review, she was dismissed from the anesthesia program.

Subsequent to her dismissal the student sued the University.  The Federal District court considered three claims: disparate treatment and a hostile environment on the basis of disability under Section 504 of the Rehabilitation Act and Title II of the ADA, as well as breach of contract.

The University of Pittsburgh did not contest that the student was an individual with a disability but moved for summary judgment on the grounds that she was not qualified to complete the program.  Of interest is the distinction drawn by the court with regard to the question of academic deference.  Much deference was accorded on the breach of contract claim, little on the disability discrimination claims.

With regard to the breach of contract claim, the court articulated the question before it as, “[Whether] the decision to dismiss [the student] was rational and had a reasonable basis in fact.”  The court stated:

[W]hen judges are asked to review the substance of a genuinely academic decision … they should show great respect for the faculty’s professional judgment. Plainly, they may not override it unless it is such a substantial departure from accepted academic norms as to demonstrate that the person or committee responsible did not actually exercise professional judgment.

Applying this standard to the plaintiff’s contract claims, the court granted the University’s motion for summary judgment.

In analyzing the disability discrimination claim, the court declined the University of Pittsburgh’s invitation to apply a similar degree of deference.

While the purely academic decisions of universities deserve deference in a due process context, if such deference were extended to situations requiring a separate discrimination analysis, universities could insulate even actions taken for discriminatory reasons by claiming that the student was not otherwise academically qualified. Instead, when a student claims she was discriminated against, courts must independently evaluate whether the student has shown she is otherwise qualified to participate in the academic program.

With regard to the disparate treatment claim, the court followed the same analytical test as would be applied in a race discrimination claim.   Although it concluded that the student had made out a prima facie discrimination, based on comparative treatment information, the high level of due process which she had received, and the potential seriousness of her errors, the court granted the University’s motion for summary judgment, concluding that the student had failed to establish that her dismissal was a pretext for disability discrimination.

It is rare to see a student litigate a claim that he or she has been subject to a hostile environment on the basis of disability.  This case is an exception.   As to this allegation, the court followed the same analytical test as would be applied to a sex discrimination claim under Title IX of the Education Amendment of 1972.  Based on this analysis, the court granted the University’s motion for summary judgment, concluding that the Walsh had failed to establish that her treatment during rotation was sufficiently severe or pervasive to constitute a hostile environment.

At best, [the student] has described a series of isolated comments relative to performance that took place intermittently over a period of several months in the Program that neither threatened nor humiliated Walsh nor prevented her from participating in the Program. This is inadequate to support a jury’s reasonable finding that Walsh endured sufficiently severe harassment.

Insert Colker and Grossman, Higher Education at p.210 before NOTE 3.

 

Notice

 

Grabin v. Marymount Manhattan College, 2014 U.S. Dist. LEXIS 79014, 2014 WL 2592416 (S.D.N.Y. June 10, 2014).  http://www.leagle.com/decision/In%20FDCO%2020140611E99/GRABIN%20v.%20MARYMOUNT%20MANHATTAN%20COLLEGE

 

Heather Grabin, a communications major, was given a failing grade in group-work oriented, web-design, communications course (Comm 225) at Marymount Manhattan College.  Grabin’s attendance exceeded a rule in the syllabus that allowed for a maximum of two unexcused absences.  The student contends that all her absences were due to doctors’ visits and hospitalizations for serious infections related to her, disability, thalassemia, which is a blood disorder.

 

When in the hospital, the student sent several emails to her Comm. 225 professor, explaining her situation and asking for ways to make up the missed classes.  These requests either went unanswered or she was told it would be very hard to make up the missed classes and exercises. The professor declined to identify any way for her to make up the missed work and recommended to her that she drop the class.  At about the same time, a Marymount administrator gave her a different message, telling her, “everything would be taken care of.”

 

Grabin also sought assistance from the Dean of Students.  The Dean made some suggestions and encouraged her to meet again with the professor.  But the Dean deferred to the authority of the professor to enforce attendance rules. The record does not reflect any direction from either the professor or the dean that the student should take her concerns to the disabled student services office.

 

Following receipt of the failing grade, Grabin made multiple unsuccessful informal efforts to receive reconsideration of her grade, subsequently filing a formal grade appeal.  The College denied her request to meet directly with the appeal committee, which twice upheld her grade in the communication class.  As a result of the failing grade, the student failed to receive her degree or diploma.

 

Grabin sued the College under Section 504 of the Rehabilitation Act of 1973 for disability discrimination on the grounds that it failed to accommodate her disability.  The College responded with a motion for summary judgment on the grounds that Grabin was not an individual with a disability, was not qualified, and that she had not requested an accommodation and, even if she had, what she wanted would constitute a fundamental alteration.

 

The College’s motion failed.  One basic reason was that the court found both sides had not submitted as much evidence as they should have, leaving several material questions unresolved.  In this vein, the court declined to find that Grabin was an individual with a disability, only that she had placed enough into evidence to raise a question for further resolution at trial.  Similarly, as to qualification, the court noted that “Plaintiff’s testimony indicates that, if she had been permitted extra time, or additional instruction, she could have made up the in-class work she had missed while absent.” This was sufficient to survive a motion for summary judgment.  (Grabin was only one course short of her degree.)

 

The most notable issue in this dispute is whether Grabin had ever requested an accommodation. It appears that the student did not register with the College’s disabled student services office or provide it with documentation necessary to support an accommodation request. This is particularly significant as the student handbook states that, students who want accommodations should register with its disabled student services office and that “[i]nforming other College offices, faculty, or staff does not constitute registering with the office.”

 

The court’s analysis of this question begins by stating that, “a defendant is not liable for failure to provide a reasonable accommodation under the ADA if the plaintiff does not ask for an accommodation, or fails to provide information necessary to assess the request for an accommodation.”  The court points out however that the student identified her disability on her transfer and housing registration forms and that a reasonable fact-finder could determine that:

 

[P]laintiff notified Marymount “repeatedly and clearly regarding her disability…. More specifically, Plaintiff repeatedly requested accommodations in order to complete Comm 225. It is also conceivable that a jury could determine that the statements of Marymount’s senior administrators—telling Plaintiff, among other things, that “everything would be taken care of”—reasonably conveyed to Plaintiff that she had properly notified Marymount of her disability and had requested an accommodation of that disability.

 

As to the argument that Grabin’s requested accommodation(s) would constitute a fundamental alteration(s), the court both noted that academic decisions are entitled to deference but, as in several other recent cases, these are fact intensive case-by-case determinations.  The court’s opinion further suggests that some differences may also exist given the kind and scope of accommodation requested and the field of study.  The court stated, in pertinent part:

 

[The precedents concerning medical students cited by College] are qualitatively different from the instant case, not least of which because they were rendered upon more completely developed records than has been presented to this Court. Yet most importantly, these cases are factually distinct from the instant case. Here, Plaintiff sought an accommodation for several assignments in one course—a web design seminar—towards her communications degree, not to be excused from passing her first year of medical school.

 

Also pertinent to the court’s determination was that in every other course the teacher was able to figure out a way to accommodate Grabin and with these accommodations she was able to pass the courses.

 

If ever a case justified disability training for all faculty, it is this one.

 

Insert Colker and Grossman, Higher Education at p. 196 before Documentation.

 

 

Reasonable Accommodations/Auxiliary Aids/Academic Adjustments

 

Testing accommodations

The Summer Reading List for last year reported that the District court in Rawdin v. ABP, had concluded that an acquired learning disability following treatment for brain cancer is not a disability, when the individual is academically and professionally successful, and has both IQ and performance scores higher than the average individual in the general population. Rawdin v. American Board of Pediatrics, 985 F. Supp. 2d 636 (E.D. Pa. 2013):

Subsequent to circulation of the Summer Reading List, the Third Circuit affirmed the judgment of the district court in favor of the ABP.  Rawdin v. American Bd. of Pediatrics, 582 Fed. Appx. 114 (3d Cir. Pa. 2014). However, the Third Circuit assumed, without deciding, that, Dr. Rawdin was an individual with a disability.  Consequently, the Third Circuit’s opinion focused on whether Dr. Rawdin was entitled to accommodations that he was denied either on the examination or as an alternative to the examination.  The Court stated that under Title III regulation 28 C.F.R. § 36.309, Dr. Rawdin was entitled to an exam that “best ensured” that it was measuring his knowledge and aptitude and not his disability.  The Court concluded that the exam offered to Dr. Rawdin, with accommodations like extra time, met this standard. The testimony of the ABP witnesses at the District Court level, demonstrated to the Court’s satisfaction that the exam is not context free, requiring test-takers to dredge up facts from memory, a format that would be very challenging for someone with Dr. Rawdin’s impairments. Rather, the Court concluded that the exam is context-based requiring responses to scenarios.   Moreover the accommodations proposed by Dr. Rawdin, an open book exam, an essay rather than multiple-choice exam, direct observation or a portfolio review by the ABP instead of any exam, or a waiver of the exam, all constituted an undue burden or a fundamental alteration.

Insert Colker and Grossman, Higher Education at p. 316 before NOTE 2.

Individuals with mobility impairments

 

Murillo v. Citrus College, 2014 Cal. App. Unpub. LEXIS 6111 (Cal. App. 2d Dist. Aug. 28, 2014).  http://www.courts.ca.gov/opinions/nonpub/B248201.PDF

This is an unpublished opinion (that is not citable) by a state court.  It is included nonetheless for its potential for use in the classroom and other teaching settings.

 

Ricardo Murillo is an individual with quadriplegia who attended Citrus College. While at the College the student experienced the sudden onset of autonomic dysreflexia, a common side effect of quadriplegia entailing excessively high blood pressure. The student asked a nurse at the campus health center to help him take three medications by lifting the pills to his mouth. The Health Center’s staff would not provide this assistance and explained to the student that it was their policy not to administer medications to students.

 

On the grounds that the College was refusing to provide a reasonable modification, the student sued the College in state court under the authority of both California antidiscrimination law and Title II of the ADA.  The College filed a motion for summary judgment on the grounds that to provide medication services would constitute a fundamental alternation of its program as it provided such services to no one. The district court agreed and granted the motion for summary judgment.

 

The student appealed the determination of the district court.   On a number of grounds, the appellate court concluded that the district court determination was in error. As has been recently noted in other reversals of summary judgment, citing to PGA v. Martin, the appellate court stated,  “[T]he determination of what constitutes [a] reasonable modification is highly fact-specific, requiring case-by-case inquiry.”  …. ‘[M]ere  speculat[ion] that a suggested accommodation is not feasible’ falls short of the ‘reasonable accommodation’ requirement.”  Further, fundamental alteration is an affirmative defense with the burden on the College and the record had not yet been developed enough to decide this issue.  For example, the court wondered about the hours and staffing at the health center.  Moreover, it was not clear on the record whether this modification could be implemented elsewhere by the College such as the DSS office.

 

The appellate court also found unpersuasive the not uncommon argument of, “if we do it for this student, we will have to do it for all (or too many) students.”

 

This argument ignores the fact that the plaintiff is seeking an “accommodation” and not a change to the Health Center’s general policies with respect to other students. Discrimination may be shown precisely where the defendant treated plaintiff the same as everyone around her, despite her need for reasonable accommodation. Accordingly, a person with a disability may be the victim of discrimination precisely because she did not receive disparate treatment when [the individual] needed accommodation. [citations omitted]

 

Finally, the appellate court acknowledged that the College raised health and safety concerns that must be considered.  But again, the court did not consider appropriate to do so on a motion for summary judgment.

 

The defendants are entitled, under the ADA’s implementing regulations, to “impose legitimate safety requirements necessary for the safe operation of its services, programs, or activities[,]” so long as such “safety requirements are based on actual risks, not mere speculation, stereotypes, or generalizations about individuals with disabilities.” (28 C.F.R. 35.130(h).) However, here, there are triable issues of fact as to whether the defendants’ safety concerns could be alleviated by giving the Health Center copies of the plaintiff’s prescriptions or requiring the plaintiff to execute a waiver with respect to claims that could arise as a result of the Health Center’s assisting with administering his medication.

 

For the above reasons, the appellate court reversed and vacated the district courts order granting summary judgment to the College and the student was awarded his costs on appeal.

 

Insert Grossman and Colker, Higher Education at p. 223 before Burden and Order of Proof.

 

Individuals with sensory impairments

As reported last year, on January 10, 2014, the National Federation for the Blind filed a complaint, in Dudley v. Miami University (S.D. Ohio 2014) (1:14-CV-00038).  See https://nfb.org/images/nfb/documents/pdf/miami%20teach.pdf (last viewed on May 22, 2014).

The complaint in this matter alleged that, a blind student pursuing a degree in zoology for the objective of attending veterinary school at Miami University, a public entity, intentionally violated title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973 by acting “with deliberate indifference” and failing to provide necessary auxiliary aids or modifications in the student’s classes and labs.  According to her complaint, the University sent a letter to her instructors suggesting that only two modifications were necessary: offering all classroom material in Rich Text Format and allowing double-time for exams and quizzes.  The letter to the faculty made no mention of Braille textbooks, tactile graphics, human assistants, timely course materials or accessible learning management software — all accommodations she stated were necessary. Her lecture instructors used LearnSmart to manage homework assignments, which she states was not accessible to her.  She also was not permitted to participate fully in lab activities.

The student, some teachers, and a graduate assistant brought a number of the identified deficiencies to the attention of the University.  In several instances, the student proposed solutions, but the University allegedly failed to act on this notice or advice. She also alleged that Miami University made technology procurement decisions with deliberate indifference to her rights in procuring inaccessibiletechnology even though accessible technology existed and was being used at other universities.

The student sought to have her grades expunged, receive a refund of tuition and costs, and an award of compensatory damages, attorneys’ fees, and prospective injunctive relief in the form of effective and timely modifications and adjustments in all classes and labs.

On April 7, 2014, the United States initiated an investigation of the above issues as well as broader issues.   On April 23, 2014, the Federal District Court tolled the proceedings, allowing the parties and the United States an opportunity to resolve this matter without further litigation.   Consequently, at this time, the University has not filed an answer to the NFB complaint nor has it exhausted its opportunity to file for a motion to dismiss the NFB complaint.

On June 25, 2014, DOJ advised the parties that it had found violations of Title II of the ADA at Miami University.  Among the violations, DOJ found that Miami University:

  • Used technologies that are inaccessible to individuals with disabilities, including those with learning, hearing, and vision disabilities
  • Failed to ensure, through the provision of appropriate auxiliary aids and services, that communications with individuals with disabilities are as effective as communications with others.
  • Failed to reasonably modify its policies, practices, and procedures where necessary to avoid discrimination on the basis of disability.

To date, the parties and DOJ have not reached a settlement and on May 12, 2015, with the consent of counsel for the plaintiff, the United States filed with the Federal District court a motion to intervene. http://www.justice.gov/opa/pr/justice-department-moves-intervene-disability-discrimination-lawsuit-alleging-miami

 

The motion for intervention rests on a number of arguments including that:

 

  • Due to the tolling, the litigation is still at its very earliest procedural stages
  • The disposition of this case impacts the United States’ interest in eliminating disability discrimination effected through the use of inaccessible technologies in higher education. This is an area of great public importance because educational institutions are increasingly using various technologies in their educational programs.
  • The NFB represents the interests of persons with vision impairments but a broader range of disabilities is implicated in this matter including hearing and learning disabilities.
  • The Department of Justice plays a central role in interpreting, enforcing, and implementing the ADA and the Department’s Title II regulation and the outcome of this litigation may adversely impact that responsibility.

 

At this time, some observers are predicting a settlement agreement under the supervision of the court. The plaintiff has withdrawn from Miami University and enrolled at another university.

Insert, Colker and Grossman, Higher Education at p. 260 after NOTE 3.

Argenyi v. Creighton University

Last year’s Reading List reported, in a case involving accommodations for a student with a hearing impairment, that summary judgment for Creighton University had been reversed and the matter was to be set for trial.    Argenyi v. Creighton Univ., 703 F.3d 441 (8th Cir. Neb. 2013).

Following a jury verdict that Creighton University had denied a deaf student auxiliary aids and academic adjustments the federal district court considered Argenyi’s request for declaratory, equitable, and injunctive relief. At the end of 2013, the court ordered the University to provide Argenyi with auxiliary aids and services for the remainder of his medical school education at Creighton including CART in didactic settings and sign-supported oral interpreters in small-group and clinical settings.  The court denied Argenyi’s request for reimbursement for the over $130,000 he had spent on CART and other interpreting services.

In May of 2014, the question of fees for the “prevailing party” was decided by the district court.  Creighton was ordered to pay Argenyi and his team of eight lawyers $487,000 for attorney fees, expert fees, and costs.  The court ruled that the jury’s verdict that the University had discriminated against Argenyi was sufficient to establish that he was the “prevailing party.”  Argenyi v. Creighton Univ., 2014 U.S. Dist. LEXIS 63726, 2014 WL 1838980 (D.Neb.)(D. Neb. May 8, 2014)

After taking a leave of absence, Argenyi returned to the University this past July to begin his last two years of medical school.  In the meantime, Creighton filed a notice of appeal in the Eighth Circuit, focusing on the question of undue burden.  Subsequently the parties announced a confidential settlement.  It is known that Creighton withdrew its appeal and that Argenyi is reported to be happy with the terms of the settlement.

Insert Colker and Grossman, Higher Education at p.280 after NOTE 1.

Food allergy accommodation

According to the Food Allergy Research and Education (FARE) foundation, “food allergy reactions send someone to the emergency department every three minutes, resulting in more than 200,000 emergency department visits in the U.S. per year. The increasing number of people with food allergies, coupled with the fact that teenagers and young adults are at the highest risk for fatal food-induced anaphylaxis, makes this a critical issue for colleges and universities.”  In response to these urgent circumstances, FARE has issued 53 pages of Pilot [draft] Guidelines for Managing Food Allergies in Higher Education, including checklists and model policies.  http://www.foodallergy.org/document.doc?id=382  The topics covered in the pilot guidelines include:

  • A clear process for requesting accommodations/modifications
  • Documentation required to establish an individual’s food allergy as a disability
  • A process for determining appropriate accommodations
  • Strategies for implementing accommodations
  • Outreach and marketing so that students and others know of food allergy/celiac disease accommodation services
  • Assessment of services, assuring compliance and remedying mistakes
  • Emergency response plans, training and signage including how to respond to anaphylaxis and promptly administer epinephrine
  • Training including who should receive it
  • Food preparation, production, avoiding cross-contact or using separate equipment, sanitizing, labeling, and serving
  • Student responsibilities
  • Confidentiality of student documentation and records

 

Insert Colker and Grossman, Higher Education at p. 317 before Safety.

 

 

Students with Psychological Disabilities

Settlement with Quinnipiac University http://www.ada.gov/ quinnipiac_sa.htm

University counselor, possibly “over-reacting,” concluded that a student was self-destructive or suicidal, called ambulance and had student hospitalized.  Before Student left hospital she was handed papers by Quinnipiac which placed her on “mandatory medical leave” with return contingent upon “assess[ment] by a university-designated psychiatrist.”   The perspective of DOJ is that college violated Title III of the ADA because it failed to engage in an individualized interactive process or even consider modifications to its dismissal policies including housing student with her parents and taking classes on-line. Analysis does not suggest that emergency response or even decision to dismiss Student from the dorm was part of the violation. The settlement agreement provides that Quinnipiac will conduct an individualized assessment and case-by-case determination as to whether and what modification(s) can be made to allow students with mental health disabilities participate in the educational programs at Quinnipiac, and to continue to attend their classes while seeking treatment for mental health conditions and to pay the student $17K for emotional distress, pain and suffering, and other consequential injury and another $15K to student loan provider to reimburse for lost tuition.

 

Insert Colker and Grossman, Higher Education at p.319 following the third paragraph.

 

Hershman v. Muhlenberg College, 17 F. Supp.3d 454 (E.D. Pa. 2014).

Student at Muhlenburg College, close to graduation, missed an unspecified number of classes due to his depression, and as a result, he did not satisfy the attendance requirement for one class. The professor refused to make any accommodation to allow the plaintiff to pass the class. Since successful completion of the class was a graduation requirement, the Student sought to substitute credit from another course to satisfy the prerequisite, but the department chair denied plaintiff’s request.  Student and his parents met with the College and were informed that he would fail the class unless he obtained a medical withdrawal.

It appears that the Student took a medical withdrawal with regard to the class in question.  At the College’s invitation, he and his family attended ceremony but the program for the ceremony listed an asterisk next to his name indicating a later graduation date.  A semester later, the Student satisfied the graduation requirements and received his diploma.

The student subsequently sued the College under Title III of the ADA on grounds that it failed to accommodate him and for “intentional infliction of emotional harm,” a state law tort claim.  The latter claim was based on the “emotional distress” he experienced due to the asterisk in the graduation program.

The College filed a motion for dismissal of the Student’s complaint on the grounds that he was not a qualified individual with a disability as the accommodations he sought were not “reasonable.” Their implementation, the College argued, would require a fundamental alteration to the College’s program.

The College’s motion for dismissal failed.  (There does not appear to have been a dispute over whether the Student was an individual with a disability.)  The district court concluded that the Student was a qualified individual as he completed his course of study and graduated. Most importantly, the court concluded that it did not yet have sufficient information to determine whether the Student’s requested accommodations were reasonable or unreasonable because the determination of what is a fundamental alteration is “a fact specific question,” as the Supreme Court explained in PGA v. Martin.  The court was concerned that it did not know about certain facts it considered relevant, including the Student’s major, the nature of the course in question, the nature of the course the student proposed to substitute, and why both the professor and the dean refused to make any form of accommodation.  Consequently, the court ordered discovery to proceed on the Student’s ADA claim.

Based on state law precedents, the College’s motion to dismiss was granted on the tort claim.

Insert Colker and Grossman, Higher Education at p.211 after Note 2.

 

 

Quinones v. University of Puerto Rico, et al., No. 14-1331, 2015 WL 631327, 2015 U.S. Dist. LEXIS 18319, 31 Am. Disabilities Cas. (BNA) 471 (D. P.R. Feb. 13, 2015).

Karina Quinones, MD, entered an ophthalmology residency program at the University of Puerto Rico in July of 2011.  At approximately the same time, she became addicted to a number of drugs prescribed to support sobriety and to help her concentrate in school, including Adderall.  To support the fact that her impairment substantially interfered with major life functions, she averred that her addiction to Adderall caused her visual disturbances, speech problems, and dizziness.  The court also noted that as a result of her addiction she had problems in complying with certain requirements of the Residency Program.  In September of 2012, Dr. Quinones was dismissed from the program.  Pursuant to a settlement agreement, she was permitted to apply for readmission in November of 2012. At that time, Dr. Quinones asked for an “accommodation” in the form of readmission and she provided evidence to the University that she had been sober for approximately 20 months, clean for “a little over three months,” and was actively participating in Alcoholics Anonymous.  In April of 2013, the University denied her request for readmission.  Shortly thereafter she filed suit for disability discrimination under Title II of the ADA and Section 504 of Rehabilitation Act.  The University responded with a motion to dismiss.

In the mix of issues before the court, the most important one was whether Dr. Quinones was drug-free long enough to qualify for the “safe-harbor” provision of these laws that pertains to the disability of drug-addiction. Under the ADA (and Section 504) if a person is a “currently engaging in the illegal use of drugs,” including abuse of prescription drugs, a covered entity may take adverse action on the basis of such use. However the ADA protects “[i]ndividuals who are recovering from an addiction to drugs, as the statute aims to protect them from the stigma associated with their addiction” To achieve this objective the ADA contains a “safe harbor” that extends ADA coverage to an individual who:

  • has successfully completed a supervised drug rehabilitation program and is no longer engaging in the illegal use of drugs, or has otherwise been rehabilitated successfully and is no longer engaging in such use;
  • is participating in a supervised rehabilitation program and is no longer engaging in such use; or
  • is erroneously regarded as engaging in such use, but is not engaging in such use . . . .

 

Relying largely upon employment discrimination precedents, in the opinion of the court, the University did not violate the ADA or Section 504 in treating Dr. Quinones without regard to the protections of the safe harbor provision.  According to the court, there is no “bright line” for how long an individual must be clean to no longer be a “current drug user.”  This determination is to be made on a “case by case” basis.  “[T]he ‘safe harbor’ provision applies only to [individuals] who have refrained from using drugs for a significant period of time.”  The courts also agree that a significant period of time must pass for an individual to not be considered a current user. This is because this “safe harbor” provision “exclude[s] from statutory protection an employee who illegally uses drugs during the weeks and months prior to her discharge, even if the employee is participating in a drug rehabilitation program and is drug-free on the day she is fired.”  A “current drug user” is one whose illegal use “occurred recently enough to justify a reasonable belief that a person’s drug use is current.”

In addition to basing its decision in favor of the University on the short duration of the time Dr. Quinones had refrained from illegal drug use, the court also noted that the duration of the addiction is pertinent and that certain fields may justify greater caution than others. “[A] short period of abstinence, particularly following such a severe drug problem, does not remove from the employer’s mind a reasonable belief that the drug use remains a problem.”   A court may examine “the level of responsibility entrusted to the employee; the employer’s applicable job and performance requirements; the level of competence ordinarily required to adequately perform the task in question; and the [individual’s] past performance record.”

Insert Colker and Grossman, Higher Education at p.126 after Note 1.

The Intersection of Race, National Origin and Disability

Salmeron v. Regents of the University of California, No. C 13-5606, 2014 U.S. Dist. LEXIS 80344, 2014 WL 2582712 (N.D. Cal.06/09/14).

A claim of discrimination in dismissal from medical school filed under Section 504, the ADA, and Title VI of the Civil Rights Act of 1964 is sufficient to withstand a motion for summary judgment by alleging that the individual’s minority group status (Mexican American) and disability (LD) status were known to the institution, the university engages in interactive communications and provides accommodations to white and other “non-Mexican American” individuals with disabilities but refuses to engage in the interactive process and denied accommodations to the plaintiff.  Such a claim is further supported when it is alleged that following dismissal, the Dean of the School refused to follow a grievance panel’s recommendation of reinstatement and the institution used the student’s image as part of diversity-related recruitment efforts, even after the student was dismissed.  “Although it is a close call, the court finds these allegations sufficient to plausibly allege discriminatory intent.”

 

Retaliation

Cottrell v. Norman, 2014 U.S. Dist. LEXIS 101645, 2014 WL 3729215 (D.N.J. July 25, 2014). http://law.justia.com/cases/federal/district-courts/new-jersey/njdce/1:2012cv01986/272545/66/

 

Making use of disability parking spaces, parent (Cottrell), her companion, and daughter with severe disability visit and participate in programs open to the public at Rowan University, a private school.  Cottrell and her companion “are self-described longtime ‘advocates for the disabled’ and often challenge parking violations of individuals who illegally park in handicap parking spaces.”  In March 2010, parent’s companion videotaped a vehicle with an expired placard parked in a designated disability space at the University.

 

In April, Cottrell drove her daughter to the campus to participate in a “Get Fit” class. Cottrell noticed the same car with an expired placard in a disability space. This time, she got in a verbal confrontation with the driver, got into her car, and took the placard.  Following a complaint by the driver, campus and local police arrested Cottrell at her home for criminal charges resulting from the event. She was also given a no-trespass order from the college, which stayed in effect even after the criminal charges were dropped.

 

Cottrell and her companion sued under Title III the ADA for discrimination and retaliation. Defendant filed a motion for summary judgment. Plaintiffs’ Title III discrimination claim was dismissed, because neither individual was disabled.  However, the court found that plaintiffs did have standing to assert a retaliation claim as “[t]he ADA … makes it unlawful to retaliate against or intimidate any individual because he or she has opposed any act or practice made unlawful by the ADA …” [emphasis added]

 

Although the plaintiffs had standing to assert retaliation, their claim failed on its merits as the defendants convinced the court that the adverse action was causally connected to impermissible conduct by the plaintiffs, not their protected activities.  The University had not taken any adverse action when the plaintiffs taped unlawfully parked cars.  The action was taken only following harassment of and theft from a driver. “[E]ven if plaintiffs had come onto campus to protect disabled persons’ parking rights, [it] does not mean they can conduct themselves in any manner without consequence. The cloak of the ADA does not extend its protections that far.”

 

Widomski v. State Univ. of N.Y. (SUNY) at Orange, 933 F. Supp. 2d 534 (S.D.N.Y. 2013)

 

Second Circuit found that the convening of a disciplinary/dismissal hearing following a letter from student’s attorney alleging that the student was misperceived as having a disability and unlawfully excluded from phlebotomy clinics, did not establish retaliation where the convener of the hearing had “a good faith belief “that the student had falsified required clinical reports and the student failed to establish that this belief that was a pretext for discrimination.

 

Sjöstrand v. Ohio State Univ., 750 F.3d 596 (6th Cir. 2014)

 

University’s articulated legitimate nondiscriminatory reasons for not admitting applicant to its graduate school of psychology were sufficient for federal district court to order summary judgment for University.  However, as reported in last year’s Summer Reading List, applying a classic disparate treatment analysis (McDonnell Douglas v. Green, 414 U.S. 811 (1973)), the Sixth Circuit reversed in light of the fact that the applicant’s disability, Crohn’s disease, was known by the admissions committee and discussed in the admissions interview, the applicant had very strong paper qualifications in comparison to other admitted applicants, and, when she asked, she was not given by the school prompt, clear, or consistent reasons for her rejection.

Subsequent to the publication of last year’s Summer Reading List, a jury trial was held and the jury found for the University. Case: 2:11-cv-00462-MRA Doc #: 103 Filed: 09/29/14

See also McKee v. Madison Area Tech. College, 2014 U.S. Dist. LEXIS 70967, 2014 WL 2159257 (W.D. Wis. May 22, 2014). http://leagle.com/decision/In%20FDCO%2020140527G48/McKEE%20v.%20MADISON%20AREA%20TECHNICAL%20COLLEGE

In a decision contrary to law, Federal District Court concludes that ADA covers disability-related retaliation claim by students, but Section 504 does not.  Due to absence of evidence of discriminatory intent, court granted defendant’s motion for summary judgment on all federal claims and remanded plaintiff’s state law claims for breach of contract and negligent infliction of emotional distress to state court.

 

 

Facilities Access

 

Williams v. Southern Univ. & Agric. & Mech. College, 2012 U.S. Dist. LEXIS 145852, 2012 WL 4829488 (M.D. La. Oct. 10, 2012)

[This is a citation to a discovery motion. I can’t find either the complaint or the consent decree on Lexis.  Correct links to the complaint and the settlement are provided below and even then I may not have a link to the final amended complaint]

Lawsuit: http://theadvocate.com/csp/mediapool/sites/dt.common.streams.StreamServer.cls?STREAMOID=miL3Pu8Yv$M$aME5$ZQguJM5tm0Zxrvol3sywaAHBAnivlp5nxSJnEO0Mfd4eDSfE0$uXvBjavsllACLNr6VhLEUIm2tympBeeq1Fwi7sIigrCfKm_F3DhYfWov3omce$8CAqP1xDAFoSAgEcS6kSQ–&CONTENTTYPE=application/pdf&CONTENTDISPOSITION=Southern%20Williams%20Lawsuit.pdf

Settlement: http://theadvocate.com/csp/mediapool/sites/dt.common.streams.StreamServer.cls?STREAMOID=jQQKWnilRvICOWv3Ez02v5M5tm0Zxrvol3sywaAHBAmTauUdzj2jhKYG34RyvxpFE0$uXvBjavsllACLNr6VhLEUIm2tympBeeq1Fwi7sIigrCfKm_F3DhYfWov3omce$8CAqP1xDAFoSAgEcS6kSQ–&CONTENTTYPE=application/pdg&CONTENTDISPORTION=Southern%20Settlement.pdf

 

As the result of a gunshot that severed her spine, Kayla Williams uses a wheelchair for mobility and a catheter and bag for toileting.  In her complaint against Southern University, as amended, Williams alleged that Southern violated Title II of the ADA and Section 504 of the Rehabilitation Act by maintaining and refusing to remove multiple barriers to accessing the academic, athletic and social programs and facilities of the University.  In her complaint, Williams cites to inaccessible paths of travel, ramps, entrances, bathrooms, classrooms, as well as work tables and desks in the building in which her MBA program was held.  She also provides detailed examples of inaccessible features in the athletic and public event venues of the University.

 

Most significant to this complaint are the insights it provides as to the burdens such an individual may face as the result of inaccessible restroom facilities. She alleged that because she could not access the restrooms at the MBA program site, she suffered  “feelings of humiliation, embarrassment and indignity” when her catheter bag overflowed, often in public, leaving her to sit in her own urine, while waiting for a ride home to change her clothes. Moreover, in some instances, these conditions also created or exacerbated serious medical conditions.  As to the absence of appropriate desks for tables, Williams alleged that she was required to “sit at a contorted and uncomfortable angle in order to use classroom desks” because they weren’t tall enough to accommodate her wheelchair. “It is especially difficult for her when she needs to use a computer, because she cannot slide under the desk to reach the computer keyboard.”

 

In 2014, the University and Williams entered into a consent decree agreement.  This agreement includes many provisions that are logically-related to her complaint including correction of steep ramps; additional wheelchair and companion seating at sports and other venues; accessible washrooms in both classroom buildings and sports venues, and provision of accessible desks in academic settings.

Of note are several provisions not regularly found in similar agreements, including:

  • A transition plan with a schedule that spreads implementation over a period of five years based on logical priorities.
  • To ensure that the option of moving a program from an inaccessible site to an accessible one is not merely a theoretical solution, the plan provides that the University “will designate one individual … with authority to move classes or other events to accessible locations … and will publicize the identity and contact of that person ….
  • University is required to “employ an ADA Coordinator who shall have the responsibility and authority to review all renovations, new construction, or modifications to facilities to ensure that the requirements of the ADA shall be This person shall also have the responsibility and authority to relocate academic classes, programs or events to accessible facilities to ensure that all programs meet the requirements of the ADA.”
  • When making a program accessible requires structural changes, “[t]he changes shall be made as expeditiously as possible, and must be completed within two years of the approval of [the] Consent ”
  • To ensure that once a barrier is removed, it will not reemerge due to lack of maintenance, the University is required to “maintain in operable working condition those features of facilities and equipment that are required to provide access to individuals with ’ This responsibility extends to night-time programs, as well.
  • In the event of any temporary interruptions in services or access, the University “will evaluate the impact of the interruption in services or access on accessibility of [its] programs to individuals with disabilities. … [T]he [University] will plan and implement such measures as are necessary to make its programs … accessible to persons with disabilities …. Such measures may include the designation, with appropriate signage, or alternate accessible routes, or relocation of programs or services to accessible ”

 

Another important concern addressed under the decree is fire safety.  For example, the decree provides that the University will create “a place of refuge” in its sports stadium.  It also provides for fire safety and training for emergency evacuation for persons with mobility impairments “on each floor of each building on campus, and will train all personnel with responsibility for carrying out this procedure, and will drill them at least once each semester on carrying it out.”  In addition, all faculty and staff are to be informed as to how to evacuate persons with mobility impairments in case of an emergency. The decree also provides for unspecified damages, attorney’s fees and costs for Williams.

Fortyune v. City of Lomita, 766 F.3d 1098 (9th Cir. Cal. 2014); cert. denied __ U.S.__ (June 29,2015).  http://cdn.ca9.uscourts.gov/datastore/opinions/2014/09/05/12-56280.pdf

http://www.supremecourt.gov/orders/courtorders/062915zor_4g25.pd 

Robin Fortyune is a paraplegic who uses a wheelchair for mobility. In his ADA Title II complaint against the City of Lomita, he alleged that, “he experiences ‘great difficulty, discomfort and, even fear for his safety’ when frequenting facilities in the City because none of the City’s public on-street [diagonal] parking is accessible to people with disabilities.”  The City of Lomita had the matter removed from state to federal district court.  The City argued that, “absent the adoption of ADA implementing regulations specifically targeted toward on-street parking, it is not required to provide accessible on-street parking.” The district court denied the motion to dismiss, concluding that “the broad language of the ADA requires public entities to ensure that all services, including on-street parking, are reasonably accessible to and usable by individuals with disabilities.”

 

The City appealed the district court decision to the Ninth Circuit.  Relying on the general regulatory language governing all Title II activities, such as 28 C.F.R. § 35.150 and 35.150(a), and U.S. Department of Justice published technical assistance guidance, the Ninth Circuit ruled that the program accessibility rules require the provision of on-street public parking even if there is no specific regulation requiring the installation of on-street public parking. “[A]t bottom, the regulation [28 C.F.R. § 35.150] mandates program accessibility for all normal governmental functions, including the provision of on-street public parking.” “T]he 2010 Standards contain detailed specifications for a range of different facilities, but none of them address on-street parking. However, nothing in 28 C.F.R. § 35.151 suggests that when technical specifications do not exist for a particular type of facility, public entities have no accessibility obligations.”

 

Further, in 1994, the Justice Department issued a technical assistance manual.  In pertinent part, that manual states: “If no standard exists for particular features, those features need not comply with a particular design standard. However, the facility must still be designed and operated to meet other title II requirements, including program accessibility.”  The Ninth Circuit accorded this guidance considerable weight, presuming it to be correct.. “An agency’s interpretation of its own regulations is entitled to deference.” …..   “[E]ven if we had doubts about the applicability of 28 C.F.R. § 35.151 to facilities for which no technical specifications exist, we would be bound to defer to the DOJ’s interpretation of the regulation because it is not “plainly erroneous or inconsistent with the regulation.”

Relying on two broad Title II regulations and DOJ technical assistance, the Ninth Circuit concludes:  “The text of the ADA, the relevant implementing regulations, and the DOJ’s interpretation of its own regulations all lead us to conclude that public entities must ensure that all normal governmental functions are reasonably accessible to disabled persons, irrespective of whether the DOJ has adopted technical specifications for the particular types of facilities involved.”

 

 

Digital Access and Equality

The Department of Justice has published its spring 2015 regulatory agenda pursuant to Executive Order 12866, ‘‘Regulatory Planning and Review,’’ 58 FR 51735, and the Regulatory Flexibility Act, 5 U.S.C. 601 to 612 (1988). The agenda reveals that DOJ has separated the web access rule-making process for public entities from that of public accommodations.  The notice provides a schedule for the final comment period for the regulations for public entities (closing August 2015).  It also has information about rule making for captioning of movies at movie theatres, with a publication date of December 2015. See http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201410&RIN=1190-AA65 (split from RIN 1190-AA61).

Insert Colker and Grossman, Higher Education at p. 289.

The U.S. Department of Justice and the U.S. Department of Education, Office for Civil Rights, have become even more active than last year in taking enforcement actions against universities whose web sites and services are not accessible to students who use adaptive technology like JAWS software (or other screen readers) to read text.  These actions are usually taken under Title II but the same principles would apply to a Title III entity.

Two OCR letters, Youngstown State University and University of Cincinnati, issued at virtually the same time, are particularly noteworthy because they go further than in the past in explicitly stating how the regulations implementing Section 504 and Title II of the ADA apply to the virtual world.

Digital access in academia

University of Cincinnati, OCR compliance review #15-13-6001 (December 2014) http://www2.ed.gov/documents/press-releases/university-cincinnati-agreement.pdf

The University of Cincinnati is a public institution subject to Section 504 and Title II of the ADA.  According to data analyzed by OCR, it has approximately 43,000 students.  Approximately 31% of its undergraduate students participate online for some part of their course work; 9% exclusively on line; while 29% of graduate students participated solely on line.  3-5% of all students are registered with DSS.

 

The OCR letter in this matter is exceptionally instructive as it lays out the legal standards; applies the standards to concrete examples; and, provides a narrative with insights on how persons who use adaptive technology are challenged by in accessible electronic information technology (EIT).

 

The scope of OCR’s review of EIT was quite comprehensive, including:  general websites, such as admissions, academic program descriptions, athletics programs, library services, health services, faculty and student directories, research tools; and resources; academic courseware, in this case Blackboard; and distance learning. The letter is also noteworthy for the fact that it considers the impact of inaccessible EIT on more than just students.

 

OCR found numerous violations including ones that did not pertain to EIT.  For example, OCR found multiple shortcomings with regard to notice of nondiscriminatory practices and procedures. With regard to EIT, OCR found that the University lacked adequate tools and procedures for ensuring that its websites were accessible, that the content it posted on Blackboard was accessible, or that the content of its on-line learning programs was accessible.  Consistent with a growing theme in many areas of disability compliance, OCR explicitly rejected the use of a system that only addresses compatibility problems when a complaint is received. This letter also addressed the duty to caption videos.

 

The remedial agreement with OCR has four basic components:

  • Develop for OCR review a policy to ensure that information communicated through University websites, on-line or e-learning systems, course management systems or EIT are accessible to students, prospective students, employees, guests, and visitors with visual, hearing, and manual impairments.
  • Develop and implement a plan for accessibility audits by the access coordinator with audit accounting
  • Develop and implement a plan for acquisition and contracting that ensure purchases are accessible
  • Annual training on EIT access for faculty, staff, administrators, support staff, and student employees and a qualified individual available to assist them on complying with technical standards

 

The agreement also contains some significant quality control and monitoring provisions which will be in effect at least through 2018.

Insert Colker and Grossman, Higher Education at p.290 before Notes.

Youngstown State University, OCR compliance review #15-13-6002 (December 2014) http://www2.ed.gov/documents/press-releases/youngstown-state-university-letter.pdf

 

Youngstown State University is a public institution subject to Section 504 and Title II of the ADA.  It has a total undergraduate and graduate enrollment of 14,000 students; with 13% of undergraduates and 5% of graduate students receiving some part of their education on-line.

It appears that Youngtown State had fewer compliance challenges than did the University of Cincinnati.  For one thing, Youngstown had published guidance and standards for making many of its EIT activities accessible.  The basis for finding noncompliance at Youngstown was largely that it lacked active implementation procedures, training, and monitoring procedures necessary to implement its guidance and standards.

The remedies negotiated with Youngstown are very similar to those negotiated with the University of Cincinnati; albeit, the period of monitoring by OCR is presumed to be of a shorter duration.

Insert Colker and Grossman, Higher Education at p. 290 before NOTES.

The National Federation of the Blind, Anthony Lanzilotti and Mitchell Cossaboon v Atlantic Cape Community College, consent decree, D.N.J. Case No. 1:33-av-00001 (2015). https://nfb.org/national-federation-blind-and-two-blind-students-resolve-complaint-against-atlantic-cape-community

Atlantic Cape Community College (ACCC) is a public two year institution with approximately 7,000 students.  The consent decree resolves two students’ allegations of discrimination on the basis of disability. The College denies the allegations of discrimination and has admitted no wrongdoing. The agreement requires the College to work with a third-party consultant and the National Federation of the Blind to take steps to improve the educational experience of students with disabilities and to prevent discrimination against these students, including:

  • Conducting a technology audit and, based on the audit results, developing a plan to make all student-facing electronic and information technology used by ACCC accessible to students with disabilities no later than three years from the completion of the technology accessibility audit;
  • Making ACCC’s websites accessible to blind students within 240 days of the execution of the consent decree;
  • Making ACCC’s integrated library system and its website fully accessible to blind students;
  • Developing a plan to provide accessible instructional materials, including textbooks, course materials, and tactile graphics, to blind students and to other students with disabilities at the same time that these materials are made available to students without disabilities, and to implement this plan no later than three years from the effective date of the consent decree;
  • Requiring cooperation among faculty, staff, and ACCC’s Disability Support Services office to handle accommodation requests made by students with disabilities;
  • Reviewing and revising ACCC’s policies and procedures for accommodating students with disabilities and for processing and resolving grievances brought by students with disabilities, including requiring ACCC’s Disability Support Services office to self-report any failure to resolve a student’s complaint or accommodation request, triggering an automatic grievance procedure; and
  • Requiring training of all personnel on the Americans with Disabilities Act and on ACCC’s policies for accommodating students with disabilities, as well as training for such students on their rights and the procedures available to them to enforce those rights.

 

Insert Colker and Grossman, Higher Education at p. 290 before Notes.

DOJ edX settlementhttp://www.ada.gov/edx_sa.htm    Litigation not filed

A settlement agreement between the Department of Justice and edX, resolves allegations by DOJ that edX’s website, http://www.edx.org, and its platform for providing massive open online courses (MOOCs), were not fully accessible to individuals with disabilities, including individuals who are blind or have low vision, individuals who are deaf or hard of hearing and individuals who have physical disabilities affecting manual dexterity, in violation of Title III of the ADA.

According to DOJ, edX was created in 2012 as a nonprofit platform for universities to offer MOOCs. Today, edX has approximately 60 university and institutional members providing over 450 courses to over 3,000,000 learners.  The courses are offered largely for free in subject matters as varied as business, computer sciences, hard sciences, food and nutrition and social sciences.

Of note is the deference paid in this agreement to the Web Content Accessibility Guidelines (WCAG) 2.0 AA.   The agreement specifically requires edX to make significant modifications to its website, platform and mobile applications to conform to these guidelines.

The four-year agreement requires edX to:

  • make the edX website, its mobile applications, and learning management system software, through which online courses are offered, fully accessible within 18 months;
  • ensure that its content management system is fully accessible and supports authoring and publishing of accessible content within an additional 18 months;
  • provide guidance to course creators at its member universities and other institutions on best practices for making online courses fully accessible;
  • appoint a Web Accessibility Coordinator;
  • adopt a Web Accessibility Policy;
  • solicit feedback from learners on the accessibility of the courses;
  • conduct Web Accessibility Training for employees responsible for the website, platform, and mobile applications; and
  • retain a consultant to evaluate conformance of the website, platform, and mobile applications

Insert Colker and Grossman, Higher Education at p. 290 before Service Animals.

National Association of the Deaf, et al., v. Harvard University, et al., US Department of Justice statement of Interest, Civil Action No. 3:15-cv-30023-MGM, D. Mass (June 23, 2015).  http://www.ada.gov/briefs/harvard_soi.pdf

National Association of the Deaf, et al., v. Massachusetts Institute of Technology, US Department of Justice statement of Interest, Civil Action No. 3:15-cv-300024-MGM. http://www.ada.gov/briefs/mit_soi.pdf

The Justice Department has announced that it has filed Statements of Interest in these two matters.  Plaintiffs allege that Harvard and MIT violated the ADA and Section 504 by denying equal access to free online courses and lectures to individuals who are deaf or hard of hearing because they fail to provide appropriate auxiliary aids, benefits and services, including captioning.

Both Universities argue that the complaints should be stayed or dismissed until the Department of Justice issues regulations under the ADA on website accessibility.  They further argue that neither the ADA nor Section 504 of the Rehabilitation Act require the provision of captions on their online programming.

In its Statements of Interest, DOJ responds to the first argument by asserting that the Plaintiffs’ claims do not require the Court to “’unravel intricate, technical facts,’ but rather involves consideration of facts within the conventional competence of the courts ….”  “And because the title III rulemaking on website accessibility is not imminent, dismissal or stay of this case … would not materially aid this Court and would significantly prejudice the Plaintiffs …”

 

With regard to the second argument of the Universities, DOJ states that a public accommodation includes an “undergraduate, postgraduate private school, or other place of education,” such as MIT and Harvard. 42 U.S.C. § 12181 (7)(J).   Under Title III, public accommodations must ensure that persons with disabilities are not denied services “because of the absence of auxiliary aids and services.”  Further, public accommodations must furnish appropriate “auxiliary aids and services” where necessary for “effective communication.”  Auxiliary aids and services include,” open and closed captioning and accessible electronic and information technology,” among other methods. 28 C.F.R. § 36.303(b).  A similar duty exists under Section 504. 34 C.F.R. § 104.4(b).   See also 34 CFR 104.44(d).

Insert Colker and Grossman, Higher Education at p. 290 before Service Animals.

Are sales and service websites “public accommodations” under Title III of the ADA?

National Federation of the Blind v. Scribd, Inc., Case No. 2:14-cv-162,  2015 U.S. Dist. LEXIS 34213, 2015 WL 1263336 (D. Vt. Mar. 19, 2015) http://the-digital-reader.com/wp-content/uploads/2015/03/30-Opinion-denying-Motion-to-Dismiss.pdf

This opinion is worth reading for its comprehensive overview of the question of whether an entity that conducts business only by the Internet is a “public accommodation” subject to the anti-discrimination protections of Title III of the ADA

Scribd is a California-based digital library that operates reading subscription services on its website and on apps for mobile phones and tablets. Scribd’s customers pay a monthly fee to gain access to its collection of over forty million titles, including e-books, academic papers, legal filings, and other user-uploaded digital documents.

Because its websites are picture-based, they are not accessible to the adaptive technologies commonly used by visually impaired individuals.  These inaccessible conditions formed the basis of a claim by Plaintiffs National Federation of the Blind (“NFB”) and Heidi Viens.

 

Among the required elements of a claim for disability discrimination under Title III of the ADA is that the defendant “owns, leases, or operates a place of public accommodation” Scribd in a motion to dismiss the NFB complaint argued that, because the services and products of Scribd are accessed, selected, and purchased exclusively on the Internet, the NFB had not sufficiently alleged this required claim element.

This dispute was a matter of statutory construction.  Because the district court concluded that the statute (Title III) was “ambiguous” as to the question before it, it needed to consult other sources, including the statute’s legislative history and DOJ guidance, focusing on the “broader context and primary purpose of the statute,” reaching an interpretation that “avoids absurd results.”

The court denied Scribd’s motion to dismiss. Quoting from the Netflix decision of Judge Posner [see last year’s Summer Reading list], the court held that

The Internet is central to every aspect of the “economic and social mainstream of American life.” In such a society, “excluding businesses that sell services through the Internet from the ADA would ‘run afoul of the purposes of the ADA and would severely frustrate Congress’s intent that individuals with disabilities fully enjoy the goods, services, privileges, and advantages available indiscriminately to other members of the general public.

 

When the motion to dismiss by Scribd was denied, it asked the lower court to stay the action pending an appeal to the Second Circuit.  This would have put discovery and proceedings on the merits of the NFB’s claim in abeyance until the above jurisdictional question was addressed by the Court of Appeals. This motion failed and discovery was ordered to proceed.  Nat’l Fed’n of the Blind v. Scribd Inc., 2015 U.S. Dist. LEXIS 69440 (D. Vt. May 29, 2015).

Cullen v. Netflix, Inc., 600 Fed. Appx. 508, 2015 U.S. App. LEXIS 5257 (9th Cir. Cal. 2015); Earll v. Ebay, Inc., 599 Fed. Appx. 695, 2015 U.S. App. LEXIS 5256 (9th Cir. Cal. 2015).  Respectively, http://law.justia.com/cases/ federal/appellate-courts/ca9/13-15092/13-15092-2015-04-01.html;   http://cdn.ca9.uscourts.gov/datastore/memoranda/2015/04/01/13-15134.pdf

Within one week of the decision in Scribd, the Ninth Circuit issued two very brief, nearly identical, unpublished decisions following earlier Ninth Circuit decisions holding that a website is not a “public accommodation” absent some kind of connection to a brick and mortar facility.  For example, in Cullen, the  Ninth Circuit stated, “We have previously interpreted the statutory term “place of public accommodation” to require “some connection between the good or service complained of and an actual physical place.” See Weyer v. Twentieth Century Fox Film Corp., 198 F.3d 1104, 1114 (9th Cir. 2000). Because Netflix’s services are not connected to any “actual, physical place,” Netflix is not subject to the ADA.” See also National Federation of the Blind v. Target Corporation, 452 F.Supp.2d 946 (ND Cal., 2006).

National Federation of the Blind of California, Kelly, Hingson, and Pederson v. Uber Technologies, Inc., Case No. 14-cv-04086 NC, N.D. Cal (2015)

http://law.justia.com/cases/federal/district-courts/california/candce/ 3:2014cv04086/280572/37/

UberX is a widely available transportation service that uses mobile software applications to arrange rides between passengers and Uber’s fleet of UberX drivers. The National Federation of the Blind of California and several individuals who are blind alleged that Uber drivers, in violation of Title III of the ADA and California disability rights laws, refused them transportation services because they were accompanied by their guide dogs.

Uber filed a motion to dismiss in Federal District Court. The ADA lists twelve categories of entities that are public accommodations.  Uber raised multiple defenses, of interest here, that it was a technology company, not a transportation company, falling outside any of the any of Congress’s examples of a “public accommodation.”

The plaintiffs alleged that Uber’s operations fall under the listed category of “travel service” category, so Uber qualifies as a public accommodation. 42  U.S.C. § 12181(7)(f).

The ADA does not define travel services.  Without much discussion, the court accepted the plaintiffs’ argument.  Quoting from Carparts Distrib. Ctr., Inc. v. Auto. Wholesaler’s Ass’n of New England, Inc., 37 F.3d 12, 13 (1st Cir. 1994), the court stated, “Congress clearly contemplated that ‘service establishments’ include providers of services which do not require a person to physically enter an actual physical structure.”

An appeal in this matter may be expected.

See also Reyazuddin v. Montgomery County, No. 14-1299, 2015 U.S. App. LEXIS 10032, 2015 WL 3651710 4th Cir. (June 15, 2015). Yasmin Reyazuddin, who is blind, worked successfully for Montgomery County as a 311 operator prior to a workplace consolidation that included the adoption of new software that was not accessible to persons with visual impairments. The County concluded that she was no longer qualified to perform the essential functions of her position and did not transfer her or hire her into a position at the consolidated call center.  Instead, the County retained her salary level and reassigned her to other public contact positions which plaintiff described as “make-work” positions with limited daily tasks and no opportunity for advancement.  She alleged disability discrimination in employment under Section 504 of the Rehabilitation Act and Title II of the ADA on the grounds that, with accommodation, she was qualified to work in the new 311 service setting and that the reassignments provided to her were to “make-work” positions only.

As part of an $80 million upgrade, the County opened a new, consolidated call center using new software.  The software selected by the County can be operated in two “modes,” one of which was accessible to individuals with vision impairments and one of which was not, at least not without a significant work-around.  The County’s software license allows it to run the software in either mode.   The County, however, chose to run only the inaccessible (“high-interactivity”) version which makes some useful but not necessarily essential functions available to operators including: scripts to read to callers; a “solutions button” with a “short, concise paragraph about how the [C]ounty handles” the caller’s particular concern and instructions for employees on how to handle the call; a field for notetaking; a “service request template” with fields that automatically populate; and, a function for transferring calls to 911.

The District Court issued a summary judgment decision in favor of the County concluding that Reyazuddin, even with accommodation, was not qualified to perform the essential functions of a 311 operator at the new call center, that the accommodations she proposed were not reasonable as the County had demonstrated that they would entail an undue burden on the County, and that the County’s reassignment of the Plaintiff had satisfied its reasonable accommodation duties under Section 504.

The Fourth Circuit reversed the lower court finding that several issues remained in genuine dispute: 1) whether Reyazuddin could perform the essential job functions of a call center employee; (2) whether the County reasonably accommodated her; and (3), if the County did not, whether its failure to do so may be excused because the County had proven that her requested accommodations would impose an undue burden on the County.

This decision is rich with a range of employment discrimination issues, particularly ones pertaining to the implementation of emerging technologies.  It is the last issue — how to prove, measure, or calculate what is an undue burden — that may be of most interest to DSS professionals, as the arguments made by the County, accepted by the lower court and,rejected by the Fourth Circuit, are frequently heard in the post-secondary setting.

 

The Fourth Circuit concluded that the lower court had made several errors in its determination of undue burden. The lower court found relevant that the County had only budgeted $15,500 for accommodations.  The Fourth Circuit rejected this reasoning, stating in pertinent part, “Allowing the County to prevail on its undue hardship defense based on its own budgeting decisions would effectively cede the legal determination on this issue [undue burden] to the employer …. Taken to its logical extreme, the employer could budget $0 for reasonable accommodation and thereby avoid liability.  The County’s overall budget ($3.73 billion in fiscal year 2010) and the [new system] operating budget (about $4 million) are relevant factors. But the County’s line-item budget for reasonable accommodations is not.” (citations omitted).

 

The Fourth Circuit further faulted the lower court for not giving nearly enough weight to the fact that four other cities in the U.S., using the same software, are accessible to individuals who are blind by operating in both modes and by providing other modifications.  The Fourth Circuit also concluded that savings gained by the new 311 system and the availability of in-house computer personnel to address accessibility challenges also should be included in the consideration of undue burden.  Finally, the Fourth Circuit found it inappropriate to issue a summary judgment for the County on the issue of undue burden when affidavits of experts provided hugely different estimates as to the effect or cost of running a 311 system using both modes and making the highly interactive mode partially or fully accessible.  The Fourth Circuit reasoned that these differences could only be resolved through further proceedings.

Of note, relying on EEOC guidance, the Fourth Circuit also concluded that the duty to provide accommodation in the workplace through reassignment to a new position means transfer to a “meaningful equal employment opportunity … to attain the same level of performance as is available to nondisabled employees having similar skills and abilities.”  Whether the opportunities provided to Reyazuddin met this standard was also a question that needed to be resolved in further proceedings .

 

Finally, the Fourth Circuit concluded that Title II of the ADA does not confer on public employees the right to sue public employers for employment discrimination.  This is not a unique conclusion.  The same interpretation of Title II has been reached in four other circuits and is the “majority view.”   This conclusion does not impair the claims Reyazuddin has made under Section 504.

 

Stay tuned.  Reyazuddin has been languishing in “make-work” positions since 2009.

 

Insert Colker and Grossman, Higher Education at p. 87 before NOTE 2.

 

 

Disparate Impact Analysis

Tex. Dep’t of Hous. & Cmty. Affairs v. Inclusive Cmtys. Project, Inc., __ U.S. __, 2014 U.S. LEXIS 4912, 135 S. Ct. 46 (U.S. 2014).

 

In the introductory chapter to The Law of Disability Discrimination for Higher Professionals at page 6, Colker and Grossman present the thesis that a principle step in the legal history of the Section 504 of the Rehabilitation and the ADA was development and adoption of two judicial insights.  The first was that an intention to discriminate was not necessary to a policy or practice having a discriminatory impact on a prohibited basis and that the identical treatment of individuals was not necessarily equal treatment.

The legal tool for attacking policies and practices that are designed without a discriminatory purpose or intent but in fact have a discriminatory effect is called disparate impact analysis. This tool was first used to implement Title VII of the Civil Rights Act of 1964, addressing certain instances of employment discrimination.  Griggs v. Duke Power Co., 401 U.S. 424 (1971).   In 1985, in Alexander v. Choate, the Supreme Court concluded that, under certain circumstances, disparate impact analysis also could be used to challenge disability discrimination where a neutral policy had the effect of denying individuals with disabilities “meaningful access” to a state benefit. 469 U.S. 287, 303.

Historically, statistics have been used as an element of proof in class-wide disparate impact cases.  Just how much persuasive power will be accorded to those statistics has been a matter of dispute, with conservative and liberal judges reaching different perspectives.  Generally, class-wide disparate impact cases that rely heavily on statistics have become more difficult to win.

This issue was front and center before the Supreme Court in a recent race discrimination case concerning interpretation of Title VIII of the Civil Rights Act of 1968, the Fair Housing Act (FHA), Texas Department of Housing and Community Affairs v. The Inclusive Communities Project, Inc.   The FHA makes it unlawful to “refuse to sell or rent after the making of a bona fide offer, or to refuse to negotiate for the sale or rental of, or otherwise make unavailable or deny, a dwelling to any person because of race, color, religion, sex, familial status, or national origin.” 42 U.S.C. § 3604(a). The FHA further prohibits discrimination “against any person in the terms, conditions, or privileges of sale or rental of a dwelling, or in the provision of services or facilities in connection therewith,” based on those same protected characteristics. Id. § 3604(b).

The Low-Income Housing Tax Credit Program (LIHTC), 26 U.S.C. § 42(g)(1), provides tax credits to developers who build low-income housing. Federal law requires that credits be distributed through a state agency. In this matter, the plaintiffs case relied largely on statistical proof in asserting that the Texas LIHTC agency disproportionately allocated tax credits for housing construction in minority neighborhoods rather than for predominantly Caucasian neighborhoods.

With a number of cautionary notes, five Justices agreed that the FHA prohibited disparate impact discrimination in a race discrimination case and that a prima facie case of disparate impact discrimination could be established relying largely on statistical proof.  Among the cautionary notes:

  • To make a prima facie case, plaintiffs must not only present statistic evidence of disparate impact but also be able to identify the specific policies and practices of the defendant that caused these disparities.
  • Defendants must be given an opportunity to defend the policies or practices put into question by the statistical showing with any valid interests their policies serve.
  • Disparate impact discrimination does not exist unless the policies or practices in question are “artificial, arbitrary, and unnecessary barriers.”

Finally, the majority recognized that, in some situation, a race conscious remedy may be necessary to rectify disparate impact discrimination based on race.

The ruling in favor of the plaintiffs in this case “saved” the disparate impact theory under various race-based civil rights statutes.  In his dissent, Justice Thomas questioned the correctness of the Griggs decision.   Disability, disparate impact cases are brought under the FHAA, Section 504, or the ADA.   It is possible that the courts might cite this precedent to sustain disparate impact theories if challenged by defendants in disability-related cases.

Insert Colker and Grossman, Higher Education at p. 6.

 

 

Transit

Transit is not often a higher education issue.  An accessible transit system is nonetheless key to students and graduates with mobility impairments becoming productive members of the American workforce.  Last year’s Summer Reading List reported on developments in New York regarding accessible taxi service.

On June 6, 2015, the Department of Justice issued its findings based on its investigation under Title II of the Americans with Disabilities Act (ADA) of AMTRAK (the National Railroad Passenger Corporation). (DJ No. 204-16-128) The investigation was also conducted under the U.S. Department of Transportation’s regulations implementing the ADA, 42 U.S.C. § 12134. . DOJ found that Amtrak discriminated against persons with disabilities in violation of the ADA by failing to make existing station facilities in its intercity rail transportation system accessible. Amtrak also violated the ADA by incorrectly classifying stations as “flag stop” stations, thereby avoiding responsibility to make those station facilities accessible. DOJ determined that Amtrak is  responsible for ADA compliance at 376 stations but only 18 stations are currently compliant. DOJ relied upon Amtrak’s own reports, including a projection that it would make only 19 stations accessible by 2013. Amtrak’s plan to make stations accessible extended to 2028, and even then, not all the stations would be accessible. DOJ is requiring Amtrak to take a wide variety of remedial measures by changing it operations, including making its stations accessible, ensuring independent monitoring and verification, and notice to responsible parties. Other requirements include training and education of staff. An additional remedy requires Amtrak to pay compensatory damages to persons aggrieved in an appropriate amount for injuries caused by Amtrak’s failure to comply with the ADA and its regulations.

 

See discussion above of National Federation of the Blind of California, Kelly, Hingson, and Pederson v. Uber Technologies, Inc., Case No. 14-cv-04086 NC, N.D. Cal (2015).  http://law.justia.com/cases/federal/district-courts/california/ candce/ 3:2014cv04086/280572/37h.

[1]This document is indexed to Colker and Grossman, The Law of Disability Discrimination for Higher Education Professionals.  This book, written for AHEAD members, Disabled Students Service Directors, and their legal advisors is published by Lexis-Nexis. It provides a comprehensive overview of disability anti-discrimination law including legal history, definition of disability, employment discrimination, and an extended chapter on the rights of students with disabilities in higher education.  This book is available through Lexis-Nexis at the following link:

http://www.lexisnexis.com/store/catalog/booktemplate/productdetail.jsp?pageName=relatedProducts&prodId=prod20900324

 

[2] The information set forth in this document is presented for informational purposes only and should not be construed as legal advice.   For any legal questions you may have, please consult with counsel for your institution.

Talking to Children About Tragedies & Other News Events

After any disaster, parents and other adults struggle with what they should say and share with children and what not to say or share with them.

The American Academy of Pediatrics (AAP) encourages parents, teachers, child care providers, and others who work closely with children to filter information about the crisis and present it in a way that their child can accommodate, adjust to, and cope with.

Where to Start – All Ages

No matter what age or developmental stage the child is, parents can start by asking a child what they’ve already heard. Most children will have heard something, no matter how old they are. After you ask them what they’ve heard, ask what questions they have.

Older children, teens, and young adults might ask more questions and may request and benefit more from additional information. But no matter what age the child is, it’s best to keep the dialogue straightforward and direct.

Avoiding Graphic Details & Exposure to Media

In general, it is best to share basic information with children, not graphic details, or unnecessary details about tragic circumstances. Children and adults alike want to be able to understand enough so they know what’s going on. Graphic information and images should be avoided.

Keep young children away from repetitive graphic images and sounds that may appear on television, radio, social media, computers, etc.

With older children, if you do want them to watch the news, record it ahead of time. That allows you to preview it and evaluate its contents before you sit down with them to watch it. Then, as you watch it with them, you can stop, pause, and have a discussion when you need to.

Children will generally follow good advice, but you have to give them some latitude to make decisions about what they’re ready for. You can block them from seeing the newspaper that comes to the door, for example, but not the one on the newsstand. Today, most older children will have access to the news and graphic images through social media and other applications right from their cell phone. You need to be aware of what’s out there and take steps in advance to talk to children about what they might hear or see.

Talking to Very Young Children

The reality is that even children as young as 4 years old will hear about major crisis events. It’s best that they hear about it from a parent or caregiver, as opposed to another child or in the media.

Even the youngest child needs accurate information, but you don’t want to be too vague. Simply saying, “Something happened in a faraway town and some people got hurt,” doesn’t tell the child enough about what happened. The child may not understand why this is so different from people getting hurt every day and why so much is being said about it. The underlying message for a parent to convey is, “It’s okay if these things bother you. We are here to support each other.”

Talking to Gradeschool Children & Teens

After asking your child what they have heard and if they have questions about what occurred during a school shooting, community bombing, natural disaster, or even a disaster in an international country, a parent can say something such as:

“Yes. In [city], [state]” (and here you might need to give some context, depending on whether it’s nearby or far away, for example, ‘That’s a city/state that’s pretty far from/close to here’), there was disaster and many people were hurt. The police and the government are doing their jobs so they can try to make sure that it doesn’t happen again.”

A parent can follow-up as needed based on the child’s reactions and questions.

Talking to Children with Developmental Delays or Disabilities

Parents who have a child with a developmental delay or disability should gear their responses to their child’s developmental level or abilities, rather than their physical, age. If you have a teenage child whose level of intellectual functioning is more similar to a 7-year-old, for instance, gear your response toward her developmental level. Start by giving less information. Provide details or information in the most appropriate and clear way you can.

Talking to Children with an Autism Spectrum Disorder (ASD)

What’s helpful to a child with an ASD may be different. For instance, the child may find less comfort in cuddling than some other children. Parents should try something else that does calm and comfort their child on other occasions. Ask yourself, “Given who my child is, his personality, temperament, and developmental abilities, what might work for him?”

Signs a Child Might Not Be Coping Well

If children don’t have a chance to practice healthy coping, a parent may see signs that they’re having difficulty adjusting. Some of things to look for are:

  • Sleep problems: Watch for trouble falling asleep or staying asleep, difficulty waking, nightmares, or other sleep disturbances.
  • Physical complaints: Children may complain of feeling tired, having a headache, or generally feeling unwell. You may notice your child eating too much or less than usual.
  • Changes in behavior: Look for signs of regressive behavior, including social regression, acting more immature, or becoming less patient and more demanding. A child who once separated easily from her parents may become clingy. Teens may begin or change current patterns of tobacco, alcohol, or substance use.
  • Emotional problems: Children may experience undue sadness, depression, anxiety, or fears.

Sometimes it can be hard to tell if a child is reacting in a typical way to an unusual event or whether they are having real problems coping, and might need extra support. If you are concerned, talk to your child’s pediatrician or a mental health professional or counselor.

Don’t wait for the signs. Start the discussion early, and keep the dialogue going.

Additional Information on HealthyChildren.org:

​​Additional Resources:

Source

 

Adapted from an eHealthMD interview with David Schonfeld, MD, FAAP, Director of the National Center for School Crisis and Bereavement and member of the AAP Disaster Preparedness Advisory Council
The information contained on this Web site should not be used as a substitute for the medical care and advice of your pediatrician. There may be variations in treatment that your pediatrician may recommend based on individual facts and circumstances.

Emergence of mental health: Possible threat to business profitability

“Stress reduction & mindfulness don’t just make us happier and healthier, they are a proven competitive advantage for any business that wants one”

– Arianna Huffington
Editor-in-chief  |   The Huffington Post

What does the World Health Organization say?
From 2016 to 2030 12 billion workdays will be lost every year due to mental health issues. Accumulated costs to the global economy will be $900 billion.

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The epidemic is real, and it’s growing. In the US alone, mental health issues cost the economy a whopping $190 billion a year. Despite the growing problem and the potential costs, many companies are not doing enough to address the issue. Many current corporate wellness programs place huge emphasis on physical wellness and pay little to no attention to improving employees’ mental well-being.

The stigma associated with mental health issues also mean that employees are unwilling to face up to potential problems and mental illnesses often go un-diagnosed.

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Demolishing the Stigma

Breaking down mental health stigma is all about removing negative assumptions about the problem. Communicate to your employees that mental suffering is a real problem just like any other health problem you would seek help for. Improve attitude towards the issue by openly emphasizing how much the company values employee mental health.

Consider holding mental health seminars to raise awareness. Employee engagement firms such as wellteq offer mental health themed programs infused with gamification, educational features to de-stigamise and bring the issue to the forefront.

Creating a safe environment

Many people are unwilling to face up to a mental issue at work because there is fear of not knowing what will happen if they do, fear of colleagues finding out, fear of isolation, and worst of all, fear of losing their job. Employees need to feel safe about asking for help.

Bring to their attention all resources available, including hotlines, articles, videos and specialist help. Emphasize how people seeking help can expect total confidentiality.

Zero Tolerance to

Workplace Bullying

Workplace bullying can be described as the deliberate and repeated abusive behaviour directed at a co-worker. Victims of workplace bullying can experience intimidation, hostility, threat, sabotage, isolation and verbal abuse.

Such disruptive behaviour cannot be allowed to exist even in it’s slightest form. Implement a zero tolerance policy towards office bullying by making clear to employees what constitutes bullying behaviour and the consequences for offenders.

Identify risks and warning signs

Feeling sad or stressed is part of normal life and it can be hard to distinguish those feelings from a true mental problem. Train managers and supervisors to be observant of vital signs, which can include:

  • –  Mood swings and anger prone behaviour
  • –  Uncharacteristic withdrawal and self isolation
  • –  Declining productivity in familiar or regular tasks
  • –  Lapses in memory, concentration and logical thinking

Re-evaluate Workloads and Timelines

Employees often take on additional workload and projects without complaining to impress their bosses. Unfortunately, employers sometimes fail to recognise that these are often performed beyond regular bandwidth.

From time to time, re-evaluate your employees’ workloads, projects, timelines and priorities. Make sure they are receiving the support and encouragement necessary to foster mental health and productivity at the same time.

Recognize and

Reward

Everyone likes a pat on the back and be told that they are doing a good job. Regularly bringing individual accomplishments to the attention of the office makes employees feel recognized. The euphoric sense of having one’s achievements amplified and publicly acknowledged can be a fantastic counter to a hard day’s stress.

Besides creating a sense of belonging, individual validation and positive reinforcement, think about how to reward employees’ accomplishments in more tangible ways such as bonuses or awards.

Emphasize Work Life

Balance

Every boss loves a hard working employee, one who goes above and beyond regular hours to complete tasks, but don’t forget that employees don’t bring their home problems to the work place, so there’s no reason they should be bringing work issues back home either.

The best way to deal with mental stressors sometimes is to completely step away from them temporarily. Give your employees enough breathing space away from work to focus on their personal lives. Consider implementing occasional “family time”, letting employees leave office 2 hours early to go home to their families.

Are you ready to improve workforce mental health and positively impact business profitability

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Let us help you start a great mental wellness program

  • Learn how to implement the most effective employee engagement program for your workforce with Vital Time’s diverse range of solutions from consultation to programing, we will devise a strategy to improve your teams mental health!
    • 877.569.MIND ext: 5454
      • questions@behavioralhealth.us
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