Issued in support of Policy 19 — Student Academic Disability Accommodations and associated Procedures
These Guidelines support the consistent, fair, and effective implementation of academic accommodations for students with disabilities at the University of Waterloo. They provide practical direction to students, course instructors, graduate student supervisors, academic advisors, academic administrators, and other University employees involved in the accommodation process.
These Guidelines are aligned with Policy 19 – Student Academic Disability Accommodations and the associated Procedures. Where there is a conflict, Policy 19 and the Procedures prevail. The Guidelines may be updated to reflect evolving legal requirements, institutional practices, or best practices.
Table of Contents
Guidelines for Resolving Accommodation Disputes
Guidelines for Referring Students to AccessAbility Services
Guidelines for Course Instructor Timelines
Guidelines for Protecting Student Personal Health Information
Guidelines for Student Documentation Requirements
Guidelines for the Use of Essential Requirements in Relation to the Duty to Accommodate
Guidelines for Resolving Accommodation Disputes
Purpose
To outline informal and formal processes to resolve disputes related to academic accommodations, accommodation plans, or services provided by AccessAbility Services.
Guidance
A student, course instructor, or graduate student supervisor may disagree with any of the following:
- An approved academic accommodation or an approved accommodation solution
- The accommodation plan as designed by AccessAbility Services
- Services or supports offered by AccessAbility Services
Depending on the nature of the dispute, the following two informal dispute resolution processes will be used before the formal dispute resolution process:
- Academic Accommodation Dispute Process
- Accommodation Plan Dispute Process
In any informal or formal dispute resolution process outlined in these procedures, a student’s accommodation plan as defined by AccessAbility Services will apply until a decision is made.
1. Academic Accommodation Dispute Process
This informal process governs disputes about an academic accommodation and/or its outcome. For example, this may arise where a course instructor believes a specific accommodation would be unreasonable because it would fundamentally alter the course’s essential requirements, or where a course instructor believes the student is already accommodated through other means.
Process
- A student, course instructor, or graduate student supervisor initiates the dispute by contacting AccessAbility Services, indicating the academic component in dispute.
- AccessAbility Services consults with relevant parties as required and seeks to resolve the dispute, including whether an alternate, equivalent accommodation is feasible.
- If the matter remains unresolved, AccessAbility Services refers it to the Chair or Director of the course instructor or graduate student supervisor.
- The Chair or Director will be informed of the recommended academic accommodation, the nature of the dispute, and any other relevant information.
- The Chair or Director reviews the recommended accommodation, the nature of the dispute, and supporting information, and decides whether the accommodation is appropriate.
- The Chair or Director has access to campus supports in rendering this decision, including AccessAbility Services.
- If the accommodation is determined to be inappropriate, AccessAbility Services works with the Chair or Director, as needed, to establish an alternate accommodation where possible.
- The Chair or Director communicates the decision to the course instructor or graduate student supervisor (copying AccessAbility Services).
- AccessAbility Services informs the student and updates records as needed.
- The accommodation is implemented.
2. Accommodation Plan Dispute Process
This process applies where a student disagrees with:
- The design of their accommodation plan
- Services or supports provided by AccessAbility Services
Process
- The student raises concerns with their assigned Accommodation Consultant.
- If unresolved, the concern may be escalated to the Manager, Student Accommodations, and then to the Associate Director.
- AccessAbility Services communicates the outcome and any changes to the student.
Formal Dispute Resolution
If informal processes do not resolve the dispute, the student may pursue a petition or grievance under Policy 70 – Student Petitions and Grievances. Students are encouraged to seek support either through the Conflict Management Office or the Office of the Ombudsperson.
Guidelines for Referring Students to AccessAbility Services
Purpose
To support timely referral, clarify when academic accommodation processes apply, and distinguish accommodation from academic consideration.
Guidance
Postsecondary institutions have a legal duty to accommodate disabilities, but they also have a “duty to inquire.” This means that educators must attempt to help students who are unwell or perceived to have a disability by offering assistance and access to accommodations. This is because some disabilities leave students unable to identify that they have a disability or that they require an accommodation.
It can be difficult for educators to know when and how to refer a student to AccessAbility Services for consideration for academic accommodation. It is important to note that, when in doubt, it is best to refer a student to AccessAbility Services. Students who do not have a documented disability are still able to apply. AccessAbility Services will work with the student to determine if an interim accommodation plan is needed pending documentation. If the student is not eligible for academic accommodations, AccessAbility Services will assist the student in connecting with resources and supports that may be more appropriate.
A referral to AccessAbility Services is required where any of the following apply:
- A request for academic accommodation is made.
- A permanent, temporary, chronic, or suspected disability is disclosed.
- An existing Accommodation Plan may no longer be appropriate.
- Academic difficulties are ongoing or recurring.
- Evaluation formats or conditions are affected.
- There is uncertainty whether a request constitutes accommodation.
Role Limitations of University Employees
Employees:
- Must not assess accommodation eligibility.
- Must not request, collect, or review medical documentation.
- Must not require diagnostic disclosure.
- Should use neutral, supportive, access-focused language.
How to Refer
Referring a student who has disclosed a disability/condition
- Thank the student for confiding in you.
- Indicate that you work with AccessAbility Services to ensure students are appropriately accommodated and supported.
- Explain that AccessAbility Services facilitates academic accommodations for students with disabilities and can guide them through next steps.
- Ask whether the student is comfortable with you referring them to AccessAbility Services.
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Offer to email AccessAbility Services on their behalf and copy them (access@uwaterloo.ca).
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Offer to sit with them while they complete the online application (if able).
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- Indicate that only AccessAbility Services will review and store medical documentation.
- Follow up with the student throughout the term to assess how the course, and any accommodations, are supporting their learning.
Referring a student you suspect may have a disability or require accommodations
- Indicate that you have observed some academic challenges and want to help connect the student with appropriate support.
- Explain that a range of campus supports and services are available, including the Writing and Communication Centre, the Student Success Office, and Counselling Services, and that AccessAbility Services is another resource if the student believes they may need academic accommodations.
- Indicate that AccessAbility Services facilitates academic accommodations for students with known or suspected disabilities and can guide them through next steps, even if they are unsure about eligibility.
- Ask whether the student is comfortable with you referring them to AccessAbility Services.
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Offer to email AccessAbility Services on their behalf and copy them.
Offer to sit with them while they complete the online application (if able).
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Indicate that only AccessAbility Services will review and store medical documentation.
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Follow up with the student throughout the term to assess how the course, and any accommodations, are supporting their learning.
Referring a student requesting a retroactive accommodation
- Inform the student that retroactive accommodations will be thoughtfully considered.
- Explain that AccessAbility Services must be consulted and engaged to assess retroactive accommodation requests.
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Ask whether the student is comfortable with you referring them to AccessAbility Services.
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Offer to email AccessAbility Services on their behalf and copy them (access@uwaterloo.ca).
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Offer to sit with them while they complete the online application (if able).
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Indicate that only AccessAbility Services will review and store medical documentation.
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Advise the student that you will follow up once a decision has been made, where appropriate.
Guidelines for Course Instructor Timelines
Purpose
To support timely collaboration between instructors and AccessAbility Services in implementing approved accommodations.
Guidance
Testing and Exams
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Testing Agreement: Due at least two weeks before the test.
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Test submission: Due two business days prior to the test.
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If deadlines are missed, instructors must either:
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Facilitate accommodations directly.
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Defer the assessment
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Guidance for Accessible and Alternate Format Materials
- Syllabus/Reading Lists: Ideally 4–6 weeks in advance.
- In‑class materials: At least 3 business days prior.
- Slides/Presentations: At least 1 business day prior, with alt‑text.
Instructors unable to meet timelines must contact AccessAbility Services promptly.
Designing for Accessibility
Instructors are encouraged to:
- Identify required textbooks, readings, and audio-visual materials in advance of the course.
- Select captioned/described media, where available.
- Ensure course materials (documents, slides, images) are created in accessible formats, including appropriate alternative text.
Guidelines for Protecting Student Personal Health Information
Purpose
To safeguard student privacy throughout the accommodation process.
Guidelines
- Only AccessAbility Services may receive and store medical documentation.
- Students must not be required to disclose medical information to instructors or staff.
- Verification of Illness or Condition Forms may be viewed only if they contain no health details.
- Accommodation information is shared on a need-to-know basis only, and discussions should occur in private, respectful settings.
- Only accommodation requirements (not medical or diagnostic details) should be shared with teaching assistants or guest instructors.
- Accommodation records must be stored securely and in accordance with University retention schedules.
If Medical Information Is Shared
- Seek consent to forward information to AccessAbility Services.
- Confirm verbal consent in writing.
- Securely destroy records if the student is inactive beyond retention timelines.
- Contact the Secretariat with questions.
Guidelines for Student Documentation Requirements
Purpose
To clarify documentation requirements and responsibilities.
The Role of Medical Documentation in the Accommodation Process
To meet its duty to accommodate under the Ontario Human Rights Code, the University must have access to sufficient, relevant information to understand a student’s disability-related needs and to design appropriate accommodations. Medical documentation is intended to be proportionate, focused, and non-intrusive. The role of medical documentation in the accommodation process is to provide AccessAbility Services with information about the functional limitations a student experiences because of a disability. This enables the development of an individualized accommodation plan that supports full academic participation. Documentation is required only when it is relevant to the accommodation being sought, and requests are limited to the information necessary for accommodation planning.
Recognized Health Professionals
Medical documentation must be provided by a qualified, regulated health professional who has direct knowledge of the student’s disability and is involved in their care (“Treating Professional”). The professional must be appropriately licensed and qualified to assess functional limitations and support accommodation needs.
Examples include, but are not limited to:
- Physicians (MDs)
- Nurse Practitioners (NPs)
- Psychologists / Psychiatrists
- Occupational Therapists
- Physiotherapists
- Audiologists
- Optometrists
- Chiropractors
- Speech‑Language Pathologists
- Other regulated health professionals with relevant expertise
Required Content
Documentation must include:
- Confirmation of disability (diagnosis not required)
- Description of functional limitations
- Capacity to meet academic requirements with or without accommodation
- Duration or prognosis (if applicable)
Documentation must distinguish between general symptoms and disability-related functional limitations. Generic references to symptoms such as “stress,” “pain,” or “feeling unwell,” without explanation of how they relate to a disability, may be insufficient to establish the need for accommodation under the Code.
Optional (only where relevant):
- Diagnosis
- Symptom or treatment details
- General accommodation suggestions
Additional Documentation
Additional documentation may be requested only when necessary, and in a manner that respects student privacy. This may occur when:
- Initial documentation lacks sufficient detail
- Disability-related needs are complex, unclear, or evolving
- There is a significant change in academic demands or health status
- A condition identified as temporary becomes ongoing
A student will be notified if additional documentation is required. Any request for further documentation must be specific, limited in scope, and justified by the accommodation process.
Interim Accommodations
Interim accommodations may be provided where documentation is pending. These are:
- Time‑limited
- Based on self-reported impacts
- Subject to review or discontinuation if documentation is not provided
Students seeking interim accommodations are expected to:
- Submit an accommodation request indicating documentation is forthcoming
- Complete a functional self-assessment
Engage in consultation with AccessAbility Services
If documentation is not provided within a reasonable timeframe, interim accommodations may be revised or discontinued.
Standardized Forms
Students are encouraged to use AccessAbility Services’ standardized documentation forms, which support consistent, relevant, and sufficient information for accommodation planning. Forms are available through the AccessAbility Services website.
Guidelines for the Use of Essential Requirements in Relation to the Duty to Accommodate
Purpose
To ensure consistent, evidence‑based use of essential requirements while upholding the duty to accommodate.
Understanding Essential Requirements
“Essential requirements” are the core knowledge, skills, or competencies that all students must demonstrate, with or without accommodation, in order to meet academic requirements. Essential requirements may exist at multiple levels, including:
- A specific task or assessment
- A course requirement or learning outcome
- A program or accreditation requirement
It is critical to distinguish between:
- Essential requirements, which cannot be altered without fundamentally changing the nature of the academic requirement or learning outcome
- Non‑essential components, which may be modified through accommodation without compromising academic integrity
Academic accommodations do not lower academic standards or alter essential requirements, but may change:
- How learning materials are accessed
- How students participate in academic activities
- How students demonstrate their learning, provided that the essential requirements are met
Essential requirements must be grounded in the academic purpose of the task or outcome. They are not established by tradition, preference, convenience, or uniformity alone (for example, “this is how the course has always been taught”).
Role of Essential Requirements in Accommodation Planning
Clear identification of essential requirements supports:
- Fair and individualized accommodation decisions
- Inclusive and accessible course and assessment design
- Transparency and consistency in grading and evaluation
- Alignment between learning outcomes, instructional methods, and assessment formats
Essential requirements must always be considered:
- In relation to the specific accommodation being requested
- In light of the individual student’s disability-related functional limitations
Essential requirements should be identified before concluding that an accommodation is not possible.
Determining Whether a Requirement Is Essential
When determining whether a requirement is essential, instructors and academic decision‑makers should consider the following questions:
- Rational connection — Is the requirement meaningfully connected to the academic task, learning outcome, or program purpose, rather than based on habit, efficiency, or convenience?
- Evidence — Is there objective evidence that the requirement is essential (e.g., stated learning outcomes, curriculum design, accreditation or professional standards)?
- Necessity — Would modifying or removing the requirement fundamentally alter the academic objective being assessed?
- Equity considerations — Is the requirement socially constructed in a way that excludes certain groups based on assumptions unrelated to the actual academic purpose?
Determinations must be evidence‑based, individualized, and defensible, and must consider whether reasonable alternatives exist that would allow the student to meet the essential requirement in a different way.
Relationship to the Duty to Accommodate
Where a component of a task or assessment is non-essential, it must be adjusted through accommodation where required.
Where a requirement is determined to be essential, accommodation planning must focus on alternate ways for the student to meet that requirement, not on excluding the student from demonstrating it.
An accommodation should only be refused on the basis of essential requirements where:
- The requirement has been clearly identified and justified.
- No reasonable alternative would allow the student to meet that requirement.
AccessAbility Services must be consulted where:
- A proposed accommodation may conflict with an asserted essential requirement.
- There are concerns that implementing an accommodation would constitute undue hardship.
Decisions must not rely on generalized assumptions about disability, academic rigor, or institutional norms, and must be capable of being clearly explained and documented.
Additional Guidance and Resources
For practical guidance on identifying essential requirements, aligning them with learning outcomes, and designing inclusive assessments, instructors are encouraged to consult the Centre for Teaching Excellence’s Teaching Tips resources.