The purpose of this policy is to provide guidelines to RISD employees to assure compliance with the Americans with Disabilities Act of 1990 (“ADA”), Americans with Disabilities Act of 2008, and Section 504 of the Rehabilitation Act of 1973.
This policy covers qualified employees and applicants for employment with disabilities.
The Americans with Disabilities Act of 1990 (“ADA”) is a civil rights law that defines disability with respect to an individual as a physical or mental impairment that substantially limits one or more major life activities of an individual. A disability may also include an individual having a record of such an impairment or being regarded as having such an impairment.
- Physical impairment – includes any physiological disorder or condition affecting one or more body systems, including but not limited to neurological and respiratory systems, speech organs, sensory organs, and/or cardiovascular.
- Mental impairment – includes any mental or psychological disorder, such as emotional or mental illness, intellectual disability, and specific learning disabilities.
- Major life activity – includes functions such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning and working.
- Regarding Impairment – includes an individual who: (1) has a physical or mental impairment that does not substantially limit major life activities, but is treated by the college as such a limitation; (2) has a physical or mental impairment that does substantially limit major life activities only as a result of the attitudes of others towards such a disability; or (3) does not have any of the impairments strictly listed above, but still is treated by the college as having such a disability.
In addition, the ADA:
- prohibits discrimination against individuals based on their relationship or association with an individual with a disability;
- prohibits retaliation or coercion against individuals who opposed any acts made unlawful by the ADA, participated in the enforcement process, or encouraged others to exercise their rights under the ADA; and
- covers part-time employees and applicants regardless of national origin or status.
The ADA prohibits discrimination against a qualified individual with a disability on the basis of that individual’s disability in, among other things, employment and the employment relationship. It is RISD’s policy not to discriminate against any qualified employee or applicant with regard to any terms or conditions of employment because of such an individual's disability or perceived disability so long as the employee can perform the essential functions of the job.
Further, Rhode Island state law protects employees and job applicants from discrimination based on pregnancy, childbirth and related conditions. Employees and applicants have the right under state law to request reasonable accommodation for conditions related to pregnancy, childbirth, and related conditions such as the need to express breast milk for a nursing child.
Consistent with this policy of nondiscrimination, RISD will provide reasonable accommodations to a qualified individual with a disability who has made RISD aware of their disability, provided that such accommodation does not constitute an undue hardship on RISD consistent with all federal and state requirements, including the ADA.
In determining whether a requested accommodation creates an undue hardship on the college, the appropriate college personnel will consider on a case-by-case basis whether such a request is unduly costly, extensive, substantial, or disruptive, and/or whether it would fundamentally alter the nature of RISD’s operation.
Applicants for employment seeking a reasonable accommodation should contact Human Resources and ask to speak to the Director of Employment.
Employees seeking a reasonable accommodation to perform the essential functions of their job must submit the Reasonable Accommodation Medical Authorization Form to their healthcare/medical provider, including a current job description listing their essential job functions. This form is treated as confidential information and will only be shared on an as-needed basis with those individuals providing reasonable accommodations.
The form must be returned by mail, email, or fax.
Rhode Island School of Design
20 Washington Place Providence, RI 02903
ATTN:Human Resources Benefit Partner
On receipt of the Reasonable Accommodation Medical Authorization Form, the HR benefit partner will invite the employee to make an appointment to discuss their request for accommodations. If the documentation is incomplete or the documentation does not indicate a qualifying disability, the employee will be contacted about next steps.
The Interactive Process
Employees who are eligible to receive accommodations for a documented disability will discuss their request and their specific needs with the HR benefit partner. During the interactive process, the individual, their supervisor, and Human Resources may explore the potential accommodation(s) that RISD may provide.
RISD will determine the reasonableness of the requested accommodation considering various factors, including, but not limited to, the nature and cost of the accommodation and the accommodation’s impact on the operations of RISD, including its impact on the ability of other employees to perform their duties and on RISD’s ability to conduct business.
RISD will inform the employee of its decision on the accommodation request or on how to make the accommodation. The ADA does not require RISD to make the best possible accommodation when other less intrusive accommodations would be sufficient, to reallocate essential job functions, or to provide personal use items (i.e., eyeglasses, hearing aids, wheelchairs, etc.).
Employees who are eligible for accommodations will receive an accommodation approval letter (“AAL”) that will list the employee’s approved accommodations. This letter will also be sent to the employee’s supervisor. The AAL must be renewed annually, or by the end date stated on the AAL. It is strongly suggested that any necessary follow-up appointments be made in ample time before the expiration date of the AAL in order to avoid interruption in services. Employees with an existing AAL may request updated accommodations in light of changing medical conditions and/or job duties.
An employee or job applicant who has questions regarding this policy should notify the Vice President for Human Resources. An employee or job applicant who believes they have been discriminated against based on a disability should contact the Office of Institutional Discrimination & Title IX by completing this form, or by contacting Human Resources. All such inquiries or complaints will be treated as confidential and shared only on a “need to know” basis.
This policy was last reviewed/modified on: 12/2/2022
Next scheduled review: Biannually in July beginning in 2024, or as required by law.
Vice President for Human Resources
Individuals/offices required for review and changes
Office of the General Counsel