The President's Report on the
Status of Handicappers
at Michigan State University

Michigan State University
February 1995


Table of Contents

Overview
Introduction
Handicapper Employees: Working for MSU
Program Accessibility: The ADA Self-Evaluation of Programs
Transportation
Handicapper Students: The Educational Experience
Extracurricular Activities
Accessibility of Computing Technology
Facilities
Telecommunication
The Outdoor Environment
On-Campus Parking
Handicapper Safety on Campus
Accommodations for the Public
Summary
Appendices


Overview

Michigan State University's commitment to institutional accessibility and diversity, and to the principle that all people matter, guides ongoing efforts to make the university community one that welcomes the contributions of all its members, including those who are handicappers.

From its earliest systematic efforts to accommodate handicappers beginning in the 1960s, MSU has made progress that is nothing short of remarkable. Major changes in the physical environment, employment practices, dedication of resources, policy and practice, and perhaps most importantly in awareness, have made MSU an internationally recognized leader providing educational and employment opportunity to handicappers.

The university recognizes that there are many issues yet to be addressed, that the process of maximizing handicapper access to employment and programming is an ongoing one. This benchmark report documents the university's progress to date in several major areas: employment, program accessibility, transportation, education, facilities, safety, and accommodations for the public. Each report section contains factual information followed by issues raised by individual handicappers, representative groups, or administrative departments. A critical look at where the university now stands, and consideration of existing issues, can provide direction for future efforts to make the university's programs, services, and activities equally accessible to handicappers.

Employment

Article II of the 1976 Michigan Handicappers' Civil Rights Act, Section 503 of the Federal Rehabilitation Act of 1973, and Title I of the 1990 Americans with Disabilities Act (ADA) obligate the university to make all aspects of employment--advertising, application procedures, interviewing, hiring, promotion, and administration of benefits programs, equally available to handicappers. A 1992 ADA task force review of the university's employment practices found that, overall, the university is in compliance with legal requirements governing faculty, support staff, and student employment. With minor exceptions, currently being addressed (e.g, modification of employment manuals), task force recommendations for improvements have been implemented by the administrative units responsible for them.

Employment practices are decentralized at MSU. They are overseen, although not necessarily directly implemented, by three separate administrative units: student employment by the Student Employment Office within Career Development and Placement Services; faculty employment by the Office of the Assistant Provost and Assistant Vice President for Academic Human Resources; and support staff employment by the Office of the Assistant Vice President for Human Resources. In those situations where employment procedures are carried out by individual departments, procedures are developed centrally and information is disseminated as needed to inform individual units of changes in legal requirements or university policy.

A November 1994 survey of 209 self-identified handicapper-employees (85 faculty and 124 support staff) found that, overall, handicapper satisfaction with work situations is high. One hundred-four handicappers responded to the survey indicating that supervisors and peers are generally neutral or positive when they learn of requested handicapper accommodations. Further, respondents generally indicated that they are satisfied with the way accommodation requests are handled, and that their workplace accommodations have been helpful. Reasonable accommodation requests are handled, either internally by the handicapper's department, or through Handicapper Operations and Services (HOS).

There are employment issues to be addressed, including the following: a need for improved peer and supervisor awareness of university policy and sensitivity to handicapper concerns; occasional lack of awareness that departmental events (e.g., parties, meetings) must be held in accessible and accommodating facilities if needed; a need to ensure consistency in the departmental review of reasonable accommodation requests; and a need to remove communication barriers in the dissemination of information to faculty and staff.

Program Accessibility

Section 504 of the Federal Rehabilitation Act of 1973 as amended in 1976, and Title II of the ADA, require the university to conduct its programs, services, and activities in a manner that provides handicappers with an equal opportunity to participate. Renovation of facilities and modification of policies and practices may be used to ensure that programs "when examined in their entirety" or "on the whole" are equally accessible to handicappers.

A mandatory program self-evaluation conducted in 1993-94 found that overall the university administers programs, services, and activities that are equally available to handicappers. At the time of the self-evaluation there were widespread, but relatively minor, issues related to accessibility of telephone communication in department offices; the need to review program materials for inappropriate language and portrayal of handicappers; the need to include, in program brochures and publicity materials, a statement inviting handicappers to request needed accommodations; and the need to establish and communicate evacuation procedures for individual campus buildings, with special attention to handicappers. Isolated situations of greater concern involve programs that appear to apply eligibility guidelines that might unlawfully limit or deny program access for handicappers; and situations where physical barriers impede handicapper access to programs (when relocation of activities is not possible).

The university is obligated, under the law, to correct identified areas of non-compliance "in a timely manner," and has taken steps to do this. A project, coordinated by the self-evaluation project coordinator, is underway calling for major administrative unit (MAU) administrators to identify changes yet to be completed, and report actions taken to correct identified non-compliance issues. The project coordinator will follow up on incomplete or unsatisfactory responses, and prepare a summary report at the project's conclusion.

Transportation

Under the Federal Rehabilitation Act of 1973 as amended in 1976, and Title II of the ADA, an institution that operates a transportation service for non-handicappers, is obligated to provide handicapper-accessible transportation as well.

The university provides handicapper-accessible transportation that, overall, meets customer demand. Daytime transportation services include handicapper-accessible buses that provide on-demand and scheduled service for approximately 40 different handicappers per day. After- hours services include the scheduled Nite-Rider service (running two buses, one of which is accessible) and Dial-A-Ride, a telephone- requested service, generally serving one handicapper per night. Automotive Services maintains a vehicle pool of 350 cars and vans available for faculty or staff who need a vehicle for on-or off-campus travel. One pool car is equipped with hand controls, but has never been used.

There is an ongoing need to ensure that all transportation needs are monitored, and, that on the whole, quality transportation is available to all members of the university community at the lowest possible cost. The age of many of the buses and vans, and the predicted cost of vehicle replacement is an issue that must be considered before the need to replace them becomes immediate. Issues related to accessibility of the vehicle pool have been addressed, satisfactorily at this time, with the purchase and installation of one set of hand controls in a pool car. Automotive Services will monitor use of the hand control-equipped car and equip additional vehicles if necessary. Faculty and staff indicate that, at times, accessible buses are not available, because ride priority is given to students going to and from classes.

Also, there is a need to consider including individuals with visual characteristics among those eligible for handicapper-accessible transportation. Options for addressing these issues in a cost-effective manner should be explored.

Handicapper Students

Federal law obligates the university to make the total educational experience accessible to handicappers. This includes the classroom and related academic requirements, as well as extracurricular activities offered by the university or groups to which it provides "significant assistance."

By the end of December 1994, 521 students had self-identified as handicappers: 184 with mobility characteristics (including 50 temporary conditions due to injury); 36 with visual characteristics; 29 who were deaf or hard-of-hearing; 182 with various learning characteristics; and 90 with "other" characteristics (e.g., asthma, diabetes, psychological conditions). The Office of Programs for Handicapper Students (OPHS) bears primary responsibility for assisting handicapper- students and working with academic and administrative units to meet their needs.

A November 1994 survey of self-identified handicapper-students found that, overall, satisfaction with the university experience is high. Ninety-one handicappers responded, indicating generally high satisfaction with OPHS services, and with the handling of service requests. Most said they feel welcome to participate in activities outside the classroom.

Issues to be addressed cover a number of areas, including: the need to evaluate handling of confidential information about handicapper characteristics; the high cost of providing sign language interpreters for a small number of deaf students; the need to ensure accessibility of course material short of fundamentally altering necessary course content; the importance of making extracurricular activities accessible to handicappers; the possibility of paying readers instead of relying totally on volunteers; the challenge of improving computer technology accessibility in view of increasing reliance on graphical applications not readily adapted for voice input and output; and the need to raise faculty awareness of the responsibility to respond to academic adjustment requests.

Facilities

Driven by program accessibility requirements, the university's enhancement of existing facilities is guided by priorities established in the Transition Plan. While the Transition Plan is administered by the Office of Planning and Budgets, Facilities Planning and Space Management (OPB/FPSM), establishing enhancement priorities and identifying funding sources is the responsibility of three separate administrative areas, as follows: OPB/FPSM for academic buildings; Housing and Food Services for residence halls; and Intercollegiate Athletics for all athletic venues.

All new construction incorporates universal design requirements and is inherently accessible and accommodating. The result is that, overall, the university has made substantial progress creating and maintaining a built environment that is conducive to handicapper participation in programs. With each new construction or renovation project the university moves closer to the goal of total program access for handicappers.

In this report, telecommunication, the outdoor environment, and parking are addressed within the facilities context. In all three areas, the university is in overall compliance with minimum legal requirements, and continues to make improvements where accessibility issues have been identified.

A number of facilities-related issues have been raised by individuals, groups, or departments, including: affordability and availability of accessible and accommodating on-campus space, especially for large events; the need to systematically evaluate the accessibility of off-campus facilities, establish enhancement priority, and identify funding; and a perceived lack of spectator seating that provides representative viewing for handicappers in the major athletic venues.

Handicapper Safety

Handicappers have raised a number of concerns about on-campus safety. They are described in this report with the recommendation that the HOS coordinator and DPPS should evaluate safety issues, and make recommendations for actions the university might take to address them. The university operates within federal and state regulations in such areas as building construction, traffic safety, and emergency planning. Concerns raised by the handicapper community are not intended to indicate violations of code or law, but to raise awareness that safety issues exist in certain areas.

Safety issues include: the need to inform on-campus drivers about Michigan's "White Cane Law," protecting individuals with visual characteristics, and enforce this law; concern about the fact that emergency telephones, marked by green lights, cannot be located by individuals with visual characteristics; the need to develop emergency evacuation plans for campus buildings; and problems associated with accumulation of snow on roads and pathways during heavy snowfall.

Accommodations for the Public

In welcoming the public to its facilities and programs, the university generally succeeds in providing equal participation opportunity for handicappers. Facility accessibility is especially critical in accommodating the public, because frequently the reason members of the public visit an on- or off-campus site is to tour the facility itself. There is a need to continue the systematic evaluation of the university's off-campus facilities, begun by the HOS coordinator, and provide information to the administrators of these facilities in order to better accommodate the handicapper public.


Introduction

Michigan State University has a history of commitment to institutional accessibility. Through MSU IDEA II the university has demonstrated its commitment to build an environment that "supports all members in reaching their full potential" (MSU IDEA II, p. ix). Most recently the Guiding Principles have called for institutional accessibility and diversity. They call for the improvement of opportunities through increased access to campus services and reduction of institutional barriers to timely graduation. They direct the university community to seek ways to increase recruitment and retention of a diverse group of students while maintaining rigorous academic standards. The Guiding Principles challenge the university to find ways to "make people matter" and improve the climate for "...all people who work and study at MSU."

The university's commitment to handicappers supports many of the goals and implementation items articulated in the Guiding Principles. This commitment is mandated by the passage of the Michigan Handicappers' Civil Rights Act of 1976, and two federal laws--the Federal Rehabilitation Act of 1973, and the Americans With Disabilities Act of 1990 (ADA). These laws prohibit discrimination against handicappers in employment and educational opportunities, and mandate equal access to programs, services, and activities. The 1973 Federal Rehabilitation Act is considered by many to be the first civil rights act for handicappers in its coverage of public and private entities receiving federal funding. The ADA reinforces the requirements of the Federal Rehabilitation Act and extends them to cover public and private entities that are not federal funding recipients.

History

The State of Michigan and Michigan State University have historically been leaders in the development of initiatives to integrate handicappers into the mainstream of society. As early as 1934 there was university recognition of the needs of students with visual characteristics, and Tower Guard members were recruited as volunteer readers. The quiet commitment to handicappers, in Michigan and at MSU, was validated by the 1963 approval of a new state constitution that mandated:

"Institutions, programs and services for the care, treatment, education or rehabilitation of those inhabitants who are physically, mentally or otherwise seriously handicapped shall always be fostered and supported" (State of Michigan Constitution, Article VIII, Section 8, adopted 1963).

Shortly thereafter the university began building upon its earlier initiatives. With the admission of the first wheelchair user in the mid-1960s, access ramps began to appear at the entries of a few classroom buildings. From that beginning a number of significant administrative initiatives mark MSU's history relative to handicappers:

Clearly, since the 1960s the university has made substantial progress improving handicapper access to employment and educational opportunities. It is appropriate, at this time, to evaluate where the university stands in order to make decisions about future directions. This report is a bench- mark document, describing the university's progress to date. Major areas covered include: employment, program accessibility, transportation, education, facilities, handicapper safety, and accommodations for the public. Each report section contains relevant facts and figures, followed by issues raised by individual handicappers, representative groups, or departments.

Handicapper Employees:
Working for MSU

Legal Requirements

Federal and state laws require that public and private employers (including institutions of higher education) not discriminate on the basis of irrelevant handicap in the recruitment, hiring, retention, and promotion of employees. The ADA strengthens and extends requirements of Section 503 of the Federal Rehabilitation Act of 1973 as amended in 1976 (Section 503), that applied only to recipients of federal funding. Both laws require that employment opportunities be made available when it can be shown that, with or without reasonable accommodation, an individual can successfully perform the "essential functions" of a job. Requirements cover all terms, conditions, and privileges of employment including:

Although Section 503 and the ADA are not affirmative action statutes (i.e., there is no requirement to give preference in employment to handicappers), there is a mandate to actively encourage application and consideration for employment and promotion of handicappers and to make these processes equally accessible to them. Employers are required to provide reasonable workplace accommodations requested by handicapper employees, and to administer benefits programs in a manner that is not discriminatory.

Michigan State University's Efforts

Michigan State University's commitment to providing equal employment opportunity to handicappers is long-standing. By the mid-1970s the university had developed its own "Affirmative Action Plan for Handicappers" that articulated the university's commitment to making all of its employment practices fair and equitable with regard to handicappers (See Appendix D). While not an affirmative action plan that set goals based on availability, and gave hiring preference to handicappers, the plan was nevertheless an important articulation of university commitment to nondiscrimination and affirmation of ability.

A task force, established in 1992, was charged with the responsibility of examining the Americans With Disabilities Act, determining its impact on the university, and recommending actions to resolve areas of non-compliance. As part of this effort, the task force thoroughly evaluated the university's employment practices for faculty, students, and staff, and made recommendations for areas needing improvement (See Appendix E for complete report). Those recommendations and the university's progress implementing them include the following:

1. Ensure that applicants and employees are informed of the right to request an accommodation. Source, the MSU News Bulletin, employee handbooks, and other appropriate media should be used to accomplish this.

STATUS: Hiring procedures for faculty, support staff, and students are in general compliance. Modification of the 1990 Employee Handbook for support staff to include information about accommodation requests will be completed by July 1995.

2. Identify essential job functions for each position and, where feasible, list them as part of individual job postings.

STATUS: Hiring procedures for faculty and staff comply with this requirement. Due to the decentralized manner in which student vacancy postings are maintained, it is impractical to maintain individual job descriptions. Therefore, essential job functions have been identified for job classifications.

3. Ensure that any pre-employment tests are job-related and necessary, and administered to job applicants in a non-discriminatory manner. Tests must measure the ability to perform job-related tasks rather than the ability to take the test, or perform tasks in a specific way.

STATUS: Hiring procedures for support staff are in compliance. Applicants for faculty and student positions are not tested.

4. Make the job application process accessible to handicappers by conducting interviews in accessible facilities and in alternative communication formats if needed. Ensure that interviewers do not ask applicants about handicaps, although they may ask about an applicant's ability to perform essential job functions.

STATUS: The offices of Academic Human Resources, Student Employment, and Human Resources provide guidelines for individual units that conduct their own interviews. It is believed that all departments comply with these requirements.

5. Post-offer medical examinations may be required if appropriate, but information collected during the examination must be maintained separately from personnel records. Supervisors may be advised of necessary work restrictions.

STATUS: Hiring procedures for faculty, support staff, and students comply with these requirements.

6. Collective bargaining agreements (CBAs) should contain language that allows for reassignment of an employee to a vacant position as a reasonable accommodation, even when this is in conflict with the CBA's provisions related to seniority and filling of vacancies.

STATUS: CBAs have not been modified to contain language providing for reassignment of support staff to vacant positions in the same or another bargaining unit, as a reasonable accommodation. Employee Relations indicates, if necessary, a waiver of seniority would be arranged with the appropriate bargaining group on an individual basis. This recommendation does not apply to faculty or student employees.

7. Accommodation requests that involve both handicapper and workers' compensation issues should be reviewed jointly by HOS and the Workers' Compensation/Long Term Disability office in Human Resources.

STATUS: Human Resources complies with this recommendation.

8. In instances where university policy or practice provides or facilitates employee transportation for on- or off-campus travel, that transportation must be made equally available to handicapper employees.

STATUS: Physical Plant Division's Automotive Services Department provides vehicles as needed for on- or off-campus travel. Employees may either use their own vehicles and be reimbursed or use a motor pool vehicle. One car has been equipped with hand controls.

9. The university needs to ensure consistency in the review of accommodation requests and in making determinations about reasonable accommodations.

STATUS: The Administrative Group on Handicapper Issues (AGHI) has approved procedures to ensure consistency in the review of accommodation requests through Handicapper Operations and Services.

10. Employment handbooks should be reviewed for discriminatory language and to be certain each handbook contains statements on non-discrimination.

STATUS: The Faculty Handbook, the Employee Handbook, and the Student Employment Manual have been reviewed by the units producing them, and are in compliance with this recommendation.

11. Any changes in benefits available to faculty and staff should be accomplished in a way that does not have a discriminatory impact on handicapper-employees.

STATUS: The Benefits office indicates that administration of employee benefits programs complies with this recommendation.

12. Administrators, supervisors, and all persons responsible for hiring staff, faculty, and student employees must receive appropriate training and information about the ADA.

STATUS: This mandatory training has been provided. Voluntary programs have been provided by HOS as requested by individual units.

Handicapper Employees at MSU

Handicapper self-identification is voluntary. Each year Human Resources and Academic Human Resources jointly survey support staff and faculty and ask handicappers to self-identify. The January 1994 survey identified a total of 209 handicappers--124 support staff and 85 faculty. Survey findings are detailed in the following table:

Handicapper-Employee Demographics
N=209

Descriptive Data Faculty Staff
N=85 N=124
Sex
Male 61 64
Female 24 60
Racial/Ethnic Background
African-American 8 11
Asian/Pacific Islander 1 -
Hispanic 2 6
Natv. Amer./Alaskan Natv. 1 -
Caucasian 73 107
Work Group Representation
General labor - 33
Skilled trades - 9
Clerical-technical - 42
Admin. Prof. (non-supv) - 16
Admin. Prof. (supervisors) - 12
Teaching Faculty 68 -
Specialists 10 -
Other 7 12
Accommodation Provided*
Facility/worksite access 17 6
Job restructure - 7
Specialized Equipment 20 13
Other 6 4
Declined to identify accomm. 45 20
No accommodation required 36 62
Accommodation unknown - 29

* Some individuals receive more than one accommodation

The demographic breakdown in the preceding table shows that handicappers represent all employee groups and diverse racial/ethnic backgrounds, and are distributed fairly equally between males and females. Data on handicapper characteristics is collected but is confidential and available only on a "need to know" basis. A wide range of reasonable accommodations have been made, either internally through handicappers' individual departments, or in consultation with HOS.

Corresponding data on handicapper-student employees is not collected by Career Development and Placement Services, Student Employment Office.

Handicapper-Employee Satisfaction

A November 1994 survey of 209 self-identified handicapper-employees found generally high levels of satisfaction with work situations, handling of accommodations, and availability and quality of programs (See Appendix F). One hundred-four handicappers returned the survey indicating:

Several survey respondents made suggestions for improvements, including:

Handicapper Operations and Services

The HOS coordinator is responsible for consulting on services and reasonable accommodations appropriate for handicapper-employees or the public. HOS can help a unit assess an accommodation request, evaluate its appropriateness, and determine whether resources exist outside the unit to respond to the request. HOS assists with the development and implementation of programming and activities related to handicappers or handicapper issues, as requested. HOS' annual budget does not include funds to provide accommodations; rather the office acts as a referral resource. Individual departments are responsible for paying for workplace accommodations that have associated costs, via in-line administration for supplemental funding if needed.

An unknown number of accommodation requests are reviewed and met by individual departments, never coming to the attention of HOS. Approximately 30 accommodation requests reached the HOS coordinator last year, either because they could not be resolved at the department level, or because the handicappers initiated their requests with HOS. The vast majority of accommodation requests processed through HOS are met; in 1994, only two accommodation requests were denied. There is tremendous variation in accommodations; some are simple and inexpensive. Others are more complex, and require the involvement of several individuals or offices in order to be resolved.

Employment Issues

1. Faculty and staff who plan departmental events such as parties, luncheons, meetings, or retreats must be sensitive to the need to hold events in accessible and accommodating facilities if needed.

2. There are some who feel there is a need for increased employee sensitivity to handicapper issues, if all members of the MSU community are to feel valued.

3. There is a need to periodically provide information to individual departments in order to ensure consistency in departmental reviews of accommodation requests.

Program Accessibility:
The ADA Self-Evaluation of Programs

The university is required to conduct its programs, services, and activities in a manner that provides equal opportunity for participation of handicappers. This report section discusses the findings of the university's recent self-evaluation of programs, and efforts being made to correct areas of non-compliance identified in the self-evaluation.

Background

The requirement that an institution's programs, services, and activities must be made equally accessible to handicappers when needed was first established in Section 504 of the Federal Rehabilitation Act of 1973 as amended in 1976 (Section 504). This requirement was extended and reinforced by Title II of the ADA.

The major requirements of these acts include the following:

The mandte for institutional self-examination has been clearly established in federal law which requires public entities to conduct a self-evaluation of the policies and practices used to conduct their programs, services, and activities. This is done to identify areas where handicappers are denied equal opportunity to participate.

The ADA Self-Evaluation Project

Michigan State University's self-evaluation of programs was conducted in a one-year project beginning in May 1993. The overriding project goal was to ensure that the university was in compliance with the self-evaluation requirement of Title II of the ADA. A secondary, but important goal, was to educate program administrators about the law and provide information to assist them in making their programs more accessible to handicappers.

The ADA self-evaluation was conducted using a written survey. Primary responsibility for the process was placed on administrators of the university's major administrative units (MAUs). This was done to increase program investment in the self-evaluation process and shift compliance responsibility to the MAUs, where it must ultimately rest at an institution the size and complexity of Michigan State University. Each MAU administrator was responsible for determining how to evaluate the programs conducted by the MAU's departments--how many self-evaluations would need to be completed, and who should complete them. MAU administrators were responsible for distributing, collecting, and reviewing the self-evaluations completed for departments within each MAU. One-hundred percent compliance in self-evaluation completion and return was achieved.

Program Accessibility Issues: Findings and Planned Modifications

Findings of the ADA self-evaluation indicate that, overall, the university's programs are administered in a manner that provides equal opportunity for participation of handicappers. In general:

At the time of the self-evaluation there were some recurring patterns of potential non-compliance (many of which have now been resolved) in areas such as: lack of accessible telephone communication; failure to review written and audio-visual materials for inappropriate language; and failure to establish and communicate building emergency evacuation plans. Many programs were in the process of modifying program brochures and special event publicity to tell handicappers how to request accommodations. Program staff and faculty were being informed about federal requirements, the university's commitment to handicappers, and of their obligation to be responsive to handicappers who wish to participate in the university's programs. A project to establish building-specific emergency evacuation plans was underway. (See Appendix G for the complete ADA self-evaluation report and elaboration on findings.)

In addition to areas mentioned above, where the self-evaluation identified widespread, but relatively minor, non-compliance issues, there were isolated situations of greater concern:

1. Eligibility Requirements for Program Participation

The self-evaluation found that there were isolated situations (approximately 20) where programs appeared to apply eligibility guidelines that might unlawfully deny or limit handicapper access. These were not situations of explicit exclusion of handicappers, but rather reflected application of possibly unnecessary eligibility criteria that incidentally exclude handicappers. This was noted most frequently in descriptions of required activities in various science courses. These situations were noted on MAU feedback forms, with cautions against making assumptions about the abilities of handicappers based on their characteristics. Comments stressed the importance of communicating with the individual handicapper to determine whether any modifications can be made in required activities and still provide the student with the essential information and experience to be gained from the course. OPHS was referenced as a source of assistance in evaluating service requests.

The list of programs applying potentially unlawfully discriminatory eligibility guidelines was forwarded to the Office of the Provost for review. These eligibility guideline issues are being addressed in the current follow-up and reporting project.

2. Availability and Use of Accessible and Accommodating Facilities

Some programs (approximately 50) reported problems related to accessibility of facilities. Among issues mentioned were inacces- sible buildings or offices housing programs, and lack of accessible and accommodating space in which to locate special events or relocate routine services as needed. Issues related to availability of accessible and accommodating facilities were referred to the Office of the Provost and the Office of Planning and Budgets, Facilities Planning and Space Management for review and follow-up (See Appendix H).

It has been asserted that there is a shortage of accessible and accommodating space on campus, especially for large events. In particular, student groups have difficulty finding accessible and accommodating space in which to hold events. This issue is usually raised in tandem with concerns about the cost of renting such space. While the shortage of accessible and accommodating space is real, there is a need to evaluate the extent to which rental cost is an issue that impacts availability.

Some of the perception that accessible and accommodating space is in short supply may come from a lack of information about available accessible and accommodating facilities in which to hold activities, or procedural difficulties booking such space. HOS has developed a reference guide to accessibility features of on-campus facilities. The guide is available in hard copy and on the Gopher system (See Appendix I), and is updated annually.

Program administrators have been advised to ensure that on- or off-campus activities are held in accessible and accommodating facilities when events are open to the public, or as needed.

Correction of Areas of Non-Compliance

The university is obligated, under the law, to correct identified areas of non-compliance "in a timely manner." These steps have been taken to ensure that this occurs:

The project timeline calls for MAU administrators to have submitted reporting forms to the ADA self-evaluation project office by January 31, 1995. The project coordinator is following up on incomplete or unsatisfactory responses, and will prepare a summary report at the project's conclusion.

Improving program accessibility at Michigan State University is a dynamic process. There will always be additional needs, new technology to be tested and adapted, and new ways to make the university's programs more accessible. The university's commitment to diversity and institutional accessibility is long-standing and has been affirmed recently in such documents as MSU IDEA II, and Foundations and Guiding Principles. It is fundamental to this commitment to continue efforts to provide programs, services, and activities that offer handicappers equal opportunity to participate.

Transportation

Under federal law an institution that operates a transportation service for non-handicappers is obligated to provide handicapper-accessible transportation as well. When viewed in its entirety, the transportation system must provide a level of service to handicappers that is equivalent to that available to others. This section discusses the university's handicapper-accessible transportation system administered by the Physical Plant Division's Automotive Services Department.

MSU has provided handicapper-accessible transportation on campus since 1972. Originally administered through the Office of Programs for Handicapper Students, handicapper transportation became the responsibility of Automotive Services in July 1993. The change in administrative responsibility was made as part of an effort to consolidate all transportation services.

The university provides handicapper-accessible transportation to faculty, students, and staff, with the goal of meeting ongoing demand in a cost-effective manner. Services include the following:

Daytime Transportation Services

Five handicapper-accessible buses of varying size and capability operate on fixed-route and demand-based schedules, from 7:30 a.m. to 10:15 p.m. Monday through Friday, and 10:00 a.m. to 6:00 p.m. on Saturday and Sunday. Handicapper-students who have been evaluated and authorized by OPHS, and handicapper-faculty or staff who have been authorized by HOS, may use the service for the cost of a regular bus pass. Buses take passengers anywhere on campus, but individuals going to classes have priority if demand exceeds vehicle availability. Each day an average of 40 different handicappers receive approximately 100 rides, with use of the service increasing somewhat in inclement weather. It costs the university $190,000 per year to operate this service and satisfy the demand for handicapper-accessible transportation.

After-Hours Transportation Services

Automotive Services operates two handicapper-accessible after-hours transportation services, at an annual cost of $90,000.

Nite-Rider is a fixed-route, free bus service that provides regularly scheduled late night, on-campus transportation to all residence halls, the union building, the library, and many other academic buildings. Hours of operation are 10:00 p.m. until 2:30 a.m. Sunday through Saturday, with buses running at 40-minute intervals. One of the two Nite-Rider buses running nightly is accessible, but Automotive Services recommends that handicappers with mobility characteristics use Dial-A-Ride instead of Nite-Rider if length of wait for the accessible bus is an issue.

Dial-A-Ride, a telephone-requested service provides free after-hours on-campus transportation to buildings and areas not served by Nite-Rider. (NOTE: Handicappers may use Dial-A-Ride to go anywhere on campus, including to and from locations served by Nite-Rider). The service operates during fall and spring semesters from 10:00 p.m. until 2:30 a.m. Monday through Friday and 6:00 p.m. to 2:30 a.m. Saturday and Sunday. Handicappers must indicate their need for accessible transportation when they call for a ride. Most nights there is one handicapper call for Dial-A-Ride service with a wait of approximately ten minutes for response. This is comparable to the length of time non-handicappers wait for Dial-A-Ride service. To date, the service has been able to meet handicapper demand. Automotive Services is not aware of complaints about the service.

Automotive Services Motor Vehicle Pool

The vehicle pool of more than 350 cars and vans, maintained by Automotive Services, is available for faculty or staff who need a vehicle for on- or off-campus university business. Until this year, none of the vehicles was equipped with hand controls or other modifications for handicapper-accessibility, and it was difficult to obtain such vehicles from outside sources.

In fall 1994, Automotive Services equipped one car with hand controls (purchased and installed at a cost of $450). To date, there have been no requests for the car, perhaps due partially to lack of handicapper-employee awareness that such a vehicle is available through the motor vehicle pool. Additional hand control sets will be installed if there is sufficient demand. The goal is to meet demand, without adding unnecessary cost or restricting vehicle use.

Transportation Issues

1. The university reimburses faculty and staff 29 cents per mile when they use their own vehicles to travel on university business. The reimbursement rate is based on federal IRS guidelines. Some handicappers whose personal vehicles are converted for their needs, take issue with the reimbursement rate. They note that their specially converted vehicles are more costly to operate and replace and, therefore, they should be reimbursed at a higher rate. Under current practices faculty or staff, including handicappers, may take a pool vehicle, or one obtained through outside sources, if available, if the reimbursement rate for use of their own vehicle is not satisfactory.

2. The university's fleet of five handicapper-accessible vans is in good condition, but four of the vehicles are limited in versatility, and are of an age that replacement or extensive repairs are imminent. Replacement cost is approximately $45,000 per van.

3. The daily transit fleet of 17 buses includes vehicles that are not handicapper-accessible, average 26 years in age, and are in need of replacement in the very near future. According to Automotive Services, the best solution would be for the university to purchase "newer used" accessible buses for the aging regular fleet. It is estimated that it would cost approximately $1.7 million to replace 17 buses with accessible used vehicles. Funds need to be identified and allocated for this purpose, either through the university's vehicle replacement account or other sources.

4. Privatization of the handicapper transportation system is an issue that the Automotive Services manager explores periodically. It is not believed that any organization could run the system at anywhere near its current operating cost, and provide a level of service comparable to what is now in place.

5. Staff- and faculty-handicappers occasionally have transportation needs (e.g., for meetings or classes) not met by existing handicapper-accessible services that give priority to students going to and from classes. Cost effective options to meet this need should be evaluated.

6. Automotive Services will update informational brochures to reflect the fact that individuals who are deaf or hard-of-hearing may request Dial-A-Ride service by calling a campus operator who then relays calls. This information needs to be included in relevant publications (e.g., Spartan Life). Alternatively, Automotive Services should consider obtaining a TTY to enable the deaf or hard-of-hearing to request services directly.

7. Policies governing eligibility to use the handicapper bus service should be written or revised. Consideration should be given to expanding eligibility to individuals with visual characteristics. It should be noted that expanding transportation services will require additional funding.

Handicapper Students:
The Educational Experience

Federal law obligates MSU to make the total educational experience equally accessible to handicappers who wish to participate. This includes the classroom and related academic requirements (e.g., internships and field experiences, required study groups, and class field trips) as well as extracurricular activities offered by the university or groups to which it provides "significant assistance." This report section addresses the extent to which the university meets its obligation to make educational requirements and extracurricular activities equally accessible to handicappers.

OPHS is administratively responsible for working with handicapper-students to ensure that they are afforded an equal opportunity to participate in the university's academic programs. The office is staffed by specialists who work individually with handicappers having a wide variety of characteristics--mobility, visual, hearing, learning, and others. They are advocates, as well as resource personnel, for the university's handicapper-student population. OPHS also serves as a resource to faculty, support staff, or program administrators who may need assistance or information in order to make their programs, classes, or other activities equally accessible to handicappers.

General Information

By the end of December 1994, 521 students had self-identified as handicappers. The table on the next page shows a breakdown of characteristics represented among these students, and types of services typically provided for individuals with each type of characteristic.

It is important to note that the number 521 represents only those individuals have chosen to self-identify, and includes 50 temporary handicappers due to injury or illness. For various reasons, many handicappers do not self-identify initially. They choose to come forward at some point during the year, usually after discovering they need more assistance than they originally thought, either in the classroom or in their living situations.

Handicapper characteristics identified include mobility characteristics (often visible and consistently the most common), visual characteristics, deaf or hard-of-hearing, learning characteristics, temporary characteristics due to illness or injury, and others (e.g., psychological characteristics, asthma, diabetes, heart condition). Accommodations for the classroom and related academic requirements (technically called "academic adjustments" or "auxiliary aids and services"), and for housing, transportation, and extracurricular activities, vary widely in type (as the chart shows), complexity, and cost.

Self-Identified Handicapper Students
(By Characteristic)

Mobility Visual Hearing Learning Other** Total
184* 36 29 182 90 521

* Includes 50 temporary handicappers (due to injury)
** Asthma, heart condition, diabetes, psychological characteristic


Typical Services Provided

Mobility Characteristic
Eligibility determination for handicapper bus service
Eligibility for handicapper parking
Housing accommodations
Personal assistant referral service

Visual Characteristic
Taping of textbooks
Alternative format for other materials (e.g., large print, Braille)
Adaptive computer lab for student training and use
Campus orientation

Deaf or Hard-of-Hearing
Sign language interpreter
Information about recruiting in-class volunteers for note-taking
Housing accommodation arrangements

Learning Characteristic
Learning strategies tutoring
Arrangements for alternative testing (e.g., extended time)

Responsibility for Serving Handicapper-Students

OPHS, in its twenty-third year, bears primary administrative responsibility for assisting handicapper-students and "provides a broad range of services enabling a diverse handicapper-student population to participate in the academic programs and other activities of university life" (OPHS 1993-94 Annual Report, p.1). The office has two major areas of responsibility:

The Self-Identification Process

Handicapper-student self-identification (registration with OPHS) is important to the university's efforts to make the educational experience equally accessible to handicappers. It is an optional first step, however, and the university's obligation to provide accessible programs is not lessened toward handicapper-students who choose not to self-identify through OPHS.

There are a number of points in the inquiry and admission processes when a student can self-identify:

Many handicapper-students choose not to self-identify during the admission and orientation process, but come forward later in the year. This generally occurs when students encounter difficulties in their academic program, housing situation, or extracurricular activities prompting them to request services. Also, students may become handicappers during the year through illness or injury.

Evaluation of Needs and Provision of Services

No matter when the student self-identifies, OPHS' role in evaluating the handicapper-student's needs and providing appropriate assistance remains the same.

When a student self-identifies, an OPHS staff specialist is assigned to evaluate needs and determine appropriate services. The specialist, along with the student, begins the process of arranging services. For example:

Identification of Handicappers by Other Offices or Personnel

Ideally handicappers self-identify through OPHS prior to arrival on campus. In reality, however, they may not be identified until (or unless) they come forward to faculty, residence hall personnel, or others and indicate a need for a service. Under these circumstances the preferred course of action is for the professor or staff person to refer the student to OPHS for evaluation.

Handicapper-Student Satisfaction

A November 1994 survey of self-identified handicappers (See Appendix F), conducted by OPHS, found generally high levels of satisfaction. Ninety-one students returned the survey, providing the following information:

Most respondents either did not answer an open-ended item that asked for comments, or they indicated satisfaction with their experience at MSU. Concerns or suggestions for improvements mentioned several times by respondents include the following:

Handicapper-Student Issues

A number of issues must be addressed in order for MSU to retain its international stature as an institution that offers handicappers equal opportunity to participate in the full range of programs offered by the university. Primary among these issues are the following that have been identified by OPHS staff, the President's Handicapper Advisory Committee, and students:

1. There is general concern that confidential information is occasionally requested from handicappers by academic departments or individual faculty or staff. Issues of confidentiality and the "need to know" suggest that processes involving confidential information (e.g., medical drop requests) should go through OPHS and an established expert review committee. The issue has been brought to the attention of the Assistant Provost for Student Academic Support Services, and Racial, Ethnic and Multicultural Issues (SASS/REM).

2. The high cost of providing sign language interpreters for the deaf or hard-of-hearing makes it imperative that the university continue to seek more cost-effective ways to provide this service. About one-quarter of the OPHS aids and services budget this year ($100,000) is being spent to provide approximately 200 hours of interpreting per week for nine deaf or hard-of-hearing students. Past problems with finding enough interpreters were generally resolved this year by hiring four interpreters (each working 20 to 30 hours per week) as OPHS staff, supplemented by freelance interpreters. To continue meeting demand in a more cost-effective manner, it will be neces sary to hire additional salaried sign-language interpreters, relying less on expensive freelancers. Also, alternatives to sign language interpreters should be explored.

3. The possibility of paying some readers, instead of relying totally on volunteers, should be thoroughly explored in view of recent quality and availability concerns and increasing demand for this service. In 1993-94, OPHS organized volunteers who spent 3,912 hours recording more than 67,000 pages of text for the OPHS library collection. Demand is expected to increase each year, and it will be more difficult to recruit enough volunteers to perform this service and maintain a consistent level of quality.

4. There is a need to inform handicapper-students about OPHS services. OPHS needs to find effective ways to "market" its services to students to increase awareness. Also, it is suggested that faculty make in-class announcements early in the semester, telling students about OPHS and recommending that handicappers self-identify.

5. Faculty and teaching assistants should be reminded of their obligation to make their classes accessible to handicappers as needed, and how to contact OPHS for assistance or advice. In particular they must remember to consider the needs of handicapper-students when they arrange for field trips, in terms of both destination and transportation.

6. Students with psychological characteristics are self-identifying in increasing numbers and their needs must be met. There is a need to determine the best method for doing this, while maintaining confidentiality in this sensitive area.

7. Consideration should be given to providing certain full-time enrollment benefits (e.g., financial aid, eligibility for certain activities) to handicapper-students who are not able to carry full credit loads. In most cases part-time enrollment is not the handicapper's choice, but a necessity due to health or other handicap-related issues.

8. The issue of handicapper-student retention should be thoroughly explored, to determine the impact and overall value of services and programs for the handicapper population.

9. The accessibility of course material in certain required or popular courses is of concern to many handicappers. This concern is expressed specifically about mathematics and science courses which may be visually oriented, and computer science courses taught using applications that cannot readily be modified for voice input or output (e.g., Windows). Collaboration between appropriate units must continue and expand in order to make courses equally accessible to handicappers whenever possible, short of fundamentally altering essential course content.

Handicapper-Student Participation in Extracurricular Activities

The importance of extracurricular activities in the overall learning experience is not disputed; a great deal of learning occurs outside the classroom, in the living situation, and through participation in spontaneous activities and organized student groups. Under the law, handicapper-students have a right to equal access to these activities.

The program or group offering an activity (e.g, party, meeting, trip, athletic event) must ensure that such activities are accessible to handi- cappers who wish to participate. This legal requirement covers student groups receiving "significant assistance" from the university. "Significant assistance" includes, but is not limited to: provision of a faculty or staff advisor, use of university facilities for activities at no charge or a reduced rate, provision of a university account, on-campus advertising, or university assistance collecting funds. Further, the university's Anti-Discrimination Policy clearly prohibits discrimination against handicappers in the conduct of "programs and activities sponsored by student governing bodies, including their constituent groups, and by registered student organizations" (See Appendix J).

The organization sponsoring an activity is responsible for meeting handicapper requests and paying for them. OPHS provides lists of resources and guidance to those planning extracurricular activities, but does not directly provide or pay for adjustments needed to make such activities accessible to handicappers.

There are currently two all-university student governing bodies at the graduate and undergraduate levels (Council of Graduate Students and Associated Students of Michigan State University), nine major governing groups (e.g., Residence Halls Association, Interfraternity Council, National Panhellenic Council, Intercooperative Council), approximately 100 constituent groups (including fraternities, sororities and housing cooperatives), and 350 registered student organizations (e.g., single-parents support group, flying club, sailing club) affiliated with Michigan State University. The advisors and leaders of the all-university and major governing groups and registered student organizations are systematically informed of their obligation to make programs and activities equally accessible to all students who meet participation criteria and wish to be involved. Efforts to make activities accessible to handicappers include, but are not limited to: locating activities in accessible and accommodating facilities when needed, providing sign language interpreters for meetings if requested, and providing written materials in alternative format when needed.

Extracurricular Activities Issues

1. As has been done with advisors and leaders of major governing groups and registered student organizations, leaders of constituent groups (e.g., fraternities, sororities, and cooperatives) should be systematically informed of their obligation to make programs and activities equally accessible to all students who meet participation criteria and wish to be involved.

2. There is a lack of affordable, accessible and accommodating on-campus space suitable for large activities. The budgets of many student organizations are not sufficient to cover charges for the use of certain accessible and accommodating facilities. Also, the spontaneous nature of many student group activities makes it difficult for these groups to reserve high-demand accessible space far enough in advance.

Accessibility of Computing Technology

The importance of computing technology in the educational experience, makes it imperative that such technology be equally accessible to handicapper-students. Computing and Technology (C&T) within the Office of the Provost supports the academic microcomputing needs of the MSU community. C&T provides a variety of technologies through its constituent units, and also through appropriate matching allocations to other campus units from the central C&T budget. The all-university "Computer and Communications Systems Advisory Committee" (CCSAC) provides advice on all phases of campus information technology. In July 1994, CCSAC voted to create the "Accommodating Technologies Committee" as a standing committee of CCSAC, to advise C&T in addressing handicapper issues. While C&T supports the computing technology needs of faculty, staff, and students, discussion here will focus on students.

Within C&T, the Client Advocacy Office is prepared to receive any adaptive technology requests and to coordinate appropriate responses across multiple units. Within the information technology purview of C&T, the Client Advocacy Office will advocate for budget commitments, policy changes, and any other needed actions, in order to serve academic and non-academic personnel, students, or members of the general public on campus or through outreach technologies.

Broadcasting Services provides a variety of alternative technologies, such as Radio Talking Book broadcasts for individuals with visual characteristics and closed-captioning of video programs for the deaf or hard-of-hearing. Since 1992, classroom television equipment acquisitions by Broadcasting Services have supported closed captioning. "Produced" (as opposed to live) instructional programs such as IAH 201 and CPS 130 have been captioned. Although the old instructional television origination classroom has a floor that is too steeply pitched for wheelchair users, new facilities permit origination from accessible space.

Among many other services, Academic Computing and Network Services provides academic microcomputing support to the MSU community. There are over 40 university microlabs located in more than 20 classroom buildings and residence halls, and in the MSU Union. Overall, university microcomputer laboratories are wheelchair user-accessible. Exceptions include the microlab located in Mason-Abbot, an inaccessible building, and a microlab under contract for Cooley Law students in Butterfield, which is not accessible). If university microcomputer labs are not on the first floor, elevators are generally available. Tables of sufficient height to accommodate wheelchairs are available in most labs.

With financial support from Computing & Technology, OPHS has acquired several systems to assist users with visual or physical characteristics requiring voice output and/or voice input. A number of DOS-based products are currently available, and the MSUCL continues to acquire voice input and output tools for Windows and Macintosh platforms, as well as additional DOS tools. Several products are presently being evaluated and pilot tested in cooperation with OPHS. They will be deployed flexibly, as needed, across more than 2000 instructional microcomputing lab seats, spanning all subject disciplines. Specific resources are deployed, replicated, and upgraded to meet actual needs and respond to advisory input. Funding for a central, network-attached Braille printer has also been allocated and the system ordered.

With the rise in personal computer ownership and the growing availability of laptops, including those loaned out by the university, MSUCL accommodation activities increasingly involve installation of individually selected tools on personal and/or portable equipment. This approach to accommodation will become more attractive as technological advances promote greater laptop utilization by the entire population of technology users.

Information concerning specific adaptive devices available in microlabs or by loan, and general services in the Computing & Technology Training Program, can be found on-line in Gopher and in a variety of print materials. New service documentation efforts are expected to deal with adaptive technologies consistently and explicitly.

Computing & Technology also supports college-based research and development efforts aimed at improving adaptive technologies. Multimedia development to assist the teaching of signing has been supported in the past. Currently, funding is being provided for the faculty-initiated development of a tactile map of campus.

Computing & Technology units cooperate with several other campus entities in providing adaptive technologies, including: the Artificial Language Laboratory, HOS, and OPHS.

Computing Technology Issue

1. Development trends in the software industry place heavy reliance on graphical user interfaces, increasing handicapper-use complexities confronted by the MSUCL and other campus units. Efforts to acquire and evaluate voice input and output tools for Windows and Macintosh platforms should continue and expand, in order to make these applications more accessible to individuals with visual characteristics.

Facilities

Federal laws obligate the university to make its programs, services and activities equally accessible to handicappers. In many cases the only way to meet this program accessibility requirement is to make facilities in which programs are conducted accessible. While relocation of a program, or part of it, is an acceptable means of meeting this requirement, it only works to the extent that a program can be moved to an alternative location. There are many situations where the facility is integral, or essential, to the program (e.g., unique and unmovable laboratory equipment, the football stadium). Also, federal requirements mandate that handicappers should be able to participate in programs in the most integrated setting possible. This is not consistent with relocation, where handicappers may be the only ones participating in the program in the alternative location. Therefore, making the university's facilities accessible and accommodating is an important part of providing programs that are equally available to handicappers. Facility modification to provide the maximum possible program access has become an institutional priority --an integral part of the university's commitment to handicappers.

Establishing Priorities for Facility Enhancement

Program accessibility drives the university's efforts to make its facilities accessible and accommodating. Priorities are based on program utilization criteria; facilities that are more "program intensive" and integral to various programs are generally higher in priority than less used, less unique facilities. Sources such as the Schedule of Courses and the Faculty and Staff Directory were initially used to identify programs and facilities housing them. Most recently the 1993-94 self-evaluation of programs identified facilities issues raised by program administrators.

To maximize program access, as funds permit, a few selected facilities are modified each year to provide accessibility and a basic level of accommodation (e.g., one toilet room per gender, one drinking fountain per floor, and one telephone lowered to a height accessible to wheelchair users). Frequently, in order to increase accessibility while reducing costs, modifications to make facilities accessible and accommodating are "piggy-backed" onto regular deferred maintenance projects. Barrier removal progresses logically from exterior access (getting into the building) to interior horizontal and vertical access (moving around and between floors). Making a facility usable (accommodating) is the next step, and requires modification of seating, toilet rooms, signage, alarms, drinking fountains, and telephones. Achieving "user friendliness" is the final stage in facility modification, consisting of "fine tuning" for maximum handicapper access and usability (e.g., multiple toilet rooms per facility, usable computer labs, and other items not addressed in construction codes). Michigan State University's commitment to handicappers includes going beyond legal requirements to make facilities user friendly, as funding permits.

The Transition Plan

The Transition Plan for barrier removal, developed initially as a requirement of the Federal Rehabilitation Act, guides all facility modification. Its focus was, and is, identification and removal of architectural or physical barriers that limit or deny access to programs in specific facilities. The first plan, written in the late 1970s, identified issues and suggested areas needing improvement. However, it was the work of various task forces through the 1980s that produced the 1988 Transition Plan, including a list of facilities and barriers. Events and documents evolving over nearly twenty years have shaped the existing Transition Plan.

The existing Transition Plan and inventory of barriers is a dynamic document that permits, in fact requires, flexibility "within the context of funds available for alterations and improvements" to address urgent individual needs that may be identified (Michigan State University Transition Plan, 1994, p.5). It requires frequent update and modification in light of changing priorities and completion of projects. The Transition Plan has guided, and will continue to guide, the university's facilities modifications to maximize program accessibility. It will cease to be an evolving document only when total program accessibility is achieved. (The complete Transition Plan is available for review in OPB/FPSM.)

Current Efforts

The Office of Planning and Budgets, Facilities Planning and Space Management administers the Transition Plan and generally oversees modification of facilities. However, three administrative areas are operationally responsible for determining priorities and allocating funds for modifications:

Projects funded by the three administrative areas for FY1994-95 include the following:

OPB/FPSM: Abrams Planetarium toilet rooms; automated doors at the north entrance to the Administration Building; International Center; handicapper access to the southeast entrance to the Natural Resources Building; an automated entry door for Marshall Hall; and interior improvements to North Kedzie Hall.

Housing and Food Services: external access or internal improvements in Akers, Case, Holmes, Hubbard, and Wonders Halls; fire alarm strobes in Case, McDonel, Wilson and Holmes Halls; Braille signage in lower public areas of Mason Abbot Hall; and improved accessibility of Spartan Village Apartments health clinic site.

Intercollegiate Athletics: handicapper seating accommodations in conjunction with field renovations in Spartan Stadium.

New Construction

Since 1984, university construction standards have required that any new facilities built on campus incorporate "universal design" features making them inherently accessible and accommodating. University standards exceed those established in state and federal codes. The HOS coordinator reviews new construction plans to ensure compliance with universal design requirements.

Facilities Issues

A number of facilities-related issues have been raised by individuals, groups, or departments. They include the following:

1. There is a need to evaluate the availability and affordability of accessible and accommodating space suitable for large events. Hopefully such an evaluation will clarify the extent to which this issue is one of actual space shortage, prohibitive rental cost, or both.

2. There is a need to continue the systematic evaluation of off-campus university facilities, begun by the HOS coordinator, to identify facility barriers to program access, establish a priority for enhancement, and identify funds to make necessary modifications.

3. Handicappers raise general concerns that seating accommodations in the major athletic facilities do not offer representative viewing options for handicappers. The Department of Intercollegiate Athletics acknowledges these concerns, indicating that, as funding is available, modifications will be made as part of an existing overall plan to make all athletic venues both accessible and accommodating.

4. Playgrounds constructed on university property (e.g., in the family housing apartment complexes) should be evaluated to determine whether they are accommodating to handicappers. Equipment used and methods of installation impact overall accessibility.

Telecommunication

Accessible telephone communication is an integral part of overall program accessibility at MSU. This report section describes the university's efforts to locate and equip telephones to provide handicapper-accessible telecommunication.

Telecommunication is a broad category, with different administrative units responsible for various aspects. Specifically:

Departmental responsibility: Individual departments are responsible for making their office telephones accessible when needed. The ADA self-evaluation found widespread need for departments to evaluate the extent of telephone contact with students or the public and to consider obtaining a TeleTYpewriter (TTY) if contact is extensive or if there is a demonstrated need within the department (e.g., a deaf or hard-of-hearing employee, deaf student enrolled in the program). Otherwise, use of the Michigan Relay Center, a free operator-assisted service that relays conversations between someone using a voice-based telephone and a deaf or hard-or-hearing individual, will suffice under the law. It is estimated, based on information provided by the Purchasing Department, that twenty departments have obtained TTY devices for their telephones.

Residence Halls: Housing and Food Services is responsible for residence hall lobby and room telephones. There is cooperation between Telecommunication Systems and Housing and Food Services when telephones in these buildings need to be equipped with TTYs. Presently five residence halls have TTYs available at reception desks for use on lobby telephones. OPHS indicates that there are 11 deaf or hard-of-hearing students living in residence halls now; four of them use TTYs and have their own equipment.

Public telephones in facilities other than residence halls: Telecommunication Systems within the Physical Plant Division is directly responsible for campus lobby, coin, and elevator telephones in academic and office buildings, and other facilities across campus. Priority for modification of telephones, based on building traffic, has been established by HOS and OPHS in cooperation with Telecommunication Systems. There are multiple aspects to telephone accessibility:

Adjustment of telephone height (if wall-mounted): To be reachable by a wheelchair user, a wall telephone must be centered in a five-square-foot area and mounted at a height that places the touchtone key pad no more than 48 inches from the floor. Ninety percent of approximately 270 wall-mounted campus lobby and coin telephones have been moved to this height, either based on a priority system or by special request. It costs approximately $400, including reinstallation of the shelf, to move a telephone to a height accessible to wheelchair users.

TTY equipment--installed or available: Four of the 210 coin telephones on campus have been replaced (at a cost of approximately $850 per phone) with TTY-equipped telephones in high-traffic buildings: the Nisbet Building, the Library, Erickson Hall, and the Hannah Administration Building. Portable TTY equipment (costing $250 to $500 per phone) is available in six other high-use buildings: Wharton Center main lobby, MSU auditorium main lobby, International Center main lobby, MSU Union main lobby, Kellogg Center main lobby, and the Breslin Student Events Center. Coin telephones in several high-traffic buildings, identified by OPHS and HOS, still need to be equipped with TTYs. These buildings include Berkey, Bessey, and Wells halls.

Three of 60 campus lobby telephones have been equipped with a TTY, or a portable TTY has been made available in a designated nearby office, per recommendation of the HOS coordinator.

Telephone accessibility is generally considered from the perspective of the deaf or hard-of-hearing, because telephone communication is auditory in nature. There are, however, potential issues for those with visual characteristics; they are unable to read telephone directories in written format, or see the dial or touchtone key pad. Because both AT&T and campus operators are cooperative and helpful providing telephone numbers and other assistance, the need for alternative format directories is not apparent. Memorization of the touchtone key pad is one of the basic tasks of individuals with visual characteristics, so there is no apparent need to consider key pad enhancements at this time.

Telephone Operators: Campus operators receive approximately two calls per month from deaf or hard-of-hearing individuals with whom they need to communicate via TTY. The office is equipped with a portable unit that is available at all times.

Elevator Telephones: All elevators are required to be equipped with telephones and emergency buttons that are accessible to wheelchair users. Since 1983, federal laws have required that any elevator inspected or repaired must meet this standard. Presently 86 of 151 passenger elevators on campus are equipped with handicapper-accessible telephones. Enhancement of elevator telephones for handicapper accessibility occurs in concert with other elevator modifications, at a cost of approximately $850 per telephone. All passenger elevators on campus now have emergency buttons, although some may not yet be lowered for wheelchair user accessibility.

The Outdoor Environment:
Building Access, Pathways, Roads, Parking, and Other Site Features

Universal site design is not a simplistic goal that can be achieved through the thoughtful handling of one or two problems on a site. Accessibility out-of-doors depends on the physical relationships between design elements both inside and outside the building. Unless there is a relationship of continuous accessibility between forms of transportation, site elements and building entries, the value in making any of these components more accessible is diminished. Consequently, it is important that all elements of circulation be made as accessible as possible. This report section discusses the university's efforts to create and maintain an outdoor environment that is accessible and safe for handicappers.

The Division of Campus Park and Planning (CPP) designs, estimates, bids, and supervises construction projects, and the Grounds Maintenance Department provides maintenance services for the university's outdoor environment. Typical services provided by CPP to develop and maintain handicapper accessibility include the following:

*NOTE: Buildings with heated snow-melt pathways are, Berkey Hall, Bessey Hall, Breslin Student Events Center, Eli Broad College of Business, Engineering Building, Kellogg Center, Kresge Art Center, Music Building, Old Horticulture Hall, Oyer Speech and Hearing Clinic, South Kedzie Hall, and Veterinary Medical Center. In other cases, structural canopies have been used to ensure all-season accessibility. The east approach to South Kedzie Hall and the main approach to the new Veterinary Medicine complex "G" Building are examples.

Campus Park and Planning is responsible for removing barriers and constructing new accessible pathways as part of the construction process when roads, walks, and other site features are altered. Since 1973, 133 new grade level approaches to building entrances and 1,211 new pathways have been constructed on campus.** Expenditures to construct these improvements total nearly $1,340,000 in general fund dollars. Today 75 to 80 percent of all pathways have barrier-free pathramps at street intersections.

**NOTE: These numbers do not include major building accessibility projects that are separately funded.

Major building access projects under construction or completed during the current year include Linton Hall, Bessey Hall, and Oyer Speech and Hearing Clinic. Two major projects planned for the coming year are the International Center and the Natural Resources Building.

Outdoor Environment Issue

1. As additional campus pathways are planned and constructed, attention should continue to be given to establishing "inter-related pathways" that are free of obstructions. Pathways with sharp and frequent turns and such "interrupting" obstructions as bushes, bike racks, and trees often cause individuals with visual characteristics to become disoriented, and on occasion injured.

On-Campus Parking for Handicappers

On-campus handicapper parking is governed generally by program accessibility requirements, and specifically by Michigan construction code requirements that establish standards for handicapper parking.

The MSU Department of Police and Public Safety (DPPS) and Campus Park and Planning are administratively responsible for planning and overseeing the construction of handicapper parking on campus. DPPS does not identify a dollar amount specifically targeted for handicapper parking, but where parking lot design is involved, DPPS works closely with CPP, and that unit's budget covers parking lot modifications. DPPS is responsible for enforcement of handicapper parking regulations.

In the design and modification of new and existing parking areas, the university complies with state and federal laws governing handicapper parking. Generally:

Overall, MSU complies with State of Michigan code in the design and construction of handicapper parking. Some minor variances from these requirements exist, however, where strict adherence would establish either inadequate or unneeded handicapper spaces (in remote parking areas for example) and reduce availability of regular parking. DPPS and HOS jointly agree on any reasonable variances from general requirements. At the same time, DPPS often provides more handicapper parking than code requires; at heavily attended entertainment or athletic events additional handicapper parking is posted at event sites.

Parking Issues

A number of handicapper parking issues surface as those most mentioned:

1. Handicapper parking near major event facilities (Spartan Stadium, Breslin Student Events Center, Munn Arena) is always in short supply during major events at any of these locations. However, posting the number of spaces that would meet demand during special events, would result in excess handicapper parking for day-to-day demand. The university has successfully addressed this problem by running handicapper shuttle services from peripheral parking areas during major events, and by reserving large numbers of parking spaces for handicappers near the event sites. Specifically:

2. Abuse of handicapper parking is a long-standing issue at MSU. DPPS and HOS believe the shortage of handicapper-accessible parking is more a matter of illegal use of handicapper parking by non-handicappers than of actual space shortage. There is generally enough parking for handicappers, but not enough to support the additional number of individuals who forge or otherwise illegally obtain or use handicapper parking permits, or who park without permits in posted handicapper spaces.

The university is trying several methods to curtail illegal use of handicapper parking. Now, in order to park in employee or student parking areas, handicappers must have both a State of Michigan handicapper permit and one issued by the university. Handicapper-students must be approved by OPHS, and employees by HOS, in order to obtain a university handicapper permit for medical reasons from DPPS. This does not address the situation in public parking areas, where only the State of Michigan permit is required, but it has already reduced the misuse of handicapper parking spaces in employee and student parking areas.

Implementation of two types of leased handicapper parking should further reduce abuse of handicapper parking:

3. Ease of access to State of Michigan handicapper parking permits contributes to the abuse of handicapper parking. Requirements for obtaining approved State of Michigan handicapper permits will become more stringent in the future, when approval of funding allows modification of procedures. Also, it is apparently easy to alter the State of Michigan permit. Design of a permit that is less easily modified would help reduce such abuse.

4. Handicappers who cannot drive are able to obtain handicapper parking permits. DPPS and HOS suggest that individuals who cannot drive not be issued permits to park. Instead, having a companion obtain an on-campus driving permit, or use of the handicapper-accessible on-campus transportation service would reduce the unnecessary use of handicapper parking.

5. In winter, the Grounds Department clears parking areas of accumulated snow. As snow is plowed, it frequently accumulates in handicapper spaces that tend to be at the end of parking areas, near building entrances. Plow drivers need to push snow far enough out of parking areas to leave handicapper spaces clear. Also, sign posts need to be located to facilitate snow removal.

Handicapper Safety on Campus

Handicapper safety is the focus of ongoing concern within the handicapper community. Safety issues, and responsibility for addressing them, range across a number of administrative units, depending on the area of concern and constituent group involved (i.e., faculty, staff, or students). Safety issues raised by the handicapper community are summarized here, with the recommendation that the HOS coordinator and DPPS should thoroughly evaluate handicapper safety and make specific recommendations for how these issues would best be addressed by the university. Issues raised here are not indicative of safety code violations, but of concerns expressed by individuals, generally to OPHS and HOS.

Handicapper Safety Issues

1. Traffic safety is a broad area, affecting faculty, staff, and students. OPHS receives the most traffic-related complaints from students; DPPS and HOS more from employees. Students are potentially most effected because they spend more time out on campus at class breaks when motor vehicle, bicycle, moped, foot, and in-line rollerskate (rollerblade) traffic are at their highest. There seems to be a general lack of awareness of, and respect for, the State of Michigan White Cane Law, protecting individuals using white canes, as motorists and bicyclists often fail to yield to them. Also, careless high-speed bicyclists often use sidewalks rather than bike paths, and run into individuals who cannot see them coming. There is a need to use appropriate media to inform motorists and bicyclists about laws requiring them to yield to handicappers, and to implement university policies regarding appropriate use of in-line rollerskates.

2. Individuals with visual characteristics have no way of knowing where to find emergency telephones, marked by a highly visible green light, but no audible signal or tactile marker of any kind. Cost-effective and aesthetically acceptable options for marking the location of emergency telephones for individuals with visual characteristics should be evaluated.

3. Tactile campus maps for individuals with visual characteristics are currently being updated through funding from C&T and SASS/REM. Completion of this project will resolve concerns about the inaccuracy of 20 year old, outdated maps.

4. During winter months when snowfall may be heavy and accumulate quickly, roads and pathways are not always cleared frequently enough to prevent snow from piling up. This makes movement difficult, indeed dangerous, for wheelchair users. Further, high piles of snow make it difficult for those with visual characteristics to hear traffic and orient themselves.

5. The university is moving forward with a project to develop emergency evacuation plans for individual campus buildings. Evacuation plans will include procedures for notification and evacuation of handicappers in the event of fire, tornado, or other emergencies. DPPS is coordinating this project with HOS, prioritizing building evaluation order on "life safety priorities" (i.e., level of risk within the building, due to the presence of chemicals, potential for human error, etc.). DPPS anticipates that the project will be completed within two years.

6. OPHS and HOS recommend that Campus Park and Planning consider highlighting certain environmental features (e.g., first steps in flights of stairs, cement bollards) so those with low visual acuity can see them.

Accommodations for the Public

Each year Michigan State University welcomes hundreds of thousands of public visitors to its main campus and facilities across the state. Members of the public participate in such activities as athletic and entertainment events, conferences, and meetings. Additional thousands visit the university informally each year to: tour greenhouses or gardens; buy ice cream at the ice cream store; visit the museum or farms; go canoeing; or hike in the Sanford or Baker natural areas, Kellogg Forest or Hidden Lake Gardens.

General Requirements

The university is obligated to make its programs for the public equally available to handicappers. Individuals needing special accommodations in order to participate in scheduled special events, or visit a university facility informally, may contact the administering department or program to inquire about facility accessibility or make specific accommodation requests. The department or program is obligated to respond to these requests and pay associated costs (e.g., for qualified sign language interpreters).

Facility Accessibility, A Key Factor in Accommodating the Public

Facility accessibility is often a critical aspect of public program accessibility. The law allows for relocation of activities or services as a means of achieving overall program accessibility. However, for many public events and most informal visit sites, relocation of activities is not possible. Either the facility is critical to the program (i.e., Spartan Stadium is the only place suitable for intercollegiate football) or the facility itself is the reason for the visit (i.e., one must go to the horticulture gardens in order to visit them). Therefore, when considering public program accessibility (particularly for individuals with mobility characteristics), facility accessibility--grade level approaches, toilet rooms, spectator seating, telephones, elevators, and drinking fountains, is the main emphasis.

Beyond facility accessibility, there may be a need for other kinds of handicapper accommodations, such as written materials in alternative format or sign language interpreters. HOS helps departments provide accommodations for members of the public, either by arranging for the accommodation directly or by referring the department to the appropriate resource. HOS serves in this capacity for the university's on- and off-campus programs.

The East Lansing Campus

To evaluate the accessibility of the university's public programs and facilities, administrators of on-campus facilities or departments responsible for various public events were contacted in the preparation of this report (See findings in Appendix L). Without exception, program administrators were aware of the Americans With Disabilities Act, and of their obligation to accommodate handicappers who want to attend a program or visit informally. They indicated that, overall, scheduled public events and major informal visit sites are accessible to handicappers. There are areas of concern: inaccessible toilet rooms in a few facilities, concession counters and ticket windows that are too high for dwarfs or wheelchair users, Fairchild Theater, Kobs Field, and some inaccessible museum exhibits. These areas need to be evaluated, and corrected if they are barriers to program participation.

NOTE: Many facilities used for public events are already incorporated into the Transition Plan for barrier removal, if facility inaccessibility is an impediment to program accessibility.

Off-Campus Facilities and Programs

It is estimated that MSU's off-campus facilities (e.g., Kellogg Biological Station, Hidden Lake Gardens, Troy Management Center) see a total of 250,000 public visitors and conferees each year. The law, and MSU's commitment to handicappers, require that off-campus programs be equally available to handicappers.

The accessibility of off-campus public events and informal visit sites is less certain than for main campus facilities, but just as important from the standpoint of legal requirements and public relations. When contacted during the self-evaluation and in the preparation of this report, administrators of the major off-campus facilities were generally cognizant of the ADA and of their obligation to accommodate handicappers. The recent self-evaluation of programs was helpful in raising awareness. They mentioned obvious problems such as inaccessible toilet rooms, but did not discuss more subtle potential barriers such as inaccessible drinking fountains, sharp turns, and steep grades to entrances. Contacts with these administrators led to the conclusion that they are certainly willing to accommodate, but in many cases need guidance on exactly what this means and how to do it.

Public Accommodation Issues

1. There is a need to continue the systematic evaluation of off-campus facilities begun by the HOS coordinator, identify barriers to program accessibility, establish priorities for enhancement, and identify funds to make necessary facility modifications.

2. A comprehensive plan should be developed to train administrators and staff of off-campus facilities and programs regarding program accessibility requirements, university obligation and commitment, general guidelines in making programs accessible, and available alternatives and resources for responding to accommodation requests. Currently the HOS coordinator provides this training upon request.

Summary

This report documents the status of handicappers at Michigan State University. Recognizing that there are many issues yet to be addressed, the report reveals progress that is nothing short of remarkable. The campus is hardly recognizable as the place where, thirty years ago there were makeshift ramps at a few classroom buildings, and no thought was given to handicappers in the planning of activities. Major changes in the physical environment, employment procedures, dedication of resources, policy and practice used to conduct programs, and perhaps most importantly in awareness, have made MSU an internationally recognized leader providing educational and employment opportunity to handicappers. The university's long-standing commitment to institutional accessibility and diversity, and the principle that all people matter, will drive and guide continued efforts to make the MSU community one that welcomes the contributions of all its members, including those who are handicappers.

Report on the Status of Handicappers at Michigan State University
Prepared by Handicapper Operations and Services
A Division of The Office of the Assistant Vice President for Human Resources

C. Keith Groty, Ph.D. Assistant Vice President for Human Resources
Eric Gentile, Coordinator Handicapper Operations and Services
Dawn Hecker, Coordinator Special Projects

Michigan State University
March 1995

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