General Nondiscrimination Commitment
Trigram Education Partners and its schools are committed to full compliance with the requirements of Section 504 of the Rehabilitation Act and its implementing regulations (34 C.F.R. Part 104 in general and in particular subpart E relating to postsecondary education institutions) and Title III of the Americans with Disabilities Act (ADA) and its implementing regulations (34 C.F.R. Part 36). Section 504 specifies that no qualified person with a disability shall, on the basis of disability, be excluded from participation in, be denied the benefits of, or otherwise be subjected to discrimination under any program or activity, which receives Federal financial assistance. Title III of the ADA prohibits public accommodations (including undergraduate private schools or other places of education) from engaging in discrimination on the basis of disability. Consistent with Section 504 and ADA, Trigram Education Partners and its schools do not discriminate against qualified individuals with disabilities on the basis of disability in its programs and activities.
The term “individual with a disability” means any person who
- Has a physical or mental impairment that substantially limits one or more of the major life activities of such individual;
- Has a record of such an impairment; or
- Is being regarded as having such an impairment.
The term individual with a disability will be construed by Trigram Education Partners and its schools consistent with the ADA Amendments Act of 2008 (Public Law No. 110-325 (September 25, 2008).
A “qualified individual with a disability” means a person with a disability who, with or without academic/nonacademic adjustments, meets the academic and technical standards requisite to admission or participation in the postsecondary education institution’s education programs or activities.
The term “programs and activities” includes admissions, academic and degree plans (including coursework and clinical placements), financial aid, recreation activities, transportation, career placement, field trips, and any other programs offered by a postsecondary education institution.
Treatment of Students, In General
It is the policy of Trigram Education Partners schools that no qualified student with a disability will, on the basis of disability, be excluded from participation in, be denied the benefits of, or otherwise be subjected to discrimination under any academic, research, occupational training, housing, health insurance, counseling, financial aid, physical education, recreation, transportation, other extracurricular, or other postsecondary education, aid, benefits, or services. It is also our policy that Trigram Education Partners schools may not, on the basis of disability, exclude any qualified students with disabilities from any course, a course of study, or other part of its education program or activity. In addition, Trigram Education Partners schools will operate their programs and activities in the most integrated setting appropriate.
Consistent with its nondiscrimination commitment, Trigram Education Partners and its schools will provide academic/nonacademic adjustments to qualified individuals with disabilities.
Academic adjustments include making modifications to the academic requirements of its policies and practices (“academic modifications”) to ensure that the requirements of such policies and procedures do not discriminate or have the effect of discriminating against a qualified individual with a disability on the basis of such disability, unless to do so could fundamentally alter the nature of the educational program and services being offered. Academic modifications may include changes in the length of time permitted for the completion of degree requirements, substitution of specific courses required for completion of degree requirements, and adaptation of the manner in which specific courses are conducted or exams are given (see below under test conditions).
Academic requirements that the Trigram Education Partners' schools can demonstrate are essential to the instruction being pursued by such student or to any directly related licensing requirement or that are required by law or accreditation standards will not be regarded as discriminatory. Academic modifications that could fundamentally alter the nature of the educational program or services being offered include, but are not limited to, modifications that could substantially modify the content of our curriculum or essential parts of the program, lowering or substantially modifying the standards of clinical competence required by the program.
The Trigram Education Partners' commitment to make academic/nonacademic adjustments also includes a recognition that our schools may not impose upon students with disabilities other rules, such as the prohibition of tape recorders in classrooms or of dog guides in campus buildings that have the effect of limiting the participation of students with disabilities in our education programs or activities. In addition, in our course examinations or other procedures for evaluating students' academic achievement, our schools will provide such methods for evaluating the achievement of students who have a disability that impairs sensory, manual, or speaking skills as will best ensure that the results of the evaluation represents the student’s achievement in the course, rather than reflecting the student’s impaired sensory, manual, or speaking skills (except where such skills are the factors that the test purports to measure).
Further, Trigram Education Partners' commitment to make academic/nonacademic adjustments also includes taking such steps as are necessary to ensure that no student with a disability is denied the benefits of, excluded from participation in, or otherwise subjected to discrimination because of the absence of educational auxiliary aids for students with impaired sensory, manual, or speaking skills, unless such steps could fundamentally alter the nature of the educational program and services being offered.
Auxiliary aids and services may include:
- qualified interpreters, note takers, computer-aided transcription services, written materials, telephone handset amplifiers, assistive listening systems, telephones compatible with hearing aids, closed caption decoders, open and closed captioning, telecommunications devices for deaf persons
(TDD' s), videotext displays, or other effective methods of making aurally delivered materials available to students with hearing impairments;
- qualified readers, taped texts, audio recordings, Brailled materials, large print materials, or other effective methods of making visually delivered materials available to individuals with visual impairments;
- acquisition or modification of equipment or devices; and
- other similar services and actions.
Trigram Education Partners schools recognize that to be equally effective, an aid, benefit or service need not produce the identical result or level of achievement for disabled and non-disabled persons; it must afford the person to whom it is provided equal opportunity to achieve equal results, gain equal benefit, and reach the same level of achievement, in the most integrated setting appropriate to the person’s needs.
Trigram Education Partners schools will not place a surcharge on an individual to cover the costs of providing the auxiliary aid or service. Trigram Education Partners schools are not required to provide personal aids and services such as personal attendants, individually prescribed devices such as prescription eyeglasses or hearing aids, or readers for personal use or study, or other devices or services of a personal nature such as assistance in eating, toileting, and dressing.
Housing. In those circumstances under which Trigram Education Partners schools assist any agency, organization, or person in making housing available to any of its students, Trigram Education Partners schools will take such action as may be necessary to assure itself that such housing, is, as a whole, made available in a manner that does not result in discrimination on the basis of disability.
Financial assistance. In providing financial assistance to qualified individuals with disabilities, Trigram Education Partners schools may not:
- On the basis of disability, provide less assistance than is provided to nondisabled individuals, limit eligibility for assistance, or otherwise discriminate or
- Assist any entity or person that provides assistance to any of Trigram Education Partners' students in a manner that discriminates against qualified individuals with disabilities on the basis of disability.
Trigram Education Partners schools may administer or assist in the administration of scholarships, fellowships, or other forms of financial assistance established under wills, trusts, bequests, or similar legal instruments that require awards to be made on the basis of factors that discriminate or have the effect of discriminating on the basis of disability only if the overall effect of the award of scholarships, fellowships, and other forms of financial assistance is not discriminatory on the basis of disability.
Assistance in making available outside employment. When Trigram Education Partners school personnel assist any agency, organization, or person in providing employment opportunities to any of its students, such personnel will assure that such employment opportunities, as a whole, are made available in a manner that would not violate the employment provisions of the Section 504 regulation (subpart B), if they were provided by Trigram Education Partners.
When Trigram Education Partners employs any of its students, it will do so in a manner that is consistent with the employment provisions of the Section 504 regulation (subpart B).
Counseling and placement services. When Trigram Education Partners school personnel provide personal, academic, or vocational counseling, guidance, or placement services to students, such personnel must provide these services without discrimination on the basis of disability. Trigram Education Partners school personnel will ensure that qualified students with disabilities are not counseled toward more restrictive career objectives than are nondisabled students with similar interests and abilities. This requirement does not preclude Trigram Education Partners school personnel from providing factual information about licensing and certification requirements that may present obstacles to individuals with disabilities in their pursuit of particular careers.
Social organizations. Trigram Education Partners schools will assure that membership practices of social organizations (such as student government and similar organizations) which are provided significant assistance do not permit discrimination otherwise prohibited by Section 504 and its implementing regulations.
Physical education and athletics. In providing physical education courses and athletics and similar aid, benefits, or services to any of its students, Trigram Education Partners schools will not discriminate on the basis of disability. When Trigram Education Partners schools offer physical education of operates or sponsors a club or intramural athletics, it shall provide qualified individuals with disabilities an equal opportunity for participation in these activities. Trigram Education Partners schools may offer physical education and athletic activities that are separate or different only if separation or differentiation is consistent with the requirement that it operates its programs or activities in the most integrated setting appropriate and only if no qualified student with a disability is denied the opportunity to compete for teams or to participate in courses that are not separate or different.
Procedure for Requesting and Documenting the Need for Academic and Non-Academic Adjustments
An applicant or enrolled student who believes that s/he might need an academic or nonacademic adjustment should make a request to the Director of Education as far in advance as reasonably possible before the scheduled program or activity or as soon as the disability becomes known to the student. Written requests are preferred. However, if an applicant or enrolled student makes a verbal request, the request will be converted to writing on an academic/nonacademic adjustment request form by the person making the request or a Trigram Education Partners school staff member and then reviewed and signed by the person making the request.
Students and prospective students requesting an academic/nonacademic adjustment must provide documentation, upon request, to the Trigram Education Partners' school regarding the disability and limitations on participation in courses and other programs and activities. The primary purpose of the documentation is to establish that the student or prospective student has a disability and needs an academic/nonacademic adjustment, including a modification or auxiliary aid or service to have an equal opportunity to participate in the Trigram Education Partners school’s programs and activities.
- The documentation should identify how a student's or prospective student’s access or participation in the school’s programs or activities is limited as a result of his or her disability.
- Documentation submitted by a student or prospective student shall be prepared by an appropriate professional, such as a medical doctor, psychologist, audiologist, or other qualified diagnostician.
- The required documentation may include one or more of the following:
- a diagnosis of current disability,
- the date of the diagnosis,
- how the diagnosis was reached,
- the credentials of the professional,
- how the disability affects a major life activity, and
- how the disability affects the ability to participate in the Trigram Education Partners school’s program and activity for which the academic/nonacademic adjustment is requested.
- The Trigram Education Partners schools may also request documentation to determine if a device or practice used by a student or prospective student reduces or eliminates the effects of the student's impairment.
- If no academic/nonacademic adjustments have been provided in the past, the qualified professional should include a detailed explanation as to why no adjustments were provided and why they are now needed.
- The student or prospective student is responsible for providing the documentation at his or her own expense. If Trigram Education Partners challenges the documentation submitted by the student or applicant, it may require that the student or applicant participate in a second evaluation. In this case, Trigram Education Partners is responsible for paying for the evaluation.
The following guidelines are provided to assure that documentation is appropriate to verify eligibility and to support requests for academic/nonacademic adjustments, including modifications and/or auxiliary aids and services.
Note: Individualized Education Plans (IEPs) from high school are not sufficient documentation to establish eligibility for academic/nonacademic adjustments in a career education setting.
1. Any documentation to identify and substantiate the disability must be current.
- For an impairment that can change over time or that responds to medication, the documentation should be no more than four years old.
- For an impairment that does not change over time, retesting may not be necessary to evaluate the student’s disability.
2. In order to provide academic/nonacademic adjustments, the documentation should address the impact of the disability within the context of the academic, vocational, or nonacademic environment.
The assessment should include the following, to the extent that it directly relates to the individual’s impairment:
- neurological functioning,
- cognitive and emotional functioning, and/or
- physical capacity.
Evaluation of psychological/emotional functioning must be in accordance with DSM-IV-TR criteria.
3. The evaluation and interpretation of results are required.
- Based on the objective evidence of test results or clinical observations in determining limitation to learning or participation in programs or activities, specific recommendations for academic/nonacademic adjustments should be stated to the extent known and available at the time.
4. Documentation must be submitted by a qualified practitioner/diagnostician involved in the process of assessment.
- Depending on the impairment being evaluated, qualified professionals may include: trained, certified and/or licensed physicians, psychologists, learning disabilities specialists, occupational, physical, or speech-language pathologists, and other professionals.
- Diagnostic reports must include the names, titles, and professional credentials of the evaluators as well as the date(s) of testing and contact information.
5. To the extent directly related to the individual’s impairment, background information such as educational, medical and social history should be submitted.
The background information should include a description of academic/nonacademic adjustments and resources that were previously provided in another academic/nonacademic setting.
The Director of Education will promptly review the request and documentation for academic/nonacademic adjustments. If the initial documentation is incomplete or inadequate to determine the extent of the disability and need for academic/nonacademic adjustments, including modifications and auxiliary aids or services, the Director of Education may require additional documentation.
Once a prospective student or student has been deemed to be a qualified individual with a disability and the Trigram Education Partners school receives notice requesting an academic/nonacademic adjustment, the Director of Education or his or her designee will promptly meet with the prospective student or student to discuss academic/nonacademic adjustments by engaging in an interactive process concerning the student’s disability and related needs. As part of the interactive process, the Director of Education will consult with faculty and/or relevant staff. Also, as part of the interactive process, the college may request that the student provides documentation (see above).
Trigram Education Partners school staff will describe the activities students will face in individual classes that may create barriers to their full participation, as well as to assist students by discussing and identifying academic/nonacademic adjustments that might enable students to overcome those barriers. In order to ensure that the aid is effective, the interactive process continues as a collaborative effort beyond the initial stage of determining which aid is appropriate. If a student notifies a Trigram Education Partners school that the aid of service is not effective, the Trigram Education Partners school must review the concerns and respond to them in a timely and reasonable manner.
With respect to auxiliary aids and services, the Director of Education will interact with the individual in choosing the specific aid or service it provides to him/her. As explained above, the interactive process with the prospective student or student may address:
- the limitations imposed by the individual's disability; and
- the effectiveness of potential auxiliary aids or services or reasonable modifications in enabling the student to have the effective communication necessary to meet the course requirements, licensing requirements, or effectively participate in nonacademic activities.
Academic/nonacademic adjustments and auxiliary aids and services are determined by the Director of Education on an individual case-by-case basis. After interacting with the student or prospective student, the Director of Education has the discretion to choose the specific auxiliary aid or service it provides to the student or prospective student, as long as the aid or service selected is effective and could not fundamentally alter the nature of the educational program and services to be provided. Based on interaction with the applicant or student, the Director of Education will determine the type of auxiliary aids or services and the date, time, and place where such services will be provided. Trigram Education Partners, at its own expense, will secure the particular aids or services necessary to ensure effective opportunity to participate in academic and nonacademic programs and activities. Such aids will remain the property of the Trigram Education Partners.
The student is required to communicate regularly with the Director of Education, providing, whenever feasible, a three day notice of any test that requires academic adjustments through the Director of Education (e.g., untimed, distraction free environment, assistive technology devices and services).
Any grant of an academic/nonacademic adjustment will relate specifically to a particular aspect of the student’s education or access to nonacademic programs or services and will not necessarily affect other aspects of his or her education or experience at the Trigram Education Partners School. For example, the provision of additional time to a testing situation will not necessarily extend to the provision of additional time for a clinical assignment.
The Director of Education will notify the student, verbally and in writing, and in a timely manner considering the nature of the request, whether the academic/nonacademic adjustment request has been approved or denied and explain the basis for any denial. If the Director of Education denies the request for academic/nonacademic adjustments, the request will be reviewed by the Vice President of Campus Effectiveness for additional consideration before the student is notified of the denial. Academic adjustments will not be offered if, in the judgment of the Vice-President for Campus Effectiveness, the academic adjustment would fundamentally alter the nature of the educational program.
Decisions regarding fundamental alteration and essential requirements for a course will include input from a group of people who are trained, knowledgeable, and experienced in the area, through a careful, thoughtful, and rational review of the academic program and its requirements; and that the decision makers consider a series of alternatives for the essential requirements, as well as whether the essential requirement in question can be modified for a specific student with a disability.
The prior granting of academic adjustments for any other testing administration does not necessarily mean that the academic adjustment will be granted by the Trigram Education Partners school. Students should also be aware that special testing adjustments agreed upon by the Trigram Education Partners school do not guarantee that the same or similar adjustment will be provided by nationally standardized examinations.
Trigram Education Partners prohibits discrimination against any individual on the basis of disability. This policy extends to all rights, privileges, programs and activities, including admissions and recruiting, treatment of students (general), academic and nonacademic adjustments, housing, financial and employment assistance to students, and nonacademic services (physical education and athletics, counseling and placement services, and social organizations). It is also the policy of Trigram Education Partners to provide reasonable academic and non-academic adjustments to persons with disabilities unless to do so would fundamentally alter the nature of the program and services being offered.
The purpose of these procedures is to ensure that all complaints of discrimination based on disability are promptly, thoroughly and fairly investigated by Trigram Education Partners. Trigram Education Partners will conduct a fair and impartial investigation of all allegations of discrimination, with due regard for the rights of all parties. Retaliation against any individual who has filed a complaint of discrimination, or who has cooperated in the investigation of such a complaint, is unlawful and in violation of Trigram Education Partners policy.
When a student believes that he or she has been discriminated against on the basis of disability, a formal grievance may be filed with the Director of Education, who is also the Section 504 Coordinator. Written grievances are preferred. However, if an applicant or student makes an oral grievance, the grievance will be converted to writing by staff and then reviewed by the applicant and student for accuracy. The statement should be as specific as possible regarding the actions(s) or inaction(s) that precipitated the grievance: date, place, persons involved, efforts made to settle the matter informally (if applicable), and the remedy sought. A complaint must be filed within 180 days of the alleged discrimination (or longer if extenuating circumstances exist).
If a student with a grievance alleging discrimination on the basis of disability is also employed by a Premier Education Group school, and the grievance arises out of the student's employment, the grievance may be filed under the Premier Education Group school’s Complaint Procedures in Cases of Alleged Unlawful Discrimination or Harassment. If the Director of Education receives a grievance, which appears to allege discrimination on the basis of disability arising out of a student's employment, the grievance may be referred to the appropriate office to be handled under the policy applicable to employees.
Where the grievance arises out of a decision made by the Director of Education regarding a student's eligibility for academic or non-academic adjustments, the grievance will be forwarded for investigation to the Vice President of Campus Effectiveness. Grievances otherwise involving academic matters, for example, cases in which grades are disputed, will also be forwarded to the Vice President of Campus Effectiveness, who will determine which office(s) should conduct the investigation. Otherwise, the Director of Education shall investigate the matters set forth in the written grievance.
In conducting this investigation, the investigator may forward a copy of the grievance statement to the persons whose actions (or inactions) are the subject of the grievance, and may request a written response from appropriate individuals in the Institution. The investigation will include an interview for the complainant and the opportunity of the complainant to present witnesses and other evidence. The investigator may also choose to interview witnesses, to meet with concerned parties, to receive oral or written statements, and to make other appropriate inquiries. After completing the investigation, the investigator will forward a copy of a report and recommendation to the Vice President of Campus Effectiveness.
If the complaint arises out of an academic department, the report will be forwarded to the Director of Education, unless he or she is the subject of the grievance. In such cases, the report will be sent to the Vice President of Campus Effectiveness. If the complaint arises from a nonacademic program, the report will be forwarded to the administrative head of the program, unless he or she is the subject of the grievance. In such cases, the report will be forwarded to the Vice President of Campus Effectiveness.
Within thirty (30) days of the filing of the grievance, the Vice President of Campus Effectiveness, Director of Education, or administrative head will render a decision on the merits of the student's complaint. If, due to extenuating circumstances, a resolution is not possible within thirty (30) days, the Vice President of Campus Effectiveness, Director of Education, or administrative head shall inform the student of the status of the investigation.
Copies of the decision by the Vice President of Campus Effectiveness, Director of Education, or administrative head will be sent to the student, the Vice President of Campus Effectiveness (when not issued by him or her), and the Director of Education. A copy may also be sent to the department and/or the persons whose actions (or inactions) are the subject of the grievance, as appropriate.
In the event that the student is not satisfied with the resolution of the grievance, an appeal may be made. The appeal should be filed within 10 days with the Director of Education, who will direct the appeal and all appropriate records to the appropriate office of the Institution (the Chief Financial Officer) for review and disposition within thirty (30) working days of receiving notice of the result of the investigation.
Copies of the decision will be maintained in the Office of the Vice President of Campus Effectiveness and the Director of Education.
These procedures shall constitute the grievance procedure mandated by regulations implementing Section 504 of the Rehabilitation Act.
Questions about the Institution's Student Grievance Procedures in Cases of Alleged Disability Discrimination should be addressed to the Director of Education.
Exceptions to these procedures may be granted by the President, Vice President of Campus Effectiveness, or the Chief Financial Officer.
At any time, an applicant or student may file a complaint with the U.S. Department of Education, Office for Civil Rights or other appropriate state agency.
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