Grievance Procedure - Section 504/ADA

Policy Name:  Grievance Procedure - Section 504/ADA

Policy Number: STU-7010

Effective: Legacy

Revised: Not applicable

Policy Statement

Grievance Procedure: Section 504/ADA

Section 504/ADA Grievance Procedures

Holy Family University prohibits discrimination on the basis of disability for faculty, staff, students, and visitors. Holy Family University has adopted an internal grievance procedure providing for prompt and equitable resolution of complaints by any member of the Holy Family University community alleging any action prohibited by Section 504 of the Rehabilitation Act of 1973 (§29 U.S.C. 794) of the U.S. Department of Education regulations implementing the Act, and the Americans with Disabilities Act, 1990 Title II & III (§42 U.S.C. 126). Section 504 and the ADA, Sections Title II & Title III prohibits discrimination on the basis of disability in any program or activity receiving Federal financial assistance. The Law and Regulations may be examined in the Office of Equity & Inclusion located in the Campus Center at the Philadelphia Main Campus.

Any participants, beneficiaries, applicants, or employees, including students, staff, faculty, and visitors who believes they have been subjected to discrimination on the basis of disability, or is unsatisfied with accommodations provided by the Office of Disability Services, may file a grievance under this procedure. It is against the law for Holy Family University to retaliate against anyone who files a grievance or cooperates in the investigation of a grievance. The Section 504/ADA Coordinator should be notified immediately if anyone associated with the grievance procedure is subjected to retaliation as a result of that person’s participation in the grievance process.

Holy Family University has both informal and formal mechanisms in place to resolve concerns about disability discrimination, denial of access to services, accommodations required by law, or an auxiliary aid they believe they should have received (“disability-related issues”), such as:

  • Disagreements regarding a requested service, accommodation, modification of a University practice or requirement, or denial of a request
  • Inaccessibility of a program or activity
  • Violation of privacy in the context of a disability


Informal Process

Holy Family University encourages anyone with concerns about a disability-related issue to first discuss the matter with Keely Milbourne, Associate Director of the Office of Disability Services, who will attempt to facilitate a resolution. Individuals are not required to pursue the informal process first and may engage the formal grievance process as their first step if preferred.

Office of Disability Services

Philadelphia Campus, Campus Center, Second Floor

Keely Milbourne, Associate Director


The Office of Disability Services will move forward in its best efforts to identify a resolution within ten working days from the date the disability-related issue is raised. The Office of Disability Services may refer the matter to the Section 504/ADA Coordinator if deemed necessary, or if formal processes are required.

Should the complaint need to be made against the Office of Disability Services itself, a formal grievance may be filed as described below.

The purpose of the informal process is to make a good faith effort to resolve the issue quickly and efficiently; however, the individual may ask to implement the formal process at any time during the informal resolution or instead of the formal resolution.


Formal Grievance

A formal grievance must be filed with the Section 504/ADA Coordinator within 21 working days of the date of the Informal decision, if applicable, or within 30 calendar days of the occurrence of the disability-related issue.

Office of Equity & Inclusion

Philadelphia Campus, Campus Center, Second Floor

April "An" Washington, MSRC, Section 504/ADA Coordinator, Director of Equity & Inclusion


The grievance must be in writing and include the following:

  • The grievant name, address, email address and phone number
  • The grievant university ID number
  • A full description of the situation
  • A description of the efforts which have been made to resolve the issue informally, if any
  • Any evidentiary items available
  • A statement of the requested remedy, e.g. requested accommodation

If the grievance involves confidential medical information, the Section 504/ADA Coordinator will maintain the confidentiality of that information and will not release that information without the individual’s permission, except as allowed by law.



The Section 504/ADA Coordinator will review the grievance for timeliness and appropriateness under this grievance procedure and notify the grievant if the grievance has been accepted.

The Section 504/ADA Coordinator may commence an investigation. Should it be necessary, the Section 504/ADA Coordinator will select a trained investigator who will promptly initiate an investigation. The investigator will be an individual who is trained on disability or civil rights issues. In undertaking the investigation, the Section 504/ADA Coordinator or investigator may interview, consult with and/or request a written response to the issues raised in the grievance from any individual the investigator believes to have relevant information, including but not limited to faculty, staff, students, and visitors to Holy Family University. All parties will have an opportunity to provide the investigator with information or evidence that the party believes is relevant to his or her grievance. All parties involved will receive a fair and equitable process and be treated with care and respect. The investigator will respect the privacy of all parties.

The University will make every effort to complete an investigation within thirty (30) calendar days of the filing of the written complaint. At the request of the grievant, the Section 504/ADA Coordinator will determine whether the formal grievance process can and should be expedited. Informal resolution upon preliminary review may be recommended and reviewed by the complainant.


Findings and Notification

Within five working days of the completion of the investigation, the investigator will make a recommendation regarding appropriate actions to be taken. The investigator will summarize the evidence that supports the recommendation, and the grievant will be advised in writing of the outcome of the investigation.



Within five (5) calendar days of receiving the determination from the Section 504/ADA

Coordinator, the grievant or the party against whom the grievance is directed, if any, may appeal the determination. To appeal, the party must file a written request for review with the Section 504/ADA Coordinator. The written request for appeal must be based on the grounds of improper procedure, or new evidence that was unavailable at the time of the investigation. The Section 504/ADA Coordinator will refer this appeal to the Dean of Students, or their designee, if the individual appealing the decision establishes standing for the appeal consideration.

The Dean of Students, or their designee, will provide the person appealing with a copy of the appeal written decision within five calendar days of the filing of the appeal. The appeal decision will be the final determination of Holy Family University.

The individual also may file a complaint with the U.S. Department of Education, Office of Civil Rights, at any time before, during or after the University’s Section 504/ADA grievance process.