No person shall be refused service in any program sponsored by the DRC, or any other DRC service, on the basis of disability, race, creed, color, sex, religion, national/ethnic origin, age, marital status, sexual orientation, veteran status, or any other class protected by law. It is the policy of the DRC, its directors, officers, employees, and agents, not to discriminate on the basis of disability, race, creed, color, sex, religion, national/ethnic origin, age, marital status, sexual orientation, veteran status, or any other class protected by law in the administration of its program, in the eligibility of program participants, in the provision of services to applicants or clients of DRC’s services, in the selection of directors, officers, or employees, or in any other respect.
DRC’S SECTION 504 COORDINATOR
To help ensure compliance with Section 504 and the Americans with Disabilities Act, DRC has developed the procedures described below, including designating a Section 504/ADA compliance coordinator to coordinate compliance efforts with these laws in regard to individuals with qualified disabilities under these laws who are seeking or receiving services from DRC and are requesting reasonable accommodations. Lynne Clay is DRC’s Section 504/ADA compliance coordinator. At any time prior to requesting a reasonable accommodation or during the process, an applicant or client may contact Ms. Clay with any questions or may make a request for the reasonable accommodation directly with her.
PROCEDURE FOR A QUALIFIED PERSON WITH A DISABILITY TO REQUEST A REASONABLE ACCOMMODATION FROM DRC
Any applicant for or client of DRC services (hereinafter for these purposes referred to as applicant/client) who believes he or she is a qualified person with a disability who needs a reasonable accommodation to effectively access or utilize DRC’s services or programs (e.g. to obtain advice, communicate with a DRC staff person, access and use DRC’s offices, participate in the attorney-client relationship), may request a reasonable accommodation from any DRC staff person. All DRC staff persons are authorized to receive the request. For example, a deaf person who may require an in-person meeting at the initial intake stage can make a request for a sign language interpreter directly to the DRC receptionist. If a client so chooses, they may make a request for a reasonable accommodation directly to the DRC’s section 504/ADA compliance coordinator.
When a request for a reasonable accommodation is made to a DRC staff person, the staff person should ascertain the qualified disability that the person is stating necessitates the reasonable accommodation, what the reasonable accommodation is, and why it is needed. The staff person shall then confer with the Section 504/ADA compliance coordinator (and in her absence , the Executive or Legal Director, or if none are available, with any available DRC attorney). If determined needed, the reasonable accommodation. shall be provided for or arranged. Generally support staff will advise the applicant/client and arrange for the accommodation, however in each case those decisions about who advises the applicant/client and arranges the accommodation shall be determined by the Section 504/ADA compliance coordinator (or the specified back-ups).
If there are questions about the right, need or the reasonableness of the accommodation or if the information that the applicant/client has provided is insufficient to make a determination, or for any other good and sufficient reason as determined by the Section 504/ADA compliance coordinator (or in his/her absence when time is of the essence, in the following order of availability the Executive Director, the Legal Director or a Senior Staff Attorney), the Section 504/ADA compliance coordinator (or specified back up) shall assume responsibility to resolve the matter by obtaining further information from the applicant/client verbally or in writing and/or by taking other necessary steps. The client may be asked to present medical documentation or authorize release of medical information to DRC as necessary to determine either the existence of a disability or the need for accommodation. The process need not be overly formal; and verbal, phone, written and/or email communications may be used in narrowing or refining issues, attempting to resolve the matter, etc. The section 504/ADA compliance coordinator shall confer with the Legal Director and the Executive Director.
When the Section 504/ADA compliance coordinator has assumed responsibility, within 10 working days of the request and receipt of appropriate documentation, the Section 504/ADA compliance coordinator shall make decision regarding the request for reasonable accommodation and send it to the client within 10 working days, with notice of the applicant’s client’s grievance rights. The aforementioned timelines may be extended by the Section 504/ADA compliance coordinator for good cause.
In each case all processes and decisions carried out pursuant to this policy shall be documented in Filemaker in activities notes and the applicant/client’s case file.
An applicant/client may grieve an adverse decision in accordance with DRC’s Client Grievance Policy and Procedures, initiating it at Step 2 in the process. The grievance policy and procedures and the grievance form may be requested from DRC or is available on DRC’s website at www.drcnh.org/help.html.
I-9.1 Procedures for Providing Notice of DRC’s Anti-discrimination Policy, ADA/504 Coordinator and Right to Request Reasonable Accommodations
To help ensure that individuals are aware of DRC’s nondiscrimination policy, DRC will provide and maintain notice of its non-discrimination policy in its reception area, on its website and its electronic newsletter within 15 days of enactment of this policy, its next annual report, next edition of its general distribution brochure, “DRC—Advocating for the Legal Rights of People with Disabilities,” and other periodic or episodic publications, disseminations, or releases the Executive Director or Legal Director determine appropriate. The notice will enable individuals to learn about (a) the existence and role of the DRC’s Section 504/ADA coordinator and (b) how qualified individuals with disabilities under Section 504/ADA may request and receive reasonable accommodations in applying for and receiving services from DRC or when seeking and maintaining employment with DRC