I. Purpose. The purpose of this Student Religious Accommodations Procedure (“Procedure”) is to implement the College’s Religious Accommodation Policy (“Policy”) for College Students.
II. Scope and Applicability
A. This Procedure applies to all Students of the College in their capacity as students.
B. Student employees seeking accommodation in the workplace must follow the Religious Accommodations for Employees Procedure.
III. Definitions
A. All capitalized terms in these Procedures have the meanings provided in the Policy.
B. All other capitalized terms in these Procedures have the following meanings:
1. Accommodation Request means a completed Religious Accommodation Request Form.
2. Appeal Committee means:
a. The Associate Vice President for Learning, or designee;
b. The Vice President, Learner Support Services, or designee, for appeals related to Co-Curricular Programs and Services, or Provost/Vice President for Learning, or designee, for appeals related to Academic Requirements; and
c. Dean of Student Development or designee.
IV. Types of Accommodations that May Be Considered
A. A Student who has a sincerely held Religious Belief that conflicts with an Activity or obtaining access to an Activity may be eligible for a Religious Accommodation, based on the circumstances.
B. Examples of Religious Accommodations that may be provided if they do not create an Undue Hardship or Fundamental Alteration include, but are not limited to, the following:
1. Excused absences from class for Religious Holidays or to participate in Religious Practices and Observances;
2. Making exceptions to dress and/or uniform standards;
3. Allowing use of College facilities for Religious Practices and Observances;
4. Providing alternative types of food to meet religious dietary requirements;
5. Making exceptions to certain rules requiring the Student to supply certain forms of identification (e.g., Social Security Numbers);
6. Permitting prayer and other forms of religious expression; and/or
7. Providing alternate course assignments, course substitutions, or course waivers.
C. If a requested Religious Accommodation would impose an Undue Hardship on the College and/or cause a Fundamental Alteration, the College will reasonably accommodate the Student’s Religious Belief to the extent that it can do so without causing an Undue Hardship to the College or Fundamental Alteration, even though such a Religious Accommodation would be partial in nature.
D. Where there is more than one reasonable Religious Accommodation that would not pose an Undue Hardship or cause a Fundamental Alteration, the College is not obligated to provide the Religious Accommodation that is preferred by the Student.
V. Accommodation Request
A. A Student who is unable to participate in an Activity because it conflicts with the Student’s sincerely held Religious Belief should submit an Accommodation Request at the beginning of a semester, and, if possible, no later than five (5) Business Days in advance of the need for a Religious Accommodation, to the following individuals:
1. CDEIO for requests related to alternate course assignments, course substitutions and waivers;
2. Faculty Member for all other Academic Requirements;
3. Authorized Employee for a Co-Curricular Program or Service.
B. The Student can submit a Religious Accommodation Request Form via email, or obtain a physical form from the Office of the Dean of Student Development and submit the Accommodation Request in person to the CDEIO, the Faculty Member or Authorized Employee.
C. If the Student does not submit the Accommodation Request by the deadline set forth above, the College’s ability to grant the Accommodation Request may be limited if the Activity has taken place prior to the College being able to process the Accommodation Request; however, to the extent that the Activity can reasonably be extended to allow the Accommodation Request to be processed, the CDEIO, Faculty Member or Authorized Employee will grant such extensions.
D. In the Accommodation Request, the Student must describe:
1. The Activity or Activities at issue;
2. The type of Activity (e.g., Academic Requirement, Co-Curricular Program, and/or Service);
3. The Student’s Religious Belief and how it conflicts with an Activity; and
4. The specific Religious Accommodation that the Student is seeking.
E. If an Accommodation Request is made to another Employee, the Employee must forward the request to the CDEIO, Faculty Member or Authorized Employee. The Faculty Member or Authorized Employee may require the Student to complete the Accommodation Request form if the information provided is not sufficient to evaluate the request.
VI. Communications regarding Accommodation Requests
A. All communications with the Student and decisions will be sent to the Student using the Student’s College-issued email address.
B. The Student is responsible for responding to communications in a timely manner, generally within two business days, and failure to do so may result in the Accommodation Request not being granted prior to the Activity.
VII. Evaluation of Accommodation Requests
A. Existence of Religious Belief that Conflicts with an Activity
1. If the Accommodation Request itself does not provide enough information to enable the CDEIO, Faculty Member or Authorized Employee to make a determination about the existence of a Religious Belief, or the CDEIO, Faculty Member or Authorized Employee has a bona fide doubt as to the religious basis for the Accommodation Request, the Faculty Member or Authorized Employee may make a limited inquiry into the facts and circumstances of the Student’s claim that the Religious Belief gives rise to the need for the requested Religious Accommodation. In making this determination, the CDEIO, Faculty Member or Authorized Employee will assume, without inquiry, the sincerity of the expressed religious belief.
2. The CDEIO, Faculty Member or Authorized Employee may consult the Office of General Counsel prior to seeking to verify the religious nature of Student’s stated beliefs.
3. If the CDEIO, Faculty Member or Authorized Employee determines that the Student does not hold a Religious Belief that conflicts with an Activity, the CDEIO, Faculty Member or Authorized Employee will send a written decision to the Student denying the Accommodation Request and providing the reason(s) for the denial in writing. They may consult with the Office of General Counsel prior to communicating the decision.
4. If the Faculty Member or Authorized Employee determines that the Student holds a Religious Belief that conflicts with an Activity that supports the Accommodation Request, the Faculty Member or Authorized Employee will determine whether the Accommodation Request can be granted in accordance with the next Section.
B. Interactive Dialogue
1. Within five (5) Business Days of receiving an Accommodation Request, the CDEIO, Faculty Member or Authorized Employee will evaluate the Accommodation Request by taking any of the following actions:
a. Requesting that the Student provide additional information about the Accommodation Request, including any possible alternative Religious Accommodations that may meet the Student’s needs;
b. Analyzing whether the Accommodation Request can be granted without creating an Undue Hardship or Fundamental Alteration; and/or
c. Requesting information from other Employee(s) who may have relevant information regarding the Accommodation Request, such as whether similar Accommodation Requests have been granted.
2. If the CDEIO, Faculty Member(s) and/or Authorized Employee(s) asserts that the Accommodation Request is not reasonable, a different Religious Accommodation would be preferable, or that granting the Accommodation Request would create an Undue Hardship or Fundamental Alteration, the CDEIO, Faculty Member or Authorized Employee may offer a different Religious Accommodation to the Student and engage in an interactive dialogue with the Student.
a. If the Student accepts the Religious Accommodation that was offered, the CDEIO, Faculty Member or Authorized Employee will send a written decision to the Student, granting the agreed-upon Religious Accommodation.
b. If the Student does not accept the Religious Accommodation that was offered by the CDEIO, Faculty Member or Authorized Employee, the Student may offer a different Religious Accommodation for the CDEIO, Faculty Member or Authorized Employee to consider and, if accepted, the CDEIO, Faculty Member or Authorized Employee will send a written decision to the Student, granting the agreed-upon Religious Accommodation.
c. If the CDEIO, Faculty Member or Authorized Employee and the Student cannot reach an agreement on a different Religious Accommodation, the Faculty Member or Authorized Employee will consider whether there is an Undue Hardship or Fundamental Alteration.
C. Determining the Existence of an Undue Hardship
1. In determining whether an Accommodation Request poses an Undue Hardship, the CDEIO, Faculty Member or Authorized Employee, in consultation with other College employees, if necessary, will consider the practical and financial impact on the overall resources of the College and the standards or structure of the Activity, including but not limited to, the following relevant factors:
a. The type of activity or service for which the Accommodation is requested;
b. The identifiable cost of the Religious Accommodation in relation to the size and operating costs of the College, which include, but are not limited to:
i. Direct monetary costs that result in substantial increased costs to the College;
ii. Impairment of the safety of the College campus, Employees, Students, and the Activity; and/or
iii. Whether the proposed Religious Accommodation conflicts with a law, regulation, policy, procedure, or practice; and/or
iv. Infringement on other Students’ rights or benefits, Employees, or the public that affect the conduct of the College’s business; and/or
v. Payment of premium wages or administrative costs that result in substantial increased costs to the College.
2. After considering this information, the CDEIO, Faculty Member or Authorized Employee will determine whether an Undue Hardship would be created by granting the Accommodation Request.
D. Determining the Existence of a Fundamental Alteration
If the CDEIO, Faculty Member or Authorized Employee believes that the Accommodation Request would cause a Fundamental Alteration, the CDEIO, Faculty Member or Authorized Employee will follow the Fundamental Alterations Review Procedure.
1. The Fundamental Alterations Review Committee will determine whether a Fundamental Alteration would be caused by the granting the Accommodation Request and provide such determination to the CDEIO, Faculty Member or Authorized Employee in accordance with the Fundamental Alterations Review Procedure.
2. The decision of the Fundamental Alterations Review Committee is binding on the CDEIO, Faculty Member or Authorized Employee and cannot be grieved or further appealed pursuant to this or any other College policy or procedure, except as provided in Section XII below.
E. Decision on Accommodation Request
1. If the CDEIO, Faculty Member or Authorized Employee determines that the Accommodation Request is reasonable and does not result in a Fundamental Alteration or Undue Hardship, the CDEIO, Faculty Member or Authorized Employee will send a written decision to the Student, granting the Religious Accommodation and stating any changed due dates, if needed.
2. If the CDEIO, Faculty Member or Authorized Employee determines that the Accommodation Request causes an Undue Hardship or the Fundamental Alteration Review Committee determines the Accommodation Request results in a Fundamental Alteration, the CDEIO, Faculty Member or Authorized Employee will determine if there is an alternative way to accommodate the Student without creating a Fundamental Alteration or Undue Hardship and if so, will offer a different Religious Accommodation and engage in an interactive dialogue with the Student.
a. If the Student accepts the Religious Accommodation that was offered, the CDEIO, Faculty Member or Authorized Employee will send a written decision to the Student, granting the agreed-upon Religious Accommodation.
b. If the Student does not accept the Religious Accommodation that was offered, the CDEIO, Faculty Member or Authorized Employee will send a written decision to the Student, denying the Accommodation Request and stating the reasons for denial.
3. Duration of the Religious Accommodation
a. If a Religious Accommodation is granted, the decision will specify a due date for the Activity or an expiration date for the Religious Accommodation, which will generally be granted for the semester in which it is requested.
b. A decision to grant a Religious Accommodation applies only to the Activity described in the Accommodation Request and does not constitute a policy or universal decision for future Accommodation Requests.
c. To the extent the Student seeks a Religious Accommodation to another Activity, the Student is required to submit another Accommodation Request and follow this Procedure.
d. To the extent that the Student seeks the same Religious Accommodation for a time period beyond the expiration date in the decision, the Student must file a request to recertify the Religious Accommodation at least two (2) weeks prior to the expiration date using the Religious Accommodation Request Form and indicating that the Religious Accommodation was previously granted.
4. The CDEIO, Faculty Member or Authorized Employee will maintain a copy of the Accommodation Request, any communications with the Student, the decision of the Fundamental Alterations Review Committee, if any, and the written decision to the Student (collectively, the “Accommodation File”), for three (3) years after the decision is issued.
VIII. Implementing the Accommodation
A. The Faculty Member or Authorized Employee is responsible for implementing any Religious Accommodations granted to the Student.
B. If the Student fails to satisfactorily complete any alternative Academic Requirement by the due date specified in the decision, the Faculty Member may respond in the same manner as the Faculty Member would as if the original Academic Requirement was not satisfactorily completed.
C. The Faculty Member, Authorized Employee, and any other Employee involved in the implementation of a Religious Accommodation must make every attempt to respect the privacy of the Student when making or implementing a Religious Accommodation (for example, it is not appropriate to announce to the class that a Student is doing a presentation or making up an exam at a later date because of their Religious Belief or for a Religious Holiday).
D. Any substitute or make-up work or class(es) that is equivalent will be intrinsically no more difficult than required in the original Activity.
IX. Monitoring and Modifying the Religious Accommodation
A. Because circumstances may change, the CDEIO, Faculty Member or Authorized Employee should check on the ongoing effectiveness of Religious Accommodations through ongoing communication with the Student, however, it is also the Student’s responsibility to communicate any concerns about the accommodation promptly to the CDEIO, Faculty Member or Authorized Employee.
B. Religious Accommodations remain in effect through the date included in the written decision, unless the Student is notified by the College of a change in writing.
C. The College has the right to modify or discontinue a previously granted Religious Accommodation if it is no longer being used for religious purposes or if the Religious Accommodation subsequently poses an Undue Hardship on the College or causes a Fundamental Alteration.
D. Before modifying or discontinuing a Religious Accommodation, the College will determine if there are alternative Religious Accommodations that would not impose an Undue Hardship on the College or Fundamental Alteration.
X. Appeals
A. A Student may appeal a decision made by the CDEIO, Faculty Member or Authorized Employee by submitting an Appeal Form in writing to the Appeal Committee no later than three (3) Business Days after the decision is sent to the Student. If the accommodation decision is based on the finding of the Fundamental Alteration Review Committee, that portion of the decision cannot be appealed, as noted in Section VII.D.2 above.
B. No individual, department, or office, including the CDEIO, Faculty Member or Authorized Employee, may appeal the granting of a Religious Accommodation to a Student.
C. The Appeal Committee will request a copy of the Accommodation File from the CDEIO, Faculty Member or Authorized Employee, review the Appeal Form and Accommodation File and decide whether to accept, reject, or modify the decision on the Accommodation Request within five (5) Business Days.
D. Appeals are limited to the following grounds:
E. The Appeal Committee will send the decision to the Student, and if a Religious Accommodation is granted or modified, will send a copy of the decision to the CDEIO, Faculty Member or Authorized Employee.
F. The decision of the Appeal Committee is final and may not be further appealed or grieved pursuant to this or any other College policy or procedure, except as provided in Section XII of this Procedure.
XI. Deadlines. Any deadlines set forth in this Procedure may be extended for good cause and with notice in writing to the Student.
XII. Complaints
A. Internal Complaint. If a Student(s) believes that they have been wrongfully denied a Religious Accommodation based on their religion, have been retaliated against for making an Accommodation Request, and/or otherwise have been subjected to religious discrimination, the Student may file a complaint with the College’s Chief Compliance and Fair Practices Officer in accordance with the College’s Equal Opportunity and Nondiscrimination Policy and Discrimination and Sexual Harassment Complaint Procedures.
B. External Complaint
1. Although Students are encouraged to attempt to resolve complaints using the College’s internal complaint procedures set forth above, Students have the right to file a complaint directly with the external agency authorized to accept such complaints or pursue other remedies available to them under state or federal law.
2. Students may file complaints of religious discrimination with the following agency:
U.S. Department of Education
Office for Civil Rights
Lyndon Baines Johnson Department of Education Building
400 Maryland Avenue, SW
Washington, DC 20202-1100
Telephone: (800) 421-3481
Facsimile: (202) 453-6012
Email: OCR@ed.gov
Procedure Title: Student Religious Accommodations Procedure
Policy Category: General
Policy Owner: President
Policy Administrator: Dean of Student Development
Contact Information: drdangerfield@warocolor.com; 410-777-2830
Approval Date: March 4, 2024
Effective Date: June 5, 2024
History: Interim Procedure approved on June 28, 2023; Updates to Interim Procedure approved on July 12, 2023
Applies to: Students of the College
Related Policies: Religious Accommodations Policy
Related Procedures:
Forms/Guidelines:
Relevant Laws: