ADA/504 Informal Complaint and Formal Grievance Procedures

I. Introduction and Purpose

1. Pursuant to its Non-Discrimination and Anti-Harassment Policy (the “Policy”), and in accordance with Section 504 of the Rehabilitation Act of 1973, Title III of the Americans with Disabilities Act (ADA) of 1990 and the Americans with Disabilities Act Amendments Act (ADAAA) of 2008, Southern New Hampshire University (“University”) does not discriminate on the basis of disability in admission, treatment or access to its programs or activities, nor does it discriminate in its employment opportunities. The Policy further provides that the University will provide reasonable accommodations to persons with disabilities unless such accommodations would impose an undue burden or fundamental alteration to the program in question; or for employees, would unreasonably interfere with the performance of the position’s essential functions.
2. The University has adopted these ADA/504 Informal Complaint and Formal Grievance Procedures to provide prompt and equitable resolution of complaints that allege Discrimination on the basis of disability under the Policy. These procedures apply to both informal complaints and formal grievances for any form of Discrimination of the basis of disability, including the following types of concerns:
1. Failure or refusal to provide or implement approved reasonable accommodations;
2. Concerns about the adequacy or timeliness of such accommodations or related processes;
3. Complaints by a student, employee, or University community member that they have been subjected to Discrimination or Harassment on the basis of a disability; or
4. Accessibility barriers (i.e., physical or technological features or spaces within the SNHU community that are unexpectedly inaccessible to people with disabilities), where submission through the Accessibility Barrier Report Form has not resulted in a timely or effective resolution or accommodation and the barrier has led to a denial of access to a University program, activity, or service.

II. Scope

1. Any student, faculty, staff, or member of the public who believes he or she has been subject to discrimination on the basis of disability by any member of the SNHU community may file an informal complaint or formal grievance under this process.
2. Pursuant to the Policy, retaliation for filing a complaint, grievance or appeal under this process is strictly prohibited under federal law. Retaliation is further defined in the Policy.
3. The formal grievance process, as it relates to students, is outlined in detail in this document but is also available in the most recently published Student Handbook. Additionally, the University’s Consumer Information page provides information about the academic and student support services available to students with disabilities, including the formal grievance process.
4. If an employee wishes to initiate a formal grievance, including concerns about an accommodation or a decision related to an accommodation, the employee should direct such concerns to their designated Human Resources Business Partner (HRBP), who will advise the employee of the applicable grievance and appeals procedure(s). The formal grievance process for employees will differ from the steps below and is available in the most recently published Employee Handbook. Additionally, SNHU employees may learn more about the process of requesting workplace accommodations by visiting Employee ADA Accommodations.
5. Southern New Hampshire University will make appropriate arrangements to ensure that persons with disabilities are provided reasonable accommodations, if needed, to participate in the formal grievance process. To initiate coordination of such accommodation support, please contact the ADA/504 Coordinator via email at adacompliance@snhu.edu.
6. This procedure is intended to guide internal complaint, grievance and appeals resolution and does not create or confer contractual rights beyond those required by applicable law. Additionally, the timelines and remedies articulated within this procedural document in no way limit an individual’s entitlement to any external remedies.

III. Definitions

Accessibility Barrier: Physical or technological features or spaces within the University community that are unexpectedly inaccessible to people with disabilities or technologies that do not conform with the standards of SNHU’s ICT Accessibility Guidelines.

ADA/504 Coordinator: The designated University official responsible for overseeing compliance with ADA and 504 law, addressing related complaints and appeals, and ensuring reasonable accommodations are made for University programs and services.

Complainant: An individual (student, employee, or member of the public) who raises a concern or allegation under the informal complaint or formal grievance process.

Extenuating Circumstances: Unusual or unavoidable events (e.g., medical emergencies, witness unavailability, holidays) that may justify an extension of standard timeframes within the grievance process.

Formal Grievance: A written complaint alleging disability discrimination or accessibility issues, submitted for resolution under the formal grievance process.

Grievant: A complainant who files a formal written grievance alleging a violation of their rights under the ADA or Section 504, or concerning accessibility barriers.

ICT Accessibility Guidelines: Refers to the University’s standards and practices for ensuring that information and communication technologies (ICT)—such as websites, learning platforms, documents, and software—are accessible to individuals with disabilities.

Informal Complaint: A disability-related concern or barrier brought forward through an unofficial, early-stage process that seeks resolution without the submission of a formal written grievance.

Respondent: The person, office, or unit whose action or inaction is the subject of a formal grievance or appeal.

Working Days: Refers to business days when the University is officially open, excluding weekends and official University holidays.

IV. Commitment to Fair and Adaptive Processes

The informal resolution option remains available at all stages of a grievance, up to and including appeal. Additionally, these rules will be construed to protect the substantive rights of interested persons, meet the appropriate due process standards, and assure that Southern New Hampshire University complies with the ADA and Section 504 and their implementing regulations. Any of the time frames articulated as a part of this process may be extended if the University determines there are extenuating circumstances. Examples of extenuating circumstances include University holidays and the absence or illness of interested parties or personnel. Under such circumstances, the complainant/grievant/appellant or any other relevant parties will be notified in writing as to the delay and a projected date for resolution.

V. Informal Complaint Process

1. The University encourages the informal resolution of complaints and will assist any complainant with that process. Pursuant to the Policy, the University reserves the right to pursue a prompt investigation and resolution of concerns pertaining to the civil rights of individuals attending the University, employed by the University, or participating in University programs or activities, whether or not a formal grievance has been filed. Student complainants may pursue an informal resolution by reaching out to leadership from the appropriate department, as delineated below, to share their concern and discuss whether a resolution can be reached without the need for formal process.

Global Campus Students: 
Online Accessibility Center 
866.305.9430 
oac@snhu.edu

University Campus Students: 
Campus Accessibility Center 
603.644.3118 
cac@snhu.edu

Employees, including Student Workers, with a complaint related to their employment at the University may pursue an informal resolution to a disability-related complaint by contacting their designated HRBP.

2. In addition to proceeding under this process, any student, faculty, staff or member of the public is encouraged to report accessibility barriers via the SNHU Accessibility Barrier Report form. Such individuals may choose to leave their name and contact information for immediate follow-up or report accessibility barriers anonymously via the Barrier Report form. A community member who submits disability-related concerns via the Barrier Report form or any other informal process reserves the right to subsequently escalate their concerns to a formal grievance.
3. All other persons, including members of the public and those with general questions or who are seeking clarification about any aspect of the informal complaint or formal grievance process should contact the University’s ADA/504 Coordinator at adacompliance@snhu.edu.

VI. Formal Student Grievance Processes

1. An individual dissatisfied with the informal resolution attempt or wishing to forego an informal resolution may submit and pursue a formal grievance. While processes for students, employees and the general public are distinct, in general, a formal grievance should be filed as soon as possible after the incident or the close of an informal resolution attempt. Although there is no deadline for filing a formal grievance, the University’s ability to effectively address concerns may be limited due to the passage of time and based on the reduced availability or access to historical information. A formal grievance must be filed in writing and should always contain a detailed statement of facts regarding the subject concern or action.
2. Global Campus Students should file a grievance using the Student Dispute form. University Campus Students should file a grievance using the University College ADA/504 Grievance Form. Any person who encounters a barrier while completing the applicable form may contact the ADA/504 Coordinator via email at adacompliance@snhu.edu to initiate coordination of relevant accommodation support.
3. Once a formal grievance form is received, it will be reviewed and investigated by an appropriate designee. For Global Campus Students, this initial investigator will be a Dispute Resolution Analyst. For University Campus students, this initial investigator will be the Director of Dispute Resolution or a designee. For grievances that allege accessibility barriers or other denials of access based on disability, the investigator will endeavor to complete their investigation within 20 working days. All other grievances will be subject to the 60 working-day timeline set forth in the Policy. Either of these timeframes may be extended due to extenuating circumstances.
4. These rules contemplate thorough investigations and the elimination of conflicts of interest, affording all interested persons an opportunity to identify witnesses and submit evidence relevant to the grievance. In conducting this initial review, 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 within the University. The investigator may also contact or interview witnesses or concerned parties, receive oral or written statements, and make other appropriate inquiries.
5. In all cases, the appointed investigator will issue a formal written determination and/or resolution and notification of grievance determination to the student grievant’s SNHU email account in accordance with the timelines set forth above. In all cases, formal written notification will be sent to the grievant’s SNHU email account at the conclusion of the investigation. Options for appeal, including the link to the appropriate appeals form or contact, will be provided in the formal written notification. Records affiliated with the initial investigation and, if applicable, any subsequent appeal will be maintained in accordance with the University’s Record Retention Policy.

VII. Additional Parties Provided Notice of Global Campus Grievance Determinations

Upon conclusion of the initial investigation and review, the investigator will forward a copy of the report and recommendation to the Director of Dispute Resolution. If discrimination is found, the reviewer will also forward a copy of the report or applicable portions of the report and the investigator’s recommendations to the University’s Equity Officer as well as any academic or administrative officials as may be deemed appropriate, including, but not limited to, the Dean or Director of the appropriate school, program or college, unless that leader is the subject of the grievance, in which case pertinent details will be forwarded to the Vice President or Associate Vice President of Academic Programs, the Vice President or Assistant Vice President of Student Experience, or a designee.

VIII. Additional Parties Provided Notice of University Campus Grievance Determinations

Upon conclusion of the initial investigation and review, the investigator will forward a copy of the report and recommendation to the Director of Campus Accessibility Center, unless that leader is the subject of the grievance, in which case pertinent details will be forwarded to the Assistant Vice President of Accommodation Services. If discrimination is found, the reviewer will also forward a copy of the report or applicable portions of the report and the investigator’s recommendations to the University’s Equity Officer as well as any academic or administrative officials as may be deemed appropriate, including, but not limited to, the Dean or Director of the appropriate school, program or college, unless that leader is the subject of the grievance, in which case, pertinent details will be forwarded to the Executive Vice President of Campus Administration, the Vice President of Student Affairs, or a designee.

IX. Student Grievance Appeals

The grievant, or, if applicable, respondent may appeal the investigator’s initial determination to the University’s ADA/504 Coordinator within 10 working days of notice of a grievance determination. The ADA/504 Coordinator will involve additional University officials as deemed necessary. The appeal must specify the particular substantive and/or procedural basis for the appeal and must be made on grounds other than general dissatisfaction with the current resolution. In the written appeal, the appellant must explain why he or she believes the factual information considered was incomplete, the analysis of the facts was incorrect, and/or the appropriate standard or procedure was not applied, and how this should change the University’s determination of the matter.

Where an appeal involves Global Campus students, a copy of the ADA/504 Coordinator’s written decision will be sent to the Vice President of Student Experience Support Services. Where an appeal involves University Campus students, a copy of the ADA/504 Coordinator’s written decision will be sent to the Director of Campus Accessibility Center, unless that leader is the subject of the grievance, in which case pertinent details will be forwarded to the Assistant Vice President of Accommodation Services. In all cases, a copy of the decision will be sent to the appellant’s SNHU email account within 20 working days of the filing of the appeal. The decision of the ADA/504 Coordinator is final.

X. Formal Grievance and Appeals Process for Employees

Employees (including Student Workers) with disability-related concerns associated with their employment at the University may pursue a formal grievance by contacting their designated HRBP, who will advise the employee of the applicable grievance procedure. The formal grievance and appeals process for employees will differ from the steps provided above and is available in the most recently published Employee Handbook.

XI. Formal Grievance and Appeals Process for All Other Persons, Including Members of the Public

Members of the public may file a formal grievance by contacting the ADA/504 Coordinator directly, at adacompliance@snhu.edu. The formal grievance process for members of the public is analogous to the processes identified above except that the investigator designated for initial review of a grievance will be identified based upon the nature of the grievance.

The effective date of this procedure is 9/1/2025. The legacy ADA Grievance Policy has been archived.