I. POLICY

The University of Iowa Office of Civil Rights Compliance investigates complaints of discrimination pursuant to the University's Policy on Human Rights, which provides, in part:

The University is committed to the principle of equal opportunity including access to facilities. Differences in treatment are prohibited when based on race, creed, color, religion, national origin, age, sex, pregnancy (including childbirth and related conditions), disability, genetic information, status as a U.S. veteran, service in the U.S. military, sexual orientation, gender identity, or associational preferences. This principle must be observed in the internal policies and practices of the University; specifically in the admission, housing, and education of students; in policies governing programs of extracurricular life and activities; and in the university’s treatment of applicants and its employees. Consistent with state and federal law, reasonable accommodations will be provided to persons with disabilities and to accommodate religious practices. The University shall work cooperatively with the community in furthering these principles.

II. PROCEDURES

Parties

Any university community member or third-party reporter may file a complaint of discrimination with the Office of Civil Rights Compliance against any member of the university community who is believed to have violated the policy. The university itself also may bring a complaint. Where appropriate, such complaints may be filed against units, departments, or other organizational components of the University.

Complaint options

Reporting parties may file either informal or formal complaints with the Office of Civil Rights Compliance.

Informal complaints

An informal complaint is a request that the Office of Civil Rights Compliance seek to reach an informal resolution of the reporting party’s concerns. The procedures for such complaints are designed to be very flexible so as to enable the Office to address an individual's situation in the most effective and expeditious manner possible. Resolutions of informal complaints are accomplished with the assistance of other offices or administrators on campus in the area relevant to the complaint and may include interim actions to protect the health or safety of the impacted party, reporting party, and/or potential witness(es) in an investigation.

In the case of an informal complaint, the responding party normally will not be informed of the reporting party’s action or identity without the consent of the reporting party unless circumstances require. No disciplinary action can be taken against the responding party on the basis of a complaint of which the responding party has not been informed.

Formal complaints

A formal complaint of discrimination involves an impartial investigation of the reporting party’s allegations by the Office of Civil Rights Compliance. The Office will conduct an initial assessment of the allegations as stated in the complaint to determine whether to initiate an investigation. An investigation will not be initiated if: 1) the factual allegations, if true, would not constitute a violation of the policy, 2) the allegations are clearly frivolous or not made in good faith, or 3) other good cause exists to decline to investigate. Good cause may include, but is not limited to, situations where the allegations have already been investigated in a separate internal or external complaint process. When the Office determines that an investigation will not be initiated, it will inform the reporting party of that decision.

The investigation begins when the Office provides written notice to the responding party of the filing of the complaint, the identity of the reporting party, and the general allegations of the complaint. The responding party is then interviewed regarding the specifics of the allegations and given an opportunity to respond fully to the allegations. The Office may also interview other persons believed to have factual knowledge relevant to the allegations. The purpose of the investigation is to establish whether a reasonable basis exists, based on a preponderance of the evidence, to conclude that the responding party violated the Policy on Human Rights.

The Office of Civil Rights Compliance will issue written findings outlining the basis for its conclusions. The written finding normally will be issued within sixty (60) university business days of when the complaint was filed. When it is not reasonably possible to issue the finding within that time, the Office of Civil Rights Compliance will notify the impacted party and the responding party that the finding will be delayed and indicate the reasons for the delay. This report is provided to the administrative official responsible for the area in which the responding party is involved and the chief administrative officer in the unit (i.e., the provost in a complaint filed against a faculty member; the Vice President for the unit in the case of a staff member; or the Vice President for Student Services and Dean of Students in the case of a student). Both the impacted party and the responding party also receive copies of the finding. Third-party reporting parties will be notified only that the proceedings are concluded.

If the Office of Civil Rights Compliance concludes that a complaint of discrimination is founded, the administrative official to whom the finding has been forwarded is responsible for determining whether a sanction is appropriate. Appropriate sanctions may range from verbal reprimand up to and including separation of the responding party from the University, in accordance with established University procedures.

Appeal Procedures

If the Office of Civil Rights Compliance concludes that the complaint is unfounded, the reporting party may appeal the finding on the grounds that the decision was arbitrary and capricious or that the investigating office did not follow procedures resulting in prejudice to the reporting party. Appeals must be made electronically or in writing and submitted together with all supporting documentation to the Office of Civil Rights Compliance within ten (10) university business days of the receipt of the finding. Generally, within two (2) university business days, the Office of Civil Rights Compliance will transmit the notice of appeal and the case record to the appropriate appeal officer as follows:

the Executive Vice President and Provost if the responding party is a faculty member or fellow.

the Vice President for Human Resources if the responding party is a staff member (organized or non-organized professional and scientific, organized or non-organized merit staff), graduate assistant, or post-doctoral appointee.

the Vice President for Student Life if the responding party is a student, including medical residents.

If the responding party is not a member of the university community, the Office of Civil Rights Compliance will examine the facts and circumstances of the underlying complaint and assign the appeal for response accordingly.

The appeal officer, or the appeal officer’s designee, will issue a written decision on the appeal to the reporting party and the Office of Civil Rights Compliance within twenty (20) university business days of the receipt of the appeal. All deadlines contained herein may be modified where the complexity of the case or the severity of the allegations warrant variation from the normal appeal process timelines.

In cases where the appeal is denied, such action constitutes final university action on the matter, subject to appeal to the Board of Regents. In cases where the appeal is successful, in whole or in part, the appeal officer will advise the Office of Civil Rights Compliance regarding appropriate measures to address the issues of concern raised in the appeal.

For complaints that conclude in a finding that there is a reasonable basis to believe that a policy violation has occurred, and sanctions have been imposed, responding parties may appeal such findings and/or sanctions through the disciplinary grievance procedures applicable to them.

Confidentiality

The Office of Civil Rights Compliance treats as confidential information received in connection with the filing, investigation, and resolution of complaints. It is anticipated and expected that the parties to a complaint will observe the same standard of strict confidentiality. This practice is in the best interests of all parties to the complaint. Failure to respect confidentiality may be regarded as retaliation.

In keeping with this practice, the Office of Civil Rights Compliance will obtain the reporting party’s written authorization to collect and discuss information relating to the complaint with other appropriate individuals, either witnesses or administrators who need to be informed of the allegations of the complaint in order to cooperate with the investigation or to implement any resolution of the complaint.

Inquiries

Office of Civil Rights Compliance will provide general information about the complaint procedures upon request. However, if an individual wishes to discuss a specific incident confidentially without filing a complaint, he or she should contact the Office of the Ombudsperson, 308 Jefferson Building, 319-335-3608.

III. COMPLAINTS WITH EXTERNAL AGENCIES

In addition to filing a complaint with the University of Iowa, individuals who believe they may have been the subject of discrimination prohibited by state and/or federal law(s) may contact one or more of the following agencies for advice, assistance, and explanation of filing deadlines.

Iowa Civil Rights Commission (ICRC)

400 E. 14th Street, Grimes Building Des Moines, Iowa 50319 Tel. (515) 281-4121, 1-800-457-4416 Fax (515) 242-5840 Website: https://icrc.iowa.gov/ (link is external)

The ICRC enforces Chapter 216 of the Code of Iowa, as amended, (The Iowa Civil Rights Act), which prohibits discrimination in employment on the basis of race, age (18 and older), creed, national origin, color, gender identity, sex, sexual orientation, pregnancy, disability, or religion.

Equal Employment Opportunity Commission (EEOC)

500 West Madison St., Suite 2000 Chicago, IL 60662 Tel. 1-800-669-4000 or 312-869-8001 (TDD)

The EEOC enforces Title VII of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, color, religion, sex (including pregnancy), genetics, national origin, or retaliation; the Age Discrimination in Employment Act (ADEA), which protects persons aged 40 or older; and disability, under the Americans with Disabilities Act (ADA).

Programs or Activities Receiving Federal Financial Assistance:

Title VI

Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in any program or activity receiving federal financial assistance.

Title IX

Title IX of the Education Amendments Act of 1972 prohibits discrimination based on sex in education programs or activities which receive Federal financial assistance. Title IX states that:

No person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits or, or be subjected to discrimination under any program or activity receiving Federal financial assistance.

Section 503 and 504 of the Rehabilitation Act

Sections 503 and 504 of the Rehabilitation Act of 1973 prohibit discrimination on the basis of disability in employment and education and require affirmative action in employment for persons with disabilities.

If you believe you have been discriminated against in a program of any institution which receives Federal assistance, you may contact the Federal agency providing such assistance.

Federal Contracts or Subcontracts

Applicants to and employees of organizations with a federal government contract or subcontract are protected under Federal law from discrimination on the following bases.

Race, Color, Religion, Sex, National Origin

Executive Order 11246, as amended, prohibits job discrimination on the basis of race, color, religion, sex, or national origin, and requires affirmative action to ensure equality of opportunity in all aspects of employment.

Individuals with Disabilities

Section 503 of the Rehabilitation Act of 1973, as amended, protects qualified individuals from discrimination on the basis of disability in hiring, promotion, discharge, pay, fringe benefits, job training, classification, referral, and other aspects of employment. Disability discrimination includes not making reasonable accommodation to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee, barring undue hardship. Section 503 also requires that Federal contractors take affirmative action to employ and advance in employment qualified individuals with disabilities at all levels of employment, including the executive level.

Disabled, Recently Separated, Other Protected, and Armed Forces Service Medal Veterans

The Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended, 38 U.S.C. 4212, prohibits job discrimination and requires affirmative action to employ and advance in employment disabled veterans, recently separated veterans (within three years of discharge or release from active duty), other protected veterans (veterans who served during a war or in a campaign or expedition for which a campaign badge has been authorized), and Armed Forces service medal veterans (veterans who, while on active duty, participated in a U.S. military operation for which an Armed Forces service medal was awarded).

Retaliation

Retaliation is prohibited against a person who files a complaint of discrimination, participates in an OFCCP proceeding, or otherwise opposes discrimination under these Federal laws.

Any person who believes a contractor has violated its nondiscrimination or affirmative action obligations under the authorities listed above may contact:

The Office of Federal Contract Compliance Programs (OFCCP) U.S. Department of Labor 200 Constitution Avenue, N.W. Washington, D.C. 20210 Tel. 1-800-397-6251 (toll-free) or (202) 693-1337 (TTY) The OFCCP may also be contacted by e-mail at OFCCP-Public@dol.gov (link sends e-mail), or by calling an OFCCP regional or district office, listed in most telephone directories under U.S. Government, Department of Labor.

Violations of these university policies are investigated by the Office of Civil Rights Compliance. Copies of these policies including complaint procedures are available upon request from: Office of Civil Rights Compliance 202 Jessup Hall Iowa City, Iowa 52242-1316

(319) 335-0705 E-mail: daod-ocrc@uiowa.edu  (link sends e-mail)

The Department of Justice released new regulations for Title II of the Americans with Disabilities Act (ADA) on April 24, 2024. These rules mandate that all web content, mobile apps, and electronic documents from the University of Iowa meet Web Content Accessibility Guidelines version 2.1, Level AA standards by April 24, 2026, with few exceptions.

Affected areas include academic and administrative technologies, course materials, departmental websites, mobile applications, social media platforms, third-party content, and other technologies involved in university programs and services.

The Office of Civil Rights Compliance is spearheading efforts on campus. Achieving compliance will necessitate a collective effort across the university. The office is collaborating with partners at the university to organize efforts campus-wide and devise strategies to fulfill ADA requirements and ensure technology access for everyone in the University of Iowa community.

For more details:

• The Justice Department offers additional resources including a fact sheet outlining rule requirements.
• The official rule is available in the Federal Register.
• A YouTube video in American Sign Language explains the rule announcement.

For inquiries: Reach out via email at ocrc-disability@uiowa.edu or visit the web home of the ADA Coordinator for more information.

BACKGROUND INFORMATION:

1. University policy limits animals in university buildings. Animals are not permitted in any University building or structure, and if found are subject to impoundment. Exceptions from this general prohibition include service animals, experimental subjects, approved animals in University student housing, or certified therapy animals at UI Health Care or in other events or programs as approved by the appropriate vice president. See University of Iowa Operations Manual, V-35.5.e.
2. This Policy applies to all individuals coming onto University property including, but not limited to, students, staff, faculty, visitors, independent contractors, and volunteers. Additional or separate policies may apply to animals in campus housing and to service animals in medical facilities, including the University of Iowa Hospitals and Clinics (UIHC) and the College of Dentistry.
3. This Policy applies only to service animals as defined above.

POLICY:

1. Service Animals Permitted
   1. Service animals are generally permitted in any area open to the general public at the University of Iowa (e.g., museums, sports venues, academic buildings, hallways, bathrooms, lobbies, and cafeterias).
   2. The University may exclude the use of service animals from certain locations due to health or safety reasons or where the animal’s presence would fundamentally alter the nature of a University service, program or activity. Some examples of areas where service animals may be excluded: food preparation areas; swimming pools; animal research facilities; sterile procedural areas (e.g., operating rooms and burn units) and laboratories; and anywhere visitors are required to don personal protective equipment (PPE).
   3. If a service animal is restricted from a certain area, the individual with a disability will be offered the opportunity to participate in the service, program, or activity without the service animal.
2. Clarifying Animal Status 
   1. In determining whether an animal qualifies as a service animal, University employees cannot inquire about the nature of the individual’s disability or medical history. However, when it is not obvious or apparent what service, task, or work the service animal performs, University employees may ask only two questions:
      1. Is the animal required because of a disability?
      2. What work or task has the animal been trained to perform?
   2. The University cannot request or require:
      1. Documentation, such as proof that the service animal has been certified, trained, or licensed as a service animal;
      2. Demonstration of the work or task; or
      3. The service animal should wear a vest, ID tag, or harness.
   3. Service animals must always be leashed or contained (through voice, signals, or other effective controls) while on University property. A service animal does not need to be on a leash, harness, or tether if such restraint interferes with the work or task the service animal has been trained to perform.
   4. The University may ask if the service animal is current with the rabies vaccination required by Iowa Code § 351.33.
   5. It violates Iowa law for a person to intentionally misrepresent an animal as a service animal or a service animal-in-training (see § 216C.11).
3. Removal of Service Animals
   1. A service animal may be removed from University property if:
      1. The service animal is out of control, and the animal’s handler does not take effective action to control it (e.g., aggressive or disruptive behavior or escaping containment/oversight);
      2. The service animal attempts to enter a prohibited area (See Paragraph A.2. above);
      3. The use or presence of the service animal constitutes a fundamental alteration of the service, program or activity;
      4. The service animal poses a direct threat to the health or safety of others or
         • i. The direct threat will be assessed on a case-by-case basis—an “individualized assessment”—by factors including, but not limited to:
           • A) The nature, duration, and severity of the risk;
           • B) Reasonable judgment that relies on current medical knowledge or objective evidence;
           • C) The probability that potential injury will occur to other students, visitors, or University employees; and
           • D) Whether reasonable modifications of policies, practices, or procedures or providing auxiliary aids or services will mitigate the risk.
      5. The animal is not housebroken.
   2. A generalized fear of dogs and/or allergies are not valid reasons for removing a service animal.
   3. Where there is a legitimate reason to ask that a service animal be removed, the University will offer the individual with the disability the opportunity to participate in the service, program, or activity without the service animal.
4. Owner Responsibilities
   1. The University and University employees are not responsible for the care, training, or supervision of service animals on University property. Care of the service animal remains the obligation of the animal’s owner and/or handler. University staff will not be made available to care for the animal’s needs.
   2. The service animal’s owner or handler is required to maintain control of the service animal at all times, whether through the use of a harness, leash, or tether. If the service animal cannot wear a harness, leash, or tether because it would interfere with the specific work or task it has been trained to perform, the animal must otherwise be under the control of its handler (e.g., voice control, signals, or other effective means). Service animals must physically accompany the owner/handler at all times and cannot be left in an office, room, crate, etc., or with other persons while the owner/handler is elsewhere.
   3. The service animal’s handler will be liable for any damage or harm of any kind caused by the service animal.
   4. If the service animal vomits, urinates, or defecates on University property, it is the responsibility of the service animal’s owner and/or handler to dispose of the waste in a safe and sanitary manner and to clean the area completely.
   5. The service animal’s owner must comply with state and local licensing, registration, and vaccination requirements. 
5. Employees with Service Animals
   1. Employees are permitted to have service animals in any area open to the general public at the University (e.g., museums, sports venues, academic buildings, hallways, bathrooms, lobbies, and cafeterias) and in any area where the employee is allowed, except for the restricted areas listed above in Paragraph A.2.
   2. University employees requesting a modification or exception to this Policy in relation to their employment must contact Faculty and Staff Disability Services (FSDS) to initiate the reasonable employment accommodation process.  UIHC employees must contact UIHC Leave and Disability Administration (LDA).
6. Students with Service Animals
   1. Students are permitted to have service animals in any area open to the general public at the University (e.g., museums, sports venues, academic buildings, hallways, bathrooms, lobbies, and cafeterias) and in any area where the student is allowed, except for the restricted areas listed above in Paragraph A.2.
   2. Students requesting a modification or exception to this Policy as a reasonable accommodation must contact Student Disability Services. 
   3. Students who reside in campus housing and have a service animal should contact University Housing and Dining for additional information, as additional or separate policies may apply.  
7. Visitors
   1. Visitors who require the use of a service animal on University property are encouraged to contact the University’s ADA Coordinator with any accessibility related questions or concerns.
   2. Visitors requesting a modification or exception to this Policy as a reasonable accommodation should contact the University’s ADA Coordinator. 
8. Expectations of All Members of the University Community 
   1. All members of the University community are expected to adhere to the following expectations regarding interacting with service animals: 
      1. Service animals should be allowed to accompany their owners at all times and in all areas open to the public, except where service animals are specifically restricted or as otherwise provided in this Policy.
      2. Individuals should not touch or pet a service animal without permission from the owner.
      3. Individuals should not give treats or otherwise feed a service animal without permission from the owner.
      4. Individuals should not harass, distract, startle, or interfere with a service animal.
9. Miniature Horses 
   1. The University shall make reasonable modifications in policies, practices, or procedures to permit the use of a miniature horse by an individual with a disability if the miniature horse has been individually trained to do work or perform tasks for the benefit of the individual with a disability. Other requirements which apply to service animals shall also apply to miniature horses.
   2. In determining whether reasonable modifications in policies, practices, or procedures can be made to accommodate a miniature horse into a specific University facility, the following factors will be considered: 
      1. Whether the facility can accommodate the miniature horse’s type, size, and weight;
      2. Whether the miniature horse is under the owner’s control;
      3. Whether the miniature horse is housebroken; and
      4. Whether the miniature horse’s presence in a specific University facility will compromise legitimate safety requirements necessary for the safe operation of that facility.
      5. Students who wish to use a miniature horse shall contact Student Disability Services.  University employees who wish to use a miniature horse shall contact FSDS. UIHC employees must contact LDA. Visitors who wish to use a miniature horse shall contact that ADA Coordinator. Individuals who wish to use a miniature horse at UIHC facilities shall contact the Program of Hospital Epidemiology (PHE).
10. Policy Violations and Complaints 
    1. Any university community member who believes they have been discriminated against on the basis of their disability, or who feels that the University is out of compliance with their obligations to people with disabilities under Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act, as amended (ADA AA), is encouraged to work with the University’s ADA Coordinator to resolve their concerns informally. Formal complaints may be filed with the Office of Institutional Equity, 202 Jessup Hall.
    2. Animals that are out of control, causing a disruption, or posing a threat to the campus community should be reported to the University’s Department of Public Safety. 
    3. Concerns with animals in campus housing should be reported to University Housing and Dining.

CORRESPONDING POLICIES:

University of Iowa Operations Manual, V-35.5.e, Prohibitions in Use of Facilities

REFERENCES:

Americans with Disabilities Act of 1990, 42 U.S.C. §12101 et seq.

28 CFR §§ 35.104, 35.130, 35.136, 36.104, 36.208, 36.301, 36.302

Iowa Code § 216C Rights of Persons with Disabilities

Iowa Code § 351.33 Rabies Vaccination

Service Animals, ADA 2010 Revised Requirements, U.S. Department of Justice, Civil Rights Division, Disability Rights Section, 2011 (last updated February 24, 2020) available at  https://www.ada.gov/service_animals_2010.htm.

Frequently Asked Questions about Service Animals and the ADA, U.S. Department of Justice, Civil Rights Division, Disability Rights Section, 2015 available at https://www.ada.gov/resources/service-animals-faqs/

• Section 504 of the Rehabilitation Act of 1973(link is external)

• Americans with Disabilities Act of 1990(link is external), as Amended

• Section 503 of the Rehabilitation Act of 1973(link is external), as Amended

• Accessibility Statement

• Disability Protection Policy

• Visit Teaching Accessible Courses on accessibiliy.uiowa.edu