Objective

To determine whether the State University of New York has adequately provided access to campuses, programs, and services to students with disabilities. The audit covered the period from July 2018 through June 2021 and our observations of accessibility through October 2022.

About the Program

The State University of New York (SUNY) is the largest comprehensive system of public education in the nation, comprising 64 institutions (14 of which are University Centers and Doctoral Degree Granting Institutions), including research universities, academic medical centers, liberal arts colleges, community colleges, colleges of technology, and an online learning network. In the fall 2021 semester, SUNY served nearly 370,000 students. During the 2020-21 academic year, 31,367 students self-reported a disability at the campuses.

Title II of the Americans with Disabilities Act of 1990 (ADA) prohibits discrimination on the basis of disability by State and local governments. Similarly, section 504 of the Rehabilitation Act of 1973 prohibits disability discrimination by recipients of federal funds. Generally, under the ADA’s implementing regulations, a public entity may not deny the benefits of its programs, activities, and services to individuals with disabilities because its facilities are inaccessible. The 2010 ADA Standards for Accessible Design (ADA Standards) set minimum scoping and technical requirements for newly designed and constructed or altered State and local government facilities, public accommodations, and commercial facilities to be readily accessible to and usable by individuals with disabilities. For any new construction or alteration that began on or after March 15, 2012, the project must comply with the ADA Standards. Although the ADA Standards apply to new construction and alteration projects that began on or after March 15, 2012, they may also be used as a guide to determine when and how to enhance accessibility within existing structures built before 2012.

SUNY’s System Administration (SUNY Administration) provides support to the Campus Coordinators of Disability Services (Coordinators) on all campuses. The Coordinators meet with students who experience disability-related barriers with regard to any aspect of college life (e.g., physical environment, housing, parking, communication, dietary needs, academic requirements). Students with disabilities meet with their Coordinator to identify needs, provide appropriate disability documentation, and arrange for reasonable accommodations. Accommodations may include but are not limited to test-taking modifications, note-taking assistance, print materials in an alternative format, auxiliary aids, assistive technologies, and auxiliary services.

Each fiscal year, SUNY Administration develops a Master Capital Plan. The objective of this plan is to protect, maintain, preserve, and modify its physical plant to comply with health and safety codes. The Master Capital Plan sets forth the projects proposed to be constructed, reconstructed, rehabilitated, or otherwise substantially altered during the succeeding 5-year period. Additionally, campuses have their own Facility Master Plan that evaluates existing space inventories, usage, and condition to accommodate need. Both the Master Capital Plan and the campuses’ Facility Master Plans incorporate projects to address accessibility.

The State Education Department’s (SED) Higher Education Data System (HEDS) collects and distributes information annually on the status of higher education in New York State. As per the HEDS Instruction Manual, campuses must report all students (undergraduate and graduate) who self-identified as a student with one or more disabilities and are enrolled in at least one credit-carrying course.

Key Findings

• For the six campuses we reviewed (Binghamton University, Maritime College, Stony Brook University, SUNY Morrisville, SUNY Cobleskill, and SUNY Oneonta), we found they provided academic accommodations to students with disabilities. Additionally, we determined the campuses provided outreach and training to students and staff about their services and received no complaints regarding discrimination based on a student’s disability. However, we found that SUNY Morrisville failed to adequately document that 13 students did not complete the disability self-reporting process. We also found inconsistencies in how and when campuses reported students with disabilities within HEDS. For example, we found five campuses reported the disability in their system once the student self-identified as having a disability, as required, whereas Binghamton University did not report the student with a disability until the accommodation plan was created.
• For the building structures we reviewed, we found the six campuses were ADA-compliant. However, we identified 170 areas where accessibility could be improved should SUNY seek to exceed the ADA’s minimum requirements. Many of the improvement areas we identified are related to the height of certain amenities or fixtures such as bathroom sinks, mirrors, paper towel and soap dispensers, and toilet seats. We used the ADA Standards to assess the accessibility of sampled buildings, transportation structures (e.g., bus station shelters), and parking lots built before 2012. Although the ADA Standards apply to new construction and alteration projects, they may also be used as a guide to identify and address potential accessibility improvement areas with existing structures.

Key Recommendations

To SUNY Administration:

• Continue to work with SED to provide training and education to campuses to accurately and consistently report data on students with disabilities.

To Campuses:

• Maintain sufficient documentation for students with disabilities who don’t follow through with the process to obtain accommodations.
• Accurately and consistently report students with disabilities in accordance with SED requirements.
• Continue to actively evaluate and improve accessibility and incorporate the potential improvement areas identified where feasible.