University of Illinois Urbana-Champaign

Office of the Vice Chancellor for Diversity, Equity & Inclusion

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Reasonable Modifications Requests

A student may request a reasonable modification based on pregnancy or a related condition from the Title IX Office in one of the following ways:

The Process

Individualized Assessment to Determine Reasonable Modifications

The Title IX Office will meet with the student as part of an individualized assessment to determine what modifications are reasonable. Each reasonable modification will be based upon the student’s individualized needs and the nature of the academic program the student is participating in. The Title IX Office may consult with the student as well as relevant faculty and/or staff (this may include Deans, Department Heads, and other Unit leaders), to ensure all information is reviewed to determine reasonable modifications. The student has the discretion to accept or decline each reasonable modification offered. If a student accepts the offered reasonable modification, the university will work with the student to implement it. A document setting forth the approved modifications will be provided to the student and relevant staff or faculty, as appropriate.

Students who are pregnant or have a pregnancy-related condition are allowed to voluntarily access any available separate and comparable portion of the University’s education program or activity, provided that the separate portion is comparable to that offered to students who are not pregnant and do not have related conditions.

What is a Reasonable Modification?

Reasonable modifications are made to policies, practices, or procedures as necessary to prevent sex discrimination and ensure equal access to the university’s education program or activity. Each reasonable modification must be based on the student’s individualized needs.

Reasonable modifications may include, but are not limited to:

  • Breaks during class to express breast milk, breastfeed, or attend to health needs associated with pregnancy or related conditions, including eating, drinking, or using the restroom
  • Intermittent absences to attend medical appointments
  • Access to online or homebound education (Requests for virtual learning will be assessed on a course-by-course basis. In certain circumstances, there may be situations where certain courses are approved for virtual learning rather than all courses during a given semester.)
  • Changes in schedule or course sequence
  • Extensions of time for coursework and rescheduling of tests and examinations
  • Allowing a student to sit or stand, or carry or keep water nearby
  • Counseling
  • Changes in physical space or supplies (for example, access to a larger desk or a footrest)
  • Elevator access
  • Other changes to policies, practices, or procedures.

A modification that would fundamentally alter the nature of its education program or activity, constitute an undue burden, or conflict with any licensing or accreditation requirements is not a reasonable modification. This is reviewed on a case-by-case basis. Faculty and/or staff who receive documentation of the approved modifications and have questions or concerns about implementing approved modification should promptly contact the Title IX Office to discuss.

If the reasonableness of a modification has been requested for review, the Title IX Office may attempt to arrange for temporary modifications while the review is underway.

Informal Discussion and Request for Reconsideration of Student Modifications

Modifications deemed reasonable by the Title IX Office and thus appearing on the student’s reasonable modification letter must be implemented unless it would pose an undue hardship, fundamentally alter the course or program, or conflict with any licensing or accreditation requirements.

If Title IX Office staff, upon receiving a request for a modification, have questions or need to explore the reasonableness of the request, they may reach out to appropriate faculty and/or staff as part of the individualized assessment process. In addition, upon receiving a request for a reasonable modification, faculty and/or staff may reach out to the Title IX Office for reconsideration of the modification if they feel the modification is not reasonable.

Fundamental Alteration Analysis

The goal in a fundamental alteration analysis is to distinguish the nature of how the course has always been taught from the truly essential objectives and requirements of the course or academic program. Through this review, methods of instruction and assessment may be examined to determine how the course or program information is taught and whether there are opportunities for alternate format of materials, alternative teaching and learning methods, additional skills or strategies, etc.

If it is determined that a requested modification would result in a fundamental alteration, the University must then consider whether there are alternative modifications that could accommodate a student without fundamentally altering the course (or program).

If a faculty member or other employee is concerned that a modification fundamentally alters an essential requirement or course objective of a course or academic program, the following deliberative process will be followed:

The Title IX Office staff member identified on the letter requesting modification, or who contacted the faculty member during an individualized assessment process, will consult on the concern.

The Title IX Office staff member may involve campus partners as needed, such as the Title IX Coordinator, faculty member within academic program/course, the Chair of the academic department, and other knowledgeable and trained administrators deemed appropriate in determining the reasonableness of the request, fundamental requirements of the course or program, or the possible alternatives to assist the student.

After deliberation, the Title IX Office staff member informs the student of the final decision from the group of knowledgeable university professionals engaged in the process. If the requested modification is denied or modified, the Title IX Office staff member will provide a written explanation of the reasons why it was denied or modified.

To determine the essential requirements for a course or program, faculty and Title IX Office staff will consider the following questions:

  1. What fundamental course objective does this modification alter?
  2. What practical function does this fundamental objective serve in the academic program?
  3. Please provide documentation of the fundamental course objective (e.g. syllabus, professional association certification requirement, technical standard, etc.)
  4. How does the requested modification alter this fundamental course objective?
  5. Has this modification been approved to students without a pregnancy or related condition or for any other situation or reason in your class in the current semester or in the past? If so, why?
  6. Is there any alternate way the student could demonstrate competence without undermining the essential course objectives? For example, an alternate modification that would not alter the essential objective of the course/program.

Faculty can discuss these questions in a meeting with a Title IX Office staff member over the phone or a video call, or in-person. Faculty may also submit a Fundamental Alteration Review Form to provide the information in writing for consideration prior to the meeting.

Evaluating Undue Burden or Licensing or Accreditation Conflict

If the faculty member or other employee has information not previously considered during the interactive process that the modification for the student poses an undue hardship or conflicts with any licensing or accreditation requirements, they may submit a request for reconsideration to the Title IX Coordinator at titleixcoordinator@illinois.edu. The Title IX Coordinator will seek to resolve the issue and may gather details from each person involved in the situation, consult as needed with appropriate university employees, meet individually or as a group with those involved, and ultimately seek a resolution to the issue.

This request can be discussed with the Title IX Coordinator over the phone, a video call, or in-person.

Supporting Documentation Guidance

The University will not require supporting documentation for reasonable modifications, voluntary leaves of absence, voluntary access to any available separate and comparable portions of programs or activities, or access to lactation spaces unless the documentation is necessary and reasonable to determine the reasonable modifications to make or whether to take additional specific actions.

Necessary and reasonable documentation generally includes no more than is sufficient to confirm—in a manner that is fair to the student under the circumstances—that a student has a need related to pregnancy or related conditions that requires a reasonable modification or other specific action related to voluntary leaves of absence, voluntarily access any separate and comparable portion of the university’s education program or activity, or lactation space. 

If supporting documentation is necessary and reasonable, the student will be asked to provide documentation from their chosen health-care provider to advise the University about the student’s needs and parameters of the need related to the pregnancy or related conditions, such as the extent of the need, limitations, and expected duration.

  • Documentation must be submitted on the official letterhead of the professional describing the need that requires a reasonable modification or other specific action.
  • The documentation should be dated and signed, and include the name, title, and professional credentials of the evaluator, with information about license or certification.
  • Documentation must adequately verify the nature and extent of the need or limitation related to the pregnancy or related conditions, and it must clearly substantiate the need for the student’s specific modification request(s).

Examples of situations when requiring supporting documentation is not necessary and reasonable include, but are not limited to:

  • The information requested is only to confirm pregnancy
  • Other students are provided the change without submitting documentation
  • When the student’s need for a specific action is obvious, such as when a student who is pregnant needs a bigger uniform
  • When the student has previously provided the university with sufficient documentation
  • When the reasonable modification because of pregnancy or related conditions at issue is allowing a student to carry or keep water nearby and drink, use a bigger desk, sit or stand, or take breaks to eat, drink, or use the restroom
  • When the student has lactation needs

Certification from a Healthcare Provider

The University will not require a student who is pregnant or has related conditions to provide certification from a healthcare provider or any other person that the student is physically able to participate in the University’s class, program, or extracurricular activity unless:

  • The certified level of physical ability or health is necessary for participation in the class, program, or extracurricular activity;
  • The university requires such certification of all students participating in the class, program, or extracurricular activity; and
  • The information obtained is not used as a basis for discrimination prohibited by the Sex-Based Misconduct Policy.