Disabled Students and Reasonable Adjustments Policy and Procedure

The Tavistock and Portman NHS Foundation Trust (The Trust) is committed to being inclusive and accessible to all students in all aspects of the academic and social life of the Trust. It is the Trust’s policy that all Students, will be treated fairly and equitably.

2 Purpose

This policy and procedure articulates the Trust’s Education and Training commitment for ensuring students receive a positive learning experience, and are supported to achieve their learning objectives, throughout the duration of their study with the Trust.

This policy and procedure is also intended to meet our obligations under the Equality Act 2010 and to ensure we provide a safe, effective and inclusive learning environment for all students studying at the Trust.

3 Scope

The following policy applies to all applicants and students who are applying to, or studying with, the Trust at any site of delivery, on any course leading to a recognised qualification, including Trust Certificates. Digital Academy and Short Courses (CPD) are within the scope of a separate policy.

It will be followed by all members of the Directorate of Education and Training within the Trust, at any site of delivery.

If a student or applicant chooses not to share a disability, specific learning difficulty, long-term health condition or any other physical or mental impairment, difficulty or difference, this may limit the support that could otherwise be provided.

4 Definitions

Disability: “A physical or mental impairment…that has a ‘substantial’ and ‘long-term’ negative effect on one’s ability to do normal daily activities”. (Equality Act 2010 c.15).

Fluctuating conditions: the Trust recognises that physical or mental health conditions may be fluctuating in nature. Students are urged to make us aware, should their condition and support needs change after reasonable adjustments have been agreed.

Impairment: An impairment is a condition in which a part of a person’s mind or body is not working in a standard way.

Long-term health condition: Such as heart or lung conditions, chronic pain, and other conditions.

Menopause: A change in hormone levels which leads to the ceasing of menstruation. Can cause a range of mental health and physical symptoms such as joint pain and palpitations (Menopause – NHS (www.nhs.uk))

Mental health conditions: Such as bipolar disorder, depression, and obsessive compulsive disorder.

Neurodiversity: Neurodiversity refers to differences in brain function and behaviour that affect daily mental functions, such as Autism or Attention Deficit (Hyperactivity) Disorder ADHD/ADD.

Pregnancy/Maternity: A protected characteristic under the Equality Act 2010.

Reasonable Adjustments: Adjustments to the delivery of the course which are proportionate and reasonable (e.g. do not significantly adversely affect the rest of a cohort of students).

Social model of Disability: According to Scope.org.uk, “the model says that people are disabled by barriers in society, not by their impairment or difference. Barriers can be physical, like buildings not having accessible toilets. Or they can be caused by people’s attitudes to difference, like assuming disabled people can’t do certain things”.

Specific Learning Difficulty (SpLD): Any Assessed Learning Difficulty/Difference such as Dyslexia or Dyspraxia.

The Trust: The Tavistock and Portman NHS Foundation Trust, including all national centres.

Universal Design: A concept where things (buildings, processes, systems, policies) are created with disabilities and differences in mind to avoid putting in place barriers in the first place, in relation to the social model of disability.

5 Policy Statements

This section sets out the Trust’s commitments and expectations. It comprises the following headings:

5.1 Inclusivity
5.2 Equality in Academic Practice
5.3 Digital learning Environments
5.4 Admissions
5.5 sharing of Disabilities
5.6 Confidentiality
5.7 Communication
5.8 Responsiveness to the Changing Environment
5.9 Student Responsibilities
5.10 Physical Environment
5.11 Extenuating Circumstances
5.12 Library and Learning Resources
5.13 Providing reasonable adjustments for students with disabilities, conditions, impairments, differences or difficulties

5.1 Inclusivity

The Trust embraces and encourages diversity, and we work to make our services and training as accessible and inclusive as possible. We recognise the value of lived experience and understand that people with impairments and other conditions and experiences have an important contribution to make to the mental health and wellbeing of others. Whilst the numbers of enrolled students sharing a disability is generally in line with the national average, it is widely accepted that disabled people may not have the same opportunities to progress in education and employment. (Add data re proportion of disabled clinicians in NHS and in population of therapists if that is available). In its intention to be an inclusive education provider, the Trust is committed to ensuring it is removing barriers to disabled students applying to the Trust to study and in supporting them to achieve their potential and ensure representation across health and social care professional groups and roles.

5.2 Equality in Academic Practice

Wherever possible, staff must ensure that individual students are not singled out or brought to the attention of others in meeting their needs.

Where possible, lecture notes and slides will be made available on Moodle (the virtual learning platform) in advance of the lectures. This enables students with difficulties (and all students) to follow the thread of the discourse and retain the information more effectively.

Assessment should be created with disability and difference in mind, to accommodate the various ways in which people work and learn.

5.3 Digital Learning Environment

Our digital learning platforms must be digitally accessible and work with assistive technologies such as screen readers. Videos must be accompanied by subtitles &/or a transcript. Course information and learning material shared by staff on our platforms should be available in a digitally accessible format. The Digital Education Services team will provide support for staff on how to create digitally accessible content. Disabled students and students with learning difficulties will be offered practical and confidential support, particularly for online submissions.

5.4 Admissions

Course publicity will describe the Trust’s commitment to inclusivity and accessibility of courses and training provision.

The entry requirements and admissions criteria for individual courses are reviewed to avoid unnecessary barriers to applicants and students with disabilities.

Applicants will be asked prior to interview if they need any reasonable adjustments to accommodate their needs, either at interview or during their studies.

Applicants who are invited for interview will have the optional opportunity to discuss disability during their interview.

The Trust has a duty of care to both applicants and to patients. If an applicant shares a disability, impairment, condition or difference on the application form or during interview, which would prevent them from safely working with patients (where this a requirement of the course), it will be taken into account in decisions about offering a place on the course, to protect both the patients’ and applicant’s interest. The Trust will always make reasonable adjustments to allow study wherever possible.

5.5 Sharing of Disabilities

Students have opportunities to share disabilities, conditions, differences, and difficulties at application, enrolment or at any other time for the duration of their course.

Students are encouraged to share disabilities, conditions, differences, and difficulties as soon as possible to allow for timely reasonable adjustments to be arranged. The Procedure Statements (Section 7) describes the process. Where a student chooses not to share a disability in this way may lead to delays in action by the Trust.

A student may also withdraw the information they have shared at any point, which will cease any previous arrangements that have been made to accommodate the shared disability, condition, difference or difficulty, by emailing DETDisability@tavi-port.nhs.uk. The Trust will update and delete records as appropriate.

If a student shares a disability, condition, difference or difficulty, but states that they do not want or need any reasonable adjustments, or no reasonable adjustments are judged necessary at that point in time, a formal record will be kept and the decision will be reviewed at least annually.

5.6 Confidentiality

The Trust will protect students’ rights to privacy and confidentiality. Information relating to a student’s disability, condition, impairment, difference or difficulty will be shared with staff on a need-to-know basis, and with the student’s prior consent.

Meetings with students will be conducted in private locations.

Where staff are required to make adjustments to support students, the minimum information about the disability, condition, impairment, difference or difficulty will be shared to allow this to happen.

Anonymised data about shared disabilities, conditions, impairments, differences or difficulties will be analysed and shared for quality assurance and equality, fairness and inclusion purposes.

See ‘student responsibilities’ for information regarding the recording of lectures/seminars or other teaching sessions.

5.7 Communication

All written communication with students will be primarily electronic to enable the use of assistive software.

Wherever possible, enquiries to the DETdisability@tavi-port.nhs.uk  email address will be acknowledged within 5 working days.

5.8 Responsiveness to the Changing Environment

The Trust will review this policy and procedure annually to ensure good
practice and compliance with regulatory changes.

5.9 Student Responsibilities

Students are responsible for ensuring they have informed the appropriate staff about a disability, condition, impairment, difference or difficulty, or an improvement or worsening of it by following the formal process for sharing a disability, condition, impairment, difference or difficulty (Section 7 below) where this is needed.

If a student is given permission to record lectures, or other teaching sessions as part of their agreed Statement of Reasonable Adjustments (SoRA), the recording(s) must be handled appropriately. Confidentiality of others must be maintained according to instructions given when this permission is granted, and students must abide by Trust policies on confidentiality.

5.10 Physical Environment

Buildings and facilities will be maintained and updated to ensure universal design principles wherever possible.

Reasonable adjustments will be made to buildings and facilities, where possible and according to the needs identified by disabled students.

Accessibility of new or refurbished sites of delivery will be assessed at the time of initial approval and during periodic reviews.

5.11 Extenuating Circumstances

If a student has a disability or condition which unexpectedly worsens, preventing them from submitting assignments on time or affecting the quality of their work, they may seek Extenuating Circumstances.

It will not normally be appropriate for students to claim Extenuating Circumstances for reasons relating to a disability where reasonable adjustments have already been agreed. Should a student’s condition worsen or have unexpected impact, they should approach the Student Disabilities Officer.

5.12 Library and Learning Resources

The Trust Library provides equitable access to resources and a range of services for users wherever possible. Details of library services for disabled students and students with learning difficulties are available on the Disabled Users’ page on the library website.

5.13 Providing reasonable adjustments for students with disabilities, conditions, impairments, differences or difficulties

The Trust will provide adjustments which are reasonable in terms of cost and impact on others to enable a disabled student to succeed in their course.

All students must be able to meet all published learning outcomes on their course once adjustments are in place. Discussions regarding adjustments may therefore need to include course-related activities due to take place at another location, for example infant observation, or clinical placement.

Adjustments will be made in agreement with the Trust and the student in the Statement of Reasonable Adjustments (SoRA) form. The Procedure Statements (Section 7), describes the process for agreeing the SoRA. Where applicable, and with the student’s prior consent, adjustments will be discussed and agreed with individuals outside of DET or the Trust, for example where a student is due to attend a clinical placement or other course-related activity at another organisation.

The list below gives examples of the types of adjustments which may be made. Adjustments will be agreed depending on the student’s documented needs and the nature of their course of study.

Reasonable adjustments may include (where possible), but not be limited to:

• Revising an assessment task via the University of Essex’s Special Syllabus Request process (Special syllabus requests | University of Essex.)
• Putting in place a PEEP (Personal Emergency Evacuation Plan) where this is necessary
• Library support where required (see ‘Library and Learning Resources’ above)
• Support/guidance with completing a Disabled Student Allowance (DSA) application
• Access requirements (e.g. scheduling classes on the ground floor, ensuring a student is able to attend their placement), where possible
• Providing space to store equipment such as specialist chairs or bags
• Providing a Marking cover sheet for students with a Specific Learning Difficulty (SpLD) (not published with this policy but kept securely)
• Allowing lectures or seminars to be recorded (see ‘student responsibilities’ above)
• Providing lecture notes or hand-outs prior to lectures
• Providing hand-outs electronically (or in hard copy on a coloured background where appropriate)

The Trust aims to have reasonable adjustments in place within 10 working days of the meeting with a Student Disabilities Officer (see section 7 for details of the process). Where this is not possible, the student will be kept informed of progress.

Where the Trust is unable to make the necessary adjustments to enable a student or applicant to study with the Trust, or where the student has requested specific adjustments which the Trust cannot meet, then they will be notified in writing together with the rationale for this decision. Alternative arrangements may be suggested in these circumstances.

6 Duties and responsibilities

This section describes the duties and responsibilities of staff members and
students. It comprises the following sections:

6.1 Chief Education Officer
6.2 Chief Education and Training Officer/Dean of Postgraduate Studies
6.3 Head of Academic Registry
6.4 Head of Digital Education and Library Services
6.5 Education and Training Committee
6.6 Student Disability Lead (SDL)
6.7 Student Disability Officer (SDO)
6.8 DER Equalities Leads
6.9 Course Leads 6.10 Heads of Portfolios 6.11 Student Admissions Advisors 6.12 Supervisors and Personal Tutors 6.13 Students

6.1 Chief Education Officer

Has responsibility for ensuring that Trust-wide services such as estates, IT and others have a clear directive to support students who require reasonable adjustments, and to promote the principles of Universal Design.

The CEO adopts and promotes the Disabled Student Commitment, by the Disabled Student Commission (The Disabled Student Commitment | Advance HE (advance-he.ac.uk).

6.2 Chief Education and Training Officer/Dean of Postgraduate Studies

Has overall responsibility for ensuring all staff within the Directorate of Education and Training, comply with this policy and procedure.

The CETO ensures that there is a designated member (or members) of staff to provide advice to students who share a disability, and to staff who are working with a student with disabilities.

The CETO adopts and promotes the Disabled Student Commitment, by the Disabled Student Commission (The Disabled Student Commitment | Advance HE (advance-he.ac.uk)

6.3 Head of Academic Registry

Has responsibility for ensuring academic policies and quality strategies are inclusive for all students with impairments, conditions, difficulties and differences, and promoting the principles of universal design.

6.4 Head of Digital Education and Library Services

Has responsibility for ensuring Digital Education Services and Library Services provide inclusive services and pursue the principles of Universal Design where appropriate.

6.5 Education and Training Committee

Supports the CETO and the CEO in their responsibilities to ensure compliance with this policy and promoting the principles of Universal Design and the Disabled Student Commitment.

6.6 Student Disability Lead (SDL)

Has responsibility for keeping policies, procedures, guidance and web pages relating to disabilities up to date. The SDL has responsibility for moderating the Statements of Reasonable Adjustments.

They will also be responsible for:

• Keeping up to date with policy changes within Government and the sector;
• providing training, guidance and advice to staff, promoting the principles of Universal Design and the Disabled Students Commitment;
• overseeing Student Disability Officer (SDO) activity and offering support and advice to the SDO where needed;
• liaising with other teams within the Directorate of Education and Training and the wider Trust to ensure consistency and adherence to this Policy and the Standard Operating Procedures for Disabled Students.
• consulting with, and gathering feedback from, students about their student experience relating to reasonable adjustments, disabilities, neurodiversity, and other conditions.
• reporting on students with disabilities and reasonable adjustments requirements to ensure fairness, equality and proportionality.
• overseeing the Disabled Students Support Fund

The SDL will report on compliance monitoring to the Academic Governance and Quality Assurance Committee, Education and Training Committee, and any other appropriate committee or body.

6.7 Student Disability Officer (SDO)

The Student Disability Officer (SDO):

• Coordinates the process of supporting students with reasonable adjustments, guiding and supporting these students through their studies, including those not eligible for Disabled Student Allowance (DSA) support, and provides all aspects of administration of support for disabled students, including meeting with students and/or applicants where required;
• Provides information and advice to applicants, students, staff and other stakeholders in relation to support for disabled students;
• Provides guidance and training to staff across the directorate in relation to disability support, including reasonable adjustments, and ensures guidance documents and standard operating procedures are kept up to date;
• Oversees the creation and signing off of Statements of Reasonable Adjustments (SoRAs), and monitoring the subsequent implementation of the SoRA, liaising with Course Leads and other staff as appropriate;
• Coordinates applications to the DSA. Provides support and leading on resolving enquiries relating to DSA support;
• Liaises with external agencies including assessors and funding bodies and the DSA;
• Administers the Trust’s Disabled Students Support Fund, and monitors the budget available;
• Agrees Personal Emergency Evacuation Plans (PEEPS) for students that have a physical disability and liaise with the Trust’s Health and Safety and Estates teams as appropriate;
• Works with the Academic Quality team to support Research degree students ahead of VIVA examinations with adjustments and guidance as required;
• Supports the Head of DET Operations and Student Support and Engagement Lead to deal effectively with enquiries and complaints relating to disabled students;
• Ensures student records are kept up to date on SITS in relation to Reasonable Adjustments, and reviews the disability information on SITS (the student records system), taking a leadership role in relation to reviewing system requirements and annual user acceptance testing;
• Keeps up-to-date with system and sector requirements to ensure that the system and reporting meet our obligations as a higher education provider, including attending external training and/or conferences;
• Supports events such as Open Days, welcome activities, promotion activities, induction events and programmes, and graduation;
• Supports the enhancement of the disabled student agenda;
• Records and monitors actions for the Student Disabilities, Conditions and Differences Working Group meetings.

6.8 DET Equalities Leads

Have responsibility for promoting and supporting equality, diversity and inclusion across the Directorate of Education and Training. They will contribute to the identification of staff development needs and provision of CPD as required. They will liaise with the Student Disabilities Lead and Student Disabilities Officer where appropriate. They will facilitate a Disabled Student and Trainee Group on a termly basis.

6.9 Course Leads

Course Leads are responsible for ensuring that students are treated with respect in relation to disabilities, conditions, impairments and differences; that the right to anonymity is observed (i.e. not sharing a student’s condition without their consent), and that inclusive curriculum and assessment are put in place wherever possible.

Course Leads have a responsibility for ensuring their tutors are conversant with issues relating to disability, such as inclusive curriculum, learning, and assessment policies. They also have a responsibility for liaising with the SDL/SDO where issues relating to disabilities arise and where reasonable adjustments are being considered.

Where a Course Lead has been informed of a student’s disability, they are responsible for putting in place any academic reasonable adjustments agreed on the student’s signed Statement of Reasonable Adjustments, which are pertinent to the course.

Where a SoRA allows a student to obtain recordings of lectures, seminars and other sessions, it is the Course Lead’s responsibility to ensure that recordings are made and other students are made aware of the recording, where possible without identifying the student who requires the recording.

They must refer any student who mentions a disability to this Disabled Students Policy and Procedure. This ensures that the student gets timely and appropriate support and advice. Any arrangements/ adjustments by a Course Lead must be made with reference and in the context of Procedure Statements (Section 7).

6.10 Heads of Portfolio

Have a responsibility for ensuring their Course Leads and their teaching teams, including visiting lecturers are conversant with this policy, and the Procedure Statements (Section 7).

6.11 Student Admissions Advisors

Student Admissions Advisors are responsible for arranging interviews and coordinating any reasonable adjustments that may be needed (within reason) to conduct a fair interview, liaising with the SDO where needed.

6.12 Supervisors and Personal Tutors

Supervisors and Personal Tutors are expected to provide pastoral care to students and to implement any adjustments on the request of the Course Lead.

6.13 Students

Students must abide by the ‘student responsibilities’ described in Section 5 of this document.

7 Procedures

Step 1: The student requests Reasonable Adjustments on MyTAP (student portal). You can share a disability, condition, impairment, difference or difficulty on your application form, enrolment form, or by logging into your student profile on the MyTAP student portal. If you share, you will be directed to complete the Reasonable Adjustments request on MyTAP.

Step 2: Once you have submitted your request for Reasonable Adjustments, you will be given the opportunity to meet with the Student Disability Officer. If you are unsure about the Reasonable Adjustments you need, or if you need help with completing a DSA application, requesting an assessment, or would like to discuss anything, we encourage you to meet with the SDO.

Step 3: The SDO liaises with the relevant stakeholders to get approval (or to approve themselves) the Reasonable Adjustments.

Step 4: The agreed Reasonable Adjustments will be put in place. Please note that depending on the reasonable adjustments, it may take some time to put in place (for example where equipment needs to be purchased).

8 Training Requirements

Student Disability Officer(s) and/or the Student Disability Lead and/or other relevant members of staff will attend training and/or relevant conferences to keep abreast of developments and changes in the social or regulatory climate.

Continuing Professional Development (CPD) training will be provided to academic and Directorate of Education and Training (DET) professional staff on this policy and associated Standard Operating Procedure for Disabled Students, at least once per year.

CPD will also be provided to DET staff on other relevant topics, such as marking assignments with an SPLD cover sheet.

All Trust clinical and administrative staff complete regular mandatory training on the Data Protection Act and the Freedom of Information Act and training on learning disabilities and autism.

As part of new staff induction, staff with a relevant role will be provided with training on this policy and associated Standard Operating Procedure for Disabled Students.

9 Process for monitoring compliance with this policy

Student survey feedback relating to relevant questions – the SDL will be responsible for monitoring and reporting on relevant student survey feedback.

Complaints – the SDL will be responsible for acting on any relevant student complaints relating to disabilities, which have been upheld.

Monitoring of student numbers, take-up of reasonable adjustments and other data points.

A Key Performance Indicator on the length of time taken between sharing a disability/condition/difference and having reasonable adjustments in place will be established as part of the DET dashboard.