Volume 83 | Issue 5
September/October 2015

Making College Unions More Inclusive: Conducting an Accessibility Review

Michael J. Kutnak

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In 2010 in the United States, 56.7 million people had some form of disability, according to the U.S. Census Bureau. That’s one out of every five individuals. In addition, Disabled World reported earlier this year that only 4% have a visible disability; the remaining 96% have an invisible disability. These individuals have guaranteed civil rights in the United States and can freely interact with all aspects of society, including higher education.

Accessibility – CCMore students each year come to college with some form of disability, and institutions must be ready to accommodate their educational needs. Since the passage of the Rehabilitation Act of 1973, the population of students with disabilities has increased more than any other student population, according to the 2000 New Directions for Student Services volume on “Serving Students with Disabilities.” The National Center for Education Statistics reported that 20.6 million students enrolled in higher education in the United States in the fall semester of 2012, and of that total, students with disabilities accounted for 11.1%, or approximately 2.3 million students. These students are legally guaranteed access to all the programs and services offered at colleges and universities. Everything from the classroom to the college union must be accessible.

Legal Requirements

Two main pieces of federal legislation affect physical and programmatic access within higher education. First, the Rehabilitation Act of 1973 applies to any higher education institution receiving federal funding. It requires institutional administrators to proactively remove barriers found on campus for individuals with disabilities. 

Second, the Americans with Disabilities Act (ADA) of 1990 and the Americans with Disabilities Act Amendments Act (ADAAA) of 2008 prohibit discrimination on the basis of disability in all matters of society, including higher education. The ADA and ADAAA are civil rights laws and guarantee access in all aspects of society. They expand and enhance the basic protections found in the Rehabilitation Act of 1973. The ADA and the ADAAA also extend the reach of the protections to include all higher education institutions, not just those receiving federal funding. 

Title I of the ADA and ADAAA prohibits discrimination in relation to employment. Title II prohibits discrimination in any services, programs, or activities provided by public entities, including colleges and universities. Title III does the same for private entities, including private colleges and universities. Both Title II and Title III of the ADA and the ADAAA include not only physical access but also service and programmatic access.

State and local laws also govern physical and programmatic access at an institution. While federal law stands as the baseline for accessibility requirements, states and localities are free to enact legislation that goes beyond the federal requirements. Each locality will differ in this matter, so it is critical that college union staff familiarize themselves with the local conditions.

Defining Physical and Programmatic Access

Physical access is a fairly straightforward concept. Under the law, individuals with a disability must be able to physically navigate the spaces, buildings, or facilities found on a college campuses. From the parking lot to the final destination, the spaces and places on campus must be accessible. 

Programmatic access pertains to the programs, goods, and services the institution provides. Individuals with a disability must be able to participate in the same activities or services and to the same level that individuals without a disability do. This includes not only educational programs but also recreational programs.

These concepts are one side of the same coin. First consider the physical access side of the coin: where a program or service takes place on campus undoubtedly influences how administrators carry it out and who has perceived and real access to it. Now consider the other side of the coin: the ways in which an administrator intends to carry out a specific program or service will influence what types of spaces and places on campus in which the activity takes place. Clearly, physical access and programmatic access are interconnected.


The Big Picture

So what does this mean for administrators of college unions specifically? Accessibility applies not only to the union’s students and guests but also to its employees. First, it is important to address a college union’s spaces and places dedicated for student and guest use. Accessible entrances and accessible pathways must connect all the areas of interest within a space. This includes the spaces in which services and programs are offered: restrooms, water fountains, among others. 

Second, the programs and services within the college union should be accessible. Students and guests must be able to interact with all programs and services provided at the union. This includes those the institution sponsors directly and those a third-party vendor provides. 

Third, employees must also have the appropriate access on the job. Because of requirements under Title I of the ADA, the physical spaces employees utilize, along with the processes and routines used within the course of normal business activities cannot be overlooked.

How can staff members make sure a college union is accessible? By conducting a systematic objectives-oriented evaluation, leaders can understand the current state of the college union in terms of accessibility and what areas need attention. Objectives-oriented evaluations focus on the extent to which some goal or objective was achieved by the object under evaluation. Administrators utilizing this approach can better formulate plans of action to address barriers to access that the evaluation uncovers.

Conducting an Access Review

Conducting a systematic evaluation of the physical and programmatic access in a college union, or any other campus facility for that matter, involves six steps: set the scope, establish evaluation objectives, identify involved stakeholders, create guiding questions, collect data, and analyze data. This method involves the use of both quantitative and qualitative data and ensures a complete review of the college union’s facilities, programs, and services for accessibility concerns.

Step 1: Set the Scope
First, the evaluation’s size and scope must be determined. The scope sets the parameters of what will and will not be included as part of the evaluation. By understanding exactly what programs and services the college union manages and where it conducts its business, those evaluating the union for accessibility concerns can set the parameters of the evaluation.

As a starting place, fully identify the footprint of the physical spaces. Include not only the spaces or buildings for which the college union has sole responsibility, but also the spaces and buildings that it may occupy or utilize jointly with another entity on campus. Include common spaces adjacent to the college union spaces. Make sure to include restrooms as part of the footprint; they are an essential function for any department’s physical presence. Consider what types of transportation the students and visitors to the college union would most likely utilize. If people drive, then where is the closest accessible parking? If people take the bus, where is the closest accessible bus station? If they use a wheelchair, what are the accessible pathways that lead to the building?

Next, identify all the programs and services in which the college union has a role. Start with each of the activities sponsored directly within and by the college union. Include any programs or services offered by another department or third party within the college union’s spaces and buildings as well. Beyond those, consider any programs or services the college union jointly sponsors as part of the union’s programmatic footprint. These might include long-term initiatives (e.g., a partnership with athletics that lasts year-round) or short-term programs (e.g., a commencement reception jointly held with the graduate school). Although these programs and services sometimes take place in other locations for which college union staff do not have direct oversight, leaders can still influence accessibility by examining the processes used to deliver the program or service. 

Step 2: Establish Evaluation Objectives
Two main objectives drive access evaluations: physical accessibility and programmatic accessibility. It is important to decide if one or both of these objectives will be included in the union’s specific evaluation effort. It is possible to address each individually, though a more comprehensive review is achieved when both objectives are evaluated. Additional objectives may also be included per the needs of the individual college union. 

If both objectives are included in the evaluation, leaders must decide which should be addressed first. While either order can be successful, it is easier to evaluate physical access first, followed by programmatic access. Once the physical accessibility of a space is determined, the evaluators can better provide solutions to any exposed programmatic access issues. For example, if a particular program can be made more accessible by moving it to a new location, the evaluators will already know of appropriate alternative spaces to accommodate the program with the least amount of modification necessary.

Step 3: Identify Involved Stakeholders
Stakeholders are the people who have a direct interest in the evaluation and those who may be affected by the evaluation results. Among them are not only the people who utilize or administer the programs, services, and spaces under evaluation, but also any people or groups that would participate in the evaluation effort itself. Stakeholders are an excellent source of information on how a program plays out in real time and what can and cannot be accomplished in a specific space.

For a college union, an accessibility review might affect students, faculty, staff, visitors, and institutional administrators. Outside vendors and service providers may be involved as well. Necessary participants for conducting the evaluation might be the union program coordinators, service managers, the institution’s assessment office, facilities staff, and other key administrators on campus. Each will be able to provide information to help guide the evaluation effort.

Accessibility – Checklist

Remember that any particular group of stakeholders represents a range of opinions, needs, and ability levels. Because of these differences, it is important to consult with a variety of individuals found within each stakeholder group. Students are a great example. A student could be an able-bodied, single parent taking two night classes while working full-time during the day, or a student could be a traditionally aged undergraduate who has a disability and is taking a full course load. One student cannot adequately represent the needs of the hundreds or thousands of students enrolled. Similarly, one individual with a disability does not and cannot represent all individuals with disabilities or even all individuals with the same disability. This is why it is imperative that evaluators get the widest array of representation possible in each of the stakeholder groups determined for the evaluation. Doing so will prove most beneficial in the next two steps of the evaluation.

Step 4: Create Guiding Questions

The guiding questions provide direction for the evaluation. The evaluators will attempt to answer these questions as they proceed. These questions are greatly influenced by the scope of the evaluation and the stakeholders. Remember that this evaluation will collect both quantitative and qualitative data. Write guiding questions in such a way as to generate both types of data.

In regard to accessibility of physical spaces, a set of guiding questions already exists. The U.S. Department of Justice issued the ADA Accessibility Guidelines (ADAAG) beginning in 1991; its most current version is 2010. The ADAAG outlines the minimum acceptable standards for complying with U.S. federal regulations. Converting the requirements found in the 2010 ADAAG into question format will result in a list of questions that generates quantitative data about specific physical access requirements. Examples of these types of questions include: “Does the building have an accessible entrance?” “How much pressure is required to open the door to the facility?” or “Does this room have the appropriate number of designated wheelchair seating spaces?” 

For this portion of the evaluation, a helpful resource is the 2011 ADA Checklist for Readily Achievable Barrier Removal, produced by the ADA National Network. This checklist simplifies the legal language found the 2010 ADAAG and provides diagrams to depict each concept. These diagrams aid observers with specific measurements and situations found in the field. The checklist divides the 2010 ADAAG into four categories. The first category addresses the pathways and entrances to buildings. The second category examines how individuals would participate in or receive services given the physical layout of a space. The third category relates to restroom access. The final category covers other general physical access issues. 

Guiding questions related to programmatic access are different, and unfortunately, there is no quick checklist, so stakeholder involvement will be important in identifying the questions. These guiding questions are more nuanced and require an understanding of circumstances surrounding the delivery or reception of a particular program or service. They are open-ended and aim to generate qualitative data about the how and why of accessibility. Questions may be directed to the users or providers of the programs and services under evaluation. Examples of these types of questions include: “What is the process for delivery of a particular program?” “What aspects of this service were difficult for you to access?” or “Were all of your accessibility needs met during the duration of this program?” 

Make sure that the guiding questions address multiple aspects of the program or service under examination. For example, if a process to request a meeting space is to fill in a form, then the required form should be accessible and available in alternative formats. If it is a physical form, then it should be located in an accessible location. If it is a digital form, then the website hosting the form must be accessible. 

Ancillary materials are another aspect to consider. For example, if the program or service contains any corresponding materials such as handouts, fliers, brochures, etc., then each of those materials must be accessible and available in alternative formats. 

Electronic presence should also be considered as part of programmatic access. Websites, emails, multimedia, and any other digital platforms must be accessible in college unions. Multimedia must be captioned. Electronic forms and reservation systems must be screen reader accessible or available in alternative formats. If the program or service has a corresponding website, that too must be accessible. Guidelines do exist for use in creating guiding questions related to websites. In 2013, the World Wide Web Consortium created the Web Content Accessibility Guidelines (WCAG) for creating accessible websites. The WCAG 2.0 is the current edition and can easily be converted into guiding questions to evaluate a program or service’s website.

Step 5: Collect Data
Data collection occurs in multiple ways in an accessibility evaluation. Divide data collection into two phases: physical access data collection and programmatic access data collection. Start with physical access. Data collection in this phase takes place primarily through observations and measurements. 

Begin by identifying the accessible parking (or bus stop students would most likely use) closest to the college union and work forward to the specific space or building. Take measurements and record observations along the way. Utilize the later parts of the checklist to determine the accessibility of specific areas. If the union occupies spaces in multiple facilities, examine each facility separately. Make sure to collect data on the restrooms as part of the effort. Refer back to the 2010 ADAAG when specific questions arise. Remember to examine not only the spaces that students use within the college union but also the spaces that employees would use. 

Next, move on to data collection related to programmatic access. In this phase, data collection happens primarily through interviews. Interview employees responsible for the delivery of each program or service, along with recipients of each program or service, to gain a variety of perspectives on accessibility issues. Staff will likely be familiar with the intended purposes of the programs and services offered within their unions and should be able to tailor guiding questions for this phase with that knowledge.

Step 6: Analyze Data

Finally, analyze the data. Begin with the data related to physical access. Analysis of this data is straightforward; spaces and places either meet or do not meet the accessibility criteria set forth in the 2010 ADAAG and other state and local laws. A chart for each facility can be created to document findings. Within the chart, include the specific access issues, locations of the issue, proposed solutions, the time table for implementing the solutions, and the anticipated cost/budget for implementation.

Next, move to the data related to programmatic access. In this phase, examine the qualitative data for patterns and themes related to accessibility concerns. Create another chart for each group of programs and services, including the same categories as found in the first set of charts. In addition, include the name of the specific program or service under examination. When access issues emerge from the interview data, document them. 

The resulting two sets of charts will give college union leaders a solid action plan for tackling each of the documented accessibility concerns. Comparing data across sets of charts provides a full picture of accessibility within the college union. This allows college union staff to efficiently address any accessibility issues uncovered in the evaluation.

Accessibility – Chart


Access to programs and services is a concern for all who work in higher education. College union administrators are no different. By proactively addressing physical and programmatic access issues, leaders can improve the experience of all students, faculty, and staff. Utilizing the objectives-oriented evaluation methodology outlined, administrators can successfully review the college union for accessibility issues and formulate comprehensive plans to remove the identified barriers, ensuring a more inclusive and accessible college union.


Accessibility – KutnakMichael J. Kutnak is Virginia Tech’s Americans with Disabilities Act specialist in the Office of Equity and Access. He also is a doctoral candidate in Virginia Tech’s higher education program. His research interests include students, faculty, and staff with disabilities and their interactions within the physical environments we create and utilize for work and learning in post-secondary education. Kutnak obtained his Master of Science degree in occupational and technical studies from Old Dominion University and a Bachelor of Arts in foreign affairs from the University of Virginia.