Section 504 Self-Evaluation and Program Access Plan

This policy establishes the organization’s process for conducting a Section 504 self-evaluation and maintaining a program access plan. The purpose is to identify policies, practices, facilities, communications, and digital content that may deny qualified individuals with disabilities meaningful access, and to document corrective actions, owners, and deadlines.

This policy is intended to support compliance with Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794) and applicable agency regulations, including 34 C.F.R. Part 104 where applicable.

This policy applies to all programs, services, activities, employment-related processes, and facilities operated by the organization that receive federal financial assistance.

It applies to all policy holders, managers, supervisors, HR personnel, compliance staff, facilities teams, IT staff, and third-party vendors acting on the organization’s behalf.

California employees: If a state or local overlay provides broader disability access rights or accommodation obligations, the broader requirement will apply to the extent permitted by law.

For purposes of this policy:

• Essential function means the fundamental duties of a job or role, not marginal tasks.
• Good-faith means a timely, sincere effort to identify barriers and implement effective access solutions.
• Documented warning means a written notice describing a compliance issue, missed deadline, or unresolved barrier.
• PIP means a performance improvement plan used when a responsible employee or team repeatedly misses remediation obligations.
• Program access plan means the written action plan used to remove, mitigate, or provide alternative access when a barrier is identified.

The organization will maintain a current, written self-evaluation and program access plan that identifies barriers to access and assigns corrective actions.

The organization will not discriminate against qualified individuals with disabilities and will provide access through one or more of the following methods, as appropriate:

1. Removal of physical, communication, policy, or digital barriers.
2. Modification of policies, practices, or procedures.
3. Provision of auxiliary aids and services.
4. Reassignment of services to an accessible location.
5. Alternative methods of participation when equivalent access can be provided.

The organization will engage in a good-faith interactive process when a barrier, request, or complaint indicates that access may be insufficient.

1) Conduct the self-evaluation

The policy holder must coordinate a periodic review of:

• Hiring, onboarding, leave, attendance, discipline, and complaint procedures
• Program eligibility criteria and participation rules
• Physical access, signage, routes, entrances, restrooms, and meeting spaces
• Digital accessibility, forms, portals, and employee communications
• Vendor-managed services that affect program access

2) Document findings

Each identified barrier must be recorded with:

• Barrier description
• Location, system, or process affected
• Impact on access
• Applicable law or standard
• Interim control, if any
• Remediation owner
• Target completion date
• Status and evidence of completion

3) Create the program access plan

The plan must prioritize barriers based on severity, frequency of use, and impact on qualified individuals with disabilities. The plan should include interim measures when immediate removal is not feasible.

4) Implement corrective actions

Owners must complete assigned actions by the target date or request a documented extension with justification, interim controls, and approval from Compliance.

5) Verify and close

Compliance or the designated accessibility lead must verify completion, retain evidence, and close the item only after the fix is validated.

6) Escalate unresolved barriers

Unresolved items beyond deadline must be escalated to leadership for a documented warning and, if necessary, a PIP for the responsible owner or department.

Policy holder: Owns the policy, approves the self-evaluation schedule, and ensures remediation resources are available.

Compliance Officer / Accessibility Coordinator: Leads the self-evaluation, maintains the program access plan, tracks deadlines, and documents closure evidence.

HR: Reviews employment-related policies and coordinates the interactive process for employee requests.

Facilities: Assesses physical barriers and coordinates building-related remediation.

IT / Digital Services: Assesses websites, applications, forms, and internal systems for accessibility issues.

Department Managers: Cooperate with audits, implement corrective actions, and report barriers promptly.

Third-party vendors: Must cooperate with accessibility reviews and remediation obligations in scope of their services.

Failure to participate in the self-evaluation, provide requested information, or complete assigned remediation actions may result in a documented warning, removal from project ownership, escalation to leadership, or a PIP.

Repeated noncompliance, refusal to implement approved corrective actions, or retaliation against a person who raises an access concern may lead to further disciplinary action, up to and including termination of employment or contract remedies.

Nothing in this policy limits rights under the NLRA, FMLA, ADA, EEOC-enforced anti-discrimination laws, or applicable whistleblower protections.

Any exception to this policy must be approved in writing by Compliance and the policy holder.

Exceptions may be granted only when:

• The requested modification would fundamentally alter the program or service;
• The change would create an undue hardship under applicable law; or
• An equivalent alternative access method is implemented.

California employees: Any state-specific requirement that provides greater access, notice, or remediation obligations will control where applicable.

This policy must be reviewed at least annually and whenever there is a material change in law, agency guidance, program structure, facilities, digital systems, or complaint trends.

The organization should retain self-evaluation records, remediation logs, approvals, and closure evidence according to its records retention schedule and any applicable federal grant or agency requirements.