Support
Support and
and Inclusion
Inclusion of
of students
students with
with disabilities
disabilities at
at higher
higher
education
education institutions
institutions in
in Montenegro
Montenegro
Support and Inclusion of students with
disabilities at
Higher Education
Institutions in Montenegro
WP2
Improvement of institutional frameworks for inclusion of students with
disabilities
DEV 2.2
Defining institutional structure to support inclusion of students with
disabilities
Final Report
Prepared by
Joe Cullen (Arcola), jcullen@arcola-research.co.uk
Ramo Sendelj (UNIM), ramo.sendelj@gmail.com
Ivana Ognjanović (UNIM), ivana.ognjanovic@unimediteran.net
Enes Banda (UDG), enes.banda@udg.edu.me
Sandra Tinaj (UDG), sandra.tinaj@udg.edu.me
October 2012
This project has been funded with support from the European Commission. This publication
reflects the views only of the author, and the Commission cannot be held responsible for any use
which may be made of the information contained therein.
Tempus Project 516758-TEMPUS-1-2011-1-GR-TEMPUS-JPGR
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Scope of this Document
This document is intended to provide inputs to SINC@HE Deliverable 2.2 - Defining
institutional structure to support inclusion of students with disabilities. The main aim
of DEV 2.2 is to produce guidelines and recommendations for new institutional
structures for support of students with disabilities; roles and responsibilities for all
students and staff involved, and also the formal/legal structure on which the support
services should be established at each HEI. On their basis, the Deliverable 2.3 will
include the regulatory documents for possible and sustainable modifications of the
present and establishment of new services for students with disabilities.
In this context, this document sets out a framework for supporting this aim. Rather
than developing a single, static text that sets out what needs to be achieved and how to
achieve it, our approach to the goal of supporting the establishment of new services
for students with disabilities is based on envisaging a new university regulatory
system as a ‘process’. Moreover, this process is based on supporting progressive
‘adaptive learning’ within the HEIs in Montenegro. This approach draws on theory
and practice from organizational learning and ‘adaptive systems theory’. It aims to
support the progressive development and improvement of new services for students
with disabilities as a result of iterative development, testing and validation of these
services. Figure 1 shows this process schematically.
Strategic Framework – results
of WP1 and WP2
Iterative feedback
Figure 1: Developing support systems for students with disabilities in Montenegrin HEIs through
an adaptive systems process
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As Figure 1 shows the overall aim of the proposed approach is to generate ‘iterative
feedback loops’ within the overall Montenegrin education system and within the HEIs
in order to support ‘organisational learning’ within the Montenegrin HEIs (Argyris &
Schön, 1996). 1 Using this approach, the expectation is that a regulatory system for
support of students with disabilities will be progressively established within
Montenegrin HEIs. Furthermore, it should become progressively refined through the
aggregation of the organisational learning derived from the experiences of the HEI
stakeholders in applying its principles, methods and tools in their practice. As Figure
1 shows, four stages are envisaged in this process:
Stage 1: Based on the results of SINC@HE work packages 1 and 2, initial regulatory
framework should be developed. The framework should define methods for
integration the EU practices in order to overcome gaps in current HEIs’ systems.
Stage 2: A ‘Road Map’ document should specify tasks for the implementation of the
process. Each task represents planned changes in current HEIs’ systems and needed
services that should be implemented.
Stage 3: Operational actions implement the Road Map and ensure the realization of
defined services for support of students with disabilities.
Stage 4: Validation of the system and Road Map through monitoring
The methodology can thus be seen as an ‘action research’ and ‘action learning’
exercise that ‘endeavours to achieve an improved understanding of a practice,
improved understanding of a situation and the improvement revision of practice
through collaboration between researchers and practitioners’ (Carr and Kemmis,
1986)2 and via a cycle of empirical enquiry that is both grounded in theory and
supported by evidence (Reason and Bradbury, 2001)3. By embedding iterative
feedback loops within the process, the approach also aims to combine the formal
knowledge embedded in the conceptual framework of the regulatory system with the
‘tacit’ and experiential knowledge of the stakeholders involved. This ‘adaptive
systems’ design aims to ensure that the improvements recommended for Montenegrin
HEIs are grounded both conceptually and through experiential learning (Nonanka and
von Krogh, 2009). 4
As a starting point to develop this regulatory framework and process, this document
sets out proposals to implement it in the form of a ‘Green Paper’ and accompanying
‘Road Map’. The Green Paper covers the following elements:
Argyris, C. and Schön, D. (1996) Organizational learning II: Theory, method and practice, Reading, Mass: Addison
Wesley
2 Carr, W. and Kemmis, S. 1986, Becoming Critical. London: Falmer
3 Reason, P. and Bradbury. 2001. Introduction: Inquiry and Participation in Search of a World Worthy of Human
Aspiration. In Reason, P. and Bradbury, H. 2001. Handbook of Action Research. Sage
4 Nonaka, I; von Krogh, G (2009). "Tacit Knowledge and Knowledge Conversion: Controversy and
Advancement in Organizational Knowledge Creation Theory". Organization Science 20 (3): 635–652
1
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
The context addressed – this encompasses the ‘environment’ in which
Montenegrin HEIs operate; the main drivers that shape the need for reform in
these institutions

The target groups addressed – who should be the ‘beneficiaries’ of the new
regulatory system, and who needs to collaborate in order to implement it

Key challenges – the problems, issues and needs that the system should
address

Approaches – the broad strategies that need to be developed to promote
support for students with disabilities in Montenegrin HEIs and the underlying
principles of these strategies

Actions – practical suggestions to implement these approaches and principles,
and the expected outcomes and impacts aimed at, i.e. a ‘Road Map for
Change’
1. The Context
The context in which the reform of the regulatory environment in Montenegrin HEIs
is called for is shaped by the following key drivers:




The Bologna declaration on the European higher education area (1999) and
the Council Directive 2000/78/EC of 27 November establishing a general
framework for equal treatment in employment and occupation. In essence, the
main impact of the Bologna process should be to support increased
standardisation and benchmarking in relation to legislation, policies and
practices covering disability.
The UN convention and protocol on rights of persons with Disabilities, which
has been ratified by the Montenegrin Government, together with EU
legislation - the Disability Action Plan and the new ‘Disability Strategy’ – as
well as legislation and instruments put into place at the national level, like the
‘Strategy of integration of the persons with disabilities’ and the ‘Law of
prohibition of discrimination of the persons with disabilities’
The ‘hidden demand’ for new forms of provision to support students with
disability in Montenegrin HEI’s. At present only a very small number of
students are either registered as students with disability in Montenegrin HEIs,
or are currently receiving support. However, there is probably a much larger
number of potential students who are currently not fully provided for.
The readiness of key stakeholder groups to collaborate in the development of
new support structures and services. At present, the NGO sector is a strong
presence in the domain – but other key stakeholders – like Ministries;
University management and staff – are less active, although the research
carried out by SINC@HE does show a high level of support from these
stakeholder groups for reforms.
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2. The Target Groups
The main target groups for the proposed reforms in the HEI regulatory process
identified by the SINC@HE research are as follows:




Students currently studying at Montenegrin HEIs. As noted above, at present
this constitutes a very small number in total, but is likely to rise significantly
in the future.
Young people with disabilities who are not applying for entry to higher
education. The SINC@HE research shows that this group is currently hardly
supported at all.
Students who have completed their higher education studies and who have a
need for support like career counselling; the provision of internships and other
support aimed at supporting their transition from education to work.
Staff employed at Montenegrin HEIs. Although the SINC@HE research
identified a strong ‘will’ to collaborate in reforms, staff across the board –
including management; teaching staff; technical staff and support workers –
lack the necessary skills to provide ‘quality’ support for students with
disabilities.
In addition to these key target groups, any reform of the regulatory system will not
succeed without the active collaboration of the following key stakeholders:




The NGO sector in Montenegro – illustrated by organisations like the
Association of Youth with Disabilities of Montenegro (AYDM) and already
strongly active
The Ministries, particularly those responsible for education policy
Families of students with disabilities
Schools – in addition to HEIs, elementary and secondary schools represent
institutions responsible for youth education, and therefore, for education of
upcoming students with disabilities.
3. The Challenges
The main challenges that need to be addressed by regulatory reform are as follows:






The absence of a coherent and integrated system of financial and benefits
support for students studying at HEI’s
The lack of a progressive and holistic support system – one that bridges
‘transition stages’ between school-higher education and work
The lack of specialized administrative and academic staff trained to give
proper support to students with disabilities
The low level of technological infrastructure intended to facilitate the
inclusion of students in HEI
Poorly-developed pedagogical support for guidance and counselling
Variability in the provision of environmental support infrastructure, such as
signage, ramps and specialised accommodation facilities
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

The lack of a coherent structure to support collaborative action between
different stakeholder groups
The lack of opportunities to support greater awareness of the needs of students
with disabilities
4. Proposed Approach
To address these challenges, a new regulatory framework and process to support a
Road Map for the development of support services for students with disabilities in
Montenegrin HEIs is set out below, summarised in Figure 2.
HEI Charter
for Students
with
Disabilities
Figure 2: Schematic of regulatory system for Montenegrin HEIs
As shown in Figure 2, the central core of the proposed regulatory system is a new
‘Charter for Students with Disabilities’. This sets out the guidelines, procedures and
practices recommended for Montenegrin HEIs to adopt. It is described in more detail
below.
Six additional support elements are proposed aimed at embedding the Charter in HEI
organizational structures and practices. These are as follows:
Stakeholder Forum
Action: set up a Stakeholder Forum, which needs to be endorsed and formally adopted
at Ministerial level. The Forum should be composed of representatives of the key
stakeholder groups identified above, i.e.: students with disabilities studying at HEI’s;
representatives of the management and governance agencies of the Montenegrin
HEIs’; representatives of Ministries; representatives of key NGOs; schools
representatives; representatives of the commercial sector – particularly those who
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could play a role in supporting post-graduate labor market entry. The main tasks of the
Forum are:





to co-ordinate and oversee the Road Map for the implementation of regulatory
reforms
to oversee the monitoring and evaluation of the reforms
to specify the terms of reference for the setting up of a new Financial benefits
and Regulation Agency
to specify and oversee an awareness-raising and support programme to raise
awareness of the needs of students with disabilities
to set up a strategy for continuing collaboration with relevant agencies in the
EU and beyond who are currently working to support students with disabilities
in HEIs, including supporting exchange of good practices and peer-learning
Pre-entry awareness-raising and support
Action: working through the Stakeholder Forum to implement an awareness raising
campaign, working with schools, NGOs and family and parents groups. In particular,
the campaign should develop methodologies and tools to enable a more accurate
appraisal of the potential population of young people with disabilities who could
benefit from being supported achieve entry to HEIs.
Financial Benefits Agency
Action: to set up a new Agency, involving representatives of Ministries and
management and governance structures of HEIs. The task of this Agency is to review
the current system of financial support for students with disabilities; to identify
weaknesses and gaps in provision; to develop a strategy to address these gaps and
weaknesses; to develop an integrated and cohesive benefits and support system.
Advisory and Counseling Service
Action: Working within the Stakeholder Forum, and with the particular collaboration
of Ministries, HEI governors and managers and NGOs, to design and set up a national
Advisory and Counseling Service to support the implementation of the Charter ‘on the
ground’. The Service should develop an integrated set of services for students with
disabilities covering:
-
Advice on rights
Advice on finance and benefits
Help with accommodation
Pedagogic support, including access to assistive technologies
Pastoral support, including help for emotional and psychological issues
Post-study support (see below)
Post-study support
Action: Working in collaboration between the Stakeholder Forum and the Advisory
and Counseling Service, to design and implement a programme to support students
with disabilities on graduation. This should cover:
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


Career counseling and advice to prepare students with disabilities for the
‘world of work’
Internship programmes to enable students with disabilities to gain work
experience
Placement programmes to increase the participation of graduates with
disabilities in jobs
Monitoring and Evaluation System
Action: to design and implement an M&E system, overseen by the Stakeholder
Forum. The main objectives of this system are:
-
to map the current situation of young people with disabilities at a national
level, in order to identify future needs for support for students with disabilities
to monitor the implementation of the proposed new regulatory framework and
Charter
to continually assess progress with regard to baseline, benchmarks and
performance targets set by the framework and Charter
to carry out regular evaluation to measure the outcomes and impacts of the
framework and Charter
The next stage in the development of this Green Paper should focus on the production
of a detailed ‘Roadmap for Change’, as follows.
5. Roadmap for Change
This section more precisely defines the actions and changes needed to be implemented as
well as recommendations for regulative bodies which should be adopted and established.
The following main levels have been identified:
5.1. Charter for Students with Disabilities
States Parties, HEIs and other relevant institutions should recognize the right of
persons with disabilities to education. With a view to realizing this right without
discrimination and on the basis of equal opportunity, they should ensure an
inclusive education system at all levels and life-long learning directed to:
(a) The full development of human potential and sense of dignity and self-worth,
and the strengthening of respect for human rights, fundamental freedoms
and human diversity;
(b) The development by persons with disabilities of their personality, talents
and creativity, as well as their mental and physical abilities, to their fullest
potential;
(c) Enabling persons with disabilities to participate effectively in a free society.
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States Parties, HEIs and other relevant organizations should ensure that persons
with disabilities are able to access general tertiary education, vocational training,
adult education and lifelong learning without discrimination and on an equal basis
with others. To this end, States Parties, HEIs and other relevant organizations
should ensure that reasonable accommodation is provided to persons with
disabilities.
States Parties, HEIs and other relevant organizations should take and continue to
take all kinds of measures which have as their aim the creation of proper conditions
for full participation of persons with disabilities in all forms of academic life. In
particular, the States Parties, HEIs and other relevant parties should aim to continue
removing all architectural and constructional barriers, as well as barriers in access
to information, and will also aim to introduce such organizational measures as will
provide equal opportunities to students with disabilities and chronic illnesses, without any lowering of academic standards -.
5.2. Student Advisory Office (SAO)
To reach the highest level of providing support to students with disabilities, the Student
Advisory Office (SAO) should be established. The Office should offer its services to all
individuals with legally recognized disabilities, as well as to those who are able to
document the negative effect of health on their education. Assistance should be
offered whenever a health-related handicap is proven to influence the process of
learning.
The SAO’s work should be organized in the form of services that students may be
qualified for the assistance. The SAO’s services should be addressed to anyone whose
disability or other health-related problems make the following of a 'regular' course of
studies difficult. The difficulties in question may be connected with an inability to
participate in lectures (hearing disabilities), the availability of reading material (visual
disabilities), access to university buildings (mobility disabilities) or attendance (e.g.
due to recurring illness).
5.2.1.
SAO’s services
The aim is to develop the Office open to all students with good connections and
cooperation with all participants in Stakeholder Forum (see 6.5 below). The results of
analyzes performed in work package 1 and deliverable 2.1 of SINC@HE project give
reasonable conclusions about moving from EU practice in establishing SAO for each
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HEI to establishing of one integral SAO for students of all Montenegrin HEIs. The
responsibilities and obligations (i.e. set of services) of SAO should be:
Medical and Psychological Support Service. This service should establish cooperation with
medical institutions in order to:
- assist for required official documentation of students’ medical condition and
certificate stating the degree of disability;
- cooperate with both, student and HEI in deciding on the most effective solutions
suited to the student's needs and to the facilities the HEIs have at their
disposal;
- provide psychological support and counseling.
Transportation assistance of students with disabilities. The main objectives of the
transportation assistance could be summarized as follows:
-
-
-
Using transportation facilities to cater for the needs of students with mobility
disabilities, for those who use wheelchairs or have other difficulties with selfsufficient mobility.
Providing a help of transportation assistant for students in appropriate
situations (such as cases where lectures or classes are held in a building not
adapted to the needs of students with disabilities, or where lectures or classes
are held in several buildings, and a student with a disability cannot move
independently between those buildings)
Providing a help of a spatial orientation instructor for blind students and
students with sight impairments in order to become acquainted with the
topography of the HEI premises and with the routes between the place of
living and the HEI buildings
Accommodation in halls of residence/dormitories. The SAO should be responsible for
accommodations of students in halls of residence and rooms adapted to the needs of
students with mobility disabilities. Currently, Ministry of education and sports is
responsible for the management of accommodation in Students’ dormitories. This role
should be fully delegated to SAO with cooperation agreement with Ministry and
Government.
Rights and duties assistance. The SAO should provide full support for establishing,
gatering and negotiation of students’ rights in respect to measurements which the
SAO may decide to take in their case. To this end, the following more specific
activities should be performed:
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-
-
Legal representation of students’ rights and needs at all levels and
organizations acting on their own behalf.
Assistance to students in order to fulfill their administrative obligations,
cooperate with HEI departments in the rescheduling of classes and
examinations to suit the individual needs of students with disabilities and other
non-learning activities.
Provide full confidentiality, autonomy and privacy of students with
disabilities
Establish clear applicant procedures that include registration questionnaires,
medical documentations etc.
5.2.2.
HEIs support to SAO
In order to provide full support for students with disabilities and accept SAO as
organization with mentioned responsibilities and obligations, HEIs should consist of
several units, among them the Administration Unit, Teaching Unit and Computer
Centre for Students with Disabilities.
Administration Unit should be responsible for cooperation with SAO, giving
permanent information and implementation of recommendations provided by SAO.
To this end, the following major activities should be recognized:
-
-
-
provide administrative procedure for students with disabilities with full
assistance of SAO
cooperate with SAO in order to recognise individual circumstances and
abilities of each individual student in respect to its disability and medical
condition
make assistance to Computer Center Unit (see below) for selecting ICT
services and facilities related to needs and disability of each particular student
make assistance to Teaching Unit (see below) and Dean/Head of Departments
for adaptation of teaching materials, examination procedures and scheduling
tasks
make assistance to Dean/Head of Departments for making decisions about
increasing of allowed absences
make timetables available sufficiently in advance of the beginning of
a semester for needs of SAO’s transportation assistance
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Teaching Unit should be responsible for HIE’s teaching process and adapting teaching
materials to the needs of students. The following activities should be provided:
-
-
-
Adoption of teaching materials and examinations based on SAO’s and
Administration Unit’s suggestions with full flexibility in considering the
educational needs of students with disabilities.
Adoption of teaching process by providing appropriate educational settings
that best suits the individual’s needs of each student with disability (e.g.
special classes/units in mainstream schools, special equipment in classes, etc.)
Trainings for teaching staff for work with students with disabilities and
preparation of learning materials
Cooperation with Computer Centre (see below) in order to prepare learning
materials and make them available to date on which it is planned to use the
materials.
Computer Centre for Students with Disabilities should allow ICT support for:
- access to information and knowledge
- learning and teaching situations
- personal communication and interaction
- access to educational and administrative procedures
Furthermore, the following responsibilities should be emphasized:
- offering specialized hardware and software equipment for each kind of
disability (e.g. work-desks with personal computers, speech synthesizers,
scanning devices, specially adapted keyboards, special equipment like FM
System etc.)
- implementation, development and maintenance of learning management
system (LMS) that should provide full support to activities of Teaching Unit
- usability adoption of LMS for students with disability (according to
recommendations of SAO and Administration Unit)
- cooperation with Teaching Unit in activities about adoption of teaching
materials
- creation of digital library which should be responsible for recording teaching
materials in digital format (e.g. computer text files which can be further processed
by specialized software, etc.) and making them available on external devices (e.g.
CDs).
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5.2.3.
Financial plan
The Stakeholder Forum (see below) should make analyzes in order to make detailed
financial plan including assumptions, key financial indicators, break-even analysis,
financial details and long-term plans. During the SINC@HE project, SAO may be
located at Association of Youth with Disabilities of Montenegro (AYDM) with
provided full support from all governmental institutions and HEIs.
5.2.4.
Management system
The management system should be built up as an umbrella organisation, which shall
include representatives of students with disabilities and their families.
Administratively it should be structured under the Director for Administrative
Matters.
6.3. HEI’s law regulatives
HEIs should establish their own Charter for students with disabilities and all relevant
regulative which clearly defines principles of implementation of alternative solutions
concerning students with disabilities. To this end, the following principles are singled
out:
-
-
-
Providing teaching materials in alternative form, including:
o Administrative procedures for requesting the alternative forms of
teaching materials
o Specification of alternative forms of teaching materials (e.g. Braille
print, enlarged print, audio recordings, video recordings, computer files
etc.)
Providing alternative forms of examinations and other tests, including:
o Administrative procedures for requesting the alternative forms of
examinations and other tests
o Specification and recommendations of allowed forms depending on the
type of disability (e.g. time extensions, use of additional equipment,
changed forms of examination (written to oral or oral to written); thirdparty assistance during exams, involving for example sign language
interpreters, short-hand note-takers or reading assistants, changes of
examination venue, etc.)
o supervision of the alternative form of examination
o responsibility for the confidentiality of materials during their
conversion into alternative forms.
Providing rescheduling exam sessions including:
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o Administrative procedures for requesting the exam’s rescheduling
o Circumstances under which the rescheduling may be enabled and its
relation to deadlines for the fulfillment of course requirements and
other prerequisites
The regulative should be established by each HEI in the form which is fully
compatible with other existing acts and regulatives. It may include several steps
which may start with Rector’s recommendation principles, further acceptance by
Senate and the highest institutional bodies.
5.3.
Stakeholder Forum
Stakeholder Forum should be composed of representatives of the following key
stakeholder groups: students with disabilities studying at HEI’s; representatives of the
management and governance agencies of the Montenegrin HEIs’; representatives of
Ministries (Ministry of Education and sports, Ministry of Labour and Social Welfare,
Ministry of Health); representatives of key NGOs; schools representatives;
representatives of the commercial sector – particularly those who could play a role in
supporting post-graduate labor market entry.
The main activities of Forum should be related to both, co-ordination and overseeing
the Road Map for the implementation of regulatory reforms and later analyzes and
monitoring of the ORD’s and HEIs’ activities related to implementation, providing
and use of services for students with disabilities, such as follows:
-
Measurement of implemented and fulfilled rights and needs of students with
disabilities
Quality measurement of provided health care to students with disabilities
Degree of provided transportation assistance of students with disabilities and
Accommodation capacities in halls of residence/dormitories
Control of efficiency and effectiveness in financing schemes for SAO and
students with disabilities
Control of efficiency and effectiveness in adopted learning process, the use of
specialized equipment and implemented ICT services, quality and adequacy of
learning materials related to all kinds of disability, adequacy and adaptivity of
examinations and testing procedures
5.4. Dissemination plan
SAO should be responsible for leading of the most of activities related to promoting,
awareness raising and advising of rights and needs of students with disabilities. To
this end, SAO should make annual dissemination plan finally accepted by Stakeholder
forum, while both entities should take activities about consultation and controlling of
its realisation.
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