Health Sciences : Process Document Support for students who have declared a recognised disability including Specific Learning Difficulties (SpLD). In order to aid navigation and provide clarity this document has been divided into two sections. The first of these relates to support for students with a disability in general terms. The second section focusses on Specific Learning Difficulties (SpLD) such as dyslexia and dyspraxia. These are themselves classified as a disability however the mechanisms of support are subtly different requiring additional information and a different set of flow charts. The flow charts and appendices are designed to provide specific guidance relating to different stages of the student journey. Policy status: Process Document Originated by: Michelle Cowen Date of Approval 8th December 2010 Updated 18th February 2013 Policy Effective from (date) 14th March 2013 Date for review Summer 2014 Contents: Page Section 1 : Support for students who have declared a recognised disability 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. Background Discrimination Disability and Fitness for Practice Notification of support available Disclosure Support for students who declare a disability whilst on programme Transfer of student to a different Academic Tutor Consent to share personal data Disability and Health related adjustments database Reasonable adjustments Adjustments in clinical practice 3 3 3 3 4 4 4 4 4 5 5 Section 1 Appendices 1. Flow chart: Admissions process for students who have declared a disability on their application form. 2. Flow chart: Managing disability and health related adjustments for campus based learning and practice. 3. Flow chart: Support for students who declare a disability whilst on programme. 4. Sample letters notifying practice partners of required adjustments when no risk assessment is required. 5. Sample letters notifying practice partners of required adjustments when a risk assessment is required. 6. Risk Assessments for students with a disability or health related condition. 7. Use of alternative assessment formats for students with a recognised disability 8. Types of discrimination 7 8 9 10 11 12 14 16 Section 2 : Support for students who have declared a Specific Learning Difficulty (SpLD) 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. Background Disclosure Identification of a SpLD Sharing of personal data Notification of support available Transfer of student to a different Academic Tutor Dyslexia database Reasonable adjustments Inclusive teaching practices Adjustments in clinical practice Inclusive assessments 18 18 18 18 18 19 19 19 19 19 20 Section 2 Appendices 1. Flow chart: Support for students who have declared a Specific Learning Difficulty (SpLD) prior to admission. 2. Flow chart: Support for students with a SpLD who have registered with Enabling Services 3. Flow chart: Support for students who suspect they might have a SpLD 4. Procedure for the use of a viva in addition to the written submission of an assignment for students with a recognised SpLD 5. Use of alternative assessment formats for students with a recognised SpLD 6. Standard adjustments for students with a SpLD 21 22 23 24 26 28 2 Section 1 : Support for students who have declared a recognised disability 1. Background The Faculty of Health Sciences places considerable importance on matters relating to equality and diversity and is committed to the on-going development and enhancement of a culture which promotes inclusivity and the provision of equal opportunities for all healthcare students. One group of students for whom this is particularly important are those who have a recognised disability. These conditions are covered by the Equality Act (HMSO, 2010) and as such students are entitled to reasonable adjustments to help them to overcome any difficulties caused by their condition. In order to help them to reach their potential it is imperative that their individual needs are identified in a timely manner and access to appropriate support is provided as early as possible on the programme. This document aims to clarify the processes in place for students who have declared a disability. 2. Discrimination The faculty is aware that it is unlawful to discriminate against a student with disability: In refusing to accept or omit an application for admission or enrolment In arranging the determinants of admission or enrolment without due consideration for the disabled student In the terms on which admission is offered In permanent or temporary exclusion where reasonable adjustments have not been made In the provision of student services provided by the faculty which are not accessible to the disabled student. Student services’ includes services of any description which are provided for students and include: teaching, examinations and assessments, practice experiences, learning facilities, careers advice and training, job references and study skills sessions. There are five types of unlawful disability discrimination which relate to FoHS education provision under the terms of the Equality Act of 2010. 2.1 2.2 2.3 2.4 2.5 Direct discrimination - including discrimination based on perception or association. Combined discrimination. Indirect discrimination. Discrimination arising from disability. Failure to make reasonable adjustments (for disabled people). Further details on these specific types of discrimination is contained within Appendix 8 3. Disability and Fitness for Practice Selection for admission onto a healthcare programme within the Faculty implies selection for a healthcare profession. Where candidates have a disability which may impinge on their fitness to practise in accordance with the standards and guidelines laid down by the NMC or HCPC, the FoHS has a duty to satisfy itself that, given reasonable adjustments, the candidate could practise safely as a healthcare practitioner in accordance with these professional standards. The faculty follow a transparent process when considering applications from students who have declared a disability (see appendix 1). The shortlisting and selection process is the same for all students, however all offers made are conditional on clearance by Occupational Health and the ability of the faculty and practice partners to be able to implement required adjustments. 4. Notification of support available To ensure that all students are aware of the support available, both from the central University of Southampton Student Services and within the Faculty of Health Sciences, information is provided in the student handbook and via a specific link on the Blackboard site SOHS – Pre registration healthcare 3 programmes. Contact details for the Faculty Lead for Inclusivity are provided and students are encouraged to ask for further advice and information if required. 5. Disclosure The faculty recognises that students may be reluctant to share personal sensitive information relating to a disability. It therefore strives to create a culture where students feel empowered to do so, confident in the knowledge that they will not be disadvantaged in any way. The FoHS prospectus highlights our commitment to inclusivity and encourages students to declare relevant conditions in order that support can be planned in advance to avoid unnecessary delays. This is reinforced on Open Days and Selection Days where several slides have been inserted into the presentation reassuring students that this will not affect their application but will enable us to meet their needs more effectively. Whilst it is accepted that support cannot be put in place where the faculty is not aware that a student has a disability, the legal position is that if one person in the organisation knows, the organisation is deemed to know. It is therefore essential that when a student discloses a disability to their Academic / Personal Tutor or Programme Lead that the Faculty Lead for Inclusivity is made aware. The student may not want or need any adjustments but this must be documented on the disability and health adjustments database (see section 9). 6. Support for students who declare a disability whilst on programme On occasions students may not be willing to disclose a disability prior to admission, or are diagnosed with a new condition whilst on programme. This potentially places the student at a disadvantage until their support needs are identified and put in place. Appendix 3 details the process for managing situations where the faculty becomes aware of a student with a disability after they have commenced a programme of study. Where possible the student will be maintained on programme and support put in place as quickly as possible. However on occasions it may not be possible to provide necessary equipment/ access to specialist support until funding is secured. In exceptional circumstances the student may be required to interrupt their studies in order that they are not disadvantaged during an assessment process by support not being in place. Failure to disclose a disability which may significantly impact on their ability to practice may be considered under the faculty Fitness to Practice Policy. It is acknowledged that students may not have the professional insight to recognise this, it is therefore important that students are encouraged to discuss any potential health / disability issues with a member of academic staff and that they in turn seek advice if unsure. 7. Transfer of student to a different Academic Tutor In the event of a change to the Academic Tutor it is the responsibility of the outgoing academic tutor to provide a handover to the incoming academic tutor to ensure that support is maintained. 8. Consent to share personal data When students enrol on a programme of study at the beginning of each academic year of study they are notified that the university may need to share personal data with other parties as necessary. In order to complete the enrolment process they are required to consent to this happening by ticking agreement to the following message: “The University is required to report information about student disabilities. Where necessary this may be passed in confidence to academic and administrative staff and placement supervisors.” 9. Disability and Health related adjustments database All students who have declared a disability or who require short term health related adjustments are recorded on the faculty database. Due to the sensitive nature of the material information is shared on a strictly need to know basis only and details of the disability / health condition are not recorded. When students are entered onto the database a copy of the entry will be sent to the student, their Academic 4 Tutor and the relevant Programme Lead. The database records biographical data and details the Additional Examination Requirements (AER’s) which have been agreed, along with campus based adjustments and adjustments for practice (see also section 11). Where adjustments are required in clinical practice the Placement Team will also be notified. 10. Reasonable adjustments The Equality Act 2010 requires the university and our practice partners to provide students with ‘reasonable adjustments’ to ensure that those who are disabled are not placed at a “substantial disadvantage” in comparison to those who are not disabled. It is important to note that this duty is anticipatory and on-going and requires the faculty to consistently review adjustments made or which might be made. There is no defence in law for a failure to make a reasonable adjustment. It is the question of ‘reasonableness’ which alone determines whether the adjustment has to be made, if an adjustment is considered a reasonable one, then it must be made. The Faculty Lead for Inclusivity is asked to consider all proposed adjustments and will agree all of those which meet the criteria used to judge reasonableness. Where suggested adjustments are more contentious, and/or there is the potential for them to be declined a discussion will take place with appropriate staff and if necessary a case conference be convened. Although the Equality Act requires implementation of reasonable adjustments there is no duty to make any adjustment to a provision, criterion or practice of a kind which the Equality Act defines as a “competence standard”. This is defined as “an academic, medical or other standard applied for the purposes of determining whether a person has a particular level of competence or ability”. The use of a competence standard can only be justified if: it applies equally to both disabled and non-disabled students, and its application is a proportionate means of achieving a legitimate aim. Whilst the Equality Act does not require an academic institution to undermine its academic or other prescribed standards, it will inevitably require institutions to consider whether any or all of the standards applied are indispensable to achieving the academic or professional award identified in circumstances where their application amounts to less favourable treatment for a reason relating to disability. In the Faculty of Health Sciences this would include careful consideration of the fitness to practise and competency criteria prescribed by the Nursing and Midwifery Council and Health Care Professions Council which need to be met by all students prior to registration on the relevant parts of the register. 11. Adjustments in clinical practice Under the Equality Act the FOHS has a responsibility to prepare the student with a disability and the practice experience provider for the placement and ensure that the provision of necessary support is in place in advance of the start of the experience. The NMC advises that all mentors, practice teachers and teachers should receive disability equality training, whilst the HCPC suggest that HEI’s may wish to provide specific training to practice providers. The FoHS works in partnership to prepare practice experiences for students with disabilities and to prepare students to utilise the learning opportunities available to them. This includes ensuring that practice and academic learning environments enable students to feel confident that disclosure of their specific needs will not lead to discrimination. Where adjustments are required in practice these will be identified in advance and the practice provider notified (see appendix 4 and 5). If a risk assessment has been requested by Occupational Health this will also be identified. Risk assessments are conducted by the placement provider and a copy should be sent to relevant staff (see appendix 6). Practice experience providers have the same duties towards disabled students as they do towards their employees. When students are undertaking their practice experiences, they are regarded as honorary employees and treated accordingly. Although this does not allow the HEI to abrogate responsibility for 5 communicating with the practice experience provider beforehand in relation to putting all requisite support in place for the student, it cannot be held responsible for any failure by them to ensure that the support is implemented. Practice experience providers are expected to meet reasonable costs incurred in providing reasonable adjustments for example provision of Dermol 500 hand wash, or nitril gloves as required. Where students require specialised equipment such as an enhanced stethoscope for a student with a hearing impairment this is likely to be provided through the Disabled Student Allowance. 6 Key Blue : Admissions team / admissions tutor Green : Enabling Services / OH Yellow : Faculty Lead for Inclusivity Orange : Practice partners Appendix 1 : Admissions Process for students who have declared a disability on their application form Admissions team short-list applicants Applicant judged not suitable – application rejected Applicant judged suitable For professions where an interview is part of the selection process the candidate is called for interview (standard letter asks candidate to advise us of any specific arrangements needed for the interview) Applicant not suitable at interview - rejected Where complex adjustments are required Faculty Lead for Inclusivity discusses required adjustments to programme with relevant Director of Programmes prior to referring case to Admissions Panel for consideration3 Adjustments for both campus based learning and practice viewed as ‘reasonable’ by panel – offer formalised Adjustments viewed as not reasonable - reject Applicant judged suitable - conditional offer made. All offers are subject to clearance by Occupational Health (OH) on / prior to admission. Letter sent to every student with their offer letter encouraging them to disclose any disability as early as possible to facilitate planning of support. If necessary OH and / or Enabling will be asked to review the students’ needs PRIOR to admission. Admissions team notifies Faculty Lead for Inclusivity (FLI) of any student offered a place who has declared a disability and the nature of that disability. Where the student is likely to only require minimal adjustments for both campus based learning and practice, the offer is formalised but still subject to OH clearance following admission1. Where the nature of the disability suggests that more adjustments may be required the student may be contacted by FLI to discuss the support which they might require whilst on programme. Admissions tutor and Faculty Lead for Inclusivity receive report from OH and / or Enabling Services. Required adjustments discussed by Programme Lead, Faculty Lead for Practice / Placement Lead (AHP) and Faculty Lead for Inclusivity. Informal discussion may take place with practice partners. Where adjustments are still considered to be minimal for both campus based learning and practice offer formalised2 Notes 1. 2. 3. The University have a legal obligation to provide reasonable adjustments. Where adjustments are considered minimal they will be agreed automatically examples include use of alternative soap for hand washing, use of an enhanced stethoscope, minor adjustments to shift patterns. No consultation will take place as failure to agree such adjustments would be in breach of the Equality Act. Even when students have potentially complex needs the actual adjustments required may be minimal. Informal discussion may take place with practice partners but this will not always be necessary. Admission panel consists of representatives at Director of Nursing level from practice partners Blue : Student Office Green : Enabling Services / OH Yellow : Faculty Lead for Inclusivity (FLI) Orange : Practice partners Pink : Student Appendix 2: Managing disability and health related adjustments for campus based learning and practice. Enabling Services or Occupational Health (OH) notify the FoHS Student Office of the students’ needs by email / fax / post Student office access relevant shared resources folder on j drive and print off two copies of the report or photocopy letter from Occupational Health Student Office enter the student onto the Disabilities / Health adjustments database recording biographical data. One copy of report / letter filed in students file (AT, PL and PALL (AHP) access report in file as required) One copy of report / letter forwarded to the Faculty Lead for Inclusivity Faculty Lead for Inclusivity reviews proposed adjustments and where necessary in negotiation with Enabling / OH and the relevant Programme Lead / PALL adds any specific practice related adjustments which have not been identified. Agreed adjustments entered onto the disability / health adjustments database by FLI. Copy of the database entry sent to relevant Programme Lead, Academic / Personal Tutor and PALL (AHP only) NB Full report available in student file. Where students have more complex needs the Faculty Lead for Inclusivity will convene a case conference in accordance with the “Support for students who declare a disability whilst on programme” process document. Practice partners involved in decision making as to whether required adjustments can be met in practice settings Letter for practice detailing agreed adjustments3 and whether a risk assessment is required generated by secretaries and forwarded to Placement Team. required. Faculty Lead for Inclusivity writes to the student with a list of agreed adjustments and asks them to return a signed copy which confirms that : – they feel that the adjustments cover all of their perceived needs at that time1 – they recognise that it is their responsibility to alert the Faculty Lead for Inclusivity if adjustments are not being put in place or need to be reviewed – that they understand that the adjustments will be shared with relevant staff including practice partners (where adjustments have been requested by Occupational Health will be asked to sign Release of Sensitive Data form2 ) – Where no adjustments are felt to be required (by OH / Enabling) this will be recorded on the database and the student asked to contact the Faculty Lead for Inclusivity if the situation changes. Placement team send letter out to designated contacts within the placement area prior to each placement. Where deemed necessary a risk assessment is undertaken by the placement provider with the student, to identify potential risks and ensure that adjustments can be made. Copy of risk assessment sent to Learning Environment Lead, PAC/ PALL and Faculty Lead for Inclusivity. Student discusses required adjustments with mentor/ practice educator in advance of / or at the beginning of each experience. Required adjustments documented in the Assessment of Practice document. Notes 1 If during their programme the student, their mentor or a member of FoHS staff feels that the adjustments are insufficient the student will be referred to the Faculty Lead for Inclusivity for an urgent review of their adjustments – this may necessitate further assessment by Enabling / Occupational Health or Wessex Needs Assessment Unit. Once this is complete the original flow chart processes will be followed again. 2 Students sign a declaration agreeing that information related to a disability can be shared with relevant staff each year when they enrol. Students registering with Enabling Services part way through a year will be asked to sign a declaration at that time. 3 Details of the student’s diagnosis are not shared with practice partners (unless required by the Health and Safety at Work Act, 1974) in which case the student will be made aware that this will happen eg Latex type 1 allergy. Green : Enabling Services / OH Yellow : Faculty Lead for Inclusivity Orange : Practice partners Pink : Student Appendix 3 : Support for students who declare a disability whilst on programme Whilst on course the student declares a disability which they have previously chosen not to disclose. Student advised to register with Enabling Services. Information shared with PL, Academic / Personal Tutor and Faculty Lead for Inclusivity. Student identified as not fit to study by OH or Enabling PL, Academic / Personal Tutor or Faculty Lead for Inclusivity request advice from Occupational Health (OH) and /or Enabling Services relating to: Fitness to study policy implemented Concerns relating to Fitness to Practice identified Fitness to Practice policy implemented Required adjustments Fitness to study Fitness to practice This may form part of the investigation phase in relation to the Fitness to Practice / Study policy. Report from OH and/or Enabling considered by Faculty Lead for Inclusivity in consultation with Programme Lead if necessary. Required adjustments considered reasonable. Follow processes outlined in the Managing disability and health related adjustments for campus based learning and practice flowchart.’ Reports from OH / Enabling considered - complex needs identified. Faculty Lead for Inclusivity convenes a case conference with Programme Lead, Enabling Services / OH and Faculty Lead for Practice or representative. List of required adjustments created all of which are considered to be minor List of required adjustments agreed by admissions panel as acceptable List of required adjustments created but viewed as complex. Requested adjustments sent to representatives from Admissions Panel for consideration1. Concerns relating to Fitness to Practice identified Fitness to Practice policy implemented 1: Admission panel consists of representatives at Director of Nursing level from practice partners 9 Appendix 4 Sample letter sent to practice partners notifying them of required adjustments when no risk assessment is required Insert name of contact Address Date Dear name of contact inserted Re: Student Nurse Florence Nightingale 2020 intake; Bachelor of Nursing Placement Date 06.06.21 - 19.08.21 Florence is due to commence practice experience on 6 June 2021 in your area and will require additional support to enhance her potential to achieve the required skills and proficiencies in practice. The adjustments detailed below constitute ‘reasonable adjustments’ under the Equality Act 2010 and must be implemented. If for some reason you feel that it would not be possible to provide this support please contact Michelle Cowen, Faculty Lead for Inclusivity on 023 8059 7854 or by email on mdc4@soton.ac.uk as soon as possible. Unless we hear from you at least 2 weeks prior to the placement commencing we will assume that these recommendations are being followed. Once these adjustments are in place Florence will be expected to achieve the same competencies as her peers. No additional adjustments should be put in place without discussion. If you or Florence feel that the adjustments are not sufficient please contact the faculty as a matter of urgency on the number above. Florence has been advised that she should alert staff working with her of the required adjustments. Adjustments No nights until blood sugar stabilises, ideally 3-4 nights in a row to establish routine, access to regular breaks. Risk assessment Florence is expected to be constantly aware of potential risk and has been advised that she should not engage in activities which may expose herself or others to risk. A formal risk assessment is not required. Should you have any concerns, please contact the Learning Environment Lead or Practice Academic Coordinator. Yours sincerely Laura Powell Placement Assistant cc: Xxxxx - LEL Xxxxxx - PAC Xxxxxxx - Academic Tutor Xxxxxxxx (student) Appendix 5 Sample letter sent to practice partners notifying them of required adjustments when a risk assessment is required Dear name of contact inserted Re: Student Nurse Florence Nightingale 2020 intake; Bachelor of Nursing Placement Date 06.06.21 - 19.08.21 Florence is due to commence practice experience on 6 June 2021 in your area and will require additional support to enhance her potential to achieve the required skills and proficiencies in practice. The adjustments detailed below constitute ‘reasonable adjustments’ under the Equality Act 2010 and must be implemented. If for some reason you feel that it would not be possible to provide this support please contact Michelle Cowen, Faculty Lead for Inclusivity on 023 8059 7854 or by email on mdc4@soton.ac.uk as soon as possible. Unless we hear from you at least 2 weeks prior to the placement commencing we will assume that these recommendations are being followed. Once these adjustments are in place Florence will be expected to achieve the same competencies as her peers. No additional adjustments should be put in place without discussion. If you or Florence feel that the adjustments are not sufficient please contact the faculty as a matter of urgency on the number above. Florence has been advised that she should alert staff working with her of the required adjustments. Adjustments No nights until blood sugar stabilises, ideally 3-4 nights in a row to establish routine, access to regular breaks. Risk assessment Florence is expected to be constantly aware of potential risk and has been advised that she should not engage in activities which may expose herself or others to risk. In addition a formal risk assessment is required. You should undertake a risk assessment with Florence using your standard documentation. This should take place either prior to the start date or within the first few days of placement. A copy should be retained by yourself and the student. In addition a copy must be sent to: The Learning Environment Lead (LEL) The Practice Academic Coordinator (PAC) Faculty Lead for Inclusivity - Xxxxx Xxxxxxx Michelle Cowen (or PALL for AHP students) Should you have any concerns, please contact the Learning Environment Lead or Practice Academic Coordinator. Yours sincerely Laura Powell Placement Assistant cc: Xxxxx - LEL Xxxxxx - PAC Xxxxxxx - Academic Tutor Xxxxxxxx (student) 11 Appendix 6 Risk Assessments for students with a disability or health related condition Background When students are referred to Occupational Health (OH) for consideration of a disability or health related condition a report is subsequently received which details required adjustments and identifies if a risk assessment is required. In the past there have been instances where no risk assessment had been requested but the student has been perceived as being at risk by a member of staff. Furthermore there have been occasions where a risk assessment has not been requested by OH and an incident has occurred. One example of this is a student ‘collapsing’ in practice and it coming to light that this has occurred previously. In the light of concerns from practice partners that they were not being notified of potential risks a meeting was convened to discuss the use of risk assessments. Participants Dr Julia Smedley, Lead Consultant in Occupational Health. University Hospitals Southampton Foundation Trust Jean Piernicki, Senior Nurse Occupational Health, University Hospitals Southampton Foundation Trust. Peter Fisk, Faculty Health, Safety and Sustainability Officer, Faculty of Health Sciences Paula Libberton, Faculty Lead for Practice, Faculty of Health Sciences Juliette Truman, Faculty Lead for Practice, Faculty of Health Sciences Michelle Cowen, Faculty Lead for Inclusivity, Faculty of Health Sciences Sue Faulds, Programme Lead Bachelor of Nursing, Faculty of Health Sciences Sylvia Chapman, Placement Team Lead, Faculty of Health Sciences Kathryn Earle, Enabling Services, University of Southampton Jill Pallister, Practice Based Learning Manager, Portsmouth Hospitals Trust Alison Trenerry, Learning Environment Lead, University Hospitals Southampton Foundation Trust Principles of good practice 1. That confidential information should only be disclosed where absolutely necessary. In particular where disclosure will not lead to any request for action then it is not necessary for people to be informed. 2. That we should not be medicalising conditions where the probability of risk is perceived as small. For example an individual with well controlled epilepsy who has not had a fit in the last year should not be considered as any higher risk than any other member of the public and does not require a risk assessment. 3. That it is accepted that incidents may occur where the perceived risk did not warrant a risk assessment and that the decision not to perform one was appropriate. 4. That each Trust will already have a generic risk assessment for each clinical area and that these should be used to identify specific risks associated with that area for all students. Risks likely to be identified include potential latex exposure, specific moving and handling risks for example bariatric patients, lone working, remote locality, potential exposure to violence and aggression. 5. That individual student risk assessments will build on the generic version to highlight specific issues related to that individual student. 12 6. Individual student risk assessments will be considered when planning placement lines and lines adjusted as necessary. Actions 1. 2. 3. 4. Occupational Health will clearly identify when a risk assessment is required. Risk assessments will only be requested when absolutely necessary. Generic risk assessments will be made available (or created) for each clinical area / cluster. Where students are identified as requiring a risk assessment that these will be conducted by Trust staff using their approved risk assessment documentation. 5. Copies of completed risk assessments will be forwarded to the relevant Learning Environment Lead, Practice Academic Co-ordinator and Faculty Lead for Inclusivity within 48 hours of the placement commencing. 13 Appendix 7 Use of alternative assessment formats for students with a recognised disability including Specific Learning Difficulty (SpLD) The Faculty of Health Sciences recognises that students with a disability may require adjustments in relation to the assessments that they undertake. The Faculty fulfils its 'anticipatory duty' under the Equality Act (HMSO, 2010) by ensuring that all assessments are internally reviewed to assess their suitability and are created and presented in an inclusive manner. This includes ensuring that assignments are dyslexia friendly. In addition to this, the Act requires that individual students 'specific needs' are met. As a Faculty we respond promptly and in a supportive manner to all requests for adjustments. These are reviewed on an individual basis, in close consultation with central University services, and where these are judged as 'reasonable' the adjustments are agreed and implemented. The Faculty has a history of offering alternative format assessments where appropriate. The following guidelines have been drawn up in relation to the use of alternative assessment formats for students with a recognised disability. Identification of need 1. A request for an alternative assessment format can come from the student, a member of academic staff or from appropriate Support Services including Enabling Services, Occupational Health or the Student Union Advice and Information Centre (SUAIC). 2. All requests will be directed to the Faculty Lead for Inclusivity to consider in consultation with the relevant Programme Lead. 3. Evidence that the student has a recognised disability will be sought unless this is already held by the faculty for example in previous report from Enabling Services. 4. The Faculty Lead for Inclusivity will review any supporting evidence and where necessary in discussion with relevant external experts identify what the student’s personal needs are. Recommendations for an alternative format 5. The Faculty Lead for Inclusivity will prepare a case document outlining what the justification is for the student requiring an alternative format and what format is being requested. 6. This case document will be presented to the relevant Programme Lead and External Examiner for discussion and agreement. A copy will also be forwarded to the Assessment Officer and relevant Chair of the Exam Board for information. 7. If necessary a request for a new assessment date will be considered by the Chair of the relevant Exam Board. This will reflect any additional time which might be required by the student to prepare or for the faculty to make arrangements. 8. The assessment team will notify the student of the date of the assessment (original or delayed) by email at least 2 weeks prior to the agreed date. Academic Standards The following assessment principles should be observed when undertaking an alternative format assessment. 9. There should be parity in the assessment process. The revised format should address all of the learning outcomes covered by the original assessment and utilise the marking grid used for the original format. 14 10. Academic rigour must be maintained. Records of the assessment process and where appropriate a digital voice recording should be available for scrutiny by the Exam Board and External Examiner. 11. Where a viva is used as the alternative format it must be conducted under exam conditions and must take place on the date / time agreed. If the student is unable to attend on the day they must apply for a deferred date following the normal procedure and provide appropriate evidence. 12. A marking report will be prepared and signed by both examiners, before being submitted to the assessment office. This will be filed in the students file. 13. The student will be notified of the outcome of the assessment in the normal way. 15 Appendix 8 Types of discrimination Taken from the Equality Act 2010 2.1 Direct discrimination on the grounds of a protected characteristic It is unlawful to discriminate against someone on the grounds of a protected characteristic. Protected characteristics include age, disability, gender reassignment, race, religion or belief, sex, sexual orientation, marriage and civil partnership1, pregnancy and maternity. This means treating a person less favourably “on the grounds of” his/her disability – and applies to the admission of students, access to facilities and all other aspects of treatment when studying including teaching and learning, assessment and conferment of qualifications. Treatment of a disabled person which amounts to direct discrimination under the Equality Act is unlawful and cannot be justified. Education providers must refrain from making stereotypical assumptions about disabled applicants and students, and fully consider their individual abilities and needs. In determining whether a person has been treated less favourably in relation to a protected characteristic that person’s treatment must be compared with that of an appropriate comparator – eg a non-disabled person or someone with other disabilities whose relevant circumstances, including abilities, are either the same or not materially different from the disabled person. Associative discrimination - occurs when a student is treated less favourably because of their association with another person who has a protected characteristic. Discrimination by perception - direct discrimination also occurs when you treat a student less favourably because you mistakenly think that they have a protected characteristic (other than pregnancy and maternity). 2.2 Combined discrimination This is a new type of discrimination introduced through the Equality Act where a person is treated less favorably because of a combination of two relevant protected characteristics, for example a disability and sexual orientation. 2.3 Indirect discrimination Indirect discrimination occurs when an education provider applies a provision, criteria or practice in the same way for all students or a particular student group, but this has the effect of putting students sharing a protected characteristic at a particular disadvantage compared with students who do not share that characteristic. One example of this would be the choice of a certain format of assessment or examination which would potentially disadvantage a group of students with a disability. The Faculty of Health Sciences has considered this carefully in the design and implementation of its curricula. All new modules and awards are reviewed carefully to ensure that the faculty meets its anticipatory duty under the Equality Act. In addition all exam papers are reviewed by the Faculty Lead for Inclusivity to confirm that the question design and wording of questions does not inadvertently disadvantage any group of students or individual. 2.4 Discrimination arising from a disability. A student is deemed disabled if he/she “has a physical or mental impairment which has a substantial and long-term adverse effect on his/her ability to carry out normal day-to-day activities”. This covers most physical impairments as well as hidden disabilities such as dyslexia, mental illness, learning difficulties, 1 Marriage and civil partnership do not apply to students as a protected characteristic . 16 epilepsy and diabetes. Also, since December 2005, people with HIV infection, cancer or multiple sclerosis are deemed disabled with effect from the point of diagnosis (and no longer need to prove that the illness has an adverse effect on their ability to carry out day to day activities). Discrimination arising from a disability occurs when there is discrimination against a disabled person by treating him/her less favourably for a reason relating to his/her disability. Such treatment will be discrimination unless it can be demonstrated that the less favourable treatment of a disabled student is justified, after taking into account the duty to make reasonable adjustments to assist the student. There are only two circumstances when less favourable treatment for a reason related to a person’s disability can be justified: When the reason for the treatment is both material to the circumstances of the particular case and substantial, or When it as result of the application of the competence standard. (see section 10) 17 Section 2 : Support for students who have declared a Specific Learning Difficulty (SpLD) 1. Background The Faculty of Health Sciences places considerable importance on matters relating to equality and diversity and is committed to the on-going development and enhancement of a culture which promotes inclusivity and the provision of equal opportunities for all healthcare students. One group of students for whom this is particularly important are those who have a Specific Learning Difficulty (SpLD) such as dyslexia or dyspraxia. These conditions are normally recognised as a disability under the Equality Act (HMSO, 2010) and as such students are entitled to reasonable adjustments to help them to overcome any difficulties caused by their condition. In order to help them to reach their potential it is imperative that their individual needs are identified in a timely manner and access to appropriate support is provided as early as possible on the programme. This document aims to clarify the processes in place for students who have declared a SpLD. However the faculty recognises that a significant number of students are diagnosed with a SpLD whilst on programme and appendix 3 describes the process for those who suspect that they may have a SpLD but have not been formally diagnosed. 2. Disclosure The Faculty recognises that students may be reluctant to share personal sensitive information relating to a disability, including a SpLD. It therefore strives to create a culture where students feel empowered to do so, confident in the knowledge that they will not be disadvantaged in any way. The FoHS prospectus highlights our commitment to inclusivity and encourages students to declare relevant conditions in order that support can be planned in advance to avoid unnecessary delays. This is reinforced on Open Days and Selection Days where several slides have been inserted into the presentation reassuring students that this will not affect their application but will enable us to meet their needs more effectively. 3. Identification of a SpLD The Faculty of Health Sciences recognise the importance of early identification of students with a previously undiagnosed SpLD in order that access to appropriate support can be provided in a timely manner. The identification of a condition such as dyslexia, even when anticipated, has a life changing effect on any student and the faculty recognise that students may be reluctant to request an assessment. It therefore strives to create a culture where students feel empowered to seek an assessment confident in the knowledge that they will not be disadvantaged in any way. Enabling Services operate a self-referral system but students can seek advice from the Faculty Lead for Inclusivity if they wish when deciding whether to request a screening. The potential benefits, in terms of targeted and appropriate support are explained to students who ask for more information along with the process of obtaining a diagnosis. 4. Sharing of personal data When students enrol on a programme of study at the beginning of each academic year of study they are notified that the university may need to share personal data with other parties as necessary. In order to complete the enrolment process they are required to consent to this happening by ticking agreement to the following message: “The University is required to report information about student disabilities. Where necessary this may be passed in confidence to academic and administrative staff and placement supervisors.” 5. Notification of support available To ensure that all students are aware of the support available, both from the central University of Southampton Student Services and within the Faculty, information is provided in the student handbook and via a specific link on the Blackboard site SOHS – Pre registration healthcare programmes. Contact details for 18 the Faculty Lead for Inclusivity are provided and students are encouraged to ask for further advice and information if required. 6. Transfer of student to a different Academic Tutor In the event of a change to the Academic Tutor it is the responsibility of the outgoing academic tutor to provide a handover to the incoming academic tutor to ensure that support is maintained. 7. Dyslexia Database All students who have declared a SpLD and who have registered with Enabling Services are recorded on the faculty database which is split into two sections. The first of these contains students who are on a programme of study leading to initial registration / qualification. The second section lists students on Learning Beyond Registration (LBR), Post Graduate Taught and Post Graduate Research Programmes of study. The university require all staff who are involved in the students programme to be made aware of the students’ needs. In order to achieve this, section 1 of the database is circulated electronically to all academic staff at the beginning of September, November, February and May each year. This enables staff teaching on a particular programme to make themselves aware of students within the group who have declared a SpLD (see section 9). The database records biographical data and details the Additional Examination Requirements (AER’s) which have been agreed, along with campus based adjustments and adjustments for practice (see section 10). Embedded within the database is a copy of the students report from Enabling Services to facilitate ease of access by academic staff. Academic staff are encouraged to review the report for students for whom they act as academic / personal tutor. In order to maintain confidentiality relating to students undertaking Learning Beyond Registration (LBR), Post Graduate Taught and Post Graduate Research Programmes of study, many of whom are staff, section 2 of the database is not circulated to all staff in the same way. Relevant Programme / Module Leads are notified of students undertaking their Programme / Module and are asked to disseminate the information to relevant colleagues. 8. Reasonable adjustments Specific Learning Difficulties (SpLD) count as a disability under the terms of the Equality Act 2010 and students are therefore entitled to ‘reasonable adjustments’. However the requirement to demonstrate professional competence may mean that some suggested adjustments may not be possible to accommodate within the students programme. All requests for adjustments are directed to the Faculty Lead for Inclusivity and where appropriate a case conference is convened before a decision is made. Once adjustments are in place the student will be required to reach the same academic / professional standard as their peers. Appendix 6 details ‘standard adjustments’ which are strategies designed to support students with a SpLD in relation to Additional Examination Requirements (AER’s) and campus based learning. 9. Inclusive teaching practices Due to the large number of students undertaking pre-registration programmes within the FoHS, and a similarly large number of lecturers delivering individual lectures, seminars and clinical skills sessions, it is not possible for academic staff to be personally aware of every student within the audience who has a SpLD. The faculty therefore strives to facilitate all learning in an inclusive manner which meets the needs of all students. Staff development sessions are provided and a range of guided study materials relating to inclusive teaching and learning practices is being developed. 10. Adjustments in clinical practice The nature of Specific Learning Difficulties (SpLD) means that the way in which the individual is affected is unique to them. There are a range of difficulties which students commonly experience, however every student will have a unique profile which changes as they develop strategies and encounter new challenges. The booklet ‘Supporting dyslexic students on practice placements’ therefore provides suggestions for 19 practice based adjustments, all of which would be considered reasonable. This allows the student to identify the areas which they find challenging and identify possible strategies to help them overcome their personal difficulties. Practice based adjustments are recorded on the database as ‘standard’ meaning that the student would use the booklet to identify the adjustments they need in consultation with their mentor / practice assessor. Where students or the mentor / practice assessor require additional support they are encouraged to contact the Faculty Lead for Inclusivity. Advice can then be provided by telephone or email with the potential of a practice visit where necessary. 11. Inclusive assessments The Faculty of Health Sciences recognises that students with a disability may require adjustments in relation to the assessments that they undertake. The Faculty fulfils its 'anticipatory duty' under the Equality Act (HMSO, 2010) by ensuring that all assessments are internally reviewed to assess their suitability and are created and presented in an inclusive manner. All examination papers are reviewed by the Faculty Lead for Inclusivity to ensure that question design / wording do not disadvantage students with dyslexia. Guidelines are currently under development to assist academic staff when creating Computer Assisted Assessments (CAA) including multiple choice / multi response formats. 20 Appendix 1 : Flow chart : Support for students who have declared a Specific Learning Difficulty (SpLD) prior to admission. Admission teams will identify all students who have formally accepted an offer for a preregistration programme of study OR are undertaking a LBR module / programme who have declared a SpLD on their UCAS / faculty application form. Pre-registration Admissions team notify Faculty Lead for Inclusivity of new admissions who have declared a Specific Learning Difficulty (SpLD) one month prior to the programme or module commencing. LBR Admissions team record students who have declared a disability on the module register. Copies of all registers are sent to Faculty Lead for Inclusivity prior to the module commencing. Admissions teams send students who have declared a SpLD the standard pre-admission letter from the Faculty Lead for Inclusivity advising them of the support available and asking them to register with Enabling Services as soon as possible on admission. . When students enrol on their programme of study they will be asked if they have any disabilities. If they tick this box they will see a message from Enabling informing them of the need to register. Students attend an initial interview with Enabling Services where the Specialist Dyslexia Practitioner reviews their Educational Psychologist / Specialist Practitioner report and identifies the level of support required. Where a student has provided a report which is too old or insufficient for HE purposes Enabling Services will arrange an up-to-date assessment – this will delay notification of the support required by the student to the faculty, however the student will still be able to access support from Enabling Services whilst they are awaiting an updated assessment Enabling Services notify the FoHS via the faculty email address that the student has registered with them. A copy of the confidential memo which summarises the students strengths and weaknesses, makes recommendations for support within the faculty, gives information about support offered by Enabling Services and gives details of the recommended AER, is saved on the j drive and made accessible to the faculty. Support for the student then follows the existing faculty processes related to support for students with a SpLD. Blue = FoHS Student Services Pink = Enabling Services : Dyslexia Support Team 21 Pink = Enabling Services (ES) Blue : FoHS Student Services Team Appendix 2: Flow chart: Support for students with a SpLD who have registered with Enabling Services Where a student has provided a report which is too old or insufficient for HE purposes Enabling Services will arrange an up-to-date assessment – this will delay notification of the support required by the student. Green = Faculty Lead for Inclusivity Students attend an initial interview with Enabling Services where the Specialist Dyslexia Practitioner reviews their Educational Psychologist / Specialist Practitioner report and identifies the level of support required. Student encouraged to apply for Disabled Student Allowance (DSA) and referred to Wessex Needs Assessment Centre. Enabling Services notify the FoHS via the faculty email address that the student has registered with them and provide access to the confidential memo. DSA application submitted to relevant funding body. Examination adjustments (AER’s) are recorded on Banner. Personal equipment ordered when funding approved. In the meantime students can assess Dyslexia Support for tutorials and use equipment in the Assistive Technology Suite. Student records team enter the student onto the Dyslexia Database recording: Profession Report received Student number Surname Forename Cohort Programme Learning Group Academic Tutor If AER’s are in excess of the standard extra time / AER room Enabling Services will discuss the students requirements with the Faculty Lead for Inclusivity who will approve them or justify why they are not acceptable. (Where necessary this decision is made in consultation with the relevant DoP / Programme Lead) Student records team receive notification and access the ES memo. One copy of the memo is placed in the student file and one copy forwarded to the Faculty Lead for Inclusivity. An electronic version is embedded within database. Faculty Lead for Inclusivity reviews the ES memo and enters details of adjustments required for theory / practice on database. Section 1 of the database sent to all academic staff beg Sept, Nov, Feb & May. Section 2 shared with relevant module / programme lead E mail sent to Academic Tutor and Programme Lead with copy of report attached Letter detailing practice adjustments generated by secretaries and forwarded to Placement Team Where the memo indicates significant areas of concern Faculty Lead for Inclusivity to request full report from Enabling Services. E mail sent to student by Faculty Lead for Inclusivity explaining support available in relation to theory and practice. Students requested to notify Faculty Lead immediately if adjustments not being implemented Full diagnostic report reviewed and case conference set up if required Appendix 3 : Support for students who suspect that they have a Specific Learning Difficulty (SpLD) Whilst on course the student refers themself to Enabling Services for a screening assessment. Specialist Dyslexia Practitioner carries out an initial screening assessment. * At certain times of the year there may be a delay between the screening and full assessment due to high demand. If the student has assignments / examinations due please contact Screening indicates need for further assessment Initial screening does not indicate evidence of a SpLD the Faculty Lead for Inclusivity for advice. Enabling Services arrange a full diagnostic assessment* – the student is advised that they will be asked to pay part of the cost SpLD identified SpLD not identified Study skills deficit identified – Dyslexia Support refer student to the Independent Learning Advisors or to Disability Practitioner for further advice Copy of referral sent to Academic Tutor Follow processes outlined in the Process Document ‘Support for Students who have declared a Specific Learning Difficulty’ Appendix 4 Procedure for the use of a viva as an alternative assessment format for students who have declared a Specific Learning Difficulty (SpLD) The Faculty of Health Sciences recognises that students with a disability may require adjustments in relation to the assessments that they undertake. The Faculty fulfils its 'anticipatory duty' under the Equality Act (HMSO, 2010) by ensuring that all assessments are internally reviewed to assess their suitability and are created and presented in an inclusive manner. This includes ensuring that assignments are dyslexia friendly. In addition to this, the Act requires that individual students 'specific needs' are met. As a Faculty we respond promptly and in a supportive manner to all requests for adjustments. These are reviewed on an individual basis, in close consultation with central University services, and where these are judged as 'reasonable' the adjustments are agreed and implemented. The Faculty has a history of offering alternative format assessments where appropriate. The following guidelines have been drawn up in relation to the use of a viva as a supplementary assessment alongside a written submission. Procedure Following discussion of each individual case with the relevant Programme Lead and External Examiner the following procedure will be followed: 1. If necessary a request for a new submission date will be considered by the relevant FoHS exam board. This will reflect any additional time which might be required by the student prior to submission of the written work2. 2. The student will be notified of the date of submission (original or delayed) and of a date for the viva. This would normally be one month following submission to allow for marking / moderation processes. 3. The student will submit the assignment in the original format, which will be marked in the normal manner. A provisional mark will then be awarded. 4. Two examiners will be identified. This should include the 1st marker and either the 2nd marker or Module Lead. The two markers should agree on areas of concern that are unclear from the written submission. 5. One week prior to the viva the student will be advised of broad areas of content to focus on. They will not be advised of the exact questions but will be guided to identified areas which require clarification and notified that the questions that they will be asked will target these areas. 6. The two examiners will meet and agree exact questions to be asked. 7. The viva will be conducted under exam conditions and must take place on the date / time agreed. If the student is unable to attend on the day they must apply for a deferred date following the normal procedure and provide appropriate evidence. 8. Students will be permitted to take a copy of their written submission into the viva with them. 9. The viva will be recorded and the voice file made available to the External Examiner along with the markers comments. 2 Students with specific learning difficulties are encouraged to maintain original submission dates in order that subsequent assignments are not affected. However if a student is newly diagnosed they may require additional time to develop appropriate strategies and access support services. 10. Following the viva the two examiners will discuss the supplementary answers that the student has given and decide if the provisional mark should be adjusted upwards or remain the same. Marks will not be reduced. 11. A summary report of the viva will be prepared and signed by both examiners, before being submitted to the assessment office. This will be filed along with the original feedback in the students file. 12. The student will be notified of the outcome. 25 Appendix 5 : Use of alternative assessment formats for students with a recognised disability including Specific Learning Difficulties (SpLD) The Faculty of Health Sciences recognises that students with a disability may require adjustments in relation to the assessments that they undertake. The Faculty fulfils its 'anticipatory duty' under the Equality Act (HMSO, 2010) by ensuring that all assessments are internally reviewed to assess their suitability and are created and presented in an inclusive manner. This includes ensuring that assignments are dyslexia friendly. In addition to this, the Act requires that individual students 'specific needs' are met. As a Faculty we respond promptly and in a supportive manner to all requests for adjustments. These are reviewed on an individual basis, in close consultation with central University services, and where these are judged as 'reasonable' the adjustments are agreed and implemented. The Faculty has a history of offering alternative format assessments where appropriate. The following guidelines have been drawn up in relation to the use of alternative assessment formats for students with a recognised disability. Identification of need 14. A request for an alternative assessment format can come from the student, a member of academic staff or from appropriate Support Services including Enabling Services, Occupational Health or the Student Union Advice and Information Centre (SUAIC). 15. All requests will be directed to the Faculty Lead for Inclusivity to consider in consultation with the relevant Programme Lead. 16. Evidence that the student has a recognised disability will be sought unless this is already held by the faculty for example in previous report from Enabling Services. 17. The Faculty Lead for Inclusivity will review any supporting evidence and where necessary in discussion with relevant external experts identify what the student’s personal needs are. Recommendations for an alternative format 18. The Faculty Lead for Inclusivity will prepare a case document outlining what the justification is for the student requiring an alternative format and what format is being requested. 19. This case document will be presented to the relevant Programme Lead and External Examiner for discussion and agreement. A copy will also be forwarded to the Assessment Officer and relevant Chair of the Exam Board for information. 20. If necessary a request for a new assessment date will be considered by the Chair of the relevant Exam Board. This will reflect any additional time which might be required by the student to prepare or for the faculty to make arrangements. 21. The assessment team will notify the student of the date of the assessment (original or delayed) by email at least 2 weeks prior to the agreed date. Academic Standards The following assessment principles should be observed when undertaking an alternative format assessment. 22. There should be parity in the assessment process. The revised format should address all of the learning outcomes covered by the original assessment. 26 23. Academic rigour must be maintained. Records of the assessment process and where appropriate a digital voice recording should be available for scrutiny by the Exam Board and External Examiner. 24. Where a viva is used as the alternative format it must be conducted under exam conditions and must take place on the date / time agreed. If the student is unable to attend on the day they must apply for a deferred date following the normal procedure and provide appropriate evidence. 25. A marking report will be prepared and signed by both examiners, before being submitted to the assessment office. This will be filed in the students file. 26. The student will be notified of the outcome of the assessment in the normal way. 27 Appendix 6 : Adjustments determined as good practice for students with a Specific Learning Difficulty for examinations and campus based learning The following adjustments are normally recommended by Enabling Services for all students with a Specific Learning Difficulty. Additional Examination Requirements (AER’s) Student’s individual requirements are recorded on Banner but normally include: 25% extra time in all timed assessments, including practical examinations when appropriate. Separate room with other students receiving extra time so that they are not disturbed when other students leave the room. Examination scripts to be flagged with a coloured sticker to indicate dyslexia. This is in order to ensure that in anonymous marking a dyslexic student is not penalised for typical dyslexic spelling and syntax errors. Use of a coloured overlay if needed. Adjustments for campus based learning The following adjustments are considered as ‘standard’ by the university and are recorded on the database as such. Permission to record lectures - this is restricted to the lecture theatre as confidentiality issues may arise, particular for students on health-related courses. Guided reading lists.3 Hand-outs from lectures provided in advance.4 Written instructions provided as well as oral. All tutors should be made aware of the students’ specific learning difficulty as far as possible. University policy does not permit special considerations for coursework. 3 Enabling Services suggest that texts are listed in order of priority. Within the FoHS texts are not prioritised in this way as reading lists provide a range of resources for students to select from based on particular areas of interest. Indications as to which resources are particularly valuable are made verbally by lecturers where appropriate. 4 Faculty policy requires these to be posted on blackboard 48 hours prior to the session unless there are exceptional reasons as to why this is not possible. 28