Accommodations for Religious Beliefs & Practices FAQ

Students, staff and faculty have the right to request a reasonable accommodation for a religious
observance if their sincerely held religious belief or practice conflicts with a Rowan University
policy, procedure, or other academic or work requirement. This FAQ is intended to assist
students, faculty and staff effectuate Rowan’s policy of providing reasonable accommodations
for sincerely held religious beliefs and practices.

What is Rowan’s responsibility to provide reasonable accommodations for religious beliefs
and practices?
Rowan will provide reasonable accommodations for an individual’s sincerely held religious
beliefs and practices, defined broadly. Religious beliefs and practices include those that come
from traditional, organized religions, and other moral or ethical beliefs and practice that are
similarly sincerely held.

Failure to provide a reasonable accommodation may give rise to a claim of discrimination under
Rowan’s Policy Prohibiting Discrimination in the Workplace and Educational Environment, or
other policies and applicable law.

What is a reasonable accommodation for religious beliefs or practices?
A reasonable accommodation is a modification to an environment, practice, or process that
allows an individual to follow their religious beliefs or practices. An accommodation that
fundamentally alters the educational program or results in an undue hardship for the University is
not a reasonable accommodation, and Rowan is not required to grant such a requested
accommodation.

In the academic context, a reasonable accommodation could include an excused absence with an
opportunity to make up coursework in accord with Rowan’s Attendance Policy, an extension on
an assignment, or the rescheduling of an exam due to the observation of a religious holiday. In
the employment context, a reasonable accommodation could include time off for the observation
of a religious holiday, a break or other work schedule modification for prayer, or the provision of
facilities for washing in accordance with a religious practice.

When does a requested accommodation constitute a fundamental alteration to an
educational course or program?
A fundamental alteration is a change so significant that it alters the essential nature of a course or
program of instruction, such as lowering an academic standard or waiving acquisition of an
essential skill. In the academic context, essential requirements are learning outcomes (including
skill, technical standards, knowledge and professionalism) that all students must demonstrate and
those that are required to uphold the academic and technical standards and integrity of courses
and academic programs.

Whether a requested accommodation fundamentally alters the educational program is determined
on a case-by-case basis. In determining whether a requested accommodation constitutes a
fundamental alteration, the following may be considered:

• What essential requirement does the proposed accommodation compromise?
• What function does that requirement serve in the academic course or program?
• Is there documentation of the essential requirement in a course syllabus, professional standards, certification requirement, or elsewhere?
• How does the requested accommodation compromise the essential requirement?
• Has the requested accommodation been provided for any other student?
• Is there another way that the student could meet the essential course or program objective?

When does a requested accommodation constitute an undue hardship?
Whether a requested accommodation creates an undue hardship is determined on a case-by-case
basis. An accommodation for religious beliefs / practices may cause an undue hardship when:

• The cost of granting the accommodation is substantial in the overall context of the University’s work, taking into account the accommodation’s practical impact on the University in light of the University's nature, size, and operating cost;
• The accommodation jeopardizes the safety of the individual who requires the accommodation or others; or
• The accommodation imposes an unreasonable burden on other University members.

It is not appropriate to determine that an accommodation would create an undue hardship
because others might request the same or similar accommodation in the future or because other
employees or students might think it is unfair.

What is the process for requesting a reasonable accommodation for religious beliefs or
practices?
Rowan will engage in an interactive process with an individual seeking a reasonable
accommodation based on religious beliefs / practices. An interactive process consists of good
faith communication between the individual seeking the accommodation and the responsible
administrator (e.g., instructor or supervisor). The interactive process is intended to identify and
implement a reasonable accommodation for an individual’s religious beliefs or practices that
does not create an undue hardship for Rowan or fundamentally alter an educational course or
program.

Employees
Employees requesting reasonable accommodations for religious beliefs / practices should
complete a Religious Workplace Accommodation Request Form and submit it to the Office of
Employee Equity (“OEE”). OEE will engage in the interactive process with the employee.

Students
Students requesting reasonable accommodations for religious beliefs / practice should:

• Submit the request to the appropriate administrator (e.g., instructor or supervisor), preferably in writing.
• Make the request in advance and/or as soon as reasonably practicable.
  • Retroactive or untimely requests for accommodation may render the requested accommodation unreasonable.
• Identify that the request relates to sincerely held religious beliefs / practices.
• Identify the academic expectation to be modified and requested accommodation
  • E.g., excused absence from class, extension of time to complete an assignment, rescheduling of an exam.

In response, the appropriate administrator should:

• Implement the requested accommodation, or engage in the interactive process with the student to determine whether there is an alternative reasonable accommodation.
• Be thoughtful and respectful during the interactive process.
• Focus conversation with the requestor on possible accommodations that would reasonably allow the individual to follow their religious beliefs or practices, and not on whether the individual’s religious beliefs or practices are genuine.
• Confer with department leadership if the administrator believes that an accommodation cannot be granted because it constitutes a fundamental alteration or an undue hardship for the University, or in the rare case that there is a bona fide doubt that the belief or practice at issue is religious or sincerely held.
• Consult the Office of General Counsel if the requestor is represented by legal counsel.
• Confirm in writing to the requestor the agreed upon accommodation and/or outcome of the interactive process.

Additionally, students who require an excused absence for a religious observance may request
the Dean of Students to issue a Student Absence Notification here, or request the accommodation
directly from an instructor or supervisor as noted above.

Is Rowan required to provide the specific accommodation requested?
Generally, no. Rowan is not required to provide the specific accommodation requested.
However, if the requested accommodation is reasonable and does not cause an undue hardship or
fundamentally alter a course or program requirement, an administrator should provide it unless
there is a legitimate reason for suggesting an alternative accommodation.

What can I do if I believe I have not been provided a reasonable accommodation for my
religious practice or belief?
If, after engaging, or attempting to engage, in the interactive process, you believe that you are not
being provided with a reasonable accommodation, you can (1) notify the supervisor of the
individual who declined to provide the accommodation; and/or (2) contact the Office of Student
Equity and Compliance or Office of Employee Equity.
What can faculty do to support the policy for accommodating religious beliefs and practice
in the academic setting?

• Do not reject a request for accommodation for religious beliefs / practices while making the same accommodation for another individual for a non-religious reason, except for exceptional circumstances in which there are legitimate reasons for the different approach.
• Confer with a Department head or chair when engaging in the interactive process.
• Do not retaliate against the requestor. Retaliation is prohibited.
• Share information about how to request a reasonable accommodation for religious belief and practices in a syllabus or other communications.

Other Resources:
Attendance Policy (students)
Office of Student Equity & Compliance
Office of Employee Equity