Are attendance flexibility accommodations consistent with Section 504?

A growing number of students seek modifications of class attendance requirements, often labeled as “attendance flexibility,” as a disability accommodation for classes that cap the maximum permissible absences. Institutional practices appear to vary widely, and the Education Department's Office for Civil Rights has offered little recent guidance beyond repeatedly insisting on the importance of adherence to the process — leaving each institution to assess through the interactive process whether and under what circumstances Section 504 might require attendance flexibility. OCR has found schools in violation of Section 504 by failing to go through the interactive process and requiring students to negotiate extra absences with faculty (but has not found a violation by an institution that properly adhered to process).