Student accommodation requests continue to evolve, and institutions are seeing a wider range of issues than in prior years. While many requests still involve familiar academic adjustments, colleges and universities are increasingly asked to evaluate accommodations connected to housing, attendance, technology (including AI), temporary health impacts, and mental health. Summer is an important time to assess whether institutional processes are prepared to address these requests in a way that is timely, individualized, and legally sound.

Current challenges may include:

Newer or less common requests: These requests can test the boundaries of established policies and procedures, both within the disability services office and the institution as a whole. When a request does not fit neatly into a standard form or long-standing practice, disability services staff may be tempted to treat it as unusual in a way that slows review or leads to inconsistent analysis, and academic supports and staff offices may automatically reject a requested accommodation without following required processes. Examples of new or less common requests that the Hunton team has advised on recently include: the use of AI (including AI recording devices), multiple emotional support animals in campus housing, accommodations for overlapping food allergies or sensitivities, and distinguishing between pregnancy accommodations and disability accommodations for postpartum students. Institutions should focus on whether their process is built to evaluate the request on its own facts, using an interactive and documented approach. The legal issue is often not whether a request feels novel, but whether the institution responds appropriately, considers relevant information, and explains its determination in a reasoned manner.

Coordination across offices on campus: Student accommodation issues may involve disability services, housing, dining, academic affairs, student conduct, counseling, health services, and/or technology support. As new types of requests emerge, institutions can face delays or mixed messages if those offices are not working from the same understanding of roles and process, as well as legal obligations. Summer is a practical time to confirm where requests should be directed, who makes decisions, how interim support is handled, and how related concerns are communicated internally. Clear pathways can reduce frustration for students and help avoid disputes caused by inconsistent responses.

Housing-related accommodation requests: Disability accommodations in student housing present a distinct set of considerations. The Fair Housing Act and the ADA/Section 504 (as applicable) all affect on-campus student housing accommodations. Recent guidance from HUD addresses how emotional support animals should be considered in the housing context, but this does not change the institution’s obligations to provide reasonable accommodations for disabilities under the ADA and Section 504, as applicable. This distinction frequently creates confusion when housing staff and disability services offices are operating from different assumptions about what is required. Summer is a practical time to confirm that both offices are working from consistent, current guidance.

As disability accommodation requests continue to change, institutions do not need a separate approach for every scenario. They do, however, need a process flexible enough to handle new questions thoughtfully and consistently. A summer review can help ensure that accommodation systems are ready for the kinds of requests the next academic year is likely to bring.

Hunton’s higher education team regularly advises and trains institutions and disability services coordinators on student accommodation requirements, disability services compliance, and related legal matters. If you would like to discuss how we can assist, please contact Gerry Leone, Amy Fabiano, or Brigid Harrington.