Tag: grip

  • Universities need to get a grip on reasonable adjustments

    Universities need to get a grip on reasonable adjustments

    Part of the problem in covering the annual Disabled Students UK Access Insights report is that I’ve written this article before.

    Quotes like this could be from any year:

    That repeated exposure – of disclosing vulnerabilities and trying to convince others my difficulties are real – is exhausting, humiliating and, at times, traumatic.

    Students shouldn’t have to repeatedly advocate just for their course to be accessible – this is really draining.

    You are pretty much left to your own devices and feel that you would need to fight for everything.

    This is DSUK’s third annual survey – drawing on over 1,100 responses from disabled students across more than 110 UK higher education providers. They point to a stubborn, systemic problem that goodwill alone isn’t fixing.

    And the context is challenging. The sector is under significant financial pressure, disability services are stretched, and pandemic-era accessibility gains that transformed many disabled students’ experiences are being rolled back to “improve belonging” or drive up attendance.

    It poses uncomfortable questions – if attitudes toward disabled students have genuinely improved, and the data suggests they have, why isn’t that translating into reliable support?

    What would it actually take to close the gap between the adjustments universities agree to provide and the adjustments they actually deliver? And is the entire model of individualised reasonable adjustments – administered centrally, implemented locally, monitored by nobody – fundamentally broken?

    The danger is that (yet) another report that wags the finger lands on a sector with little “spare” capacity to act. But maybe the framing of delivering adjustments into that “spare” space is part of the problem.

    Handle with care

    Before getting into the findings, some important caveats. The DSUK survey is the largest disabled student-led dataset in UK higher education, and its consistency across three years gives it real value – but it is not, and does not claim to be, representative of all disabled students.

    Respondents are disproportionately engaged with disability support systems – 87 per cent have at least one adjustment agreed, compared with perhaps 30 per cent of declared disabled students sector-wide, and over half are in receipt of DSA.

    Only 2 per cent have not declared their disability to their institution. The students least connected to support – those who never disclosed, never engaged, dropped out early – are barely represented, making this a survey of the system’s users, not its avoiders.

    Year-on-year comparisons also require caution. Several key questions have moved from three-point to five-point Likert scales in 2025, which mechanically reduces “neither agree nor disagree” responses and inflates both agreement and disagreement.

    When the report shows satisfaction rising from 53 per cent to 61 per cent, or “having all support needed” jumping from 38 per cent to 52 per cent, we can’t really tell how much reflects real improvement versus methodological artefact.

    I’d add in passing that quite why an independent student organisation has to carry out this research when other countries manage to do this via state-sponsored bodies is beyond me.

    In the Netherlands, for example, the ECIO (Expertisecentrum Inclusief Onderwijs) is a national expertise centre focused on accessibility, support and inclusion for students in Dutch post-secondary education, and commissions and publishes research on disabled students and those with chronic conditions, and translates findings into institutional tools and guidance. Its national reports are impressive, and infrastructure of this sort enables focused work on tricky areas like internships.

    The good news is real

    Let’s start with what’s working, because the picture isn’t uniformly grim.

    Cultural change is happening. Four in five disabled students have not been made to feel unwelcome by staff, and that figure has improved. Eighty-four per cent have encountered at least one positive attitude from staff, nearly 70 per cent have heard staff say “it’s ok to need support”, and the proportion reporting that staff treat adjustments as “mere suggestions” has declined steadily across all three survey years.

    Students are more likely to report that institutions understand invisible disabilities, that mental health problems are taken seriously, that accessibility is seen as a shared responsibility.

    I’m really pleased with everything. I started as a mature student lacking all formal education, and slowly worked my way up from a level 2 science course right to PhD… The disability support really had the capacity to make or break my achievements.

    Disability services work when they’re accessible. Eighty per cent of students who met a disability advisor found them knowledgeable and helpful, 72 per cent with support plans felt empowered to influence the content, and when one-to-one support is delivered, 74 per cent find the staff skilled. The problem isn’t competence – it’s capacity, reach, and what happens after the plan leaves disability services’ hands.

    Some universal design measures are embedding. Seventy per cent of students receive slides in advance of lectures most of the time, extensions are becoming easier to access, and uncapped resits are slowly spreading.

    These aren’t dramatic numbers, but they represent real, sustained progress on provisions that benefit large numbers of students without requiring individual negotiation.

    Institutional proof points exist. London South Bank University delivers 63 per cent of agreed adjustments fully, against a sector average of 44 per cent, while the Universities of Bath and Kent achieve over 90 per cent lecture recording rates. These aren’t institutions with unusual student populations – they’re mainstream providers making different operational choices, and what’s achievable somewhere is, in principle, achievable everywhere.

    The bad news is structural

    But the good news sits alongside findings that ought to concern the sector. The report’s central message is that the gap between policy and practice is not closing.

    Eighty-seven per cent of disabled students have adjustments agreed, but only 44 per cent report that all those adjustments are actually delivered. Sixty-three per cent go without adjustments at least some of the time because chasing them takes too much energy, and 34 per cent have to chase up adjustments more than half the time:

    I have always needed to chase up adjustments due to university lack of resources and/or understanding of accessibility in general by facilities teams, timetabling via the access support staff and/or my head of department.

    Getting this help requires email after email between the departments who seem to communicate very poorly with each other.

    As the report puts it:

    The result is a system in which access exists on paper but fails in practice. This is not a failure of individual staff goodwill. It is the predictable outcome of systems that rely on disabled students to monitor, prompt, and repair the delivery of their own access.

    The process of getting support is itself disabling. Fifty-seven per cent have to explain the same thing about their disability repeatedly to different staff, 42 per cent experienced delays from disability services that negatively affected them, and even students who submitted evidence more than two months before term started – only 59 per cent had their support plan in place when their course began:

    Neurodiverse and disabled individuals should not be the ones bearing the responsibility for educating everyone else in this sector.

    Pandemic gains are being rolled back. Remote attendance options have fallen to just 24 per cent, lecture recording has plateaued at 61 per cent – down from pandemic highs – and for students with fluctuating conditions, the return to inflexible in-person requirements has been particularly damaging:

    When I was unable to attend an in-person meeting and asked them to do an online meeting they refused saying it would be ‘too difficult’ which I found really frustrating as during COVID pandemic everyone was using online meetings.

    And in many cases, assessment remains inaccessible. Forty-six per cent believe they’ve received a lower mark because assessment wasn’t accessible to them, 55 per cent say assessment style doesn’t let them demonstrate their knowledge effectively, and only 14 per cent have access to alternative assessment forms for a majority of their assessments:

    Stammering also makes some forms of oral assessment difficult and stressful – I know that I’ve got worse grades in some areas of my course due to a perceived departmental unwillingness to change the setting of these assessments to accommodate me.

    The EHRC says that rapid escalation routes are one way a university can be compliant – but only 28 per cent know how to make a formal complaint, and of those who escalated an issue, only 32 per cent felt heard. Twenty-one per cent were treated worse after raising an access issue, and 40 per cent of complaints reaching the Office of the Independent Adjudicator in 2024 were from disabled students:

    I have no idea how to make a complaint without being singled out.

    My experience has been that concerns and formal complaints are shut down (or ignored entirely) rather than opportunities taken to learn and put things right.

    Thirty-six per cent have been discouraged from or refused an adjustment, and the reasons given are as upsetting as in other years – “not fair to other students” (46 per cent), “requirement of the course” (42 per cent), “if you get this everyone will ask” (31 per cent), “calls into question your fitness to study” (29 per cent):

    I have been threatened repeatedly with ‘fitness to practice’ as my health condition deteriorated and really they should have been looking at ways to support me.

    It all has health impacts. Forty-one per cent report their physical health negatively affected by undertaking their course, 54 per cent report negative mental health impacts, and one in five have previously left, changed course, interrupted, or gone part-time specifically due to inaccessibility:

    My experiences in requesting support and adjustments on this course and getting it in a timely and acceptable manner, and sometimes not getting it, have been generally traumatic and have negatively impacted my mental and physical health.

    Why change is so hard

    I’ve banged on before here about the default framing of student-raised issues as the “nice to haves”. The cultural assumption is often that everything is OK, and that what students say in an SSLC or a survey is usually a great idea if we find the time or resource.

    I’ve also banged on before here about the problem with that framing when it comes to disabled students’ legal right to be able to access their education and not be put at a disadvantage to their nondisabled peers. These are not luxuries.

    But there’s no point just finger wagging. The pattern the data shows – cultural improvement outpacing systemic improvement – is not accidental. It reflects something structural about how universities work, and about the design of the reasonable adjustments model itself.

    Service quality research distinguishes between attributes that delight when present (satisfiers) and attributes that infuriate when absent (dissatisfiers). Staff attitudes, feeling welcomed, sense of belonging – these are satisfiers, and investment here shows results.

    Actually delivering agreed adjustments, physical access, working complaints processes – these are dissatisfiers, where absence causes harm but presence is simply expected.

    The sense is that the sector is investing in satisfiers while the dissatisfiers remain broken – but you can’t delight your way out of failing on fundamentals.

    A friendly lecturer who doesn’t implement your adjustments is still failing you, and the warm email from disability services doesn’t help if the support plan never reaches your department.

    There’s also an accountability vacuum. If we apply basic deterrence logic to a department that doesn’t deliver agreed adjustments, the question is – what’s the expected cost of non-compliance?

    Expected cost = Probability of detection × Magnitude of sanction

    Both for universities being regulated by EHRC and OfS, and for departments being regulated by their “centre”, I expect that the probability of detection is near zero – the system relies entirely on disabled students noticing, chasing, escalating, and only 17 per cent ever escalate. Of those who do, 47 per cent have nothing resolved.

    The magnitude of sanction is also zero – the report identifies no consequences anywhere, not for individual staff, not for departments, not for institutions.

    Hence expected cost = Near-zero × Zero = Zero.

    The rational institutional and departmental response is to ignore adjustment requests unless the student makes enough noise. That’s effectively what the data shows.

    We could interrogate the results from the perspective of basic quality management thinking. If that was being applied, we’d see the documentation of processes, monitoring of whether they’re followed, the tracking of failures, the implementation of corrective actions, and the reporting of patterns to management. That is what ISO 9001 certification would require – but I suspect is usually absent.

    If universities applied it to adjustment delivery, questions would arise. Is there a documented process for implementation at department level? Often no, because responsibility is “diffused across the institution with no single point of ownership.” Is delivery monitored? No – “only 15 per cent of providers have an established process for evaluating effectiveness,” according to OfS. Are failures tracked? No – the system relies on complaints most students don’t make. Does senior management see it? No – “accessibility competes with other priorities and loses.”

    If universities are, in effect, regulators of their own departments, there’s little evidence of an inspection function, poor definition and understanding of compliance standards, little monitoring data, and no consequences for failure.

    Power asymmetries run through the report. Disability services often can’t compel academic departments – they’re typically a service function, not a regulatory function, so they advise but don’t enforce. Academic departments have autonomy – disability services don’t have authority over them.

    So who does? A pro-Vice-Chancellor (Education)? Quality assurance? The report’s recommendation to “assign clear senior ownership” is exactly this – someone with actual power over departments needs to own accessibility and use that power. But that requires data flowing to them (it doesn’t), accessibility in their objectives (it usually isn’t), and willingness to have difficult conversations with heads of department (the path of least resistance is don’t).

    The strategic failure

    But the deeper problem goes beyond implementation to the model itself.

    If over 60 per cent of your disabled students need recorded lectures, that’s not an “adjustment” – that’s baseline provision failing. If a university is writing “extensions available” into thousands of individual support plans, it has designed inflexible assessment and is papering over it student by student. When disability services are spending their time on casework that could be prevented by better universal design, they’re deploying a specialist service as a workaround for systemic inaccessibility.

    The report notes that 87 per cent of declared disabled students have at least one adjustment agreed, but it doesn’t break down which adjustments are most common – though we know from sector experience that some provisions appear repeatedly, including slides in advance, recorded lectures, extra time, rest breaks, extensions, and quiet exam rooms. These are not niche accommodations for unusual conditions – they’re mass requirements being processed as individual exceptions.

    The Equality Act’s anticipatory duty requires institutions to plan ahead for reasonable adjustments, to anticipate the barriers students with various impairments will face and design them out. Most universities know how many disabled students they have and roughly what conditions they have, but few have a strategic analysis of what adjustments they’re making repeatedly, at scale, that could be converted to universal provision.

    As I argued with Meg Darroch back in 2022, this is where regulatory leverage could help. If providers were required to analyse their own adjustment data, identify high-frequency accommodations, and demonstrate plans to convert them to anticipatory provision, things could shift – but currently they’re not even collecting data in a way that would enable the analysis.

    The disability service is not solely responsible for disabled students – all staff are.

    The report quotes this student advice approvingly. But making that real requires more than cultural change – it requires systems that surface where provision is failing, that hold departments accountable, that convert repeated individual accommodations into universal design, and that push universities to act as regulators of their own practice with the monitoring, enforcement, and consequences that implies.

    Eight priorities

    DSUK sets out eight priorities for institutions:

    • Make delivery of agreed support non-negotiable – clear assignment of responsibility, monitoring mechanisms, rapid resolution routes, consequences for repeated failures
    • Create dedicated capacity to coordinate and monitor universal design – not in disability services or time-limited working groups, but embedded in quality assurance with power to influence design
    • Resource disability services to advise, not compensate – align staffing with demand, protect advisory time, clarify their role as partners in design rather than sole owners of access
    • Reduce administrative burden as a matter of access – minimise evidence requests, integrate systems, design processes that work when students are unwell
    • Make escalation safe, easy, and effective – clear information, no-penalty guarantees, systematic learning from complaints
    • Assign clear senior ownership and governance – named senior leader, integration into quality assurance and risk management, transparent reporting to governing bodies
    • Protect progress in times of financial pressure – prioritise low-cost high-impact actions, avoid rolling back what works, assess cost-cutting for disability impact
    • Measure what matters – delivery rates not just agreement rates, time to support, resolution of failures, departmental variation

    These are sensible recommendations, carefully framed to be achievable even under financial pressure. But they’re also familiar – the sector has been told what to do for years, and the question is what happens when institutions don’t do it.

    The regulatory gap

    The report is notably diplomatic toward regulators. It references OfS data showing only 15 per cent of providers have established processes for evaluating reasonable adjustments, but doesn’t call for regulatory intervention to change this. It notes that 40 per cent of OIA complaints come from disabled students, but doesn’t ask what EHRC or OfS should do about such a clear pattern.

    This restraint is probably strategic – DSUK works with institutions and needs constructive relationships. But someone needs to say the harder thing – the current regulatory posture is not working.

    OfS tracks outcomes – registration conditions could require monitoring of delivery rates, could mandate reporting to governing bodies, could set intervention thresholds. They don’t.

    EHRC has strategic enforcement powers that exist precisely for patterns of systemic failure across a sector, and 40 per cent of ombudsman complaints from one protected characteristic group is exactly that pattern. The Abrahart case established that duties don’t depend on students completing processes – has EHRC tested whether institutions are applying that principle? Where are the section 20 investigations?

    The deterrence literature is clear – credible threat of enforcement improves compliance even without widespread actual enforcement. One high-profile investigation, one regulatory intervention with real consequences, would shift institutional risk calculations across the sector. Right now the threat isn’t credible, and everyone knows nothing happens.

    The timing matters. Universities are making financial decisions right now that will shape disabled students’ experience for years, disability services are under pressure, and pandemic-era provisions are being reviewed. The report’s message – that cutting accessibility increases long-term legal and reputational risk – needs to land with governing bodies and finance directors, not just disability practitioners.

    But the harder question is whether anything structural will change. The sector has had reports, guidance, good practice examples, and legal clarifications for years, and while attitudes have improved, systems haven’t. The burden continues to fall on disabled students to make broken processes work.

    The blatant disregard for the Equality Act 2010 and the institution’s Public Sector Equality Duty is not merely an oversight – it is institutional discrimination. Where is the accountability? Where is the leadership upholding inclusion as more than a performative statement?

    That question deserves an answer. The report provides more evidence – what it can’t provide is the will to act, at institutional level, at regulatory level, at governmental level. It’s time for those in positions of power – both nationally and institutionally – to earn their big management bucks, diagnose the delivery issue in detail and deploy some meaningful strategy.

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