Does Section 504 require single‐room accommodations?

Abstract

Even before COVID‐19, higher education institutions had seen a rise in requests for single‐room accommodations for anxiety, observing that, given the choice, most students, with or without a disability, would prefer a room of their own to a double room with a roommate, particularly when offered at a reduced rate. But now, spurred by fear of COVID‐19 as well as by emotional and psychiatric disorders, even more students appear to be seeking single‐room accommodations, supported by letters from health care providers that diagnose various emotional or psychiatric disabilities and identify some therapeutic or privacy‐based benefit that a single room may provide. In considering these no‐roommate accommodation requests, institutions should review whether and, if so, when Section 504 regulations require single rooms as a disability accommodation. Surprisingly, Office for Civil Rights letters don't answer that question.