It is important that students with disabilities are not excluded from theological education, or put at a disadvantage, as a result of their disability/ies. There are clear ethical and theological reasons for this, but it is also a legal duty.
The Equalities Act 2010 defines disability as any ‘physical or mental impairment’ that has ‘a substantial and long-term adverse effect’ on a person’s ability ‘to carry out normal day-to-day activities.’ Here ‘substantial’ means anything that is not minor or trivial, and ‘long-term’ means something that lasts twelve months or more. In a theological education context, we can take this to refer to any condition that, when combined with the way that education is currently provided, has a substantial, long-term negative impact on a student’s ability to access learning, participate fully in the educational process, or demonstrate the learning they have acquired.
Disabilities may include mobility issues, mental-health-related conditions, specific learning differences (for example, Dyslexia or ADHD), autism, long-term medical conditions and more.
The Equalities Act places an obligation on organisations (universities and Theological Education Institutions included) to make ‘reasonable adjustments’ to their provision, criteria and practices, so as to remove the barriers that would otherwise exclude or disadvantage disabled students.
The notes below are not legal advice, but pointers to some of the considerations that staff and students at TEIs should take into account when exploring reasonable adjustments.
No. Not everyone who meets the definition of ‘disabled’ under the Equalities Act will have a formal medical diagnosis. There can be many reasons for that, including the time it can take to secure such a diagnosis, the cost, and the stigma that can often be attached to the process. All that is needed is for a TEI to be reasonably confident, on the basis of the evidence that they have seen, that a student’s condition is having or could have a substantial impact on their ability to access and participate in their educational programme.
It is important that TEIs policies on reasonable adjustments and support for disabled students are not restricted to those with a formal medical diagnosis.
No. If staff observe that a student is experiencing difficulties in accessing or participating in their educational programme, that in itself is enough to trigger the duty to explore reasonable adjustments. That doesn’t mean that staff have to be experts in diagnosing disabilities, but all staff (including teaching staff) do need to be on the lookout for signs that students are struggling with the activities and requirements of their courses, and to be proactive about ensuring that those difficulties are followed up. The Equality and Human Rights Commission released guidance on this in 2024. We would draw your attention to paragraphs 10 to 15 in particular.
Legally, the duty to make reasonable adjustments is also an anticipatory duty. That means that TEIs also have a duty to anticipate likely needs, and to make their provision as broadly accessible as possible, so as to be ready for students with disabilities, and not leaving disabled students always having to ask for adjustments, or allowing disabled applicants to be put off by an institution that does not yet appear to be ready for them. So, for instance, venue accessibility should be a consideration, and there should normally be plans or provision in place, whether or not any particular wheelchair user has yet needed to access that venue.
Note, however, that institutions need to tread carefully here. This duty to take anticipatory action shouldn’t lead to the blanket removal of course requirements, and needs to be understood in relation to the need to uphold academic standards – as explained in §4 below.
What is reasonable may well differ from student to student, and context to context. In general, an adjustment may not be considered reasonable if it would be prohibitively expensive or highly impractical for the institution involved. When a TEI is making judgments of this kind, however, it is a good idea to ask whether, were a student to appeal the decision not to make an adjustment, an independent panel eager to see disabled students supported, but in possession of all the relevant information, would be likely to agree with the TEI’s judgment about expense or practicality.
There is no legal duty to make reasonable adjustments to anything that is a genuine ‘competence standard’ for an educational programme. So, for instance, if a student is taking a maths degree, there’s no duty to make any reasonable adjustment that would effectively mean that a disabled student didn’t need to demonstrate the same level of mathematical ability as other students.
Great care is needed when relying on this point, however. Something is a ‘competence standard’ only if it is an inherent part of the learning that a student needs to have in order to gain the qualification for which they are studying. And, as the Equalities and Human Rights Commission have clarified, in the light of recent legal rulings, ‘Methods of assessment, by which we mean the manner or mode in which a student’s level of knowledge or understanding or ability to complete a task is tested, will rarely, if ever, amount to a competence standard.’
So, for instance, a student at a TEI might be required to demonstrate certain kinds of knowledge of the Bible, and that might well be an inherent part of their Common Awards qualification (and so count as a competence standard). The ability to demonstrate that knowledge specifically by writing an essay, say, is a method of assessment, and not a competence standard – and so those methods can be subject to reasonable adjustments.
There is, nevertheless, a complexity here. The Office for Students in 2021 published guidance on ‘Assessment practices in English higher education providers: Spelling, punctuation and grammar’, indicating that, in their view, proficiency in written English is likely to count as a competence standard for most Higher Education courses. Most Common Awards programme specifications list communication skills amongst the programme learning outcomes, and the OfS guidance suggests taking that to include skills in producing written English. If a TEI wishes to make reasonable adjustments that would lead to the removal of most or all assessment of written English across a whole programme for any given student, they should contact us in advance for advice.
More generally, the programme learning outcomes set out in the Common Awards programme specifications are a good initial guide to what might plausibly count as a ‘competence standard’ for those programmes.
There is no exhaustive list of reasonable adjustments. Any aspect of a TEI’s provision that serves as a barrier to disabled people or places them at a disadvantage, from staircases to PowerPoint slides, might need to be adjusted. While TEIs have a duty to anticipate likely needs and make general adjustments in the light of then, it will often only be careful conversation with the student that will reveal the specific adjustments that they need. TEIs should take student requests very seriously. Reasonable adjustments might include (though they are certainly not limited to) the following:
This is a just a sample of the available strategies. For other ideas, see Stephen Campbell, Supporting Disabled Students in Higher Education: The Reasonable Adjustments Handbook (Routledge, 2023) – available via the Common Awards Hub. You can also watch our 2025 webinar with Stephen.
Where a TEI judges that their standard form of assessment in a module creates an obstacle for a student with a particular disability, it is often possible to design an alternative assessment as a reasonable adjustment.
The alternative assessment will need to enable the student to demonstrate to markers that they have met the same learning outcomes as students taking the standard assignment, to broadly equivalent levels of depth and breadth. The TEI will therefore need to ask themselves exactly which learning outcomes for the module (as set out in the module outline) the assessment in question normally allows them to assess, and then consider what kind of alternative assessment will enable markers to assess the same outcomes, with broadly similar confidence and discrimination.
Note that, if a TEI thinks that the learning outcomes in a particular module outline are blurring the boundary between ‘competence standards’ and ‘methods of assessment’, as explained in question 4 above – i.e., if the learning outcomes seem to be demanding certain assessment activities, but those activities don’t really seem to be essential to the learning the module is aiming at – please contact us on the Common Awards team for advice.
Note that questions about whether the alternative assessment will involve the same amount of work as the standard assessment are secondary: TEIs are not measuring how much effort the student puts in, or how hard the assignment is in some abstract way, but whether the relevant learning outcomes have been met to broadly equivalent levels of breadth and depth. It is, however, obviously important that students with disabilities are not disadvantaged by being set work which would demand more of their time than is allowed in our learning hours policy.
Where TEI staff deem that such a reasonable adjustment is necessary, they should ensure that the Chair of the TEI’s Board of Examiners agrees, and then seek the approval of the TEI’s External Examiner, in advance of offering the revised assessment to the student. The setting of any alternative assessments should also be reported at the next meeting of the TEI’s Board of Examiners. Where the External Examiner is not available, TEIs can seek approval from the Common Awards Team.
See our Templates and Forms page for a template form for TEIs to use when considering alternative assessments as a reasonable adjustment.
Where a TEI has identified students as having a disability that can affect their written English, reasonable adjustments for those students can include refraining from penalising them for errors in their written English, provided those errors do not compromise the students’ achievement of the module’s learning outcomes.
The fact that the errors must not compromise the students’ achievement of the learning outcomes does impose some limits on this adjustment. Most obviously, errors that detract from the student’s demonstration of the knowledge and understanding or cogency of argument required by the module must still be taken into account in marking.
Or again, where a written assignment is intended to demonstrate a student’s ability to communicate with a wider audience, errors that detract substantially from that communication should still be taken into account. If, for instance, students were asked to write an article for a parish magazine, the assessment task could reasonably involve learning to ensure that the article was free from serious errors of presentation, spelling, and grammar. In such a case, it would be a more appropriate adjustment to give students with relevant disabilities access to the tools and support they need to achieve that outcome, rather than to mark their work differently from that of other students.
In other words: all reasonable adjustments made by the TEI need to take into account both the students’ needs and the purpose of the assignments that the students have been set.
Note again, however, that if a TEI thinks that the learning outcomes in a particular module outline are blurring the boundary between ‘competency standards’ and ‘methods of assessment’ (as explained in question 4 above) – i.e., if the learning outcomes seem to be demanding certain assessment activities, but those activities don’t really seem to be essential to the learning the module is aiming at – please contact the Common Awards team for advice.
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