Disability Services for Students

High Schools: Section 504 of the Rehabilitation Act of 1973 requires school districts to provide FAPE to students with a disability in their jurisdiction. The district is required by law to identify the student's educational needs and to provide related aids and services to meet those needs.

Universities: Universities are not required to provide FAPE. They are required to provide the appropriate academic adjustments to ensure equal access to education.

High School: The applicable law is the Individuals with Disability Education Act (IDEA) which is about student success.

Universities: The applicable law is the Americans with Disabilities Act (ADA) which is about providing equal access.

High Schools: An Individual Education Plan (IEP) or 504 plan is used to determine academic accommodations. The school district provides the evaluation at no cost. The documentation focuses on determining whether or not a student is eligible for services based on specific categories in IDEA.

Universities: The IEP and 504 plan are typically not sufficient forms of documentation. The Evaluation Team Report (ETR) is the most helpful for those transitioning from high school to BW. Documentation guidelines are different and specify information needed for specific disability categories. Students may obtain an evaluation at their expense. Documentation must provide DSS with information on the functional limitations and demonstrate the need for the reasonable accommodation(s) requested. 

High Schools: Parents have access to student records, can contact teachers for progress or grades, can advocate for the student and participate in the accommodation process.

Universities: The parent does not have access to student records without the student's written consent per the Federal Education Rights and Privacy Act (FERPA). The student becomes a self-advocate and participates in the accommodations process. In addition, parents are no longer allowed to contact faculty for information about the student's progress in the course or grades.

High Schools: A plan is formulated for the student. Teachers receive a copy so they have a thorough understanding of the disability and accommodations. A yearly meeting is required of teachers and typically an auxiliary service person to discuss progress and set goals.

Universities: Instructors receive an emailed Letter of Accommodation (LOA) which outlines academic modifications the student needs to have equal access. Faculty does not have access to specific diagnostic data unless provided by the student. The student is responsible for meeting with DSS and instructors to discuss any areas of concern.

High Schools: The IEP or 504 plan may include modifications to test format, unlimited test time and grading. Testing in high school is often frequent, covering small amounts of material and teachers provide students with reminders of assignment due dates.

Universities: There is no unlimited time for tests and test format changes are not available. Accommodations on how tests are given (e.g., extended test time and a reduced distraction testing environment) are available when supported by documentation.

High Schools: Teachers may make modifications to the curriculum and alter the pace and due dates of assignments.

Universities: Professors are not required to modify essential academic requirements of programs and instruction that fundamentally alter educational programs or compromise academic standards. Additionally, BW does not waive essential program requirements or permit substitutions for courses deemed essential to its academic programs. Students are assigned substantial amounts of work that may or may not be addressed in the course. Students are responsible for reviewing class notes, texts and materials and submitting assignments by the due dates listed on their course syllabi.

High Schools: Tutoring and academic support may be services included in the IEP or 504 plan. There is typically someone who assists the student with self-management of tasks, assignments and priorities.

Universities: Tutoring and academic support services are not academic accommodations provided. It is the student's responsibility to make appointments and utilize available academic support services. BW has tutoring available for most subjects, but not all. Students are ultimately responsible for self-management; however, Academic Coaching is available as a resource to help with prioritizing and time management.

Self-Disclose

You need to disclose your disability to DSS by sending an email to disability@bw.edu. Under the ADA and the Rehabilitation Act, people with disabilities have a right to equal educational opportunities. By law, a student is not a person with a disability until he/she chooses to identify as such and request protection from discrimination. If a student does not disclose a disability and follow the process, he/she is responsible for the academic outcome.

Complete DSS Online Application

For students new to disability services, complete the application for accommodations using the Disability Services Online System. Please have your BW ID number and BW email address. If you have any questions please contact disability@bw.edu. 

Submit Appropriate Documentation

Current documentation of your disability and the disability-related need for any specific accommodation(s) being requested. Current documentation is necessary for verification purposes and to determine reasonable academic accommodations. The cost of the documentation is your responsibility.  

If you do not have documentation to upload during your application, you will receive an email with a documentation upload link. Please share this link with your diagnostician or healthcare provider, who can upload the documentation on your behalf. Also, documentation can be emailed to disabiity@bw.edu or sent to our confidential fax, (440) 826.3832. Please Note: Submission of documentation does not guarantee approval of the requested accommodation(s).    

Please use the general documentation guidelines and appropriate verification forms (located under forms, below) to assist in the documentation process. 

Attend a Student Welcome Meeting 

Upon receipt of the application and documentation, DSS will schedule a student welcome meeting. The purpose of the student welcome meeting is to discuss the impact, nature and functional limitations of the disability and to determine which, if any, academic accommodations are reasonable and appropriate. Appropriate accommodations are determined on an individual, case-by-case basis.

Please know that it can take one to five weeks to get started with DSS. This is based on a number of possible factors, including but not limited to: submission of appropriate supporting documentation, scheduling and attending the student welcome meeting, and timing of the request during the semester.   

View BW's accessible housing policy >>

Emotional support animal (ESA) policy for University housing

Emotional support animal (ESA) application form

View BW's service animal policy for University housing >>

To obtain appropriate information, please use one of the following verification forms based on your documented disability. A qualified healthcare provider or diagnostician should complete the form and fax it directly to the DSS confidential fax at (440) 826-3832. DSS reserves the right to request additional documentation.

Verification Forms:

• Attention Deficit/Hyperactivity Disorder (ADHD)
• Autism Spectrum Disorder (ASD)
• Emotional Support Animal
• Hearing Impairment
• Learning Disorder
• Mobility & Upper Extremity Impairment
• Neurological Disorder
• Physical Health Disorder
• Psychological Disorder
• Temporary Impairment
• Vision Impairment

Release & Exchange of Information Form

Disability Services for Students (DSS) is committed to ensuring that all information regarding students is maintained confidentially as required or permitted by law. Any information collected is used for the benefit of the students. This information may include psycho-educational testing, grades, biographical history, disability information, and case notes. Procedures for handling student information has been adopted by DSS and is rigorously followed by the staff of DSS. Students are informed of their confidentiality rights during the Welcome Meeting with DSS.

The DSS policies and procedures regarding confidentiality and the release of information from student files are listed below:

1. Student information obtained by Baldwin Wallace University shall only be shared with others within the Institution on a need-to-know basis. Only the disability services staff has immediate access to student files and records. For example, University faculty and staff do not have a right or need to access diagnostic or other information regarding students’ disabilities; they only need to know what academic adjustments, auxiliary aids, and/or services are necessary or appropriate to meet the disability-related needs of the students. If a student requests an academic adjustment, auxiliary aid, and/or service, the student will be informed as to what information is being provided to the faculty or staff regarding the request. To protect confidentiality by assuring limited access, all disability-related information must be filed within the Disability Services for Students office.
2. Information in files will not be released except in accordance with federal and state laws, which require release in the following circumstances. If a student:
   • States that they intend to harm themselves or another person(s).
   • Reports or describes any physical abuse, neglect, or sexual abuse of children or vulnerable adults within the last three years (this includes the occurrence of abuse or neglect to the student if he or she was under age 18 at the time of the abuse).
   • Reports the use of an illegal drug for nonmedical purpose during pregnancy.
   • Reports or describes sexual exploitation by counseling or healthcare professionals.
3. A student’s file may be released pursuant to a court order or subpoena.
4. A student may give written authorization for the release of information when they wish to share it with others. Before giving such authorization, the student should understand the information being released, the purpose of the release, and to whom the information is being released. Information will not be released without consent unless federal or state law requires it.
5. DSS will not release information to a student, outside agency, parent, etc. that was obtained directly from a third party (e.g., if documentation, records or information regarding a student is obtained directly from a physician, the information will not be released). The student, outside agency, parent, etc. will need to obtain the documentation, records or information directly from the third party who originally supplied the information.
6. DSS may charge a reasonable fee for costs incurred in connection with the copying of information.

Students with documented disabilities who are eligible for accommodated testing may request to have tests proctored in the accommodated testing room at the Learning Center in Ritter Library. Accommodations for testing may include extended time, use of a word processor for written exams, a scribe, a reader or a reduced distraction test environment. Not all students are eligible for all of these accommodations and they are determined on an individual, case-by-case basis as dictated by the documentation.

Students who wish to have tests accommodated in the accommodated testing room should submit their request in the time frame outlined in their LOA. The link to submit their request is emailed to students with their username and password. This link also is available on the DSS Blackboard site. Note: Same day requests for accommodated testing will not be approved, and a private testing room cannot be guaranteed.

Upon submission of the accommodated testing request, student and faculty will automatically receive an email confirmation. DSS will approve the request, as long as it meets the accommodated testing parameters. Last, faculty will complete an online testing contract, which provides DSS with proctoring information, test receipt and test return.

With appropriate notice, books will be made available in alternate format for students whose documentation of disability supports the need for alternate format. BW offers two ways to obtain alternate book formats:

1. Bookshare is a free service provided to students with visual and learning disabilities whose documentation supports the need for alternative text formats. Students need to complete the Bookshare application and submit it to DSS. DSS will add the student to BW's institutional account and submit the application to Bookshare. Bookshare will send the student an email with their username and password. Students can then search for their textbooks. It is strongly recommend that students have their book list, ISBN number, edition and the author's first and last name before they search. Bookshare also provides a free reader students can download.
2. If your books are not available on Bookshare, please submit an alternative text request through the DSS online system. 

Concussion Management Plan

Dining Services is committed to providing meal options that meet the needs of BW students. If you need dietary accommodations, please have your healthcare provider complete the Physical Health Disorder Form and send it to:
Charles Fairchild, Director of Auxiliary Services
Baldwin Wallace University
275 Eastland Road
Berea, OH 44017

For more information, contact:

• Charles Fairchild, Director of Auxiliary Services: (440) 826-2414 or cfairchi@bw.edu
• Marie Oravec, Registered Dietetic Technician: (440) 826-2348 or moravec@bw.edu

Emotional support animal (ESA) policy in University housing

Students with disabilities who need assistance with daily living activities or nursing care within a residential setting should retain the services of a personal care attendant (PCA). A PCA provides personal care or assistance in daily living activities, such as dressing, transferring to and from a wheelchair, feeding, personal hygiene and navigating the campus. PCA services may facilitate higher levels of independent access and participation in BW programs, services and activities. BW does not provide, coordinate or assume financial responsibility for PCA services.

The services of a PCA can play an important role in a student's quality of life. The selection of the right agency or individual and ongoing effective communication with the PCA is critical for a successful experience. Students who require PCA services must make arrangements to secure a PCA and must follow the policies, procedures and guidelines below:

Student Responsibilities

• Follow all applicable BW policies, rules, regulations and procedures.
• If the student wishes to reside in University Housing, the student should follow the accessible housing process and provide documentation that supports the medical necessity of a PCA.
• Secure an agency-affiliated or private, certified PCA before attending any University-related activity (i.e., placement testing, enrollment, class attendance). BW will not be responsible for providing a PCA on an interim basis.
• Provide documentation that the PCA is qualified to perform the services.
• Ensure that the PCA registers with DSS, the department of safety and security, residence life and health services.
• Provide a copy of the contract between the student and the agency or PCA to DSS.
• Ensure any PCA personnel changes are registered with DSS, the department of safety and security, residence life and health services.
• Direct the activities of the PCA while at BW. The student is solely responsible for ensuring the PCA is fulfilling his/her responsibilities for the student's care. BW will not assume responsibility for the PCA or his/her failure to fulfill the contracted responsibilities.
• Develop an alternative plan of action should the regularly assigned PCA not be available to work.
• Pay for all PCA services, including but not limited to housing and meal plans if living off campus.
• Students are encouraged, but not required, to select a PCA of the same gender if the PCA will be assisting a student with bathing or toileting in a residence hall or shared or public area restrooms.

PCA Role in Campus Life

• The PCA assisting a student on campus is required to follow all applicable BW policies, rules, regulations and procedures.
• The PCA may assist the student before and after class as needed but should wait outside the classroom unless assistance during class is deemed appropriate or necessary and approved by DSS.
• It is generally inappropriate for the PCA to have contact with or ask questions of faculty, staff or others on behalf of the student. It is not within the scope of the PCA's responsibilities to be involved in the student's academic life on campus.
• The PCA should respect the dignity and privacy of the student and refrain from discussing confidential information about the student with faculty, staff or other students.
• The PCA is only allowed to access the student's residence hall while the student is in residence.
• If the PCA violates BW policies, rules, regulations or procedures, DSS may determine that the PCA may no longer assist the student on BW's campus. If this occurs, it is the student's responsibility to secure the services of another PCA.

View BW's reduced course load policy >>

View BW's service animal policy >>

TEMPORARY IMPAIRMENTS

DSS provides reasonable assistance to students with temporary impairments such as injuries or acute illnesses which may require temporary classroom support. According to the Americans with Disabilities Amendments Act of 2008, temporary impairments are not considered a disability as they do not rise to this level as outlined by the ADA due to the duration (generally six months or less) of symptoms or functional limitations.

Documentation is required, and reasonable assistance is determined based on the nature of the impact of the temporary condition on an individual basis. Note: Transportation services are not provided.

Students with temporary impairments and interested in seeking accommodations must complete the required steps to apply for accommodations and have their physician complete and fax the Temporary Impairment Verification Form to (440) 826-3832.

Jacket Access Van

The Purchasing Motor Pool Department provides limited transportation services for students registered with Disability Services for Students (DSS) that have motor limitations or other conditions that significantly affect their ability to travel around campus during extreme weather conditions.

Request a Letter of Accommodation (LOA) at the beginning of each term so you can begin utilizing your accommodations early. The LOA is sent on your behalf as a student with a disability who may need accommodation in order to have equal access. It is sent because you have a potential need for accommodation. Even after accommodations have been approved based on a careful review of your disability file, you can choose not to use the accommodation(s). Because BW cannot force you to use accommodations, the responsibility for requesting the LOA is placed in your hands. Professors will not grant you any academic accommodations without your LOA. To ensure your LOA is received, it is emailed to you and the faculty.

Schedule a private meeting with your course instructors to discuss your LOA detailing the approved accommodations for the semester. The meeting should take place in a private setting to maintain confidentiality. Be clear and factual. Note: You are not required to disclose or discuss the specifics of your disability. It is your decision whether you want the professor to know your diagnosis.

Address the specific arrangements of your approved accommodations, for example:

• If you receive extended time on quizzes and examinations, discuss how the scheduling will be handled. Will you take the exam with the class or in the Accommodated Testing Room?
• If you have a class immediately after, will you need to determine an alternative time to take the test?
• If you will take your quizzes and examinations in the Accommodated Testing Room, discuss the process for scheduling your tests.
• If you will be recording lectures, provide the professor with a signed copy of the recording agreement form.
• If you need a volunteer note-taker, discuss how you would like to receive the notes and how you will provide paper.
• If you receive preferential seating, where do you prefer to sit and how will the seat be reserved?

If you DO NOT schedule a meeting, it will be assumed that you have chosen NOT to utilize your accommodations for the term. Your development as a student is very important to BW's mission, vision, policies, practices and procedures. It is in your best interest to learn self-advocacy in how to shoulder the responsibility of managing your own accommodation needs. It will be a lifelong challenge to advocate and support your own success.

Qualified students with disabilities have the right to an equal opportunity to participate in programs offered at BW. Students who choose to exercise these rights have the responsibility to initiate and participate in the accommodation process. Recognizing this, students:

1. Have a responsibility to self-identify as needing accommodation in a timely fashion. The student must provide documentation from an appropriate licensed professional.
2. Have a responsibility to document how their disability affects a particular delivery system, instructional method or evaluation criteria when requesting accommodation.
3. Have a responsibility to actively participate in the search for accommodations and auxiliary aids.
4. Have the responsibility of submitting a request for LOAs and scheduling meetings with instructors to discuss approved accommodations.
5. Have the responsibility to communicate to professors their individual needs and work with them on methods of accommodation.
6. Have the responsibility to schedule proctored exams in a timely manner.
7. Have the same obligation as any student to meet and maintain the institution's academic and technical standards.
8. Have a right to be evaluated based on their ability, not their disability. If their disability affects the outcome of an evaluation method, they are entitled to an evaluation by alternate means.
9. Are entitled to an equal opportunity to learn. If the location, delivery system or instructional methodology limits their access, participation or ability to benefit, they have a right to reasonable adjustments, to be determined by University officials, in those aspects of the course or program to accommodate their disability.
10. Are entitled to an equal opportunity to participate in all aspects of the academic community at a comparable level that is provided to any student.
11. Have a right to appeal decisions concerning accommodations.

Under the Americans with Disabilities Act (1990) and Section 504 of the Rehabilitation Act (1973), a person has a disability if he or she has a physical or mental impairment that substantially limits one or more of his/her major life activities (e.g. walking, standing, seeing, speaking, hearing, breathing, learning, working or taking care of oneself), has a record of such an impairment, or is regarded as having such an impairment. Once admitted to BW, students may choose whether or not to disclose a disability. However, students with disabilities will not receive accommodations unless they disclose their disability to DSS (Erin Kelley or Alsace Toure), make a formal request for accommodations (application, documentation and student welcome meeting) and follow the University procedures for obtaining accommodations.

Baldwin Wallace University has a right to maintain academic standards, integrity and freedom. This includes determining fundamental requirements of courses and programs, maintaining and enforcing conduct codes.  Fundamental requirements include:

• Academic requirements that are essential to programs and instruction (e.g. spelling for teacher education, math for engineering majors). 
• Accommodations should not fundamentally alter educational programs or compromise academic standards. 

Baldwin Wallace University has a responsibility of providing the following to a qualified student with a disability:

• Equal access to educational programs, services, facilities and activities
• Reasonable accommodations, academic adjustments and/or auxiliary aids and services
• Written policies and procedures (including grievance).

Baldwin Wallace University is committed to ensuring that no otherwise-qualified individual with a disability is excluded from participation in, denied the benefits of, or subjected to discrimination in University programs or activities due to his/her disability. The University is fully committed to complying with all requirements of the Americans with Disabilities Act as amended, and Section 504 of the Rehabilitation Act, and to providing equal educational opportunities to otherwise-qualified students with disabilities. 

To that end, the University has established a four-step internal grievance procedure that is designed to achieve an equitable resolution within a reasonable amount of time. A University student who believes that he/she has been subjected to discrimination on the basis of disability, or has been denied access or accommodations required by law, shall have the right to invoke the grievance procedure.  The grievance procedure is intended to address disputes regarding requested services or accommodations or modifications to University practices or requirements. 

The grievance procedure shall not supersede or replace any existing University dispute resolution policies and procedures. Students are encouraged to consult with the Director of Disability Services or respective designees regarding the most appropriate University policy or procedure to address a particular concern.  All forms are available in the DSS portal page. 

Step One: A student may bring a discrimination concern or appeal a denial of an accommodation request by submitting the Step One Grievance Form to the disability specialist for his/her consideration.

Step Two: If the matter remains unresolved after step one, either the student or the disability specialist may submit the matter to the director of disability services for a prompt and informal resolution. If the informal resolution arrived at by the director is unsatisfactory to the student, the student may file a formal Step Three Grievance Form. 

Step Three: This request for a step three review must be filed within five (5) business days of the denial of or lack of resolution of the step one grievance. The director of disability services will then investigate the matter and issue a written decision within ten (10) business days after receiving the grievance. The director and the student may mutually agree on an extension of time if additional information gathering is necessary or some other unforeseen delay arises.  

Step Four: If the student wishes to challenge the step three written decision of the director of disability services, he/she has a right to file a step four grievance with the provost. In order to begin this process, the student must complete the Step Four Grievance Form. 

A Step Four Grievance Form must ordinarily be filed no later than thirty (30) days after the date of the step three written decision of the director of disability services. The provost reserves the right to refuse to investigate a step four grievance that is filed more than thirty (30) days after the date of the written decision of the director of disability services. 

Upon receipt of a timely step four grievance, the provost or his designee shall investigate the matter. Investigation will ordinarily involve interviewing relevant individuals and reviewing reasonably available documents. 

Upon completion of the investigation, the provost or designee will issue a written determination to the student and the director of disability services which will specify findings, and, if appropriate, set forth the resolution of the matter.  Such written determination shall ordinarily be issued within thirty (30) days of the date of the step four grievance.  Circumstances which may prolong the response of the provost or designee include the intervention of a semester break and such other circumstances which may render unavailable persons necessary to an appropriate resolution of the complaint. 

The provost or designee shall maintain files and records relating to all step four grievances. The right of the student to an equitable and timely resolution of a filed grievance shall not be impaired by his/her pursuit of other remedies such as the filing of a complaint with the responsible federal or state department agency. 

Office of Civil Rights (OCR) Complaint
Although students are encouraged to attempt to resolve complaints pertaining to disabilities by using this grievance procedure, they have the right to file a complaint directly with the U.S. Department of Education, Office for Civil Rights (OCR):  United States Department of Education, Office of Civil Rights, Cleveland Office, 600 Superior Avenue East, Suite 750, Cleveland, Ohio 44114-2611. Phone: 216.522.4970, Fax: 216.522.2573, Email: OCR.Cleveland@ed.gov.

Below are some recommendations on how families can help their student with the transition to university life. 

1. Upon admission to BW, encourage your student to follow the steps for "Applying for Accommodations" outlined above.
2. Once your student receives the email from DSS to schedule the Student Welcome Meeting, encourage him/her to schedule it as soon as possible. Many appointments occur the Friday before summer orientation or the first week of classes. During the Student Welcome Meeting, your student will meet with a DSS staff member to discuss the functional limitations of his/her disability and any appropriate accommodations. Your student will also learn how to access available resources. If you accompany your student to the meeting, you will be allowed in after we have talked to your student privately.
3. Once any accommodations have been approved, it is your student's responsibility to utilize the services and follow the process, policies and procedures.
4. Due to FERPA regulations, BW faculty and staff cannot answer questions about your student's course progress or grades. You should formulate a plan with your student for communicating course progress and grade information to you throughout the semester.
5. Encourage your student to be an active participant in his/her educational experience. This requires that your student is both responsible and accountable. You can foster independence and responsibility by encouraging your student to:
6. 1. Check his/her BW email account 2-3 times each day. Most communications from the University, faculty and staff will go to BW email.
   2. Respond to email in a timely manner. Since email is the primary form of communication, students need to develop a habit of communicating electronically. It is helpful if those communications include the student's first and last name, BW ID number, a greeting or salutation and spell check.
   3. Schedule meetings with his/her professors to discuss questions about assignments, difficulty with course content or concerns about his/her progress in the course.
   4. Schedule meetings with his/her academic advisor(s) each semester. Students need to meet with their academic advisor to be released for registration and to discuss dropping classes, if needed.
   5. Become familiar with and utilize campus resources. If your student is upset or having academic difficulty, advise that he/she seek out resources on campus, including faculty, academic advisors, Disability Services, Counseling Services, the Learning Center, Residence Life, Registration & Records or Dean of Students.
   6. Maintain contact with DSS throughout the academic year. This includes following processes, policies and procedures. Review the Student Handbook to be aware of and comply with University policies, practices and procedures. It is also helpful in understanding BW community and University culture.
   7. Become a self-advocate regarding his/her disability. Students need to be aware of their disability and their functional limitations and then develop appropriate coping strategies.
   8. Continue taking medications as prescribed. Many students suddenly stop their medications which can negatively impact their physical, mental health and academic success.

6. If your student is a commuter, encourage him/her to stay on campus instead of returning home between classes. This will help him/her become part of the BW community and provide an opportunity to seek helpful resources.

There are many free resources available to families of students with disabilities. Here are a few that DSS recommends: 

Online Resources

• Auxiliary Aids and Personal Services
• BW Speech Clinic
• Preparing for Post-Secondary Education
• Open Letter from Jane Jarrow A disability services expert shares her insight and concerns as her daughter prepared to enter college.
• Summer Opportune Time to Support Students with Disabilities Transitioning to College An article by Alsace Toure, director of disability services at BW. 
• Tips for Students with Disabilities to Increase College Success Article from the University of Washington

Books

• College to Career Road Map: A Four-Year Guide to Coaching Your Student (Parent Edition) by Terese Corey Blanck, Peter Vogt and Judith Anderson (Paperback - Aug. 25, 2006)
• Letting Go (Fifth Edition): A Parents' Guide to Understanding the College Years by Karen Levin Coburn and Madge Lawrence Treeger (Paperback - Mar. 17, 2009)
• Ready for Take-Off: Preparing Your Teen With ADHD or LD for College by Theresa E. Laurie, Ph.D. Maitland and Patricia O., M.D. Quinn (Paperback - Nov. 2010)
• Guiding Teens with Learning Disabilities: Navigating the Transition from High School to Adulthood by Arlyn J. Roffman (Paperback - Sep. 4, 2007)
• The Parent's Guide to College for Students on the Autism Spectrum by Jane Thierfeld Brown, Lorraine Wolf, Lisa King, G. Ruth Bork (Paperback - Jan. 2012)