AMERICANS WITH DISABILITIES ACT ACCOMMODATION REQUEST POLICY

ADA Policy

As of June 25, 2012

Purpose

FGTA, LLC d/b/a Epson Tour (the “Tour”) is committed to eliminating discrimination against individuals with qualified disabilities, as defined by the Americans with Disabilities Act (“ADA”), and seeks to assure equality in the provision of services, activities and programs to all Tour constituents. In that spirit, the Tour will work cooperatively with those individuals who make timely requests for accommodations at Tour-controlled places of public accommodation.

Procedures for Evaluation of ADA Accommodation Requests
1. Accommodation Request. An individual may submit a request for an accommodation, due to an asserted disability, to the LPGA Legal Department, ATTN: Matt Cornwell, 100 International Golf Drive, Daytona Beach, FL 32128 (or matt.cornwell@lpga.com). Each accommodation request shall include:

(a) Individual’s name, mailing address, contact phone number, fax number, and e-mail address;
(b) Exact nature and extent of the individual’s asserted disability (medical information may be requested);
(c) Major life activity(ies) substantially limited by the asserted disability and related functional limitations;
(d) A detailed description of the requested accommodation and place of public accommodation; and
(e) The individual’s signature, or that of her designee or legal representative.

Accommodation requests must be made with sufficient advance notice (minimum 30 days) to permit a thorough evaluation, including potential medical records review, prior to the Tour rendering a decision. Please note that the Tour shall have no obligation to render a decision on last-minute accommodation requests. The Tour will only grant an accommodation on a case-by-case basis, after an individualized analysis of the request and surrounding circumstances. No “blanket” accommodation requests will be granted based upon “classes” of disability or apply to multiple Tour controlled public venues.

2. Tour Information Review & Privacy Waiver. After the Tour reviews the individual’s accommodation request, it will communicate with such individual in order to better understand the accommodation request, discuss possible accommodations, and request additional medical records and documentation (which shall be prepared by a licensed medical professional within the same calendar year as the accommodation request), explanations regarding the recommended accommodation(s)
and resulting impact on impairment, historical description of accommodation(s) provided in other places of public accommodation, or other information, as necessary to verify the asserted disability and identify associated functional limitations. The individual must review and sign the “Consent, Release, and Waiver,” a document granting the Tour and its designated medical professional permission to review such individual’s medical records and/or other information; otherwise, the request for accommodation process will cease.

3. Determination of Whether Individual is Disabled under the ADA. Provided that the individual signs the Consent, Release, and Waiver document, the Tour will forward the individual’s medical documentation and other applicable documents to an experienced medical professional for review and evaluation. The medical professional may request additional information, including, without limitation, medical documentation, examinations and/or opinions, as necessary to evaluate the
individual’s asserted disability. The medical professional will not complete her evaluation until she receives all relevant information. Once the medical professional completes her evaluation, she will send an evaluation report back to the Tour, indicating whether the individual is disabled within the meaning of the ADA.

NOTE: If the individual has already previously gone through the accommodation request process with the Tour with regard to a different Tour-controlled place of public accommodation, the Tour need not re-evaluate whether the individual is disabled within the meaning of the ADA, unless such individual asserts a different disability than previously asserted.

4. Determination of Reasonableness of Accommodation Request. If the Tour determines that an individual is considered disabled within the meaning of the ADA, the Tour will next consider whether such individual’s requested accommodation is reasonable on its face, in relation to the disability and the nature of the accommodation request. Specifically, the Tour will determine whether the requested accommodation for the particular individuals’ disability and medical background would be reasonable under the circumstances (case-by-case basis) and necessary for that particular individual. In making this decision, the Tour will analyze the likely undue burdens or hardships arising from the individual’s requested accommodation(s), the likely impact on the impairment arising from the requested accommodation(s), and whether the requested accommodation(s) would fundamentally alter the nature of the service, activity or program.

5. Grant or Denial of Accommodation Request. After the Tour analyzes the reasonableness of the individual’s accommodation request, it will inform the individual whether it will grant or deny her accommodation request or whether it will grant an alternative accommodation (processing time depends on the nature of the accommodation, whether it is necessary to obtain supporting documentation, and other factors). If granted, the accommodation letter shall state specific accommodation parameters, and include the relevant period of effective accommodation. If denied, the denial letter will contain specific reasons for denying the individual’s requested accommodation (including, without limitation, such reasons as individual is not disabled within the meaning of the ADA, medical documentation is inadequate to establish that the individual has a disability and/or needs a reasonable accommodation, an undue hardship exists, etc.).

6. Confidentiality. The accommodation request process will be treated in a strictly confidential manner. All medical information obtained in connection with the accommodation request process shall be kept confidential, and used solely to determine the individual’s eligibility for accommodations under the ADA.