Universal Orlando Stops Requiring Controversial Disability Access Card
Universal Studios Florida and Islands of Adventure (and, presumably, Hollywood) theme parks have once again changed their disability access policies and requirements for the second time in just over a year. This covers the new policy along with a brief recap of what’s led to this and commentary about the possible motivations, as well as how this compares with Walt Disney World’s new approach to DAS.
Back in July 2023, Universal Orlando and Universal Studios Hollywood overhauled their Attraction Assistance Pass (AAP). They began requiring guests who requested attraction queue accommodations to apply for a special card known as the Individual Accessibility Card (IAC) prior to their visit in order to qualify for an Attraction Assistance Pass.
This was done in partnership with the International Board of Credentialing and Continuing Education Standards (IBCCES), which is an organization that provides training and certification for professionals working with autistic and neurodivergent individuals or those with other disabilities. IBCCES was controversial from the outset, or perhaps polarizing is more accurate. We heard from many readers who loved the IBCCES system, whereas others hated it. There seemed to be very little middle ground–it was typically one of the extremes. (At least, based on feedback we received.)
To receive the Individual Accessibility Card, guests with disabilities must submit a photograph and documentation from a medical provider, governmental group, or school district detailing the type of accommodations requested. Guests did not need to provide medical records, private identifying information, or other documents protected under HIPAA.
However, the process must be completed at least 48 hours before arrival at a Universal theme park. Once the prerequisites for the Individual Accessibility Card are satisfied, Team Members from Universal contact the cardholder to discuss specific accommodations and whether they’d qualify for the Attraction Assistance Pass.
Contrary to some misconceptions, receipt of IAC does not mean automatically receiving AAP. Eligibility is still determined on a case-by-case conversation. Prior to this change in July 2023, the Universal system was one of self-attestation, similar to the previous one at Walt Disney World.
Fast forward to Fall 2024, and the IAC is now an option as opposed to mandatory. Meaning that Universal guests may obtain the IBCCES Individual Accessibility Card (IAC) within 30 days of their visit to the park, but are not required to do so.
As first reported by TouringPlans, guests who do not have the IAC now can still receive an AAP. Guests whose disability prevents them from waiting for extended periods in a conventional attraction queue environment may visit Guest Services inside the parks in-person on the day of their visit and talk with a member of the Guest Accessibility Team about attraction queue accommodations and receiving the AAP.
If guests do opt to pre-register, it sounds like the process is more streamlined. Upon arrival at the park, the approved IAC cardholder will present the approved IAC to Guest Services in a dedicated IAC fulfillment location to receive their attraction queue accommodation. This should offer a time-savings as opposed to going through the same-day process in-person at Guest Services.
If this is anything like Disneyland–where lines are still long most mornings for the converted ticket booths that now serve as Accessibility Services locations–guests will be incentivized to stick with IBCCES to save themselves time. It’ll also make for more predictable planning and fewer headaches. That is, assuming Universal Team Members scrutinize the same-day requests, and they may not!
Universal has other options for accommodations, which you can read about on the Accessibility Information page on Universal Orlando’s official website.
As we noted while covering Disney’s DAS overhaul that occurred this summer, Walt Disney World and Disneyland do not use the IBCCES Individual Accessibility Card despite this becoming somewhat of an industry standard. It’s not just Universal–many other amusement and theme parks have switched to IBCCES (here’s a full list of participating parks).
However, IBCCES has not been without controversy. There has already been a lawsuit in the U.S. District Court for the Eastern District of California involving IBCCES: I.L. v. Six Flags Entertainment Corp. et al. This complaint alleges violations of the Americans with Disabilities Act and the California Disabled Persons Act, and seeks class action status.
Among other things, the lawsuit contends that using IBCCES violates the ADA’s implementing regulation, and the documentation requirement is burdensome and cannot reasonably be met by all persons with an ADA-qualifying disability. It further contends that being required to disclose sensitive personal information and provide private medical documentation in support of accommodation requests to a private, for-profit company violates the ADA.
The complaint also alleges that Six Flags’ use of IBCCES violates the ADA because of the pre-screening process for accommodation requests, which includes advance registration and documentation requirements. That prevents disabled persons from using and enjoying the amusement parks in the same manner that nondisabled persons may do so. Non-disabled guests visiting Six Flags may purchase their tickets for admission on the same-day and they may then enter the parks and enjoy all the benefits on offer spontaneously, without any advance planning or preparation.
There’s a lot more to the 57-page complaint, but those are the salient arguments. Given Universal’s change as of Fall 2024 that essentially rolls back their use of IBCCES, it strikes me as possible–if not likely–that their legal team evaluated the complaint and determined they needed to make modifications to their accessibility process or risk being named in a similar lawsuit.
This is exactly what these changes accomplish: shielding Universal from litigation. Were a substantially-similar suit filed today against Universal, the company would prevail as a result. That’s likely the key motivation in making IBCCES optional, but still strongly recommended (while also not broadcasting the changes too loudly).
This is pretty much exactly what we said when Disney rolled out its changes to DAS earlier this year.
Not wanting to be on the losing side of ADA cases, my suspicion was that Disney Legal performed litigation risk assessments on IBCCES and steered the DAS overhaul in a different direction as a result. The latest changes to DAS will almost certainly give rise to more litigation, regardless. Accessibility changes inevitably do, and it’s likely Disney’s perspective that it’s the cost of doing business.
But I’d also expect Disney to prevail in any such lawsuit, as Disney Legal is meticulous and likely had an extensive role in crafting the new DAS policy to be ADA-complaint. I also wouldn’t be surprised if the next DAS overhaul (however many years down the road that might be) does involve IBCCES, should Six Flags prevail in the aforementioned litigation. All of this is purely speculative on my part, though.
That likely explains why the changes to Disability Access Service were delayed, as well as Disney’s decision to partner with Inspire Health Alliance as opposed to IBCCES. It’s also presumably why DAS still offers options upon arrival on both coasts (a more robust day-of system in Disneyland could be due to that litigation, California laws, or Disneyland’s disproportionately local demographics–or a combination of all three).
Of course, this is not to say that Disney’s new system is perfect–or anything remotely of the sort. Only that it was likely drafted with the goal of making it litigation-proof. As is well-documented at this point, the DAS overhaul has been incredibly controversial with Walt Disney World and Disneyland fans.
There are countless sad stories of disabled guests being denied accommodations that they ostensibly need, and each week seems to bring a new such account that goes viral on social media. I won’t pretend to know what the “perfect” solution is, but I do know that the status quo is heartbreaking.
Need trip planning tips and comprehensive advice for your visit to Central Florida? Make sure to read our Universal Orlando Planning Guide for everything about Islands of Adventure and Universal Studios Florida. Also check out our Walt Disney World Vacation Planning Guide for everything about those parks, resorts, restaurants, and so much more. For regular updates, news & rumors, a heads up when discounts are released, and much more, sign up for our FREE email newsletter!
YOUR THOUGHTS
Thoughts on Universal rolling back its partnership with IBCCES to no longer require guests work with the third party? Did you love or hate the IBCCES approach? Thoughts on how this will change the attraction queue accommodations process or experience at Universal? If you’ve used the Attractions Assistance Pass at Universal, what do you think of the process for obtaining it and guest experience? Any other thoughts? Please try to stay on topic–we’ve noticed some of these comments sections get heated and personal. Discuss the policy itself, not others’ use (or lack thereof) of it. Comments that are unduly antagonistic will be deleted.
On a separate note…Over 325 airports around the world have launched the Hidden Disabilities Sunflower. The Hidden Disabilities Sunflower is a discreet sign that the wearer has a hidden disability and may need additional support. I applaud these airports for having this system in place.
Some disabilities, conditions or chronic illnesses are not immediately obvious to others. For some people, this can make it hard to understand and believe that someone, with a “non-apparent” condition genuinely needs support. Some people question whether you have a disability because you don’t look ‘like you have a disability”.
I have a rare disorder called EM (short for Erythromelalgia) It has no treatment and no cure. It causes episodes of burning pain, redness and hot skin on face, hands and feet. It compares to having second degree burns. These sudden episodes cause unimaginable pain and waiting in long lines may use up my “no-flare” time only to have to leave as the episodes commence. Flares are random so they come on in the course of a minute. I can’t plan around them and could end up using all my ‘no-flare” time in lines and never get to the ride or attraction all day. It is a form of peripheral neuropathy because it affects the nervous system, which connects the brain and spinal cord to muscles and cells. Disney is definitely a place I could use the DAS, but I am hearing that it is only available to those with autism or other like issues.
13% of the USA population are disabled. Let’s say the universal/ Disney population has the same percentage of Disabled. Each of them can take an additional 3 people Disney or 5 people universal. That would mean that 78% at universal and 52% at Disney of all guest are either on disability pass or are a guest of someone who is. These them parks can’t have over half the people in the park not in line. This caused major congestion issues and would force the selling of fewer tickets/ higher prices. The parks have to limit the passes to those who need accommodation not everyone who is disabled and hope that these limitations are enough to get the numbers needing passes down. I fully understand that not everyone who is disabled qualifies for the pass and not everyone takes the amount of people they can. So the percentage of park guest above is an exaggeration. The parks are between a rock and a hard place. I do not envy the people making the rules at any of the major them parks.
The problem at Disney isn’t that we are saying, “We need the pass because we are disabled”. The problem is we are saying “We need this accommodation because we cannot wait in a line because of X, X, and X, caused by X disability” and still being denied anyway for no discernible reason. Some people even offer up medical documentation to “prove” it, but Disney refuses to look at it even if you do so willingly. You also cannot refund your vacation at this point, if you are denied and cannot attend because you need the accommodation.
Our family prefers the Universal utilized IBCCES path versus the pathetic offerings (or better term, denials) of Disney’s DAS. We feel better providing documentation to help ensure need and like that we can use it at other parks such as Six Flags, Knobels, etc. I also appreciate hearing that Universal now gives two options for those who (like my family) do not mind providing documentation and also like to plan ahead and for those who prefer to not disclose or do not want the demand of applying before a trip, for example. IBCCES seemed a bit convoluted compare to the previous DAS offering, but now that Disney mucked their system all up, I do not have the same sentiment, as IBCCES seems more straightforward.
Although Disney’s update to DAS may be litigation proof, it is far from person-centered. Shame on those who embellished their anxiety issue to get DAS during high season (like a family member I have who has no issue waiting in line other times of the year or elsewhere….and admittedly would get DAS to not deal with the line) and shame on Disney for throwing the baby out with the bathwater and turn the system on its head and make it a waste of a day spent TOGETHER with family and friends by splitting parties to have the person who needs the pass unable to share their time with those who need to wait in line for them, anxiety provoking for those who need it, a waste of money for those who bought a ticket and were denied where they need the resource, thus not getting a full experience like other customers or suffering a loss knowing they will not visit the parks as much, if at all, anymore.
One fair and feasible solution that Disney would accept if they really did care about this issue was offer refunds to those who were denied or to offer DAS application before the need to purchase tickets. Does Disney not want to do this due to selfishness or a logistical mess for business concerns due to transactions….or both?! It adds insult to injury (literally and figurately) for Disney to offer the option to purchase Lightening Lane as a consolation prize. I know people complain about crowds, price increases, less for more, etc., of which I do not disagree but was willing to deal with all of that for the Disney magic our family has loved…my love of decades. If we get denied DAS for our child who without a doubt the pass is intended for, it might be the nail in the coffin. I know the core frustration should be at the people who took liberties, but I also place blame on Disney for letting the issue knowingly fester for so long until it got to this point where they are doing some unreasonable denials and offering a paid and unequal accommodation in its place. Bad show, indeed.
I did Universal HHN a few days ago, and it was striking how many people were using this system for access to the haunted houses, to the extent that the greeter team members were permanently occupied filling out people’s cards. It’s the first time I’d really noticed the scale of the challenge.
Unfortunately a lot of people are full of it and claim they have a disability just to skip lines. Getting mad you have to actually prove you have a disability is ridiculous- its like getting mad at a cop for pulling you over snd asking for your license . People are seriously too entitled these days.
It’s more nuanced than people not wanting to prove a need – the complaint against the current proof-based systems are (at least) three-fold. At the top of the list to me would be that the companies “certifying” one as disabled are not medical companies. They are private companies that can (and do) sell people’s private medical information for profit. They voluntarily provided it, so this is not actually illegal.
Then you have the issue that everyone has heard of the doctor who will lie for you. It’s a whole industry at this point, you can get a fake doctor’s note so there isn’t actually any certainty that a certified person is more disabled than the not certified person.
Then you have that ADA accommodations are meant to be need based, not diagnosis based. People can have needs that do not have a diagnosed named and they are no less real. People may have a very mild case of something with a diagnosis- which in a “diagnosis based” system will grant them accommodations they have no business asking for (as you say, people with no morals taking advantage)
All this just to say it’s more complicated than people not wanting to give proof. Many with disabilities also can’t afford regular enough care or to pay a doctor to write that letter – because they are allowed to charge for it- and while it can be easy to turn around and say “why is someone who can’t afford a doctor’s note going to an amusement park” – it’s really not up to us to determine who is worthy of finding someone to take them to a park, or of judging whether it’s right that someone can save up for enjoyment rather than for a note. The note can add a hurdle so that those most in need are again being subjected to a disability tax to get the accommodations that should be made for them.
Over the years I’ve heard of more people wanting to provide a note “from their doctor to prove need” that was fake than those wanting to provide a note that it was a true need. Possibly because those with disabilities are more likely to know the “proof note” shouldn’t be required. We even had a doctor offer to write us a fake note once, but when confronted with a situation where an accommodation was needed the same doctor told us to just let them know and that would be enough.
When my sciatica acts up, which isn’t all the time, I’d like a way to skip the staircases in some queues without a lot of hassle beforehand. I wouldn’t mind being forced to wait as long as everyone else as in my case, it’s not wait time that’s a problem, just a way to take whatever path the riders in wheelchairs & scooters take. Since there doesn’t seem to be an easy way to get this access without going for the whole shebang of also getting shorter wait times, and that requires justification so that you’re not cheating everyone else, on those days I have just skipped some attractions I wanted to do but I knew from previous experiences had staircases, though this made for some disappointing, lackluster outings stuck mostly watching 2nd rate street entertainment.
I don’t know what is going on at Universal, but I have seen a few of those viral videos of people who need accommodation at Disney being denied and it is awful. They should be ashamed of how they are behaving. It is not a good look for a company that for long people admired for being so accommodating to people with disabilities
We have had very good experiences with Universal’s new system. It greatly streamlined the process of obtaining the passes once we arrived at the park. If Disney is concerned about people abusing the DAS, it makes sense to simply require some proof of a disability, rather than denying people who really need the service.
Absolutely agree it seems that Disney DAS is being denied to so many people with genuine disability be that a silent disability or clearly a disability that can be seen. My self with severe scoliosis makes standing in a queue for a lengthy time so extremely painful I just can’t do it. But, I would be denied a DAS pass.
100 percent Kevin !
It seems a very American thing to me to file lawsuits over waiting line at theme parks. I wonder if this happens in other countries. I admit that I have an issue with taking the concurrent stances of “I want special treatment due to a medical condition” and “I don’t want to tell you anything about said condition”. We have ample evidence that the world is full of people with no morals and pairing those two things just leads to abuse.