United States of America v. Camp Bravo - Settlement Agreement

ACTIONS TO BE TAKEN BY CAMP BRAVO

15. Pursuant to title III of the ADA and its implementing regulation, Camp Bravo shall not discriminate against any individual on the basis of disability, including epilepsy, in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of Camp Bravo.

16. Camp Bravo will adopt, maintain, and enforce the non-discrimination statement attached hereto and incorporated by reference herein as Exhibit 1 to this Agreement.  Within 30 days of the effective date of this Agreement, Camp Bravo will prominently post a copy of this non-discrimination statement in its main office, and include a hyperlink to the non-discrimination statement on the main company webpage, currently hosted at http://www.campbravo.com/, to remain posted for the duration of this Agreement.

17. Camp Bravo will adopt, maintain, and enforce an Emergency Anti-Seizure Medication Administration (EASMA) Policy and Procedure, attached hereto and incorporated by reference herein as Exhibit 2 to this Agreement.  Camp Bravo may hire or contract with licensed healthcare professionals, such as a registered nurse, to administer Diastat to campers who require it.  This determination will be made by Camp Bravo on an individualized, case-by-case basis, in compliance with federal law.  The parents or guardians of any camper who requires Diastat are responsible for providing, at their cost, all necessary equipment and supplies for the administration of Diastat.

18. In addition, as part of its EASMA Policy and Procedure, Camp Bravo will adopt forms for (1) a Seizure Emergency Action Plan and (2) a Physician's Order for the Administration of Diastat, which are attached hereto and incorporated by reference herein as Attachments 1 and 2 to Exhibit 2 of this Agreement.  Such forms are intended to ensure that Camp Bravo has individualized information and instructions relating to the management of each child's seizure disorder. 

19. When informed that one of its campers has been diagnosed with a seizure disorder, including epilepsy, or that a child with a seizure disorder has applied for enrollment to Camp Bravo or its programs, Camp Bravo will advise the child's parents or guardians of the conditions under the EASMA Policy and Procedure and that Camp Bravo will comply with the ADA.

20. Camp Bravo will print and maintain copies of the EASMA Policy and Procedure in a central location; will provide the EASMA Policy and Procedure to any interested party requesting it or a modification of policies, practices, or procedures due to a seizure disorder; and will incorporate the EASMA Policy and Procedure into its standard operating procedures and handbook(s).

21. Camp Bravo will notify counsel for the United States in writing when it has completed the actions described in paragraphs 16-20. 

22. Within 30 days of receipt of any complaint related to reasonable modifications requested by a camper, or a camper's parent or guardian, pursuant to the ADA, Camp Bravo shall send an email to counsel for the United States with a copy of any such complaint or, if an oral complaint was made, a description of the complaint and Camp Bravo's response.