Is the Department of Ed's Office of Civil Rights shifting its position on readmission of mentally disabled students?

OCR's December decision, only recently released, involving SPring Arbor University:

http://www.nacua.org/documents/OCRLetter_SpringArborU.pdf

The Department of Justice regulation that the letter seems to adopt:

http://www.ada.gov/regs2010/titleII_2010/titleII_2010_withbold.htm

And brief analysis by the National Association of College and University Attorneys:

http://www.nacua.org/lrs/documents.asp#springarbor