While research on barriers to full participation for those with learning and other disabilities has focused largely on structural and institutional obstacles to work and education (Swain, French, & Cameron, 2005; Jones, 1996; Watson, 2002), the recognition of disability as a social justice issue is gaining currency (Kraus, 2008). Expensive, bureaucratic, and protracted procedures for reasonable accommodations for students with disabilities in colleges and universities may serve as institutional obstacles that can challenge notions of social justice. This study examined academic policy implementation surrounding foreign language substitution procedures and practices in five institutions of higher education. Nineteen academic administrators were interviewed to examine how and when policies are implemented, and how those responsible for decision-making around student requests for foreign language substitutions as a reasonable accommodation approach their decision-making. Additionally, content analysis of institutional material listed on websites and in documents available to students was conducted to understand in what model(s) of disability substitution requests are rooted. Finally, four students from one of the five institutions were interviewed to contextualize the findings from the institutional administrator interviews and content analysis. The framework of Strategic Ambiguity is utilized to examine how ambiguity in policy creation and implementation can negatively impact the experiences of some students with disabilities in higher education, even as it benefits administrators who can capitalize on ambiguity to align their policy decisions with individual interpretations of fairness. The framework of Universal Design is utilized to examine how diverse perspectives on the comparative importance of language and cultural study may legitimize the expansion of curricular options for all students.