Documentation requirements from college disability services offices can be confusing, frustrating, and viewed as a barrier. You’re not alone. Even accessibility staff find it frustrating too but for many different reasons. I have a whole blog post about those frustrations. You can read about that here.
However, once you understand the reasons for the requirements, you might change your mind and see documentation requirements in a different light. I’ll go over the basics, reasons for the requirements, some common issues, especially those for learning disabilities, and go over when you may need a new evaluation.
College disability documentation requirements exist for a reason. Regardless of the school, each school in higher educaiton has its reasons for having the requirements they have. However, documentation requirements are not about what you like, want, or find easy. That may not be what anyone wants to hear. However, it’s a reality that has a purpose.
There’s a reason behind college disability documentation requirements.
While it’s true that neither the ADA nor section 504 have a legal requirement mandating documentation, the ADA does grant post-secondary schools and training the right to ask for documentation. Asking for documentation is also where some confusion begins because each school can specify what documentation is required. There is no set standard of what to request.
However, there will be some similarities. Other documentation is needed for different disabilities unless the disability is blatantly obvious, like a wheelchair user. Health conditions, learning disabilities, ADHD, and mental health conditions will need some form of documentation.
This is in direct contrast to K-12 requirements for individualized education plans (IEPs). Those requirements were very specific and there was the annual IEP meetings to ensure that specialized instruction is taking place. This is not going to be the case for college.
Here’s why disability documentation is needed.
I’ve stated in the articles on my blog about the role of the accessibility office in higher educaiton. The first responsibility of the accessibility office is not to the student. It’s first obligation is to the school to meet its legal obligations under the ADA and section 504. Having documentation requirements helps the accessibility office meet that responsibility and legal obligation. Without outside documentation, accessibility decisions become arbitrary and inconsistent.
This leads us to another reason for requests for documentation; people sue for anything and everything.College students and thier parents are not immune form this. Arbitrary decisions about who is and is not disabled would hardly be responsible for meeting legal obligations. Having accurate, substantiated, third-party documentation from the proper professional makes the issue of legal consequences that much less. Again, college disability documentation requirements exist for a reason.
In addition, there is also a power differential inherent in the relationship between the accessibility staff and the student making the request. Third-party documentation takes much of that power differential away and leaves the staff room to determine disability status and reasonable accommodations.
Thus, accessibility office staff must rely on third-party documentation. Decisions of who is disabled and what is a reasonable accommodation become much more manageable and focused on the student’s needs and experience with their disability.
Reliance on third-party documents comes with common sense requirements. Third-party documentation must come from professionals with knowledge and expertise in the condition, who can diagnose and assess it, and who know the individual and the impact of the disability.
Documentation cannot be just from anyone.
For example, getting documentation from a therapist, not a chiropractor, would be logical if it’s a mental health condition. Of course, other professionals, such as nurse practitioners, psychiatrists, or primary medical doctors, can provide documentation for mental health conditions.
Documentation must provide accessibility staff with information about the nature and impact of the disability. For example, a therapist treating a student for anxiety can provide specifics about the student’s anxiety, how it manifests, and its impact on the student.
Can we get this from the student too? The accessibility staff should. If all the information indicates the same thing, then accessibility staff can be reasonably sure there is a disability present and then discuss reasonable accommodations like extended time and other testing accommodations.
Each school can specify disability documentation requirements.
You’ll have to look at the documentation requirements for each school and see what each requires for documentation. Some confusion begins here. Some schools may have less strict requirements for ADHD documentation, and some schools will require a neuropsychological assessment with some specific subtests.
Students should research the documentation requirements for each school they are looking at attending. If there are any questions or you have documentation from a professional not listed, reach out to the accessibility office and ask if there is any flexibility, but make sure you ask appropriate questions. Don’t ask, ‘will I get X approved.’ The staff can’t tell you that.
For further information on why ODS staff cannot answer specific questions, you can read my blog article, Reasons Disability Staff Cannot Answer Some of Your Questions.
Another area of confusion and frustration is the disability documentation requirements for learning disabilities.
The issue of students with learning disabilities and documentation guidelines that ask for a psychoeducational evaluation, not an IEP, is a common occurrence. Yet, there is a reason why accessibility offices may not be as flexible as you may want. As I’ve stated before, college disability documentation requirements exist for a reason.
The documentation must provide the information needed about the disability. In the case of learning disabilities, IEPs do not do that. It contains little information for staff to use. Can they be used as a history of having an impairment? Sure, but history alone does not corroborate or support that a disability exists right now. It just points in the right direction.
For example, if a student requests text-to-speech for testing, the IEP does not contain any tests or subtests indicating this need. The IEP cannot tell us why a student may need text-to-speech, much like a doctor’s note indicating a student has ADHD. It provides very little usable information.
The information needed to support a learning disability and the associated accommodations is in the psychoeducational evaluation. That has all the information necessary to support your accommodation request.
It sounds simple, but sometimes it’s not. Some evaluations are from when a student was much younger, from 3rd grade, for example. That evaluation can’t tell us what the status of the learning disability is for this student at age 18. Age matters and 9 is much different than 18. Almost a decade has passed, and no one would claim that a 9-year-old is the same intellectually as an 18-year-old. It’s scientifically inaccurate. Assessments for younger students are for younger students and tell us nothing of the current status of the disability.
Another issue is that assessments must be within the last three years. You may have heard that some schools require this. Most schools’ documentation policies refer to “current documentation” and may even specify a date range within the past five years.
Do you need an updated evaluation?
You may need an updated evaluation, but don’t hyperventilate yet. There is some good news. Your student may not need an updated assessment. Some will, but It will depend on two things. What accommodations are the student requesting, and what are the documentation requirements for your student’s school?
For example, an updated evaluation may not be needed if your student requests basic accommodations like extended test time and distraction reduction. Again, it will depend on the school’s documentation requirements. However, a new assessment may be necessary if your student requests anything more than the basics. I know it’s an expense, but it is also worth it. Need more help to decide? I have a podcast episode to help you decide if your student needs a new evaluation. You can listen to that podcast here.
Oh, by the way, the RISE Act won’t solve these issues. AT. ALL. It will only make the problems worse. If you want to know more about my absolute disdain for this proposed bill, I have a blog post you may want to check out, The Rise Act is the Wrong Act to Follow
Helpful Recommendations
For most disabilities, the documentation will be straightforward. For some, documentation will need some more attention. Several recommendations can minimize the issues, difficulty, and frustration. First, as you tour the campus and look at the resources, note the resources your student may need, especially accessibility and documentation requirements.
Students can handle Issues that arise before the semester begins. When touring a school, you may want to set up a meeting with the accessibility staff and ask questions about their documentation requirements, any flexibility with this, and when a student can apply. Second, request accommodations as soon as you can. Most of the time, this happens after a student gets accepted to a school. A student can compare each school’s support and approved accommodations before deciding which school to attend.
To help you with all this, I’ve put together a college services planner so you and your student can look at all the services for each college they are interested in attending. All the information is in one spot so you and your student can make the best decision about which college will meet your student’s needs best.
I hope this gives you a more comprehensive look at documentation policies. Or at least gives you more information to help you navigate your college search process and decision. My hope is that it makes the issue of college disability documentation requirements less frustrating and confusing.
