© Connecticut Association on Higher Education and Disability
Patricia Anderson, Ph.D. Coordinator, Connecticut Postsecondary Disability Technical Assistance Center ~ University of Connecticut-StorrsEvette Corujo-Aird, M.Ed., LPC. Learning Disability Counselor ~ Naugatuck Valley Community College
Maureen Crowley, M.Ed. Consultant, Connecticut Postsecondary Disability Technical Assistance Center ~ University of Connecticut-Storrs
Jane Currie, Ph.D. Director of Special Services ~ Farmington Public Schools
Lauri DiGalbo, M.Ed., CRC, LPC. Consultant/Mental Disabilities ~ Connecticut Department of Social Services, Bureau of Rehabilitation Services
Linda Domenitz, M.A., CCC-SP, LPC, MFT. Director of Career Development & Placement, Disabilities Counselor ~ Capital Community College
Susan Duques, Ph.D. Director of Disability Services ~ Connecticut College
Cathy Felice, M.A. Learning Specialist ~ Tunxis Community College
Gail Hammond, M.A. Learning Disability Specialist ~ Manchester Community College
Karen Halliday, M.S. Education Consultant, Connecticut State Department of Education, Bureau of Special Education and Pupil Services
Joan M. McGuire, Ph.D. Professor, Department of Educational Psychology; Co-Director, Postsecondary Education Disability Unit, Neag School of Education ~ University of Connecticut-Storrs
Louise Myers, M.S. Coordinator, Learning Disabilities Program ~ Naugatuck Valley Community College
Laurie Novi, R.N., M.S.N. Coordinator, Health Education and Disability Services ~ Naugatuck Valley Community College
Pamela Starr, Ph.D., CRC. Coordinator, Office of Disability Services ~ Eastern Connecticut State University
Angelo Vespe, Ph.D. Assistant Superintendent for Pupil Personnel ~ Stratford School District
Carol Young, M.S. University Assistant, Office of Special Student Services ~ Central Connecticut State University

Preface
Acknowledgments
Appendices:
Appendix A ~ Recommendations for Consumers Who Must Obtain an Independent Diagnostic EvaluationAppendix B ~ Tests for Assessing Adolescents and Adults with Learning Disabilities
Appendix C ~ Academic Accommodations and Support Services
Appendix D ~ Summary - Disability Documentation Guidelines to Determine Eligibility for Accommodations at the Postsecondary Level

In the Fall of 1999, the Connecticut Association on Higher Education Education and Disability (CT AHEAD), an organization of professionals committed to equal opportunity in higher education for students with disabilities, voted to establish an ad hoc committee that was charged with producing guidelines for documenting a disability at the postsecondary level. The purpose of these guidelines, upon the approval of the CT AHEAD membership, is to promote consistency across postsecondary institutions with regard to appropriate disability documentation.
The CT AHEAD membership also expressed a desire for students, parents, private diagnosticians, and secondary school personnel to become knowledgeable about the similarities and differences between postsecondary and secondary systems and the type of documentation necessary to verify a student's eligiblity for reasonable accommodations at the postsecondary level. In light of this request, representatives from the Bureau of Rehabilitation Services, advocacy organizations (CACLD, Easter Seals, LDA), the Connecticut State Department of Education-Bureau of Special Education and Pupil Services, and administrators from several public school service providers from two- and four-year, public and indepenedent colleges and universities in Connecticut.
The process of developing these guidelines provided an excellent opportunity for postsecondary and secondary personnel to become familiar with the differences in disability legislation, eligiblity criteria, and the provision of services and accommodations in the K-12 system and colleges and universities. These guidelines represent a monumental step in assisting each system to understand the needs and concerns of the other. However, given the inherent differences between the goals of the two systems, ongoing dialogue is essential in order to help students obtain the type of documentation necessary to transition to higher education and other adult services. Ultimately, it is the student's financial responsibility to obtain disability documentation required by postsecondary institutions and students are encouraged to discuss this process with both secondary and postsecondary disability personnel.
Both the postsecondary and the secondary personnel on the CT AHEAD Disability Documentation Guidelines Ad Hoc Committee would like to continue the collaboration and discussion initiated through this process. The Guidelines are a work in progress and will require refinement based on an ongoing dialogue between secondary and postsecondary representatives, working together in the best interest of the students.

These guidelines, developed by the CT AHEAD Disability Documentation Guidelines Ad Hoc Committee, incorporate adaptations of a variety of materials addressing disability documentation from colleges, universities, and professional organizations, including:

The Individuals with Disabilities Education Act (IDEA) provides special education and related services for those students in public schools who meet the criteria for eligibility in a number of distinct categories of disability, each of which has its own criteria. However, when students with disabilities graduate or reach the age of 21, they are no longer eligible for services under the IDEA. Students who were eligible for services at the secondary level may not necessarily be eligible for services or accommodations at the postsecondary level. On the other hand, some students who are not eligible for services under IDEA may receive protection and reasonable accommodations under Section 504 of the Rehabilitation Act of 1973 while they are attending secondary school. Since IDEA includes transition to postsecondary education in transition planning services [20 U.S.C. § 1401 (30)] and requires reevaluation if the student's parent requests it [20 U.S.C. § 1414 (a)(2)(A)], these Guidelines are intended to support that planning.
Students who graduate from high school or reach the age of 21, are still protected from discrimination on the basis of disability by Section 504 as well as the Americans with Disabilities Act (ADA). Under such legislation, individuals with disabilities are guaranteed certain protections and rights of equal access to programs and services. Eligibility is based on the existence of an identified physical or mental impairment that substantially limits a major life activity. Therefore, documentation should indicate that the impairment is a disability that substantially limits a major life activity.
It is becoming extremely difficult for postsecondary institutions to declare with certainty the circumstances under which a student will be accepted as having a disability. The question of whether a student has a disability which substantially limits his/her ability to learn is more complicated with non-visible disabilities than more apparent disabilities such as blindness, visible physical disabilities, deafness.
Not every impairment qualifies as a disability protected by the ADA because not every impairment is substantially limiting. The court in E.E.O.C. v. Harvey L. Walner & Associates, 91 F.3d 963, 996 (7th Cir. 1996), described the proper disability determination as follows:
A disability determination, however, should not be based on abstract lists as categories of impairments, as there are varying degrees of impairments, as well as varied individuals who suffer from the impairments. In fact, the regulations note that a finding of disability is not necessarily based on the name or diagnosis of the impairment the person has, but rather, on the effect of that impairment on the life of the individual. Some impairments may be disabling for particular individuals but not for others, depending upon the stage of the disease or disorder, the presence of other impairments that combine to make the impairment disabling or any number of other factors. 29 C.F.R. App. Sec. 1630.2(j).This is why a determination of disability must be made on an individualized, case-by-case basis. Whether a substantial limitation upon a major life activity exists, depends upon an analysis of (1) the nature and severity of the impairment, (2) the duration of the impairment, and (3) the permanent or long-term impact of impairment. 29 C.F.R. Sec. 1630.2(j) (Heyward, 1998, pgs. 3:5-3:6).
Thus, the key factor in answering the question of
whether there is a substantial limitation is "the
actual effect on the individual's life." Sutton v.
United Air Lines, Inc., 130 F.3d 893, 900 (10th
Cir. 1997). A review of recent judicial decisions
involving colleges and universities in which the
meaning of "substantially limits" has been
discussed reveals that the courts have been
conservative in their assessments and have
required individuals to present compelling
objective evidence to support their claims of
disability, despite the admonishment in Doe v. New
York University, 666 F.2nd 761 (1981), to be
expansive in construing the definition of
disability, (Heyward, 1998).
The following guidelines are provided in the interest of assuring that documentation of a specific disability is appropriate to verify eligibility and to support requests for accommodations, academic adjustments and/or auxiliary aids. It is acknowledged that different educational settings with different student populations will need to modify and adapt these guidelines to meet the needs and backgrounds of their student populations. It is recommended that postsecondary institutions using these guidelines consult with their legal counsel before establishing a policy on documentation relating to individuals with disabilities. In countries not regulated by this disability legislation further modification may be appropriate.
This document presents guidelines in five important areas: (a) qualifications of the evaluator, (b) recency of documentation, (c) appropriate documentation to substantiate the specific disability, (d) objective evidence to establish a rationale supporting the need for accommodations, and (e) confidentiality.
A. Evaluator Qualifications
Professionals conducting assessments, rendering diagnoses of specific disabilities, and making recommendations for appropriate accommodations must be qualified to do so. Comprehensive training with regard to the specific disability being addressed and direct experience with an adolescent and/or adult population are essential.
The name, title and professional credentials of the evaluator, including information about license or certification (e.g., licensed psychologist), the area of specialization, employment, and state/province in which the individual practices should be clearly stated in the documentation. It is of utmost importance that evaluators are sensitive and respectful of cultural and linguistic differences during the assessment process. It is not considered appropriate for professionals to evaluate members of their own families.
Recommendations for consumers who must obtain an independent diagnostic evaluation are presented in Appendix A to assist them in finding and working with a qualified professional in regard to documentation.
Because the provision of all reasonable accommodations and services is based upon assessment of the current impact of the disability on academic performance, it is in an individual's best interest to provide recent and appropriate documentation. In most cases, this means that a diagnostic evaluation has been completed within the past three to five years. Flexibility in accepting documentation is important, particularly if the previous assessment is applicable to the current or anticipated setting.
If documentation is inadequate in scope or content, or does not address the individual's current level of functioning and need for accommodation(s), reevaluation may be warranted. Furthermore, observed changes may have occurred in an individual's performance, or new medication(s) may have been prescribed or discontinued since the previous assessment was conducted. In such cases, it may be necessary to update the evaluation report and reassess the student's functional abilities with greater frequency. The update(s), conducted by a qualified professional, should include: a detailed assessment of the current impact of the disability, an integrated summary of relevant information, a rationale for ongoing services and accommodations, and previous diagnostic information.
While many postsecondary institutions define "current" documentation as assessments conducted within the past three years, the court in Guckenberger v. Trustees of Boston University (Case No. 96-11426-PBSD. Mass. 1997) ruled that it is improper for a college to require a reevaluation every three years for a student with a learning disability who is at least 18 years old, at least insofar as determining whether he/she still has the condition (Kincaid, 1997). Expert testimony reported that for adults with LD, reevaluation every five years is sufficient (Heyward, 1997). Although Boston University did not address the issue of needing current documentation to determine appropriate accommodations, this rationale is supported by the Office for Civil Rights (Kincaid, 1997). In contrast, expert testimony convinced the court that the symptoms of ADHD change in different environments, are often treated with medication, and often remit from adolescence to adulthood. Thus, the court did not find fault with Boston University's requirement that students with ADHD undergo reevaluations every three years unless a qualified examiner determines that retesting is unnecessary (Kincaid, 1997).
Disability documentation must verify the nature and extent of the disability in accordance with current professional standards and techniques, and it must clearly substantiate the need for all of the student's specific accommodation requests. Documentation should validate the need for services based on the individual's current level of functioning in the educational setting. Students requesting accommodations for the manifestations of multiple disabilities must provide evidence of all such conditions.
A comprehensive assessment battery and the resulting diagnostic report should include background information (e.g., interview, review of records), assessment of areas appropriate for the specific disability and a diagnosis. School plans such as an Individualized Education Program (IEP) or a 504 Plan are useful but are not, in and of themselves, sufficient documentation to establish the rationale for accommodations. Such plans may be included as part of a more comprehensive assessment battery. All reports should be on letterhead, typed, dated, signed and legible.
The diagnostic report should include more than test protocol sheets or a summation of individual report information. It should integrate the various views regarding a student's specific functioning abilities and the resulting impact of these abilities as they relate to postsecondary educational demands. In a public school system, the Planning and Placement Team recommends the type of evaluations necessary for the educational programming of a student and provides a special education diagnosis. A diagnostic report would synthesize all of the diagnostic information culled from the individual reports of the team members and include the resulting diagnosis.
A postsecondary institution has the discretion to require additional documentation if it is determined that the existing documentation is incomplete or inadequate to ascertain the extent of the disability or the need for reasonable accommodation. With the student's written permission, a telephone consultation with an evaluator to update or clarify information regarding the disability may be sufficient to complete the existing documentation. Any cost incurred in obtaining additional documentation when the original records are inadequate for postsecondary purposes is borne by the student. If the existing documentation is complete but the postsecondary institution desires a second professional opinion, the postsecondary institution bears the cost.
Comprehensive disability documentation should include the following six components:
1. Evidence of Existing Impairment
Statement of Presenting Problem(s): A history of the individual's presenting problem(s) should be provided, including evidence of ongoing difficulties/behaviors that significantly impact functioning.
2. Background Information
Information collected for the background information summary should be culled from a variety of sources (e.g., interview, review of records) and, whenever feasible, should consist of more than self-report. Information from third party sources is often invaluable.
The diagnostician, using professional judgment as to which areas are relevant, should review pertinent records and conduct an interview which may include, but not necessarily be limited to, the following:
3. Relevant Testing
Assessment, and any resulting diagnosis, should consist of and be based on a comprehensive assessment battery that does not rely on any one test or subtest. Neuropsychological or psychoeducational assessment is important in determining the current impact of the disorder on the individual's ability to function in academically related settings. The evaluator should objectively review and include relevant background information to support the diagnosis in the evaluation report.
Standard scores should be provided for all normed measures, including all subtests administered. Grade equivalents and/or percentiles are not useful unless standard scores are also included. The tests used should be technically sound (e.g., statistically reliable, valid) and standardized for use with an adolescent/adult population. The test findings should document both the nature and severity of the disability. The particular profile of the student's strengths and weaknesses must relate to functional limitations that may necessitate accommodations.
Interpretation of results is required. Test scores, subtest scores, or test protocol sheets alone are not sufficient and should not be used as a sole measure for the diagnostic decision. For example, in Bartlett v. New York State Board of Law Examiners (970 F. Supp. 1094 (S.D.N.Y.); 1997 U.S. Dist. Lexis 12227 (S.D.N.Y.), the court made it clear that clinical judgment is critical to the diagnosis of learning disabilities; scores alone cannot form the basis of a diagnosis nor a denial of accommodation under the ADA or Section 504 (Simon, 1997). Selected subtest scores from measures of intellectual ability, memory functions tests, attention or tracking tests, or continuous performance tests do not, in and of themselves, establish the presence or absence of a specific disability. Informal inventories, surveys and direct observation by a qualified professional may be used in tandem with formal tests (i.e., standardized and norm- or criterion-referenced tests) to further develop a clinical hypothesis. All data must logically reflect a substantial limitation to learning or another major life activity for which the individual is requesting the accommodation.
4. Specific Diagnosis
The report must include a specific diagnosis of the disability by a qualified evaluator. It is important to rule out alternative explanations for problems such as emotional, attentional or motivational issues that may be interfering with learning but do not constitute a specific disability. If the data indicate that a specific disability is not present, the evaluator should state that conclusion in the report. The evaluator is encouraged to use direct language in the diagnosis and documentation of a specific disability, avoiding the use of terms such as "suggests" or "is indicative of." It is important to note that the public school system is qualified to diagnose only educationally related disabilities in accordance with state guidelines (e.g., learning disabilities, speech and language impairment). The classification of Serious Emotional Disturbance (SED), that is used in the school systems, is not considered to be an acceptable diagnosis at the postsecondary level.
5. Rule-Out of Alternative Diagnoses or
Explanations
The evaluator must investigate and discuss the possibility of dual or multiple diagnoses, where indicated, and alternative or co-existing conditions which may confound the specific disability diagnosis. This process should include exploration of possible alternative diagnoses as well as other factors impacting the individual which may result in behaviors mimicking a specific disability.
Because of the challenge of distinguishing normal behaviors and developmental patterns of adolescents and adults (e.g., procrastination, disorganization, distractibility, restlessness, boredom, academic underachievement or failure, low self-esteem, chronic tardiness or inattendance) from clinically significant impairment, a multifaceted evaluation should address the intensity and frequency of the symptoms and whether these behaviors constitute an impairment in a major life activity.
6. Integrated Summary
A well-written summary based on a comprehensive evaluation process is a necessary component of the report. Assessment instruments and the data they provide do not diagnose; rather, they provide important elements that must be interpreted and integrated by the evaluator with background information, observations of the student during the testing situation, and the current context. It is essential, therefore, that professional judgment be used in the development of a summary. The summary should include:
Accommodation needs can change over time and are not always identified through the initial diagnostic process. The evaluator(s) should describe the impact, if any, of the diagnosed disability on a specific major life activity as well as the degree of impact on the individual. The diagnostic report should include specific recommendations for accommodations that are reasonable. When possible, a detailed explanation should be provided as to why each accommodation is recommended and should be correlated with specific functional limitations determined through interview, observation, and/or testing. Although prior documentation may have been useful in determining appropriate services in the past, to further facilitate the process of requesting accommodations at the postsecondary level, current documentation should validate the need for services based on the individual's present level of functioning in the educational setting.
The documentation should include any record of prior accommodations or auxiliary aids, including information about specific conditions under which the accommodations were used (e.g., standardized testing, final exams, licensing or certification examinations) and whether or not they benefited the individual. A school plan such as an Individualized Education Program (IEP) or a 504 Plan is insufficient documentation, in and of itself, but can be included as part of a more comprehensive evaluative report. However, a prior history of accommodations, without demonstration of a current need, does not, in itself, warrant the provision of a like accommodation. If no prior accommodations were provided, the qualified professional and/or the individual should include a detailed explanation as to why no accommodations were used in the past and why accommodations are needed at this time.
Reasonable accommodation(s) may help to ameliorate the disability. The determination for reasonable accommodation(s) rests with the designated postsecondary institution working in collaboration with the individual with the disability and, when appropriate, college faculty. Accommodations may vary based on course content and/or academic programs. If accommodations are not clearly identified in a diagnostic report, the disability service provider should seek clarification and, if necessary, additional information. Appendix C provides a description of accommodations and support services typically available at the postsecondary level.
The receiving institution or agency has a responsibility to maintain confidentiality of the evaluation and may not reveal any part of the documentation to faculty, administration, or parents without the student's informed and written consent. Disability information should be kept in a separate, secure location and should not be included in a student's general education records.
A. Acquired Brain Injury
Students requesting accommodation on the basis of an Acquired Brain Injury (ABI) must provide documentation (in most cases within two years) from a professional who has undergone comprehensive training and has relevant experience in the assessment of ABI in adolescents and/or adults (e.g. neuropsychologists, clinical or educational psychologists). In addition to the requirements specified in Sections I and II, documentation for students requesting accommodations on the basis of an ABI must include but not be limited to:
- indicates the substantial limitations to major life activities posed by the specified brain injury,
- describes the extent to which these limitations impact the academic context for which accommodations are being requested,
- suggests how the specific effects of the brain injury may be accommodated, and
- states how the effects of the brain injury are mediated by the recommended accommodations.
Students requesting accommodations on the basis of Attention Deficit Hyperactivity Disorder (ADHD) must provide documentation by a professional who has undergone comprehensive training and has relevant experience in differential diagnosis and the full range of psychiatric disorders (e.g., psychologists, psychiatrists, neuropsychologists and other relevantly trained medical doctors). In addition to the requirements specified in Sections I and II, documentation for students requesting accommodations on the basis of ADHD must include:
- indicates the substantial limitations to major life activities posed by the disability,
- describes the extent to which these limitations would impact the academic context for which accommodations are being requested,
- suggests how the specific effects of the disability may be accommodated, and
- states how the effects of ADHD are mediated by the recommended accommodations.
In addition to the requirements specified in Sections I and II, documentation for students requesting accommodations on the basis of low vision or blindness must include:
In addition to the requirements specified in Sections I and II, documentation for students requesting accommodations on the basis of on the basis of being deaf or hard of hearing must include:
Students requesting accommodation on the basis of a specific learning disability must provide documentation from a professional who has undergone comprehensive training and has relevant experience in the assessment of learning problems in adolescents and/or adults (e.g., clinical or educational psychologists, school psychologists, neuropsychologists, learning disabilities specialists). In addition to the requirements specified in Sections I and II, documentation for students requesting accommodations on the basis of a learning disability must include, but is not limited to:
- indicates the substantial limitations to major life activities posed by the specified learning disability,
- describes the extent to which these limitations impact the academic context for which accommodations are being requested,
- suggests how the specific effects of the learning disability may be accommodated, and
- states how the effects of the learning disability are mediated by the recommended accommodations.
In addition to the requirements specified in Sections I and II, documentation for students requesting accommodations on the basis of physical mobility, dexterity, or chronic health-related disabilities must include:
Students requesting accommodations on the basis of a psychiatric disability must provide documentation from a professional who has undergone comprehensive training and has relevant experience in differential diagnosis and the full range of psychiatric disorders (e.g., licensed clinical psychologists, psychiatrists, neurologists, marriage and family therapists, licensed clinical social workers, and other relevantly trained medical doctors). In addition to the requirements specified in Sections I and II, documentation for students requesting accommodations on the basis of a psychiatric disability must include:
- indicates the substantial limitations to major life activities posed by the psychiatric disability,
- describes the extent to which these limitations would impact the academic context for which accommodations are being requested,
- suggests how the specific effects of the psychiatric disability may be accommodated, and
- states how the effects of the psychiatric disability are mediated by the recommended accommodations.
In addition to the requirements specified in Sections I and II, consumers and professionals are advised to discuss the requirements of appropriate documentation for students requesting accommodations on the basis of other disabilities with postsecondary disability service providers.

Diagnostic and statistical manual of mental disorders (4th ed.) (DSM-IV). (1994). Washington, DC: American Psychiatric Association.
Heyward, S. (1997, October). The lessons of Boston University. Disability Accommodation Digest, 7(1).
Heyward, S. (1998). Disability and higher education: Guidance for Section 504 and ADA compliance. Horsham, PA: LRP Publications.
Kincaid, J. (1997, September). Westling's stereotypes discriminated against students with LD. Disability Compliance for Higher Education, 3(2), 4-5.
Simon, J. (1997, November). Reading court opinions critically. Alert, 21(6), p. 1, 5-7.

Tests for Assessing Adolescents and Adults with Learning Disabilities
Academic Accommodations and Support Services
Summary - Disability Documentation Guidelines to Determine Eligibility for Accommodations at the Postsecondary Level

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