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Disability Documentation Practices

The Office of Learning Resources (OLR), in keeping with best practices, utilizes the experience of professional staff and the documentation practices outlined by the Association on Higher Education and Disability (AHEAD) while maintaining the spirit of the legislation.  Taken as a whole, the changes to the Americans with Disabilities Act (ADA) statute and regulations for Titles I, II, and III clarify (a) who has a disability entitled to protection under the ADA and Section 504, (b) who is entitled to accommodations, and (c) how those determinations are made and by whom.  The information outlined below is extracted from the AHEAD Guidelines (full document: http://ahead.org/resources/documentation_guidance).

Sources and Forms of Documentation

Acceptable sources of documentation for substantiating a student’s disability and request for particular accommodations can take a variety of forms.  Any individual or combination of the information outlined below may be sufficient for establishing disability and a need for accommodation.

Student’s Self-report

A student’s description of his or her experience of disability, barriers, and effective and ineffective accommodations which can be obtained through structured interview or questionnaire and interpreted by experienced disability professionals. 

Observation and Interaction

The impressions and conclusions formed by higher education disability professionals during interviews and conversations with students or in evaluating the effectiveness of previously implemented or provisional accommodations are important forms of documentation. 

Information from External or Third Parties

Documentation from external sources may include educational or medical records, reports and assessments created by health care providers, school psychologists, teachers, or the educational system such as multifactorial, psycho-educational or other evaluations. This information is inclusive of documents that reflect education and accommodation history, such as Individual Education Program (IEP), 504 Accommodation Plans, Summary of Performance (SOP), teacher observations, and other reports of past accommodations.

Documentation Process

The goal of gathering information from the student and other key sources is to assist in establishing an understanding of the disability, how disability may impact a student, and making informed decisions about accommodations to provide effective access.

The best method for addressing this process is through direct interaction between the student and the experienced disability professional.  The weight given to the individual’s description will be influenced by its clarity, internal consistency, and congruency with the professional’s observations and available external documentation.  However, if the student is unable to clearly describe how the disability is connected to a barrier and how the accommodation would provide access, the institution may need to request third party documentation. 

The salient question is not whether a given condition is a “disability,” but how the condition impacts the student.  A student’s specific accommodation needs may vary based upon the unique characteristics of the course, program, or requirement.  This requires a clear understanding of how disability impacts the individual to establish the reasonableness of the accommodation for the individual.  No third party information may be necessary to confirm disability or evaluate requests for accommodations when the condition and its impact are readily apparent or comprehensively described.  If the student cannot describe a potential connection or identify the potential documentation that would support the request, the accommodation may not be reasonable.

Disability documentation should be current and relevant but not necessarily “recent.”  Disabilities are typically stable lifelong conditions. Therefore, historic information, supplemented by interview or self-report, is often sufficient to describe how the condition impacts the student at the current time and in the current circumstances.

Course modifications or auxiliary aids or services that are ineffective or constitute a fundamental alteration will not be reasonable and therefore will not meet the ADA and Section 504’s minimal standards.

Specific Guidelines

Should a student require formal assessment, the following guidelines should be shared with your diagnostician. This information will enhance consistency and provide students, prospective students, parents and professionals with the information they need to assess a student for a disability.  This information is adapted from guidelines previously used by AHEAD and MPRE.   If you plan on taking future standardized testing (PRAXIS, MPRE, GRE, GMAT, LSAT, etc.), you should utilize the guidelines of that governoring body.  This information is adapted from guidelines used by AHEAD (prior to 2012) and Multistate Professional Responsibility Examination (MPRE).   If you plan on taking future standardized testing (PRAXIS, MPRE, GRE, GMAT, LSAT, etc.), you should utilize the guidelines of that governoring body.

  • The best quality documentation is provided by a licensed or otherwise properly credentialed professional who has undergone appropriate and comprehensive training, has relevant experience, and has no personal relationship with the individual being evaluated. 
  • Quality documentation includes a clear diagnostic statement that describes how the condition was diagnosed, provides information on the functional impact, and details the typical progression or prognosis of the condition.  This should include a description of the diagnostic criteria, evaluation methods, procedures, tests and dates of administration, as well as a clinical narrative, observation, and specific results.  If the condition is not stable, information on interventions (including the individual’s own strategies) for exacerbations and recommended timelines for re-evaluation are most helpful.
  • Include information on how the disabling condition(s) currently impacts the individual, taking into account the individual’s self-report, the results of formal evaluation procedures, and clinical narrative to provide necessary information for identifying possible accommodations. 
  • A description of current and past accommodations, services, medications (and side-effects), auxiliary aids, assistive devices, and support services, including their effectiveness.   While accommodations provided in another setting are not binding on the current institution, they may provide insight in making current decisions.
  • Recommendations for accommodations, services, auxiliary aids, assistive devices, compensatory strategies and support services and a logical relationship to their functional limitations. 
  • Formal reports should be submitted in English, on signed-dated letterhead.
  • Resources for your diagnostician may include the current editions of Diagnostic and Statistical Manual of Mental Disorders, International Statistical Classification of Diseases and Related Health Problems, documentation guidelines for standardized testing (PRAXIS, MPRE, GRE, GMAT, LSAT, etc.).