Accessibility Services

Background Information

The USM/MCC documentation guidelines are provided in the interest of assuring that documentation of a disability is appropriate to verify eligibility and support requests for services and accommodations. As noted previously, IDEA does not require secondary schools to provide updated disability documentation for the purpose of determining eligibility at the postsecondary level for students preparing to graduate or exit school. Therefore, it is suggested that USM institutions and Maryland community colleges, as appropriate, consider using less recent documentation (e.g., more than three years old or use of test instruments normed on adolescents rather than adults) along with various sources of pertinent data, such as well described functional information in a Summary of Performance document (described previously). These decisions will vary depending upon the specific disability. Flexibility and professional judgment are very important.

It should be clearly noted, however, that documents such as an IEP, SOP or a secondary level Section 504 plan may not contain sufficient information to determine eligibility for services at the postsecondary level. Therefore, these documents, in and of themselves, may not constitute adequate documentation.

Additionally, students with an IEP have been determined to be eligible for services under a multidisciplinary team process. Within this process, relevant testing and diagnostic information (e.g., observations, behavioral surveys, outside evaluations) are brought to an IEP team meeting and after sharing all of the information, the team determines the student’s eligibility and need for special education services. It is less likely that such a student would have a single or integrated diagnostic report indicating a specific disability via this process unless it were specifically requested. USM institutions and Maryland community colleges should therefore use flexibility in accepting multiple types of reports to document a student’s disability. That said, if documentation is inadequate in scope or content, or does not address the student’s current level of functioning and need for accommodations, reevaluation may be warranted.

With respect to the accommodation process, it is important to note that there are significant differences between high school and college. At the postsecondary level, the responsibility for seeking out and accessing services shifts from parents and school personnel to the student.

College students are expected to function independently in an adult learning environment. The student is responsible for acting as a self advocate, following the university’s procedures, disclosing the disability, providing documentation, monitoring his or her own progress and communicating needs to instructors.

The learning environment is different as well. For example, college courses are based on a 15- week semester (or less) rather than a full academic year, which means learning must occur at a faster pace. Students are responsible for following a syllabus and typically are expected to learn material via lecture and class notes. Reading and writing demands are heavier. Less time is spent in class, requiring significantly more study time outside of class. Course material may be quite technical and require higher level thinking skills. Tests are less frequent and may cover large amounts of material. Students are expected to organize their work and manage their time independently. In addition to lectures, courses may involve an on-line format, field placement, or a combination. Given the differences between secondary and postsecondary environments and legal requirements (i.e., IDEA vs. ADA and Section 504), accommodations that a student received in high school may not be appropriate or required at the college level.

Accommodations and services that are considered to be appropriate at the postsecondary level are those that provide the student with equal access to the institution’s courses and programs; in other words, those that “level the playing the field” for the student. As noted previously, postsecondary institutions are not required to provide accommodations and services that fundamentally alter their courses or programs.

Accommodation decisions are to be made on a case-by-case basis, considering the impact of a particular student’s disability within the specific context in which that student must function. Accommodation needs can change over time and are not always identified through the initial diagnostic process. The determination for reasonable accommodations rests with the current institution, typically through its disability services staff working in collaboration with the student who has a disability and, when appropriate, college faculty. Because accommodations may vary based on the course or program, faculty may be included in the determination process as well. If recommended accommodations are not clearly identified in the documentation, the institution may seek clarification and if necessary, additional information. When recommendations go beyond equitable and inclusive accommodations and services, they may still be useful in suggesting alternative accommodations or services.

Since testing and reevaluation may be costly, such as a psycho-educational evaluation, it is recommended that USM institutions and Maryland community colleges maintain a list of providers that includes options for reduced and/or sliding fee scale testing. An example of a list of providers that includes resources for obtaining reduced or sliding fee scale testing is provided in Appendix A.

Foundational Principles for Documentation Review and Determination of Accommodations

The Association on Higher Education and Disability (AHEAD) has established seven basic principles to serve as the foundation for best practices used by postsecondary institutions in establishing disability documentation guidelines and determining accommodations for students with disabilities. As such, USM institutions and Maryland community colleges should be guided by the following principles:

• Documentation should be reviewed on a case-by-case basis, examining the impact of the disability on the student and within the specific context of the request for accommodations;
• Determination of a disability should not require the use of any specific language;
• Presented documentation can be augmented by interview with the student and contact with the evaluator for needed clarification;
• Determination of accommodations is an interactive process and should not be dictated by any one party;
• Documentation of a specific disability does not translate directly into a specific accommodation or set of accommodations;
• Disability documentation should be treated in a confidential manner and shared only on a need-to-know basis;
• Information on the individual’s disability is only one component of providing access; increasing overall accessibility through system change may reduce the need for individual accommodation.

General Documentation Guidelines

With these principles in mind, the guidelines for documentation below are recommended for USM institutions and Maryland community colleges to enhance consistency and provide students, parents and professionals with the information needed to assist students in establishing eligibility for services and receiving appropriate accommodations. The guidelines are broad enough to allow for flexibility in accepting documentation from a range of perspectives given the different educational environments within the USM and MCC systems. These differences include such factors as open versus competitive enrollment; variation in class size; type of student population (e.g., traditional, nontraditional, transfer) undergraduate versus graduate program, and course format -- classroom, on-line, hybrid or field-based.

The credentials of the evaluator

Documentation must be completed by a licensed or otherwise properly credentialed professional who has appropriate training and experience, and has no close, personal relationship with the student being evaluated. A good match between the credentials of the individual making the diagnosis and the disability being reported is expected (e.g., an orthopedic limitation might be documented by a physician but not by a licensed psychologist).

A diagnostic statement identifying the disability

Documentation must include a clear diagnostic statement identifying the disability and the date of the most current diagnostic evaluation, as well as the date of the original diagnosis, as appropriate. While diagnostic codes from the Diagnostic Statistical Manual of the American Psychiatric Association (DSM) or the International Classification of Functioning Disability and Health (ICF) of the World Health Organization are helpful in providing this information, a full clinical description can also convey the necessary information.

A description of the diagnostic methodology used

Documentation must include a description of the current diagnostic criteria, evaluation methods, procedures, tests and dates of administration, as well as a clinical narrative interpretation. Where appropriate to the nature of the disability (e.g., learning and cognitive disorders) the report should contain both summary data and specific tests scores.

Diagnostic methods that are congruent with the particular disability and current professional practices in the field are expected. Methods may include formal instruments, medical examinations, structured interview protocols, performance observations and unstructured interviews. If results from informal or non-standardized methods of evaluation are reported, a clear explanation of their role and significance in the diagnostic process should be included.

A description of the current functional limitations

Documentation must include information on how the disability currently impacts the individual. A combination of the results of formal evaluation procedures, clinical narrative, and the individual’s self-report is the most comprehensive approach to fully documenting impact.

Documentation should be thorough enough to demonstrate whether and how a major life activity is substantially limited by providing a clear sense of the severity, frequency and pervasiveness of the disability.

While relatively recent documentation is recommended in most circumstances, common sense and discretion in accepting older documentation of disabilities that are permanent or non- varying are recommended. Likewise, changes in the disability and/or changes in how the disability impacts the individual as a result of growth and development may warrant more frequent updates in order to provide an accurate picture. Additionally, if changes in accommodations are needed, updated documentation may be required. In other words, the recency of the documentation depends on the facts and circumstances of the student’s disability and the accommodations requested.

USM and MCC Disability Support Services offices, based on their staff members’ professional judgment, may consider accepting older documentation on a provisional basis. Accommodations may be provided in the interim, on a case by case basis, while the student obtains the necessary updated documentation.

A description of the expected progression or stability of the disability

Documentation must provide information on expected changes in the functional impact of the disability over time and context, if the disability is cyclical or episodic in nature (e.g., bipolar disorder, some chronic medical conditions). Information regarding known or suspected environmental triggers to episodes can be helpful in anticipating and planning for varying functional impacts. If the disability is not stable, information on interventions (including the individual’s own strategies) for exacerbations and recommended timelines for reevaluation are most helpful.

A description of current and past accommodations, services and/or medications

Documentation should include a description of both current and past accommodations, services, medications, auxiliary aids and assistive devices, including their effectiveness in ameliorating functional impacts of the disability. A discussion of any significant side effects from current medications or services that may impact physical, perceptual, behavioral or cognitive performance can be helpful. While accommodations provided in another setting are not binding on the current institution, they may provide insight in making current decisions.

Recommendations for reasonable accommodations and services

Documentation should include recommendations for accommodations and services. Recommendations from professionals with a history of working with the student can provide valuable information for review and planning. The recommended accommodations and services should be logically related to the student’s functional limitations. 

While the postsecondary institution has no obligation to provide or adopt recommendations made by outside entities, those that are congruent with the institution’s courses, programs and services may be appropriate. The postsecondary institution may substitute another accommodation, if it is considered to be effective and parallel to the one recommended and/or requested. When recommendations go beyond equitable and inclusive services and benefits, they may still be useful in suggesting alternative accommodations and services. 

A description of accommodations and services typically available at the postsecondary level is provided in Appendix B. This list is intended only to provide examples. It is not exhaustive and should not limit the recommendations for reasonable accommodations made by an evaluator for an individual student.

Recommendation for Creating Disability-Specify Documentation Guidelines

While it is neither practical nor desirable to create specific documentation requirements for every condition that may be considered a disability, individual institutions may choose to establish protocols for more common disabilities (e.g., learning disabilities, ADHD). In doing so, USM institutions and Maryland community colleges should incorporate the seven essential guidelines for quality disability documentation outlined above.