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Disabilities and Health-related Needs

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Frequently Asked Questions for Disability Service Providers

General questions

Why does a test taker need to be reevaluated if a disability (such as a learning disability, ADHD or autism spectrum disorder) is lifelong?

Although these disabilities are lifelong, the impact they have on current functioning changes over time. Therefore, their documentation needs to reflect the current status of their functional limitations and explain why they need the testing accommodations they requested. If documentation is more than 5 years old, it’s not current and needs to be updated. Note that the currency requirement may differ depending on their particular disability or disabilities. For example, for ADHD, the standard is generally 5 years. For psychiatric disorders, the generally accepted standard is an update that is not more than 12 months old, submitted with the underlying evaluation report. See Updating Documentation for LD/ADHD for more information.
 

Are the ETS disability documentation guidelines in compliance with the ADAAA?

The ADAAA requires institutions to provide equal access and opportunities to individuals with disabilities. However, its regulations state that each institution can establish its own standards or guidelines for practice. The ETS documentation guidelines are designed to comply with the intent of the ADAAA, as well as to ensure fairness to all test takers, while maintaining the integrity of the test.
 

May a test taker make a special request for accommodations needed for a medical condition, even if these accommodations aren't listed on the request form?

Yes, on Part II, "Accommodations Requested," one can write in the accommodations required for a medical condition. These requests will require documentation from a qualified professional, such as a medical doctor. With proper support, ETS may permit test takers to take additional rest breaks for snacks or medication or to use the bathroom. A footstool, earplugs, water in a closed capped container, a simple magnifying device, special lamps, an adjustable table and chair, or felt-tip pens might also be permitted, if warranted.
 

May a test taker request a paper-delivered format for a test that is usually given only on computer?

Yes, a paper format may be requested as an accommodation, but the test taker must have a documented disability (not a preference) that supports a legitimate need for paper format. The test candidate will need to submit documentation for review that meets ETS's Documentation Criteria.
 

May a test candidate take to the test center any assistive technology device(s) that this person ordinarily uses in school or at work?

A candidate may request the use of assistive technology device(s) by submitting appropriate documentation to ETS for review. The documentation must support the claim that the assistive device or technology is warranted based on the nature of the disability. ETS may be unable to grant such a request if it is determined that it infringes upon test security requirements or, in the case of computer-delivered tests, that it is incompatible with ETS's existing computer test delivery hardware and software.
 

Does ETS no longer flag test scores that are reported to score recipients?

ETS has discontinued flagging almost all scores for tests that are taken with accommodations. For example, if a test taker receives additional time or extra breaks, the score will no longer be flagged in the report. In rare instances, ETS will flag the score report as a "nonstandard administration" only if the test is significantly altered.
 

Is there an additional fee for test accommodations?

No, ETS doesn’t charge for testing accommodations.
 

What can a candidate do if they can’t afford an evaluation or an update of the last evaluation?

ETS isn’t responsible for the cost of an evaluation, but resources are available that might be able to help. If the disability documentation is dated or inadequate, the candidate can contact the local Division of Vocational Rehabilitation office and meet with a counselor. This is a free service available to any individual with a documented disability. As the Disability Services (DS) coordinator or counselor on campus, you may also be able to provide the test taker with resources available in your area. Many colleges and universities with strong school psychology programs perform evaluations at a reduced fee. See Updating Documentation for LD/ADHD for more information.
 

Review process

How long does the review process take?

If the test taker submits a properly completed Certification of Eligibility: Accommodations History (COE) without documentation, and is eligible to be approved for accommodations through this process, it will take approximately 2–3 weeks to process the request. If the candidate must submit documentation for review, the process may take up to 6 weeks, or even longer.

If the candidate is requesting the same accommodations approved within the past 2 years, they can expedite the process. See how to request previously approved accommodations.

If documentation doesn’t support the request for accommodations, the test taker will receive a letter of explanation from ETS. In such instances, the test taker may choose to address any deficiencies in the documentation and resubmit the request. To prevent delays, the candidate should be sure that the documentation meets ETS's documentation criteria.
 

Why does it take so long to process accommodation requests?

ETS strives to review requests for accommodations as quickly as possible. Given the large number of requests we receive, it’s important that requests be submitted as early as possible to ensure a decision before the test date.
 

ETS reviews requests for accommodations in the order in which they’re received. The specific approval process may differ depending on the nature of the request. For example, if a test taker seeks a minor accommodation, such as a footstool to support an injury or a test break to permit taking medication, a letter from their medical professional will suffice, and usually evaluation of such a request requires only a short time. If a test taker is denied accommodations or disagrees with the accommodations that are approved, what can the test taker do?

ETS will send a letter of explanation if we don’t approve a request. The test taker may correct any deficiencies outlined in the letter and resubmit the request. If the test taker has any complaints about ETS's procedures, they may contact us.
 

What should the candidate do if the request for accommodations is turned down because the documentation does not conform to ETS's documentation criteria?

In some circumstances, it may be possible to update or supplement relevant portions of the documentation and prevent a need for a complete reevaluation. Whenever possible, Disability Services staff will provide test takers with specific information about the ways in which their documentation is inadequate and how it should be updated or supplemented. See Reasons Why Documentation Is Deemed Insufficient by ETS for more information.
 

Certification of Eligibility: Accommodations History

What is the purpose of Part III — the Certification of Eligibility: Accommodations History (COE) form?

The COE, available in the Bulletin Supplement, serves to verify any accommodations that the test taker is currently using or has recently used.

It can also be used as a shortcut for many applicants who currently receive certain accommodations in college or on the job, which significantly reduces the wait time for a response from ETS. See Certification of Eligibility: Accommodations History.
 

Should the test taker send disability documentation along with a signed COE?

No. Sending disability documentation when it isn’t required will cause a considerable delay in processing a request due to the time needed to review documentation. A test taker who is eligible to be approved for accommodations on the basis of the COE alone should send only the appropriately completed COE without documentation.
 

Documentation

What does ETS mean by a "functional limitation?"

Under the Americans with Disabilities Act Amendments Act (ADAAA), not every impairment is a disability. For an impairment to qualify as a disability under the ADAAA, it has to be "substantially limiting" to a major life activity (e.g., seeing, talking, hearing, learning, walking, etc.). Thus, having a disability or a diagnosis alone may not be sufficient to support the need for testing accommodations. The documentation needs to clearly establish that the functional limitations resulting from a disability significantly impact the way a person performs a major life activity, compared to the "average person," before an accommodation can be considered.
 

Does the documentation recency requirement also apply to test takers who are deaf or legally blind or who have physical disabilities of a permanent and unchanging nature?

No. If a disability is a physical or sensory impairment of an unchanging nature, e.g., blindness or congenital deafness, documentation does not need to be updated.
 

What is the policy regarding LD and LD/ADHD documentation shelf life?

ETS is aware of the cost borne by test takers with learning disabilities whose documentation may exceed the 5-year limit and who are seeking accommodations for our tests. At the graduate- and professional-school levels, these individuals often do not have insurance to cover the cost of diagnostic reports. To address this concern, ETS has adopted a documentation update policy.
 

Will ETS be relaxing their documentation requirements based on the ADAAA and the Association on Higher Education and Disability (AHEAD) guidance?

ETS makes every effort to not be burdensome in our requests for documentation. However, we don’t have the same opportunity as college disability service personnel to meet and speak to each of the 15,000 test takers who request accommodations each year. ETS's documentation process is compliant with the ADAAA. The AHEAD document provides guidance and does not have the authority of legal regulations.

We have instituted a number of shortcuts, such as the COE, by which test takers can be approved for certain accommodations without the need to submit documentation. If the documentation date is beyond the limits stated in our “shelf life” policy, the test taker should submit the outdated material for our consideration. We will make every effort to help the individual find a less costly way to obtain the necessary update. The disability service provider can also assist the test taker by providing a letter that explains why, in their professional opinion, the person needs the accommodations approved for use at their institution. In this letter the disability service provider should also describe how frequently the student uses the accommodations and how effective those accommodations have been.

Why does ETS require academic achievement testing in the evaluation for ADHD when there is no underlying learning disability?

Academic achievement testing is needed in the ADHD documentation because it allows us to see the functional impact of the ADHD on the test taker's academic skills in a situation most similar to taking a standardized, high-stakes exam.
 

Why does ETS not accept documentation from a medical doctor for the diagnosis of ADHD?

Most medical doctors do not perform assessments that will show the functional limitations resulting from ADHD in a test-taking situation. Checklists of symptoms and the effectiveness of pharmacological interventions simply do not provide sufficient information to determine the amount of extended time required or what other accommodations a candidate may need.
 

Why is documenting Autism Spectrum Disorder (ASD) so complex?

Documenting ASD is complex because individuals with ASD often have co-occurring psychiatric manifestations (e.g., anxiety, depression, etc.), ADHD and/or learning disabilities (LD) that may go along with their primary diagnosis. Often, individuals with ASD exhibit behaviors affecting communication and social pragmatics. In addition, the use of medications has become increasingly common in the treatment of ASD. Disability documentation needs to address a variety of these co-occurring conditions that may impact the test-taking process. See Documentation of Autism Spectrum Disorder in Adolescents and Adults.
 

Is an IQ test all I need to document intellectual disabilities?

Intellectual functioning is assessed using a comprehensive measure of intelligence, typically the Wechsler Adult Intelligence Scale (WAIS-IV) or some other measure of intellectual ability. In addition to a test of intellectual functioning, adaptive behavior must also be assessed in three domains: conceptual, social and practical. See Documentation of Intellectual Disabilities in Adolescents and Adults. See Appendix B for a list of clinical instruments in common use for documenting intellectual disabilities in adolescents and adults.