1

A Dynamic Roadmap: Navigating Evolving Documentation Standards for LD & ADHD

Under the ADAAA

THE guidelines

• 1997 AHEAD Guidelines for Documentation of a Learning Disability in Adolescents and Adults– Qualifications of the evaluator– Diagnostic interview– Assessment: aptitude, achievement, information

processing– Specific diagnosis– Test scores– Clinical summary – Recommendations for accommodations

2

Beginning the journey

• Focus of documentation review was on:– the completeness of the testing– date of the testing

• Focus was not on:– history and anecdotal information – student self-report

3

Documentation Checklist, circa 1997

4

Benefits to 1997 guidelines

• Thorough review of a student’s strengths and weaknesses

• Data about current functional limitations, which allowed the approval of a complete set of reasonable accommodations

• Meeting the requirements for high stakes testing agencies for graduate entrance exams

5

EASIER

6

Documentation commonly denied when

• Qualifications of evaluator were missing

• Documentation was not recent

• A full and comprehensive assessment was not provided

• Standard scores and/or percentiles not included

• The evaluator did not include recommendations for accommodations

7

Checklist for denied documentation

8

Disadvantages to 1997 guidelines

• Testing provided by high schools often not what required at post-secondary

• Significant cost to students if new testing was required

• Students who were unable to shoulder the cost not accommodated

• “Screening”

9

The next leg of the journey

2004 AHEAD Best Practices: Disability Documentation in Higher Education

• Encouraged a more comprehensive view

• Less “strict”, more flexible

• Greater emphasis on professional judgment

10

Our response

• Documentation Review Committee

• Issues frequently discussed:– Date of documentation and what were the

situations in which reports that were more than 3 years old would be acceptable

– Weighing of history of accommodations vs. current data

– Intra-individual differences

11

Documentation checklist, circa 2007

12

New directions

December, 2010 AHEAD Audio-conference: “Implementing the ‘New’ ADA and DOJ Regulations”

• ADAAA provides an opportunity to re-think our documentation guidelines for LD and ADHD

13

Key take-aways from “Implementing the ‘new’ ADA”• Give considerable weight to documentation

of past accommodations received in similar testing situations

• Give deference to treating professionals, clinical and professional narrative

• Value student self-report

• Exclude ameliorative impact of mitigating measures in determining coverage

14

Our response

Major focus of documentation review:

• Determining substantial limitation

• Considering all available materials (no screening)

• Gathering input from students

15

Detours

• “Buckets”

• Accommodation-based review

16

Our response

• Focus on determining substantial limitation– “objective, authentic, relevant” (Brinckerhoff

and Banerjee, 2011)– “The amount of information, documentation, and

analysis involved in making reasonable accommodation determinations will frequently be greater than that necessary for making disability determination” (Hayward, 2011, p 56)

17

Documentation worksheet, circa 2012

18

Worksheet discussion

• information gathering

• analysis of information to determine accommodations

19

Outcomes

• Asking for additional information from the students in order to have a complete picture and make the case for approving accommodations

• Reviewing far more documentation than we had in the past (3-fold), and denying far less; more students registering with DSS

• Documentation Review Committee allows both individual review and timely response

20

A little further down the road

May 2012: AHEAD’s “Supporting Accommodation Requests: Guidance on Documentation Practices”

• Individual review

• Common-sense standard

• Non-burdensome

• Relevant

21