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Student Disability Services

Documentation Requirements

Qualified Assessors

The Rehabilitation Act of 1973 (Section 504) and the American Disabilities Act (ADA) of 1990 state that qualified students with disabilities who meet the technical and academic standard of Clemson University might be entitled to reasonable accommodations. Under these laws, a disability is defined as any physical or mental impairment which substantially limits a major life activity. Student Disability Services at Clemson University does not provide disability documentation for students. It is the student’s responsibility to provide appropriate documentation to this office and to request accommodations.

NOTE: Medical documentation alone can only establish that the student has an impairment. Everyone with an impairment is not considered disabled under the law. In addition to evidence of the existence of an impairment, a determination must also be made regarding the impact the impairment has on an individual. The determination of whether an individual has a disability is not necessarily based on the impairment the person has, but rather the effect of the impairment on the life of the individual. Thus, the student’s impairment must “substantially limit” his/her ability to participate in and/or to benefit from the educational programs and services offered by the institution.

The assessment of pertinent data and the ultimate determination of whether a student has a substantial limitation involves the consideration of a number of factors, including but not limited to: the general nature of the impairment, the specific manifestations of the impairment, the impact of the impairment on the student’s major life activities, and the student’s present abilities and limitations in relationship to the educational environment in question or to a similar or comparable environment. This is an extremely complicated assessment process, and the determination is one that disability specialists have the expertise to make and are, in fact, responsible for making that decision on the institution’s behalf.

REMEMBER — In providing academic adjustments, (an institution) does not guarantee the success of the student, rather it commits itself to providing that student whatever assistance is necessary to ensure that a disabled student has the same opportunity of academic success as any other student in the same program…We strive to level the playing field.

Source: Salome Hayward, JD. Hayward, Lawton and Associates Inc. 2002.

Learning Disability

We suggest that documentation for a Learning Disorder or Attention Deficit Disorder follow the Association on Higher Education and Disability (AHEAD) guidelines as amended in July 1997. Specific guidelines are outlined below:

Learning Disorders
  1. All reports should be current (no more than three years old), on letterhead, typed, dated, signed and otherwise legible. A current report is necessary because a student’s needs may vary over time and from setting to setting. Even reports two or three years old should have recommendations appropriate for post-secondary settings. If at all possible, the evaluator should review the report and update the recommendations. Therefore, IEPs (Individual Educational Plans) or 504 Plans, although providing information about a student’s educational experience, are not sufficient documentation to establish the student’s eligibility for accommodations.
  2. The documentation should be substantive and comprehensive to be acceptable. Such psychoeducational documentation will include:
    • summary of a comprehensive interview that should include such information as presenting problem(s); developmental, psychosocial, medical and family history; academic history, including the results of previous testing; instructional foundation in the areas or purported dysfunction; past performance in areas of difficulty; and history and effectiveness of accommodations used in past educational settings
    • a comprehensive assessment of aptitude (including a complete intellectual assessment) with all subtests, standard scores and percentiles reported
    • a comprehensive academic achievement battery that covers the relevant domains such as reading comprehension, decoding, written expression and the like with all subtests, standard scores and percentiles reported
    • an assessment of specific areas of information processing such as short- and long-term memory, auditory processing, processing speed, executive function and visual perception/processing with all subtests, standard scores and percentiles reported
    • evidence that the evaluator has ruled out alternative explanations for academic problems such as a poor or inadequate educational background or foundation, poor motivation, poor study skills, emotional problems, medical problems, or other possible alternatives that might mimic a learning disability when one is not actually present
    • a detailed description of how this impairment significantly limits a major life activity in an academic setting.
  3. The current psychoeducational evaluation should be provided by a licensed psychologist or appropriately credentialed mental health professional with appropriate training and supervised experience in psychoeducational assessment.
  4. In order to make an informed decision about the student’s learning disorder and need for accommodation, the report should provide the following:
    • the nature of the learning disorder and the specific diagnosis as delineated in the Diagnostic and Statistical Manual-IV (DSM-IV) or current edition. There must be a clear statement of whether or not a learning disorder exists, including a rule-out of alternative explanations for the stated learning problems. Terms such as “seems,” “appears,” “suggests” or “probable” in the diagnostic summary will be considered equivocal and not supporting a definitive and conclusive diagnosis.
    • a description of the severity and longevity of the condition
    • recommendations should be appropriate for a post secondary setting and the report should state a clear rationale for each accommodation requested based on the test findings. Reports written for the secondary setting apply standards and guidelines that vary widely among states, counties and even school districts. Such reports often contain recommendations that are unworkable, unsuitable or otherwise inappropriate for a post-secondary setting.
  5. Students seeking assistance regarding foreign languages will enhance the likelihood of gaining accommodations if their evaluations can document the following:
    • a developmental delay in speech acquisition or other type of early difficulty in sound production or sound-symbol association ability
    • evidence of a significant on-going auditory processing problem
    • a history of difficulty in acquiring a second language during the K-12 years
    • a history of inability to perform adequately in college-level foreign language classes
    • evidence of deficits in the phonological, syntactic, semantic and memory skills necessary in foreign language learning as measured by such instruments as the Modern Language Aptitude Test or the Comprehensive Test of Phonological Processing. However, an evaluation relying solely on these instruments may not be sufficient in establishing the need for accommodations.

NOTE: High school IEP, 504 plan, and/or letter from a physician or other professional will not be sufficient to document a learning disability. While such documentation can be helpful in establishing the student’s learning history, a recent psychological evaluation is still necessary to confirm current needs.

Attention Deficit Hyperactivity Disorder

We suggest that documentation for a Learning Disorder or Attention Deficit Disorder follow the Association on Higher Education and Disability (AHEAD) guidelines as amended in July 1997. Specific guidelines are outlined below:

Attention-Deficit Hyperactivity Disorder

Rationale: Attention-Deficit Hyperactivity Disorder poses a particular difficulty to the evaluator of adults and older adolescents. It does so not only because it requires the mental health professional to delve deeply into the individuals past behavior, but because ADHD shares overlapping symptoms with a host of psychiatric disorders and medical conditions. Therefore, a complete evaluation that includes information from multiple sources, objective measures such as rating scales and personality inventories, diagnostic clinical interviews, academic records, etc., has the best chance of making a clear and definitive diagnosis possible.

Even students who were diagnosed as children or young adolescents either by a physician, psychologist or other mental health professional, need a current evaluation because the symptom pattern can change over time, the level of severity of impairment will alter in specific areas over time, and the accommodation needs may differ as a student gets older and/or develops compensatory skills and coping strategies.

These criteria will be effective for all new clients who are enrolled on or following January 2003; students declared eligible prior to this date may be asked to supplement existing documentation if a request for additional accommodation or action is made.

  1. The report should be current (no more than three years old) on letterhead, typed, dated, signed and otherwise legible.
  2. The ADHD evaluation should be conducted by a licensed psychologist or other mental health professional qualified by academic course work, supervised training, and experience.
  3. The ADHD evaluation should be comprehensive:
    1. Evidence of early impairment. Because ADHD is by definition an early childhood disorder, it is essential that evaluation contain a clinical summary of historical information establishing presence of the disorder in childhood. The evidence should come from multiple sources. Examples of where this information may be gleaned are:
      • transcripts and report cards
      • teacher comments, IEPs, 504 Plans
      • parent and student comprehensive life-span questionnaires, parent and student interviews
      • previous psycho-educational testing
      • retrospective rating scales completed by parents, guardians, siblings, former teachers and/or other relatives who have direct knowledge of the student’s childhood behavior.
    2. Evidence of current impairment. The evaluation should contain objective evidence of on-going inattentive and/or hyperactive/impulsive behavior that significantly impairs functioning in two or more settings. Again, this evidence should come from multiple sources and not just self-report. This information can be garnered from:
      • rating scales completed by student, former teachers, parents, siblings, significant others or friends who have known student at least six months, or extended family members who have direct knowledge of the student’s behavior.
      • clinical interviews and comprehensive questionnaires completed by students and parents or guardians that cover developmental history, medical history, academic history, family history for presence of ADHD and other learning disorders, educational problems or psychological difficulties.
      • review of previous testing
      • review of school records
      • personality inventories such as the Personality Assessment Inventory, the Symptom Checklist 90-Revised, and the Minnesota Multiphasic Personality Inventory-II are good sources of information on overall psychological functioning.
    3. Alternative diagnoses or explanations should be explored. The examiner should investigate the possibility of a dual diagnosis or an alternative psychological, behavioral, neurological or personality disorder that might confound the diagnosis of ADHD. The clinical interview and personality inventories such as those mentioned above are primary but not the only appropriate resources for this information assisting in this process.
    4. Other psychological testing.
      • IQ Tests. Routine administration of a complete individually administered IQ test, such as the Wechsler IQ Test is unnecessary. However, they might be appropriate when there are specific questions about specific cognitive deficits. In most cases a brief screening measure is sufficient. No evaluation should rely mainly on IQ test data in making an ADHD diagnosis.
      • Continuous Performance Tests. As of this writing, none of the popular CPTs has proven reliable when testing adults. They might be useful to the evaluator by providing an opportunity to observe the student cope with a task of sustained attention. However, no evaluation should rely heavily on a CPT when making an ADHD diagnosis.
    5. Evaluation must include a specific diagnosis. The evaluation should contain a specific differential (the student’s impairments are due to ADHD and not some other disorder) diagnosis of ADHD that uses direct language and eschews terms such as “suggests,” “is indicative of” or “attention problems.” The diagnosis should be based on the Diagnostic and Statistical Manual–IV.
    6. Rationale for accommodations. Each student should be treated as an individual. Therefore, any post-secondary accommodation suggested for a student should be accompanied by the reasons that justify the granting of that accommodation.
  4. A typical ADHD evaluation might include but is not limited to the following:
    1. Brief IQ Screen: e.g., Kaufman Brief Intelligence Test, Shipley Institute of Living Scale.
    2. Comprehensive histories: developmental, medical, educational, social, psychological, occupational, substance use and family.
    3. Multiple source interviews: Interview with student. Corroborative interviews with parents, guardians, teachers, significant others, extended family members, etc., as available.
    4. Rating scales: scales assessing student’s retrospective behavior from multiple sources such as student, parents or guardian, former teachers, siblings, significant others, etc. Examples: DSM-IV based scales, Wender Utah Rating Scale.
    5. Rating scales: scales assessing student’s current behavior from multiple sources such as student, parents or guardian, former teachers, siblings, significant others, etc. Examples: DSM-IV based scales, Attention-Deficit Scale for Adults, Conners Adult ADD Scales.
    6. A personality inventory: an instrument such as the Symptom Checklist 90-Revised, the Personality Assessment Inventory, or the Minnesota Multiphasic Personality Inventory-II.
    7. CPT: A CPT may be included as a part of an evaluation such as the Conners Continuous Performance Test, the Gordon Diagnostic System, or the Test of Variable Attention. No evaluation should rely solely or too heavily on this type of test for a definitive diagnosis.
  5. While close adherence to the guidelines greatly increases the likelihood of an evaluation’s acceptance, there might be situations where the documentation could deviate from the guidelines and still be acceptable. Each individual’s circumstances will be considered on a case-by-case basis. If you have any questions regarding your documentation, please call Disability Services at 864-656-6848.

NOTE: High School IEP, 504 Plan, and/or letter from a physician or other professional will not be sufficient to document ADD or ADHD. Medication cannot be used to imply a diagnosis.

Basic Test Battery for Determination of LD/ADHD in College Students

The following is considered a basic list of tests that should/could be employed. Special situations might require other tests to be employed. When previous testing is reviewed, comparable tests will be accepted.

  1. Intelligence: Wechsler Adult Intelligence Scale-III
  2. Reading: decoding and comprehension
    Appropriate subtests Woodcock-Johnson Psychoeducational Battery-III
    Nelson-Denny Reading Test
  3. Math: calculation and applied problems
    Appropriate subtests Woodcock-Johnson Psychoeducational Battery-III
    Detroit Tests of Learning Aptitude
  4. Written Expression
    Spontaneous writing sample (expository essay)
    Appropriate subtests Woodcock-Johnson Psychoeducational Battery-III
    Wide Range Achievement Test (spelling only)
  5. Oral Expression
    Peabody Picture Vocabulary Tests
    Event description (scored holistically)
  6. Information Processing
    1. Memory
      1. California Verbal Learning Test
      2. Memory subtests of WJ-III
      3. Wechsler Memory Scales
    2. Visual Processing
      1. Appropriate WJ-III subtests
      2. Bender Gestalt
      3. Test of Visual Perception Skills
    3. Auditory Processing
      1. Appropriate WJ-III subtests
      2. Goldman-Firstoe-Woodcock Test of Auditory Discrimination
  7. ADHD (See Guidelines for Attention-Deficit Hyperactivity Disorder Documentation.)
    1. Comprehensive Developmental History
    2. Structured ADHD Interview (similar to Barkley’s)
    3. Retrospective Rating Scales (parent and child)
      1. ADHD Behavior Checklist
      2. Wender Utah Rating Scale
    4. Rating Scales Covering Current Behavior (parent and client)
      1. Brown ADD Scales
      2. Attention-Deficit Scale for Adults
  8. Social/Emotional
    1. State-Trait Anxiety Inventory (Beck Anxiety Inventory)
    2. Beck Depression Inventory
    3. Personality Assessment Inventory
    4. Clinical Interview

Medical

A letter or report from treating physician, orthopedic specialist, audiologist, speech pathologist or ophthalmologist (as appropriate), including:

  1. Clearly stated diagnosis, ruling out alternative explanations and diagnoses
  2. Defined levels of functioning and any limitations
  3. Current treatment and medication
  4. Current letter/report (within one year), typed, dated and signed on letterhead (with recommendations for post-secondary accommodations relative to the diagnosed disability, including rationale and duration for which these accommodations should be provided based on the current assessment).

Traumatic Brain Injury (TBI)

A comprehensive evaluation report by a rehabilitation counselor, speech-language pathologist, orthopedic specialist and/or neuropsychologist (or other specialties as appropriate), including:

  1. Assessment of cognitive abilities, including processing speed and memory
  2. Analysis of educational achievement skills and limitations (reading comprehension, written language, spelling and mathematical abilities)
  3. Defined levels of functioning and limitations in all affected areas (communication, vision, hearing, mobility, psychological, seizures, etc.)
  4. Current report/letter typed, signed and dated on letterhead (within one year with recommendations for post-secondary accommodations relative to the diagnosed disability, including rationale and duration for which these accommodations should be provided based on the current assessment).

Psychological

A letter or report from a mental health professional (psychologist, neuropsychologist, psychiatrist), including:

  1. Clearly stated diagnosis (DSM-IV criteria), ruling out explanations and diagnoses (Terms such as “appears,” “seems,” “suggests” or “probably” in the summary will be considered equivocal and not supporting a definitive and conclusive diagnosis.)
  2. Defined levels of functioning and any limitations
  3. Supporting documentation (i.e. test data, history, observations, etc.)
  4. Current treatment and medication
  5. Current letter/report (within one year), typed, dated and signed on letterhead (with recommendations for post-secondary accommodations relative to the diagnosed disability, including rationale and duration for which these accommodations should be provided based on the current assessment).

Note: Because of the changing nature of psychiatric disabilities, an updated narrative specifying diagnosis, medication, and current functional limitations is required annually.

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