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, documentation needs to reflect the current status of the individual's functional limitations and explain why the requested testing accommodations are needed. If documentation is more than five years old, it is not current and must be updated. Note that the currency requirement may differ depending on the particular disability. For example, for ADHD, the standard is generally three years. For psychiatric disorders, the generally accepted standard is an update that is not more than six 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.

I heard that ETS is no longer flagging test scores that are reported to score recipients. Is this true?

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 does not charge for testing accommodations.

What can a candidate do if he or she cannot afford an evaluation or an update of the last evaluation?

ETS is not 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 Questions

How long does the review process take?

If the test taker submits a properly completed Certification of Eligibility: Accommodations History (COE), found in the Bulletin Supplement for Test Takers with Disabilities or Health-related Needs, without documentation, and is eligible to be approved for accommodations through this process, it will take approximately two to three weeks to process the request. If the candidate must submit documentation for review, the process may take up to six weeks, or even longer. For details, please refer to the FAQ section about the COE further down this page.

If documentation does not 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. See the ETS policy statements for specific documentation requirements.

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 is 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 are 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 the candidate has been approved for accommodations within the previous two years, the documentation is still current, and the individual is requesting the same accommodations for which they were previously approved, the processing of the request may be expedited by submitting only:

  • Parts I and II of the Applicant Request for Nonstandard Testing Accommodations form, found in the Bulletin Supplement
  • the test program's registration form
  • the appropriate fee
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 do not 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, the individual may email us at stassd@ets.org or write to ETS Disability Services, P.O. Box 6054, Princeton, NJ 08541-6054.

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 Questions

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

ETS has created a form called the Certification of Eligibility: Accommodations History, or COE, which is available in the Bulletin Supplement for Test Takers with Disabilities or Health-related Needs. The COE serves to verify any accommodations that the test taker is currently using or has recently used.

The COE must be completed and signed by a qualified professional at the test candidate's school or place of employment who is familiar with their disability status. This person must certify that the documentation on file meets ETS Documentation Criteria and supports the testing accommodations the test taker is receiving. If appropriate, the form can be completed by a representative of a local vocational rehabilitation office.

The COE can also be used as a shortcut for many applicants who currently receive certain accommodations in college or on the job. Test takers with LD and/or ADHD requesting 50 percent extended time and/or extra break time can use the COE in this way. Additionally, many test takers who are blind, have low vision or are deaf or hard of hearing can use the COE as a shortcut. (Refer to the Bulletin Supplement for Test Takers with Disabilities or Health-related Needs, pages 8 and 9, for details about using the COE if the test taker has low vision or is blind, deaf or hard of hearing.)

If the test taker sends disability documentation along with a signed COE, will that increase the chance of receiving testing accommodations?

Sending disability documentation when it is not 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 Questions

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 five-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 do not have the same opportunity as college disability service personnel to meet and speak to each of the 12,000 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 Asperger's so complex?

The new terminology in the DSM-5 for Asperger's is Autism Spectrum Disorder (ASD). Documenting this disability 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. Please see ETS's new policy statement for 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. Please refer to ETS's new policy statement for Documentation of Intellectual Disabilities in Adolescents and Adults. Appendix B includes a listing of clinical instruments in common use for documenting intellectual disabilities in adolescents and adults.