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Disabilities and Health-related Needs

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Frequently Asked Questions for Evaluators

Get answers to frequently asked questions, including answers for diagnosticians and clinicians who write reports.

General questions

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

Although these disabilities are lifelong, the impact they have on current functioning changes over time. Therefore, the documentation needs to reflect the current status of the test taker’s functional limitations and explain why they need the testing accommodations they requested. Note that the currency requirement may differ depending on their particular disability or disabilities. For example, for ADHD, the standard is generally 5 years. See Documentation Update on LD/ADHD for more information.

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. The test taker can also contact their Disability Services (DS) coordinator or counselor on campus. See Lower-Cost Evaluation Options for more information.

Review process

If a test taker is denied accommodations or disagrees with the accommodations that are approved, what can they do?

ETS will send a letter of explanation if we do not approve a request. In some circumstances, it may be possible to update or supplement relevant portions of the documentation and prevent the 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. The test taker may correct any deficiencies outlined in the letter and resubmit the request. If the test taker has any questions about ETS's procedures, they may contact us.

Certification of Eligibility: Accommodations History (COE)

Why can't the professional who diagnosed the test candidate's disability sign off on the COE?

ETS requires a neutral party to verify that the documentation is legitimate and conforms to ETS policy. ETS also seeks verification that the institution or place of employment granted the accommodations and that the test taker is using them.

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.


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.

Why is there a need for test takers to send in cognitive and achievement testing for disabilities such as ADHD?

A disability or diagnosis alone, such as ADHD, isn’t sufficient to support the need for testing accommodations. The ADAAA requires that the disability result in a substantial limitation to a major life activity. For ETS purposes, this means that the current functional impact of the disability on test taking must be clearly indicated. Objective cognitive tests that measure information processing, as well as memory, organizational and sequential thinking skills under both standard timing and extended-time conditions, can be very helpful in supporting the need for the requested accommodations. Results from objective cognitive tests are especially important in determining the need for 100% extended test time. Depending on the type of accommodations requested, academic achievement testing may be necessary. For example, if a reader is requested as an accommodation, achievement measures pertinent to reading may be required.

What does complete disability documentation look like?

Guidelines for Writing Diagnostic Reports provide greater detail on what comprehensive documentation might look like. For our purposes, the documentation should include the following:

  1. a specific diagnosis and rationale for it, supported by the diagnostic battery and/or clinical assessment that meets the DSM 5 criteria or ICD code
  2. historical information — developmental, educational and/or medical information that includes information on response to treatment (if applicable) relevant to the diagnosed disability
  3. evidence that alternative explanations are ruled out (e.g., differential diagnoses, motivational factors, personality issues)
  4. evidence of the current functional limitations resulting from the disability as supported by objective data from quantitative testing and qualitative self-report
  5. an appendix of actual score summaries of standard or scaled scores and percentiles for all subtests, including index and cluster scores for LD and LD/ADHD documentation.

Does ETS accept documentation from evaluations conducted via tele-assessment?

Yes. ETS recognizes that tele-assessment may provide greater flexibility to test takers and will accept documentation from an evaluation conducted via tele-assessment or via a “hybrid” format, i.e., a combination of in-person and tele-assessment services. The evaluation should be conducted according to the best practices and standards of the profession of the clinician who conducts it. Tele-assessment involves special considerations and an evaluator conducting tele-assessment should have specific training in this domain. Please see the ETS Tele-Assessment Guidance (PDF) for additional information regarding tele-assessment.

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 3 domains: conceptual, social and practical. See Documentation of Intellectual Disabilities in Adolescents and Adults for more information. See Appendix B for a list of clinical instruments in common use for documenting intellectual disabilities in adolescents and adults.

Is academic achievement testing required for all disabling conditions?

If the test taker is requesting devices such as a calculator or a spellchecker, achievement testing is necessary to determine the individual's functional limitations in the relevant academic area.

What documentation is needed if a candidate has multiple disabling conditions?

It’s best to provide the most complete packet of information possible when multiple disabling conditions are identified. If a test taker has multiple disabilities, it is best to document functional limitations associated with each of their disabilities. However, if documentation is being submitted for only one disability, please be sure there is a discussion of functional limitations and a disability-related rationale for each requested accommodation.