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Why your IEP plan probably isn't adequate for post-high school accommodations

Many people are surprised to discover that their educationally-identified condition that

they received an IEP plan for during their K-12 years is insufficient for accommodations in college , standardized testing, licensure testing, or the workplace. Here are some of the key reasons why and what you can do about it.


Laws that apply to IDEA plans only apply to K-12 public schools


The Individuals with Disabilities Education Act (IDEA) applies to public schools Pre-K through 12th grade, up to age 21. IDEA stipulates that public schools must provide access to free and appropriate education for children identified to have one of 15 specific conditions, measured by school/ district personnel to result in "educational need." This means that even if a child has a disability documented by a health or mental health professional outside of the school or district, the school is not required to offer any accommodations-- not unless their own identification process identifies the child as having an educational need. IDEA is the source of regulations around who receives special education services in public schools.


Disability-related laws that apply to postsecondary (i.e., after high school) include Section 504 of The Rehabilitation Act of 1973 and The Americans with Disabilities Act (ADA). Both are federal laws that are broadly designed to remove impediments to participation for individuals who have disabilities. Individuals covered include people with documented disabilities and those who may be perceived to have a disability, including diseases. Individuals and their families are responsible for providing adequate documentation of their disability and need for accommodation.


Accommodation are qualitatively different under IDEA than Section 504 or ADA


Under IDEA in K-12 settings, individuals identified as being in "educational need" of accommodations may have their coursework altered to reduce homework, lower the difficulty level, or provide additional services (e.g., speech or occupational therapy, special education). IDEA does not extend past 12th grade and neither do the services provided as a result. Post high school, under Section 504 and ADA, accommodations are limited to "reasonable accommodations" that do not present an undue burden on the classroom or institution and do not change the difficulty or essential requirements of a course or degree program. That is, the student is responsible for completing the same work as those students without accommodations. After high school, the responsibility for requesting accommodations shifts to the individual, who must make requests in a timely manner. Often, students need to register with disability services at the beginning of the semester and make requests for accommodations prior to each exams. A student must be vigilant and organized, as the onus of responsibility for their accommodations lies with them, not their professors, school administrators, or supervisors.


Common accommodations in postsecondary settings include (but are not limited to) extra time on tests (e.g., time and a half), access to notes or outlines, having a note-taker in class, recording lectures, sign language interpreter, screen enlarger, talking calculator, and having tests read out loud by a reader. A much less common accommodation is replacing an entire course, though it cannot be a course that covers material that is core to the degree program. For example, I have successfully petitioned for clients with severe Specific Learning Disorder in Reading, with Dyslexia, to have their foreign language courses substituted with courses that focus on other cultures or communication. However, if a school has never made such a substitution, understand that it is up to their discretion to interpret the meaning of "reasonable accommodation" under Section 504 and ADA. Your only recourse, should you believe that you are being unlawfully denied accommodation is to file a complaint (and potentially a lawsuit) with the office of civil rights.


Educational "identification" is NOT a medical diagnosis


IDEA plans hinge on an "educational identification," rather than a medical diagnosis, which is required for Section 504 and ADA. Given that special education staff are licensed by departments of education and not state boards for mental health or medicine, an educational identification is not a medical diagnosis. Furthermore, special educators are not trained to diagnose conditions in the Diagnostic and Statistical Manual of Mental Disorders (DSM-5-TR), which is the manual utilized by mental health and medical professionals to diagnose mental health conditions. This also means that educational identification of need for special education may not include a specific diagnosis. This is most often the case when a student who has behavioral symptoms that affect their learning is identified in their IEP plan as needing academic accommodation for an "emotional disturbance," rather than including the name of the underlying diagnosis (e.g., PTSD, Major Depressive Disorder, Generalized Anxiety).


To meet the documentation requirements under Section 504 and ADA, a medical or mental health professional must make a diagnosis and include specific documentation for how the condition requires classroom or workplace accommodation. This sort of diagnostic evaluation becomes the responsibility of the individual, as medical insurance does not cover this kind of testing. They only cover what is "medically necessary," which means services that are necessary to restore your health (i.e., reduce symptoms). Success in school, work or relationships is not viewed as medically necessary by insurance companies. While I could wage a reasonable debate against this limited view of medical necessity, I am unlikely to change the way multi-billion (or perhaps trillion) dollar corporations conduct their business. You might find assistance with your state's office for disability services in pursuing testing (e.g., Division of Vocational Rehabilitation here in Colorado).


Most schools, standardized testing organizations (e.g., MCAT, GMAT, etc.) and licensing exams require updated diagnostic information


Requirements for updated testing typically include that testing was performed within the last 5 years. Some disabilities change as a person learns how to compensate, their brain develops, or they receive the proper intervention. For example, some people outgrow ADHD between childhood and adulthood. People diagnosed with PTSD can successfully complete treatment with Cognitive Processing Therapy or EMDR and no longer have symptoms that interfere with their daily life.


Some people never received the proper testing to rule out other potential conditions affecting their learning and behavior. As the K-12 educational system has shifted to the "response to intervention" system of identifying need for IEP plans, some students never received full diagnostic testing. While "response to intervention" in the K-12 realm may make sense for both budgetary and efficient service-provision, there are not equivalent interventions or special education services to provide in college and beyond. Updated testing can speak to the current conditions of an individual's diagnosis, as well as identify the underlying medical diagnoses that IEP plans often do not explicitly state.


Misidentified often means misdiagnosed or missed diagnoses


In my practice, I have been witness to a host of misdiagnoses or missed diagnoses, when assumptions are based on educational identifications. Given that the objectives of providing special education and medical diagnoses differ quite significantly, this should come as no surprise. However, it is the student who often pays the price, as they may base their future plans and choice for post-secondary training on wrong information.


One major concern is when children are identified as having multiple specific learning disorders (e.g., in reading, math and written expression), but they actually have Intellectual Disability, which is a condition marked by global delays in learning and often adaptive functioning. The problem with this misidentification are the implications for setting a student up to assume the debt of a semester or 2 of college when degree completion is highly unlikely. Not only are they left with the financial burden, but also with feelings of failure, frustration, and confusion.


Educational identification for the purpose of allocating special education services is fine to a point. After high school, young people considering the college pathway need accurate diagnostic assessments that can provide a medical diagnosis, help them to identify their strengths, and have an accurate understanding of their best options for career training.


Final thoughts and next steps

If you've decided to pursue accommodations after high school ends, you may want to consider your options for diagnosis and testing by a medical or mental health professional. Things that you will want to consider may include the credentials of the professional, their training in diagnostic assessment using multiple measures, the cost of the evaluation, the documentation required by the site you are requesting accommodations from, and the time it may take to get a final report (e.g., waitlist, testing time, report-writing time, etc.). For more in-depth considerations, please see "How to pick a provider when you need disability accommodations for school or work."


U.S. Department of Education. Students with Disabilities Preparing for Postsecondary Education: Know Your Rights and Responsibilities. Accessed on 2/11/2023.https://www2.ed.gov/about/offices/list/ocr/transition.html


Office of Disability Employment Policy. Accommodations. Accessed on 2/11/2023.



University of Akron Office of Disability Services. What to Expect as a College Student with a Disability: Differences in Legislation. Accessed on 2/11/2023. https://www.uakron.edu/access/students/policies/ideavsada.dot


Colorado Department of Education. Individualized Education Program (IEP). Accessed on 2/11/2023. https://www.cde.state.co.us/cdesped/iep


College Board. Accommodations. Accessed on 2/11/2023. https://www.cde.state.co.us/cdesped/iep


AAMC. MCAT® Exam with Accommodations. Accessed on 2/11/2023. https://students-residents.aamc.org/mcat-exam-accommodations/mcat-exam-accommodations


Educational Testing Service (ETS). Disabilities and Health Related Needs. Accessed 2/11/2023. https://www.ets.org/disabilities.html


** DISCLAIMER: The information in this blog is informative only and is limited to the experience, knowledge and opinions of the author. The content should be read with caution and individuals are responsible for doing their own research and speaking with relevant professionals (e.g., legal, mental health, medical, insurance plan, educator, etc.) before making any decisions based on the information read here. Use at your own risk. The information in this blog is not a substitute for consultation with relevant professionals (e.g., legal, mental health, medical, insurance plan, educator, etc.). The author, entity, and/or poster of this content is not responsible for its use.**




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