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Accommodation
2/20/2015 12:00 AM

When students with hearing impairments seek accommodations on standardized tests such as those needed to enter graduate school or gain professional licensure, they sometimes find their requests questioned or even denied. As a disability services provider, you’re in a good position to help students understand why that is, and guide them in requesting accommodations that make sense and have a good likelihood of being granted to ensure they have an equal opportunity to succeed in these critical exams.

When students with hearing impairments seek accommodations on standardized tests such as those needed to enter graduate school or gain professional licensure, they sometimes find their requests questioned or even denied. As a disability services provider, you’re in a good position to help students understand why that is, and guide them in requesting accommodations that make sense and have a good likelihood of being granted to ensure they have an equal opportunity to succeed in these critical exams.

That’s according to Ruth C. Loew, the assistant director of ETS’s Office of Disability Policy; and John A. Hosterman, the director of global accessibility for Pearson VUE and the GED Testing Service.

Define ‘accommodation’

While this may sound overly basic, a common issue Loew and Hosterman encounter is a lack of understanding among students as to what constitutes an accommodation.

“Accommodations enhance access to a test. They change how something is assessed,” Hosterman explained. “On the other hand, modifications change what is being assessed.”

In other words, accommodations change the input or output, whereas modifications change the content. For example, when captioning is provided, students receive the same information, just in a different way, so this is an accommodation. Now, let’s consider an essay question. If the essay format is meant to assess writing skills, allowing a student to instead answer a multiple-choice question would be a modification and a prohibited fundamental alteration.

Hence, be sure that students aren’t seeking modifications, because they’ll likely find their requests are denied. But receiving an accommodation is no guarantee that students will do well on a test, or even that they will finish it. Make sure they understand that to promote proper preparation.

Address assumptions and generalizations

Another part of the problem is that people — including parents and students themselves — sometimes make false assumptions about the accommodation needs of deaf and/or hard of hearing students on standardized tests, Loew said. And those assumptions can hurt students.

Some common assumptions include that students who are deaf or hard of hearing will need accommodations for all tasks and in all settings; that they are always poor readers; that they generally process information more slowly than their hearing peers and thus need extra time; or that they will need an interpreter for all tasks and in all settings, she said.

But every student is different, even if their hearing impairments are equal in severity, she said. One student who is deaf may be able to read lips and respond clearly, while another may lack both abilities altogether. Accommodation requests should be clearly tied to students’ specific limitations and not to assumptions or generalizations.

For example, a student with a hearing impairment may very well have another disability that hinders his ability to process information at the same speed as his hearing peers, in which case extra time to take a test may be necessary. But there’s nothing about being deaf or hard of hearing alone that would cause this impairment. So, while deaf or hard of hearing students may desire extra time to read questions on an exam, the accommodation request will likely be unsupported by documentation and approving it won’t make sense to agency evaluators.

Explain factors that determine reasonableness

While ensuring that requests are tied to documented impairments is critical, there are various other factors students should consider to make sure their accommodation requests are reasonable. One of those has to do with context.

“The accommodation must fit the setting,” Loew explained.

An accommodation that may be appropriate in the classroom may not always be appropriate on a standardized test. For example, it may make sense to accommodate a student in class by having an instructor provide clarification or check for understanding of concepts being taught or discussed. In some situations, it may even make sense to allow students to use notes for quizzes and exams or deliver an answer to an essay exam orally in the classroom setting. But because of the very nature of standardized tests, those types of requests simply cannot be allowed.

“While we are very much in favor of testing equity, we also have a responsibility to ensure that the test and test scores are meaningful,” Loew said.

Get students to consider what the test is intended to measure in determining what accommodations to request. And remind them that accommodations can’t fundamentally alter the test. For instance, if a standardized math test is meant to assess computational skills, the use of a calculator would not be appropriate.

Likewise, if a test with a practical skills component, such as a nursing licensure exam, is meant to measure whether a test-taker can perform the tasks required of individuals in that profession, a request to have a task waived will not go over well. On the other hand, testing agencies will consider — and very often grant — accommodation requests that allow students to perform tasks differently.

For example, someone taking a nursing licensure exam could ask to use a digital stethoscope instead of a traditional one because either way, they are still showing that they know how to assess a patient’s heartbeat.

“Show us you can accomplish required tasks in different ways. That’s something we’re very open to,” Hosterman said.

Clarify interpreting role

Students who use sign-language interpreters may feel entitled to bring a sign-language interpreter to a testing site with them. And often, that’s an easily granted accommodation. However, there are some limitations in how students can use interpreters.

“Generally, interpreters are more appropriate as an instructional accommodation than as a testing accommodation,” Loew said.

While interpreters are typically allowed to help students with check-in procedures and other communication with testing center staff, they are usually not allowed to interpret written test instructions or questions. There are several reasons for that.

For one, individual interpreters may inadvertently change the meaning of a text question, give away an answer, or change the difficulty of a question. Plus, it just doesn’t make sense to provide on-the-fly sign-language interpreting when on-the-fly translation into any oral language isn’t permitted for hearing students who feel more comfortable communicating in an language other than English, Loew pointed out.

Spell out documentation requirements

Students who are deaf or hard of hearing may feel that they don’t need to provide documentation of their impairments to receive accommodations on standardized tests because their condition is obvious and maybe lifelong. But while disability services providers who provide these students with accommodations in the college setting get to interact with students and see how their impairments affect them, that’s not the case for testing agency evaluators, noted Loew and Hosterman. That’s why they still need to see documentation, namely:

  • Evidence of a disability. Documentation should provide evidence of the disability, and can consist of an audiogram or audiometric report or a simple letter from a doctor or audiologist.
  • History and relevant background information. That could include a history of how an accommodation has helped a student in various past settings; an explanation of comorbid conditions or other extenuating circumstances; information about a student’s reading and writing skills if he claims these are impaired; and information about the age of onset of the hearing loss and history of amplification usage.
  • Rationale for the requested accommodations. This may take the form of a short note that addresses things such as whether listening and/or speaking assistance is needed in checking in to a testing site; whether help is needed communicating with a proctor during the test; compatibility issues between a student’s hearing aid or cochlear implant and headphones used for listening portions of the test; whether background noise will be an issue and why; and how needs for assistive technology such as FM loops, amplified stethoscopes, or digital readouts of blood pressure monitors address documented limitations. “We’re not looking for chapter and verse here; just a couple of short sentences are OK,” Hosterman said.

While students don’t need to submit everything on the list above, the more documentation they can provide, the better.

“We don’t want to haggle with anyone over accommodations, but we need to know what’s appropriate,” Hosterman said. “And the more information we have, the easier it will be for us to approve the accommodations that students need.”

For more information, you may contact Ruth C. Loew at rloew@ets.org or John A. Hosterman at john.hosterman@pearson.com.

Accommodation
2/18/2015 12:00 AM

There’s much you can do to limit your institution’s liability related to providing accommodations and ensuring accessibility for students living in fraternity and sorority housing.

That’s according to Laura Rothstein, University of Louisville law professor; and Beth Stathos, general counsel for Chi Omega Fraternity in Memphis, Tenn. They spoke at Stetson University’s last National Conference on Law & Higher Education.

There’s much you can do to limit your institution’s liability related to providing accommodations and ensuring accessibility for students living in fraternity and sorority housing.

That’s according to Laura Rothstein, University of Louisville law professor; and Beth Stathos, general counsel for Chi Omega Fraternity in Memphis, Tenn. They spoke at Stetson University’s last National Conference on Law & Higher Education.

When determining whether your institution is required to provide accommodations in fraternity/sorority housing, you must consider so many different factors, including state laws and whether your institution or a chapter owns the building and land, whether the house is on or off campus, and if your institution regulates recruitment or other aspects, they said. The more involvement the institution has in the chapter, the more responsibility the institution bears, Stathos said.

So rather than trying to figure out what’s required, and rather than risking costly litigation after the fact, just focus on doing the right thing, they said.

Consider whether you have accessible properties that are safe and secure for members, guests and elderly grandparents.

You don’t have to provide every accommodation for free. For example, a sleepwalking fraternity member requesting a single room can be charged a higher fee for that room as long as you can demonstrate your institution can’t afford it and it’s unduly burdensome.

Check architectural barriers

If a three-story fraternity house without elevators has a member who uses a wheelchair, move basement chapter meetings to the main floor, Rothstein suggested. But remember that an intrinsic part of living in a fraternity house is the ability to go into all the different rooms, she said.

And don’t always assume accommodations require expensive retrofitting or significant alterations to a historic building, Rothstein said. Creative, affordable changes could suffice, such as installing a ramp in the back entrance, she said. Also consider safety.

If elevators or ramps aren’t available, don’t expose the institution to liability by allowing members or visitors to be carried up the stairs, Stathos said. Talk to the chapter president, facility manager, landlord and national/local organization to determine how you can all improve safety and accessibility, including parking spots and ramps, Rothstein said.

Instead of saying “We can’t afford it” or “We’re not even going to try,” take a proactive approach, because a good attitude goes a long way in preventing and defending litigation, Rothstein said.

Prepare for service, therapy animals

Think about members bringing therapy, support or service animals. Although it’s difficult to determine exactly what the rules are, the Department of Justice says only dogs or miniature horses are permitted as service animals in public places, Rothstein said.

You’re legally permitted to only ask if the dog/horse has been trained for an accommodation but you can’t ask for documentation, she said. And you can remove the animal if it’s disruptive, bites or makes a mess, she said.

Fraternity and sorority housing can also be subject to the Fair Housing Act, which would allow you to legally require more documentation for emotional support animals in those settings, Rothstein said.

Consider how you’ll handle roommates who have legitimate allergies or phobias related to animals, Rothstein said. And be ready to address health concerns about animals in fraternity and sorority kitchens or dining rooms, or fleas in bedrooms.

Don’t assume it’s unhealthy to have animals around food areas or charge up-front fees for animals in bedrooms — instead, make individualized assessments, she said.

You can probably charge members for repairing damage an animal caused, she added.

Consider food, mental health

With increases in food sensitivities and allergies, expect to have more members requesting ingredient lists and gluten-free or nut-free meals, Rothstein said. But you’re required to comply only if it’s a true allergy, not a preference, Rothstein said.

Also have plans for handling mental health issues. For example, a sorority member with anorexia, bulimia or depression could be a danger to herself because it could result in death or serious physical problems, Rothstein said. However, you can’t treat an individual differently because she’s a danger to herself — only if she’s a danger to others, Rothstein said.

So unless you can demonstrate her condition is so disruptive to the sorority environment, you could be liable for discrimination, she said. Instead, make individualized assessments and don’t act on myths or stereotypes, she advised.

Such situations can impact other members who might become enablers or feel overwhelmed, Stathos said. Ensure members know how to access resources and your counseling center if a member seems depressed or hasn’t come out of her room for a while — before everyone’s impacted, she advised.

Review membership requirements

“You do not have to excuse misconduct even if a student says, ‘I’m an alcoholic or addicted to drugs,’” Rothstein said. Instead, consider whether the student meets membership requirements, which often include GPA, conduct and morals — all permitted for private organizations, she said.

If members with learning disabilities request extended probation to meet a fraternity’s GPA requirement, that calls for individualized assessments, Rothstein said. As long as that fraternity consistently applied the GPA requirement, they don’t have to lower it for students with disabilities, she said. Talk to disability services about other assistance, Stathos said.

You may contact Laura Rothstein at laura.rothstein@louisville.edu or Beth Stathos at BStathos@ChiOmega.com.

Accommodation
1/29/2015 12:00 AM

Individuals with autism spectrum disorder are attending college in record numbers. Unfortunately, completing a college degree does not appear to improve employment outcomes for individuals with ASD, and many find it difficult to both acquire and retain jobs.

Approximately 46 percent of individuals on the autism spectrum who hold a bachelor’s degree or higher are unemployed, and of those with employment, 75 percent are underemployed, according to the Asperger Training and Employment Program reports. Those statistics highlight the growing need for college support services that capitalize on the strengths of individuals with ASD while fostering career development.

Individuals with autism spectrum disorder are attending college in record numbers. Unfortunately, completing a college degree does not appear to improve employment outcomes for individuals with ASD, and many find it difficult to both acquire and retain jobs.

Approximately 46 percent of individuals on the autism spectrum who hold a bachelor’s degree or higher are unemployed, and of those with employment, 75 percent are underemployed, according to the Asperger Syndrome Training and Employment Partnership reports. Those statistics highlight the growing need for college support services that capitalize on the strengths of individuals with ASD while fostering career development.

Many of the barriers to gainful employment (e.g., opportunity, interview skills, prior experience, etc.) can be addressed through collaborative support. We partnered with career and counseling services staff at our respective institutions to provide such support for undergraduate and graduate students with ASD. The model was piloted at Arizona State University, and Case Western Reserve University followed suit, augmenting the level of support provided.

As a result, students at both institutions can now access a cycle of support, referral and employment preparation through any one of those offices, increasing the likelihood of reaching the maximum number of students on the spectrum. They are specifically prepared for the U.S. government’s Workforce Recruitment program and the American Academy for the Advancement of Science’s Entry Point initiative, both of which are geared for individuals with disabilities.

We worked with career services and counseling center liaisons with expertise or an interest in ASD. All CWRU employees from both the career and counseling centers received a special, half-day training about students with ASD.

We enlisted help from the career center and counseling centers, conducting all trainings and managing the interface between the employment programs and students. Liaisons were also identified in each unit to ensure appropriate referrals were being made.

Students received invitations from all three offices to participate. Our disability resource offices performed initial screenings to ensure that interested students met the qualifications of the program they were interested in applying to. Students were offered the opportunity to join an existing ASD support group and participate in weekly individual meetings. Disability Resources was also responsible for scheduling interviews and maintaining contact with both employment programs.

At CWRU, the career center liaison hosted three employment workshops. The workshops introduced students to their employment program of choice and helped them build résumés and prepare for interviews. That liaison also conducted two individual follow-up meetings with students. The counseling center at CWRU also held a centerwide training regarding students with ASD, co-led by Disability Resources and a clinical psychologist. Eligible counseling center staff members received three hours of continuing education units. Afterward, the participants reported a greater understanding of the diagnosis and the supports available for students with ASD. The counseling center liaison also maintained individual appointments for student-participants and contributed to weekly support group meetings.

Enlisting offices for cross-collaboration to assist students with ASD benefits both the ASD student population and other offices on campus. For example, students referred to an employment program are more likely to obtain full-time, gainful employment after graduation. Engaging with multiple supports also increases retention and persistence of students with ASD. Individual offices grew in their understanding of one another’s roles, and cross-training increased the likelihood of students receiving needed assistance. Training offered by DR also afforded counseling staff members the opportunity to earn free continuing education units.

This no-cost collaboration can be easily implemented on any campus, using existing resources and offices.

Conversation With: Elizabeth G. Harrison
1/19/2015 12:00 AM

Elizabeth G. Harrison is the director of the University of Dayton’s Office of Learning Resources and associate director of the Ryan C. Harris Learning Teaching Center. She has presented extensively on the topics of working with faculty to promote universal design and expanding accessibility for students with disabilities.

Elizabeth G. Harrison is the director of the University of Dayton’s Office of Learning Resources and associate director of the Ryan C. Harris Learning Teaching Center. She has presented extensively on the topics of working with faculty to promote universal design and expanding accessibility for students with disabilities.

Q: How can disability services providers work with faculty members to increase accessibility?

A: It’s sometimes easier to say this than to do, but disability services providers should really get to know the faculty development and learning support people on their campuses. These people can become powerful allies in reaching out to the faculty and educating them about how to broaden accessibility.

Get to know those folks on campus who, from your point of view, have roles that seem in one way or another to be related to what you do. See exactly what it is they do and how it overlaps with your own role or what you think needs to be done to broaden accessibility. Find out what they think about disability and talk with them about the things you want to do. If they’re receptive, work together on those things. Don’t think that it has to be you alone doing this, because we all care about helping students succeed.

Q: Why aren’t such collaborations more commonplace?

A: Disability services providers may sometimes think of themselves as the only people on campus who serve students with disabilities, the only ones who care about serving students with disabilities, or the only ones who can serve those students. But that’s not the case. There are many others who, if you could just help them to understand the issues facing students with disabilities, would become committed to expanding accessibility.

For some DS providers, I think it may be the case that they got into disability services because they have a family member or someone they care about who has a disability and needed support in college. Or perhaps the DS providers themselves experienced college as students with disabilities, so now they feel a personal commitment to expanding access for others, and they feel that they can’t put that commitment on others. We all operate on certain assumptions that have been built over the years as a result of our own experiences, and that can get in our way.

I encourage people to explore their own assumptions about things such as faculty and their own roles at their institutions. Ask: Why do I think I’m the only one, or my office is the only one, who can do this work? Why am I convinced others will say “no, we can’t do this” or “this won’t work”? Why do I think others may not care? Try to get past that and work intentionally to expand your own mental model while at the same time educating others to help them do the same thing.

For more information, you may contact Elizabeth G. Harrison at eharrison1@udayton.edu.

Conversation With: Tom Merrell
1/7/2015 12:00 AM
Image of Tom Merrell
Tom Merrell

Tom Merrell is the assistant dean and director of student disability services at the University of San Francisco, where he has used technology to improve the efficiency and effectiveness of his office’s myriad functions, deliver more personal service, and improve accountability through the use of a digital database.

Tom MerrellTom Merrell is the assistant dean and director of student disability services at the University of San Francisco, where he has used technology to improve the efficiency and effectiveness of his office’s myriad functions, deliver more personal service, and improve accountability through the use of a digital database.

Q: Why did you decide to embrace a digital solution for your unit?

A: Part of our jobs in disability services is to deal with things like assistive technology and alternate media, so it’s kind of ironic that sometimes we tend to fear new technology for our own offices. When I first proposed going digital, I got some sideways looks from the higher-ups. And of course, there was the question of “Do we really need this?” because everything costs money. But digital is simply where the world is going, so if you don’t do this now, you’ll just have to do it later. And we knew that in the long run, having an electronic database in place would help us capture and use data about our students, improve accountability on every side, and better serve our students.

Q: Can you tell me about the database you use and how you selected it?

A: We found this great tool called Accessible Information Management. It’s a database platform that covers our disability services operation from beginning to end. Students start out by completing a quick registration form. That puts them in the queue to speak with one of our specialists, and from there all the touch points from the program are done through the database. Everything from requesting accommodations, communicating with their assigned DS specialists, and getting accommodation letters to instructors takes a lot less time, so that our specialists can spend the majority of their time listening to and talking with students, as opposed to taking care of different housekeeping tasks.

What we were looking for was a solution developed by someone who really understood disability services and our day-to-day operations. AIM was patient with the hundreds of questions we had in the beginning and even flew someone down to really show us how the product works. I also liked that the database talks to Banner to get specific information such as students’ GPAs and demographic data. At the same time, it doesn’t feed information in the opposite direction, so disability-related information is kept confidential.

Q: What was the implementation process like for your office?

A: We implemented AIM in January 2012. We were given two options. The first was the equivalent of dipping your toes in the water, which could have entailed just entering freshman students into the database to start. The second option was to jump right in. We decided to jump right in and make the switch over the spring semester because there are typically fewer students then. We also began by using the more basic features until we felt more comfortable working in the program.

Q: What advice can you share about choosing an electronic database provider?

A: Every disability services office is different. Look at what’s out there and make a choice based on your office’s individual needs. For example, we wanted something with a comprehensive proctoring component, and AIM offers that. Also, don’t settle for one that just doesn’t feel right, because there are many of these vendors out there now. Look for something that’s very user-friendly and intuitive to navigate.

For more information, you may contact Tom Merrell at merrellt@usfca.edu. Check out AIM at www.accessiblelearning.com.

 

Coversation With: Paul D. Grossman
10/30/2014 12:00 AM
Image of Paul D. Grossman
Paul D. Grossman

Paul D. Grossman is a retired chief regional attorney for the U.S. Department of Education’s Office for Civil Rights. He is currently a disability law consultant and adjunct professor of disability law at the University of California’s Hastings College of Law. This is the second of a two-part Q&A session with him.

Paul D. GrossmanPaul D. Grossman is a retired chief regional attorney for the U.S. Department of Education’s Office for Civil Rights. He is currently a disability law consultant and adjunct professor of disability law at the University of California’s Hastings College of Law. This is the second of a two-part Q&A session with him.

Q: What advice would you give novice disability services coordinators to help them avoid noncompliance issues?

A: When I ask whether people have read the Section 504 regulations that pertain to postsecondary institutions, I’m surprised at how many have never read them. So the first thing is to read the regulations and the appendices that go with them. I also strongly believe that every disability services office should be subscribing to Disability Compliance in Higher Education. The information your publication provides is invaluable.

It’s equally important to seek out training, either through the national Association on Higher Education And Disability or one of the regional AHEAD affiliates. For those who have responsibilities more in line with Americans with Disabilities Act officers, the National Association of ADA Coordinators offers excellent training. My law school textbook co-author, Professor Ruth Colker, and I are in the process of publishing through AHEAD those portions of our book that pertain to postsecondary disability law. This will make an excellent primer for disability services personnel, and it will be available in accessible formats including DAISY, which I believe is a first for a law school textbook.

As a group, disability support services personnel are very close and willing to share information. Look around to see who is in that role at the nearest colleges and reach out to them.

OCR offices are happy to take calls from DSS staff members who want some free advice. I never refused a call, even when the person didn’t say what institution she was at. OCR can also provide some formal technical assistance under the right situation. For example, if 10 colleges wanted to sponsor a day to interact with OCR folks and ask questions on designated topics, OCR is likely to participate.

Finally, many schools have house or contract counsel. In my experience, it’s important to check in with them. In my career with OCR, college counsels were often a constructive key to resolving complex matters.

Q: Beyond compliance, what advice can you share for creating a more welcoming campus environment?

A: There would be no disability rights but for the sacrifices and accomplishments of those individuals who fought for equality on the basis of race, national origin and sex. Nonetheless, I always feel badly when administrators and others who value civil rights and diversity on these bases somehow fail to appreciate disability as another important element of diversity. By placing services for students with disabilities into the broader civil rights perspective, the needs of these students are more likely to be understood and appreciated. The ultimate goal should be support for universal design, something that promotes student achievement for everyone.

My brother, Richard, had non-Hodgkin’s lymphoma. When he was told he had six months to a year to live, he made the very unexpected decision to enter law school. He graduated and passed the New Jersey Bar Exam and then passed away. When I was with him at hospice, I asked him whether spending his limited time attending law school was a mistake. He said, “When you’re dying, there are things you slowly can’t do or can’t do like everyone else. But as long as you can read, write, think, debate and analyze, you’re still a human being.”

We may recognize that a few individuals with disabilities may never be employable, but we must still make it possible for them to have those educational experiences that make life fulfilling.

For more information, Paul D. Grossman can be reached at paulgrossman@comcast.net.

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  • Meet the Editor

    Cynthia Gomez
    Managing Editor

    Cynthia Gomez has been the editor of Disability Compliance for Higher Education since 2005 and has covered higher education for more than a decade. She has also written and edited pamphlets and books on a variety of disability-related topics.
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