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July 2001
Office of Disability Policy
Educational Testing Service
Princeton, NJ 08541
Content
Copyright Information
Copyright © 2001 by Educational Testing Service. All rights
reserved. EDUCATIONAL TESTING SERVICE, ETS, the ETS logo, and the modernized ETS
logo are registered trademarks of Educational Testing Service. Permission is hereby
granted to reproduce this booklet in its entirety for educational purposes, but
not for sale, provided that the copyright notice appears in all reproduced materials.
ETS Office of Disability Policy
Sheree Johnson-Gregory, Director
Loring C. Brinckerhoff, Disability Accommodations Specialist
Task Force on Psychiatric Disabilities
Arunas J. Kuncaitis, Co-chair
Collaborations in Critical Care
Canton, Massachusetts
Stuart S. Segal, Co-chair
University of Michigan
Phyllis Brown-Richardson
Long Island University – Brooklyn Campus
Patricia Carlton
The Ohio State University
Cyndi Jordan
Hutchison School
University of Tennessee Center for Health Sciences
Nancy Pompian
Dartmouth College
Louise H. Russell
Harvard University
Deborah E. Taska
Arizona State University
Acknowledgments
The Task Force on Psychiatric Disabilities wishes to express its appreciation
to the individuals who served on the following panels and the external consultants
listed below for their insightful comments and review of these guidelines.
College Board Review Panel
ETS Review Panel for Testing Accommodations
External Consultants
John L. Barton, Ph.D.
Director, Clinical Psychology Center
Arizona State University
Kenneth Benedict, Ph.D.
Licensed Psychologist
North Carolina Neuropsychiatry, P.A.
Betsy Busch, M.D.
Assistant Professor of Pediatrics
Tufts University School of Medicine
Mark S. Greenberg, Ph.D.
Neuropsychologist, Department of Psychiatry
Harvard University Medical School
Eric Heiligenstein, M.D.
Clinical Director, Psychiatric Services
University of Wisconsin-Madison
Leighton Y. Huey, M.D.
Professor and Chairman Department of Psychiatry
University of Connecticut School of Medicine
Peter S. Jensen, M.D.
Ruane Professor of Science in Child Psychiatry
Columbia University
Richard F. Kaplan, Ph.D., ABPP/CN
Associate Professor, Department of Psychiatry
University of Connecticut School of Medicine
Charles Klink, Ph.D.
Director, University Counseling Services
Virginia Commonwealth University
Bruce L. Levine, Ph.D.
Adjunct Assistant Professor of Psychiatry
Dartmouth Medical School
Robert L. Mapou, Ph.D., ABPP/CN
Clinical Neuropsychologist
Silver Spring, Maryland
Mark Reed, M.D.
Director, Counseling and Human Development
Dartmouth College
Larry B. Silver, M.D.
Clinical Professor of Psychiatry
Georgetown University Medical Center
Lorraine E. Wolf, Ph.D.
Clinical Director, Office of Disability Services
Boston University
Guidelines for Documentation of Psychiatric Disabilities in Adolescents and
Adults
Preface
The mission of the Task Force on Psychiatric Disabilities is to provide a comprehensive
set of guidelines for documenting psychiatric disabilities (PDs) for individuals
seeking accommodations for tests developed and administered by Educational Testing
Service (ETS). ETS acknowledges that each test taker’s circumstances are unique,
and that a flexible approach to documentation requirements for psychiatric disabilities
is helpful to both individuals and their evaluators. These guidelines may also be
used by licensing and testing agencies, secondary and postsecondary personnel, and
consumers to verify eligibility for reasonable and appropriate accommodations under
Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities
Act (ADA).
ETS encourages all institutions to provide secure storage for confidential and
sensitive student information that may be used in support of requests for accommodations.
Confidentiality Statement
ETS will not release any information regarding an individual’s diagnosis or documentation
without his or her informed written consent or under compulsion of legal process.
Information will be released only on a "need to know" basis, except where otherwise
required by law. Furthermore, to safeguard the confidentiality of individuals with
psychiatric disabilities, evaluators may withhold or redact any portion of the documentation
that is not directly relevant to ETS’s criteria for establishing a rationale for
requested testing accommodations.
ETS encourages all institutions to provide secure storage for confidential and
sensitive student information that may be used in support of requests for accommodations.
Introduction
Under the Americans with Disabilities Act (ADA) of 1990 and Section 504 of the
Rehabilitation Act of 1973, individuals with disabilities are protected from discrimination
and may be entitled to reasonable accommodations and equal access to programs and
services. To establish that an individual is covered under the ADA, documentation
must indicate that a specific disability exists and that the identified disability
substantially limits one or more major life activities. The documentation must also
support the request for accommodations, academic adjustments, and/or auxiliary aids.
A diagnosis of a disorder/condition/syndrome in and of itself does not automatically
qualify an individual for accommodations under the ADA.
ETS recognizes that "psychiatric disabilities" is a generic term used to refer
to a variety of conditions involving psychological, emotional, and behavioral disorders
and syndromes. The terms psychological disabilities and psychiatric disabilities
are used interchangeably in this document. The two official sources designed to
outline the criteria used in making these diagnoses are the Diagnostic and Statistical
Manual, Fourth Edition (DSM-IV-TR) and the International Classification of Diseases
Manual, Tenth Revision (ICD-10). For the purpose of determining eligibility
for accommodation, the symptoms must meet the ADA definition of a disability.
This document provides guidelines necessary to establish the impact of psychiatric
disabilities on an individual's educational performance and to validate the need
for accommodations. In instances where there may be multiple diagnoses, including
learning disabilities and/or attention-deficit/hyperactivity disorders (ADHD), evaluators
should consult the ETS policy statements at
www.ets.org/disability.html
.
Information and documentation submitted by test takers to verify accommodation
eligibility must be comprehensive in order to avoid unnecessary delays in decision
making related to the provision of accommodations.
This document contains information regarding five important areas:
- evaluator qualifications
- recency of documentation
- comprehensiveness of the documentation to support the diagnosis of a psychiatric
disability
- evidence to establish the functional limitation of the psychological condition
supporting the need for accommodation(s) and
- multiple diagnoses
Appendices A, B, and C, respectively, provide recommendations for consumers,
suggestions for assessment measures, and a listing of resources and organizations.
Terms
Psychiatric disabilities: Comprise a range of conditions characterized
by emotional, cognitive, and/or behavioral dysfunction. Diagnoses are provided in
the DSM-IV-TR or the ICD-10. Note that not all conditions listed in the DSM-IV-TR
are disabilities, or even impairments for purposes of the ADA. Therefore, a diagnosis
of a disability does not, in and of itself, meet the definition of a disability
necessitating reasonable accommodations under the ADA or Section 504 of the Rehabilitation
Act of 1973.
Major life activity: Examples of major life activities include walking,
sitting, standing, seeing, hearing, speaking, breathing, learning, working, caring
for oneself, and other similar activities. In particular, individuals with psychiatric
disabilities may also experience thinking disorders/psychotic disorders that may
interfere with the test-taking situation (e.g., attending, reading, writing, calculating).
Functional limitation: A substantial impairment in the individual’s ability
to function in the condition, manner, or duration of a required major life activity.
Documentation Requirements
I. A Qualified Professional Must Conduct the Evaluation
Professionals conducting assessments, rendering diagnoses of psychiatric disabilities,
and making recommendations for accommodations must be qualified to do so. It is
essential that professional qualifications include (1) comprehensive training and
relevant expertise in differential diagnosis of psychiatric disorders and (2) appropriate
licensure/certification. Qualified evaluators are defined as those licensed individuals
qualified to evaluate and diagnose psychiatric disabilities.
Qualified evaluators may include psychologists, neuropsychologists, psychiatrists,
neuropsychiatrists, other relevantly trained medical doctors, clinical social workers,
licensed counselors, and psychiatric nurse practitioners. Documentation may be provided
from more than one source when a clinical team approach consisting of a variety
of educational, medical, and counseling professionals has been used.
Diagnoses of psychological disabilities documented by family members will not
be accepted due to professional and ethical considerations even when the family
members are otherwise qualified by virtue of training and licensure/certification.
The issue of dual relationships as defined by various codes of professional ethics
should be considered in determining whether a professional is in an appropriate
position to provide the necessary documentation.
Finally, the name, title, and credentials of the qualified professional writing
the report should be included. Information about license or certification, as well
as the area of specialization, employment, and state or province in which the individual
practices, should also be clearly stated in the documentation. All reports should
be in English, typed or printed on professional letterhead, dated, and signed.
II. Documentation Must Be Current
Due to the changing nature of psychiatric disabilities, it is essential that
a test taker provide recent and appropriate documentation from a qualified evaluator.
Since reasonable accommodations are based upon the current impact of the disability,
the documentation must address the individual's current level of functioning and
the need for accommodations (e.g., due to observed changes in performance or medication
changes since previous assessment). If the diagnostic report is more than six months
old the test taker must also submit a letter from a qualified professional that
provides an update of the diagnosis, a description of the test taker's current level
of functioning during the preceding six months, and a rationale for the requested
testing accommodations.
III. Documentation Necessary to Support the Diagnosis
Must Be Comprehensive
In most cases, documentation should be based on a comprehensive diagnostic/clinical
evaluation that adheres to the guidelines outlined in this document. The diagnostic
report should include the following components:
- a specific diagnosis (see III.B)
- a description of current functional limitations in the academic environment
as well as across other settings (see III.A.5)
- relevant information regarding medications expected to be in use during
test administration and the anticipated impact on the test taker in this setting
(see III.A.4)
- relevant information regarding current treatment
- a specific request for accommodations with accompanying rationale (see III.D)
III A. Historical Information, Diagnostic Interview,
and/or Psychological Assessment
The information collected for the summary of the diagnostic interview should
include, but is not limited to, the following:
- history of presenting symptoms
- duration and severity of the disorder
- relevant, developmental, historical, and familial data
relevant medical and medication history, including the individual's current medication
regimen compliance, side effects (if relevant), and response to medication
- a description of current functional limitations in different settings with
the understanding that a psychological disorder usually presents itself across
a variety of settings other than just the academic domain and that its expression
is often influenced by context-specific variables (e.g., school-based performance)
- if relevant, a description of the expected progression or stability of the
impact of the condition over time
- if relevant, information regarding kind of treatment and duration/consistency
of the therapeutic relationship
III B. Documentation Must Include a Specific Diagnosis
The report must include a specific diagnosis based on the DSM-IV-TR or ICD-10
diagnostic criteria and include the specific diagnostic section in the report with
a numerical and nominal diagnosis from DSM-IV-TR or ICD-10. Evaluators are encouraged
to cite the specific objective measures used to help substantiate the diagnosis.
The evaluator should use definitive language in the diagnosis of a psychiatric disorder,
avoiding such wording as "suggests," "has problems with," or "may have emotional
problems."
Given that many individuals benefit from prescribed medications and therapies,
a positive response to medication in and of itself does not confirm a diagnosis,
nor does the use of medication in and of itself either support or negate the need
for accommodations.
III C. Alternative Diagnoses or Explanations Should
Be Ruled Out
The evaluator must also investigate and rule out the possibility of other potential
diagnoses involving neurological and/or medical conditions or substance abuse, as
well as educational, linguistic, sensorimotor, and cross-cultural factors that may
result in symptoms mimicking the purported psychiatric disability.
III D. Rationale for Requested Accommodations Must
Be Provided
The evaluator must describe the degree of impact of the diagnosed psychiatric
disorder on a specific major life activity, as well as the degree of impact on the
individual. A link must be established between the requested accommodations and
the functional limitations of the individual that are pertinent to the anticipated
testing situation. Accommodations will be provided only when a clear and convincing
rationale is made for the necessity of the accommodation. A diagnosis in and of
itself does not automatically warrant approval of requested accommodations. For
example, test anxiety alone is not a sufficient diagnosis to support requests for
accommodations. Given that many individuals may perceive that they might benefit
from extended time in testing situations, evaluators must provide specific rationales
and justifications for the accommodation. A prior history of accommodations, without
demonstration of current need, does not in and of itself warrant the provision of
accommodations. If there is no prior history of accommodations, the evaluator and/or
the test taker must include a detailed explanation of why accommodations were not
needed in the past, and why they are now currently being requested. Psychoeducational
or neuropsychological testing may help to support the need for accommodations based
on the potential for psychiatric disorders to interfere with cognitive performance.
IV. Multiple Diagnoses
Multiple diagnoses may require a variety of accommodations beyond those typically
associated with only a single diagnosis, and therefore the documentation must adhere
to ETS policy. For example, when accommodations are requested based on multiple
diagnoses (e.g., a psychological disability with an accompanying learning disability),
documentation should also comply with the ETS policy statements pertaining to the
documentation of these specific disabilities. In such instances, an evaluator may
want to consult with ETS’s policies and guidelines for documentation. The ETS guidelines
for documentation of psychiatric disabilities as well as policy statements pertaining
to LD and ADHD can be found at
http://www.ets.org/disability.html.
They may also be obtained by contacting:
ETS Disability Services
PO Box 6054
Princeton, NJ 08541-6054
Telephone: 609-771-7780
TTY: 609-771-7714 (for hearing or speech impaired)
Fax: 609-771-7165
Email: stassd@ets.org
Appendix A
Recommendations for Consumers
1. If you are currently not under the care of a qualified professional and need
assistance in identifying one, contact:
a. your primary care physician to discuss obtaining a referral
b. the disability services coordinator or college counselor and/or mental health
service provider at a college or university for possible referral sources
c. the high school guidance office and/or a counselor
d. a physician who may be able to refer you to a qualified professional with demonstrated
expertise in psychological disorders
2. In selecting a qualified professional ask:
a. what experience and training he or she has had diagnosing adolescents and
adults
b. whether he or she has training in differential diagnosis and the full range of
psychological disorders. Clinicians typically qualified to diagnose psychiatric
disabilities include psychologists, neuropsychologists, psychiatrists, neuropsychiatrists,
other relevantly trained medical doctors, clinical social workers, licensed counselors,
and psychiatric nurse practitioners
c. whether he or she has ever worked with a postsecondary disability service provider,
a high school guidance counselor, or with the agency to which you are providing
documentation
d. whether you will receive a comprehensive written report
3. In working with the professional:
a. take a copy of these guidelines to the professional
b. be prepared to be candid and thorough in providing requested information
4. As follow-up to the assessment by the professional:
a. schedule a meeting to discuss the results, recommendations, and possible treatment
b. request additional resources, support group information, and publications if
you need them
c. maintain a personal file of your records and reports
d. be sure to discuss the issues of confidentiality with the professional both at
the outset of the evaluation as well as during the follow-up meeting
Appendix B
Assessing Adolescents and Adults with Psychological Disorders
This appendix contains selected examples of tests and instruments that may be
used to supplement the clinical interview and support the presence of functional
limitations. All tests used should be current and have sufficient reliability, validity,
and utility for the specific purposes for which they are being employed. All tests
should also be normed on relevant populations, and the results should be reported
in standard scores and/or percentile ranks. Tests that have built-in validity scales
or indicators are preferred over those that do not. 1.
- Rating scales: Self-rater or interviewer-rated scales for categorizing
and quantifying the nature of the impairment may be useful in conjunction with
other data, but no single test or subtest should be used solely to substantiate
a diagnosis.
- Beck Anxiety Inventory
- Beck Depression Inventory-II
- Brief Psychiatric Rating Scale (BPRS)
- Burns Anxiety Inventory
- Burns Depression Inventory
- Children’s Depression Inventory
- Hamilton Anxiety Rating Scale
- Hamilton Depression Rating Scale
- Inventory to Diagnose Depression
- March Anxiety Scale for Children
- Profile of Mood States (POMS)
- State-Trait Anxiety Inventory (STAI)
- Symptom Checklist-90-Revised
- Taylor Manifest Anxiety Scale
- Yale-Brown Obsessive-Compulsive Scale
- Neuropsychological and psychoeducational testing: Cognitive, achievement,
and personality profiles may uncover attention or information-processing deficits,
but no single test or subtest should be used solely to substantiate a diagnosis.
Acceptable instruments include, but are not limited to:
Aptitude/Cognitive Ability
- Kaufman Adolescent and Adult Intelligence Test
- Stanford-Binet IV
- Wechsler Adult Intelligence Scale - III (WAIS-III)
- Woodcock-Johnson-III - Tests of Cognitive Abilities
Academic Achievement
- Scholastic Abilities Test for Adults (SATA)
- Stanford Test of Academic Skills (TASK)
- Wechsler Individual Achievement Test - II (WIAT)
- Woodcock-Johnson-III - Tests of Achievement
Specific achievement tests, such as
- Nelson-Denny Reading Test
- Stanford Diagnostic Mathematics
- Test Test of Written Language-3 (TOWL-3)
- Woodcock Reading Mastery Tests-Revised
Information Processing
- California Verbal Learning Test-II
- Category Test
- Continuous Performance Test
- Detroit Tests of Learning Aptitude-Adult (DTLA-A)
- Detroit Tests of Learning Aptitude-3 (DTLA-3)
- Halstead-Reitan Neuropsychological Test Battery
- Rey-Osterrieth Complex Figure Test
- Stroop Interference Test
- Trail Making Test
- Wechsler Memory Scales III
- Wisconsin Card Sorting Test
Information from subtests on the WAIS-III or Woodcock-Johnson-III-Tests of Cognitive
Abilities, as well as other relevant instruments, may be useful when interpreted
within the context of other diagnostic information.
- Personality Tests:
Acceptable instruments may include, but are not limited to:
- Millon Adolescent Personality Inventory (MAPI)
- Millon Clinical Multiaxial
Personality Inventory-III (MCMI-III)
- Minnesota Multiphasic Personality Inventory-Adolescent
(MMPI-A)
- Minnesota Multiphasic Personality Inventory-2 (MMPI-2)
- NEO Personality
Inventory (NEO-PI-R)
- Personality Assessment Inventory (PAI)
- Sixteen Personality
Factor Questionnaire (16PF)
- Thematic Apperception Test (TAT)
-
Appendix C
Resources and Organizations
Anxiety Disorder Association of America (ADAA) 11900 Parklawn Drive
301-231-9350 voice
301-231-7392 fax
http://www.adaa.org
The ADAA promotes the prevention and cure of anxiety disorders and works to improve the lives of those who have them.
Association on Higher Education and Disability (AHEAD)
University of Massachusetts-Boston
100 Morrissey Boulevard
Boston, MA 02125
617-287-3880 voice/TTY
617-287-3881 fax
http://www.ahead.org
AHEAD sponsors numerous training programs, workshops, publications, and conferences for professionals in the field of higher education disability.
Children and Adults with Attention-Deficit/Hyperactivity Disorder (CH.A.D.D.)
8181 Professional Place, Suite 201
Landover, MD 20785
1-800-233-4050 voice - toll free
301-306-7070 voice
301-306-7090 fax
http://www.chadd.org
CH.A.D.D. is a national organization with over 32,000 members and more than 500 chapters nationwide that provides support and information for parents of children with AD/HD and adults with AD/HD.
The Council for Exceptional Children (CEC)
1920 Association Drive
Reston, VA 22091-1589
703-620-3660 voice
703-264-9446 TTY
703-264-9494 fax
http://www.cec.sped.org
The CEC is the largest international professional organization committed to improving educational outcomes for individuals with disabilities.
The Internet Mental Health Web page,
http://www.mentalhealth.com
is another very good resource.
Learning Disabilities Association of America (LDA)
4156 Library Road
Pittsburgh, PA 15234-1349
412-341-1515 voice
412-344-0224 fax
http://www.ldanatl.org
LDA is the largest nonprofit volunteer organization advocating for individuals with learning disabilities. LDA has more than 600 local chapters and affiliates in 50 states, Washington, DC, and Puerto Rico. LDA seeks to educate individuals with learning disabilities and their parents about the nature of the disabilities and inform them of their rights.
National Center for Learning Disabilities (NCLD)
381 Park Avenue South, Suite 1401
New York, NY 10016
212-545-7510 voice
212-545-9665 fax
Toll-free Information and Referral Service: 1-888-575-7373
http://www.ncld.org
NCLD provides the latest information on learning disabilities and resources available to parents, professionals, and adults with learning disabilities. Specific information about learning disabilities, as well as local referrals to schools, clinics, camps, colleges’ parent support groups, and other sources of help are available.
National Depressive and Manic-Depressive Association (NDMDA)
730 North Franklin Street, Suite 501
Chicago, IL 60610-7204
1-800-826-3632 voice – toll free
312-642-0049 voice
312-642-7243 fax
http://www.ndmda.org
The NDMDA is a nonprofit organization aimed at helping people with depressive spectrum illnesses and their families.
Obsessive-Compulsive Foundation, Inc. (OCF)
337 North Hill Road
North Branford, CT 06471
203-315-2190 voice
203-315-2196 fax
http://www.ocfoundation.org
The OCF is an international not-for-profit organization composed of people with OCD and related disorders, their families, friends, professionals, and other concerned individuals.
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