Guidelines for Documentation for Students with Physical Disabilities and Chronic Health Conditions

This document provides guidelines necessary to establish the impact of physical disability or chronic health condition on an individual's educational performance and to validate the need for accommodations. In instances where there may be multiple diagnoses, including learning disabilities, attention deficit/hyperactivity disorders (ADHD) or psychiatric disabilities evaluators should consult Loyola’s Disability Support Services Office for those guidelines.

These guidelines were adapted with permission from the Educational Testing Service’s Guidelines for Documenting Physical Disabilities and Chronic Health Conditions in Adolescents and Adults (2003).

Confidentiality Statement

Loyola College will not release any information at any point in the disability accommodation process regarding an individual's diagnosis or medical information 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 physical disabilities, evaluators may withhold or redact any portion of the documentation that is not directly relevant to Loyola College’s criteria for establishing a disability as defined by the ADA and a rationale for requested accommodations.

Introduction

Under the Americans with Disabilities Act (ADA) of 1990 and Section 504 of the Rehabilitation Act of 1973, qualified individuals with disabilities are protected from discrimination and may be entitled to reasonable accommodations and equal access to programs and services. DSS recognizes that "physical disability" is a generic term that can refer to a variety of conditions of short or long duration. 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 or restricts the condition, manner, or duration under which an average person in the population can perform a major life activity. Both acts define a disability as a physical or mental impairment that substantially limits one or more of the major life activities of such individuals. A diagnosis of a disorder/condition/syndrome or impairment in and of itself does not automatically qualify an individual for accommodations under the ADA. The documentation must also support each request for accommodation, academic adjustment or modification, or auxiliary aid.

This document provides guidelines necessary to establish the impact of physical disabilities on an individual's education or living arrangement and to validate the need for accommodations. In instances where there may be multiple diagnoses, including psychiatric disabilities, learning disabilities, and/or ADHD in addition to physical disabilities, evaluators should consult the appropriate the DSS policy statements regarding these conditions.
Information and documentation submitted by students to verify accommodation eligibility must be comprehensive in order to prevent unnecessary delays in decision making related to the provision of accommodations.

This document contains information regarding four important areas:

I. evaluator qualifications
II. recency of documentation
III. comprehensiveness of the documentation to support the diagnosis of a physical disability, including evidence to establish the current functional limitation(s) of the condition supporting the need for accommodations
IV. multiple diagnoses

Relevant Terminology

Physical disabilities include but are not limited to impairments, chronic illnesses, traumatic brain injury, arthritis, and visual, hearing, mobility, and manual limitations. When these occur in combination with attentional, psychiatric, and/or learning disorders, relevant information pertaining to these latter diagnoses as it applies to the academic or housing environment must be included.
Major life activity: Examples of major life activities include walking, sitting, standing, seeing, hearing, speaking, breathing, learning, working, caring for oneself, and performing manual tasks.
Current functional limitation: A substantial impairment in an individual's ability to function with respect to 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 physical diagnoses, offering opinions about physical disabilities, and making recommendations for accommodations must be qualified to do so. It is essential that professional qualifications include both (1) comprehensive training and relevant expertise in the specialty and (2) appropriate licensure/certification.

Qualified evaluators are defined as those licensed individuals who are qualified to evaluate and diagnose physical disabilities or who may serve as members of a diagnostic team. These individuals or team members may include physicians, surgeons, dentists, optometrists, audiologists, physical therapists, occupational therapists, neuropsychologists, and other relevantly trained healthcare professionals qualified to make such diagnoses. Documentation may be provided from more than one source when a clinical team approach employing a variety of professionals has been used.
Diagnoses of physical disabilities documented by family members will not be accepted because of professional and ethical considerations even when the family members are otherwise qualified by virtue of training and licensure or 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 licensure or certification, including the area of specialization, employment, and the state or province in which the individual practices, should also be clearly stated in the documentation. All reports should be in English, typed on professional letterhead, dated, and signed.

II. Documentation Must Be Current

Although some individuals have long-standing or permanent diagnoses, because of the changing manifestations of many physical disabilities, it is essential that a student provide recent and appropriate documentation from a qualified evaluator that is relevant to the specific college environment. 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 student must also submit a letter from a qualified professional that provides an update of the diagnosis, a description of the student's current level of functioning during the preceding six months, and a rationale for each of the requested accommodations. In some cases the updated letter from a qualified professional may simply address why documents or reports that have been submitted and that are older than six months continue to be relevant in their entirety.

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. In addition to a history of presenting symptoms, date of onset, duration and severity of the disorder, and relevant developmental and historical data, the diagnostic report should include the following components:

1. a specific diagnosis. Clinicians are encouraged to cite the specific objective measures used to help substantiate diagnoses. The evaluator should use definitive language in the diagnosis of a physical disability, avoiding such speculative language as "suggests," "has problems with," or "could have problems."

2. a description of current functional limitations in the academic and housing environments, as well as across other settings, with the understanding that a physical disability usually presents itself across a variety of settings other than just the academic domains. The description should include medical information describing the degree to which the current functional limitations restrict the condition, manner, or duration under which the student can perform a major life activity as compared to the average person in the general population. 

3. relevant information regarding any medications that may impact academic performance. 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.

4. relevant information regarding current treatment for this or any other conditions, and the degree of impact on living and learning in a college setting.

5. evidence that alternative etiologies or explanations have been considered in a differential diagnosis and ruled in or out as appropriate. Such alternative explanations include substance abuse; medication effects; psychiatric, learning, and attentional disorders; and motivational factors affecting performance/functioning.

6. a rationale for each accommodation requested. The clinician must describe the degree of impact of the 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 learning or housing situation. DSS encourages clinicians to be highly specific with the disability-accommodation link. Accommodations will be provided only when a clear and convincing rationale is made for the necessity of the requested accommodations.

Note that a diagnosis in and of itself does not automatically warrant approval of requested accommodations. For example, although migraine headaches can be very painful and distressing, the mere anticipation that one is going to have a migraine is not a disability.

A prior history of accommodations, without demonstration of current need, does not in and of itself warrant the provision of accommodations. Furthermore, if there is no prior history of accommodations, the evaluator and/or the student must include a detailed explanation of why accommodations were not needed in the past and why they are now being requested.

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 DSS policy. For example, when accommodations are requested based on multiple diagnoses (e.g., cancer with an accompanying depression), documentation should also comply with the DSS policy statements pertaining to the documentation of these specific conditions. In such instances, qualified healthcare professionals can consult Loyola College's policies and guidelines for documentation. The DSS guidelines for documentation of psychiatric disabilities as well as policy statements pertaining to LD and ADHD can be found at www.loyola.edu/dss. They may also be obtained by contacting:

Disability Support Services
Loyola College in Maryland
4501 N. Charles Street     
Baltimore, MD 21210

(410) 617-2062  or e-mail mwiedefeld@loyola.edu