Listening, Learning, Leading : ETS Makes Changes to Documentation Guidelines AHEAD Conference July 21, 2017 Loring Brinckerhoff, Ph.D. Director, Office of Disability Policy ETS lbrinckerhoff@ets.org Nora Pollard, Ph.D. Sr. Disability Policy Coordinator npollard@ets.org Morgan Murray M.S. Ed. Disability Policy Coordinator mmurray001@ets.org 9/17/2018

Agenda Brief history lesson Overview to changes Changes to documentation guidelines ADHD (2016) LD (2017) Introducing the new COE Personal statements and letters of support from campus DS providers Copyright © 2016 by Educational Testing Service. All rights reserved. ETS, the ETS logo and MEASURING THE POWER OF LEARNING are registered trademarks of Educational Testing Service (ETS). 34728

Brief History

A short history lesson LSAC consent decree Panel of experts report DOJ technical assistance to testing agencies

Overview of Changes to ETS Guidelines for Documenting ADHD and Guidelines for Documenting LD

Our Process for Developing New Guidelines Brought together a small group of experts in the respective fields of ADHD and LD Bi-weekly meetings to debate changes over a 12 to 18 month time frame for each document

Common Changes in the ADHD and LD Guidelines Streamlined by reducing the number of pages Bullet format with hot links to other ETS documents Expanded the audience to include professionals and test takers Used a Q & A format, more white space, and less text More specific information on who is qualified to conduct the evaluation.

Softer wording (e. g. , “must be included” vs Softer wording (e.g., “must be included” vs. “may be helpful”) including the word “generally” whenever appropriate so as not to sound burdensome. Less emphasis on a diagnosis and more emphasis on current functional limitations. Acknowledge that co-occurring conditions often go with LD or ADHD and that it is often difficult to tease out the primary disability from a secondary one.

Guidelines for Documenting ADHD in Adolescents and Adults 3rd Edition 2016

Changes to 3rd Edition of “ETS ADHD Documentation Guidelines for Adolescents and Adults” Comprehensive neuropsychological reports or psycho-educational reports “may be helpful” but are not required for most accommodations. Inviting other sources of documentation, including the personal statement and/or letter from DS service provider attesting to the effectiveness of accommodations. More emphasis on the importance of the clinical interview and the gathering of supportive data from multiple sources. Documentation that is more than 5 years old may be considered, if applicable. Specific recommendations are offered for submitting a “documentation update” for outdated documentation.

Elements that have remained consistent in our guidelines: Importance of the DSM-5 Criteria Documentation needs to address the DSM-5 diagnostic criteria and include information about the severity and frequency of symptoms and whether these impact a major life activity. Merely having ADHD symptoms is not sufficient for providing accommodations. Symptoms of the ADHD need to date back to childhood (age 12) and occur across two or more settings.

Elements that have remained consistent in our guidelines: Importance of the DSM-5 Criteria A positive response to medication does not in and of itself either support or negate the need for accommodations. The link between the diagnostic data and the need for accommodations is essential. Report should rule out alternative explanations. Depending on the accommodations being requested, achievement data may still be necessary to determine the functional impact of the disability.

Elements that have remained consistent in our guidelines: Importance of Historical Information ADHD Checklists are viewed as “supplemental data.” For test takers with a long history, the current assessment needs to reconfirm the diagnosis with new clinical data and an updated rationale for accommodations. Strong emphasis is placed on detailed historical information. Rich history and/or a legacy of accommodations from another testing agency are important elements to include.

Guidelines for Documenting Learning Disabilities in Adolescents and Adults 4th Edition 2017

Changes in the 4th Edition of “ETS Guidelines for Documentation of LD in Adolescents and Adults” Includes the National Joint Committee on Learning Disabilities (NJCLD) definition  Encourages the use of the COE   Invites other sources of documentation, including the personal statement and/or letter from DS service provider attesting to the effectiveness of accommodations.   Documentation that is more than 5 years old may be considered, if applicable.  Specific recommendations are offered for submitting a documentation update for outdated documentation. 

Essential Elements for LD Documentation Age-appropriate norms should be used Evidence of impaired functioning and impact on test- taking/academic performance Cognitive and academic achievement testing, with link between the diagnostic data and the need for accommodations, are essential. Standard scores from testing preferred Detailed historical information (e.g., developmental, educational, occupational, etc.) Clear rationale to support each accommodation requested

New COE

Expansion of the COE Why are we expanding the eligibility for the COE to include most disabilities? Changes in the legal landscape - Department of Justice (DOJ) Technical Assistance Document: - “the Department continues to receive questions and complaints relating to excessive and burdensome documentation demands, failures to provide needed testing accommodations, and failures to respond to requests for testing accommodations in a timely manner.” Feedback from university DS providers To continue to be a leader in the field

Expansion of the COE Expanded COE will include ASD, TBI, physical, and psychiatric disabilities for 50% extended test time and extra breaks Deaf/Hard-of-Hearing and Blind/Low Vision will continue to be eligible to use the COE as in prior years The documentation on file at the post-secondary institution must conform to our guidelines, including recency requirements Documentation for medical disabilities/chronic health conditions and “other” will require review due to the episodic/transitory nature of these disabilities

Questions to be answered on the COE by the DS provider Does the candidate’s documentation… Meet the currency criteria set forth at www.ets.org/disabilities (e.g., LD, ADHD, and/or ASD within 5 years)? Include complete educational, developmental, and medical history relevant to the disability for which accommodations are being requested? Describe the functional limitations resulting from the diagnosed disability? List the test instruments used in the evaluation report and relevant subtest scores used to document the stated disability; all test instruments should have adult norms? Describe the specific accommodation(s) requested and adequately supports each requested accommodation? Present itself on official letterhead, printed or typed, signed and dated by an evaluator qualified to make the diagnosis (include information about license, certification, and area of specialization)

Other Changes to the COE Credentials of the evaluator: Must provide name, degree, and area of expertise For example, Mary Smith, MD, psychiatrist Testing accommodations used Added 25% extended time as an option Only extended time is listed, you must list any other testing accommodations the student received Time using the accommodations Must have used the accommodations for at least one semester (or 4 months)

Personal Statements and Letters of Support from Campus DS Providers

Personal Statements We always welcome test takers to provide additional sources of information to support their disability documentation Generally we ask that the personal statement describe the nature of the test taker’s disability, current/past use of accommodations and why the requested accommodations are needed for the upcoming test May help explain why certain accommodations have been requested Often, test takers ask what type of information ETS is looking for in a personal statement. Guidance for how to compose a personal statement is available on the website!

Letters of Support from DS Providers Letters from DS service providers attesting to the effectiveness of accommodations may be helpful supplemental information as well; additional information may include: What did you observe about this candidate during your intake interview that might support the need for testing accommodations? Has the candidate used testing accommodations consistently, or are the accommodations used only for a specific type of test (for example, only for essay tests)? What was the basis for your decision to provide this candidate with accommodations at your institution? “Tips for Disability Service Providers” is available on our website (www.ets.org/disabilities)

Q&A