Applying for ETS Testing Accommodations: GRE, Praxis, TExES, and TOEFL Loring Brinckerhoff, Ph.D. Ruth C. Loew, Ph.D. AHEAD conference New Orleans, LA July 12, 2012

ETS Confidential & Proprietary Agenda Introduction to ETS DOJ issues new ADA AA regulations AHEAD’s “Guidance on Documentation Practices” and ETS’s approach Accommodations review process –Bulletin Supplement update Current initiatives at ETS

ETS Confidential & Proprietary ETS goals for providing service Establish policies and procedures that provide people with disabilities access to our tests. Maintain consistency across testing programs, adhering to the legal requirement that requests for accommodations be treated on a case- by-case basis.

ETS Confidential & Proprietary Population Snapshot For GRE, Praxis, TExES, and TOEFL programs combined: From 2005 to 2011, accommodations requests increased from 9,938 to 11,383. Throughout this period, approximately 80% of applications received approval for some or all of the accommodations requested.

ETS Confidential & Proprietary DOJ Issues New Regulations Pertinent to Testing Agencies (2011) Documentation requested by a testing entity must be "reasonable and limited to the need for accommodations." A testing entity should "give considerable weight to documentation of past accommodations received in similar testing situations as well as those provided under an IEP or Section 504 Plan.” A testing entity "must respond to requests for accommodations in a timely manner."

ETS Confidential & Proprietary Lessons Learned from Enyart Case Enyart v. National Conference of Bar Examiners October, 2011 A blind law school graduate sued the NCBE because she wanted to use a computer equipped with assistive technology on the California Bar Exam. The judge ruled that Ms. Enyart was entitled to take the bar exam with screen reading and screen magnification software instead of with the accommodation NCBE approved, a human reader. The court determined that these assistive technologies, Ms. Enyart's preferred means of accessing print, would "best ensure" that she was tested on her aptitude rather than her disability.

ETS Confidential & Proprietary Lessons Learned from Enyart Case (cont’d) U.S. Court of Appeals rejected "reasonable accommodations" as the appropriate standard for determining access and adopted a more stringent "best ensure" standard. Some testing agencies asserted that "using the ‘best ensure’ standard would fundamentally alter how standardized tests are administered,” since agencies would have to provide any accommodation a test taker thinks would best ensure academic success. ETS views this case to apply specifically to the use of technology by persons with sensory disabilities.

ETS Confidential & Proprietary AHEAD’s “Guidance on Documentation Practices” and ETS’s approach AHEAD's Guidance Documentation requests must not be burdensome. Primary documentation is student's self-report. Secondary documentation is DS provider’s interaction with student. Tertiary documentation is documentation from external sources, such as psychometric data, clinical observations, IEPs, SOPs, and teacher observations. ETS‘s Approach Primary documentation is psychometric data and clinical observations from qualified professionals. Secondary documentation is test taker’s personal statement, along with DS providers’ observations. Tertiary documentation is IEP, 504 plan, and/or SOP.

ETS Confidential & Proprietary ETS Perspective Guidance is provided for documentation updates as well as initial documentation. Each response to a request is determined on a case-by-case basis. Focus is on current functional limitations, not diagnostic labels. History of accommodations in high school or college is considered. Documentation needs to be current and relevant. Test taker’s personal statement is solicited and taken seriously.

ETS Confidential & Proprietary ETS Accommodations Review Process Disability Services customer service center answers questions from test takers processes accommodations requests schedules tests

ETS Confidential & Proprietary Accommodations Review Process (continued) Accommodations Review Panel 32 members DS providers, psychologists, special education faculty, and private evaluators reviews over 2100 cases/year

ETS Confidential & Proprietary Accommodations Review Process (continued) Everyone needs to submit: –Completed registration form & fee –Part I (Applicant Information) –Part II (Testing Accommodations Requested) – Test taker should complete this. –Part III (Certification of Eligibility: Accommodations History) if possible

ETS Confidential & Proprietary Bulletin Supplement Update “How to Request Accommodations” section: seven steps with a checkbox for each step. Each step has its own section and instructions. Supplement now spells out what documentation is needed for minor accommodations such as snacks, water bottle, etc. COE is now a history of accommodations as well as the decision point about whether additional documentation is needed.

ETS Confidential & Proprietary Bulletin Supplement Update (cont’d) A new section lists accommodations available and what to do if you need one that is not listed. A new glossary defines commonly used terms such as ADHD, ergonomic keyboard, oral interpreter, scribe, etc.

ETS Confidential & Proprietary Step 1: Determine the accommodations you need. Extended testing time Extra breaks Accommodations for CBT only (hardware/software) Assistance Alternate test formats Other

ETS Confidential & Proprietary Steps 2, 3, and 4 Step 2: Find the program bulletin for the test you’ll be taking. Step 3: Go to the program website to learn about the test. Step 4: Complete the appropriate registration form for that program.

ETS Confidential & Proprietary Step 5: Complete testing accommodations request form. Part I – Applicant information Part II – Accommodations requested Part III – COE: Accommodations History

ETS Confidential & Proprietary Step 6: Disability Documentation You must submit disability documentation if: you are not submitting a COE: Accommodations History, and/or your disability is LD and/or ADHD and you are requesting accommodations other than 50 percent extended time (time and one-half) and/or extra breaks, and/or you were diagnosed with a disability within the past twelve months.

ETS Confidential & Proprietary Step 6: Disability Documentation (cont’d) You must submit disability documentation if: you indicate in Part I of the Testing Accommodations Request Form that you have a physical disability or a psychiatric condition, or you check "Other" under "Nature of your disability,“ and/or you are requesting accommodations that are different from those that have been approved by ETS for you within the last two years, and/or you have not previously used the accommodations you are now requesting.

ETS Confidential & Proprietary Step 6: Considerations for blind and low-vision test takers If you are blind or have low vision, you do NOT need to submit documentation if you are submitting a COE and are requesting only accommodations from the list below. Screen magnification Selectable background and foreground colors Braille Large print Computer-voiced (GRE General Test only) Recorded audio Reader Scribe

ETS Confidential & Proprietary Step 6: Considerations for deaf and hard of hearing test takers If you are deaf or hard of hearing, you do NOT need to submit documentation if you are submitting a COE and you are requesting only accommodations from the list below. Listening section omitted (TOEFL only) Speaking section omitted (TOEFL only) 50 percent extended testing time (time and one-half) Extra break(s) Printed copy of spoken directions Sign language interpreter (for spoken directions only) Oral interpreter (for spoken directions only)

ETS Confidential & Proprietary Step 7: Submit your request to ETS. Submit: all completed forms (appropriate registration form, Testing Accommodations Request Form, and ETS Vision Documentation Report, if applicable) disability documentation, if required proper test fee

ETS Confidential & Proprietary Reminders to Test Takers with Disabilities Register early to allow time for review. If you’re not required to send documentation, please do not send it! Doing so may cause undue delays. Only request the accommodations you think you need.

ETS Confidential & Proprietary Service Providers’ Perspective Encourage students to register early! Please review documentation on file before signing off on a COE. Verify that the accommodations requested are appropriate. Our documentation specialist, Nora Pollard, Ph.D., is available to speak with DS providers.

ETS Confidential & Proprietary Current Initiatives at ETS Accessibility Steering Committee Ongoing development of alternate test formats Updated guidelines for documenting psychiatric and physical/medical disabilities Improving website design and accessibility

ETS Confidential & Proprietary Current ETS Research Initiatives Accessible digital testing (tablets, refreshable braille, haptics) ASL translation of math test content Text to speech for math GRE General Test validity study for test takers with disabilities

ETS Confidential & Proprietary Q and A

ETS Confidential & Proprietary Contact Information Loring Brinckerhoff, Ph.D. Director, Office of Disability Policy, ETS Ruth C. Loew, Ph.D. Assistant Director, Office of Disability Policy, ETS