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Frequently Asked Questions for Evaluators

General Questions

Why does a test taker need to be reevaluated if a disability (such as a learning disability, ADHD or autism spectrum disorder) is lifelong?

Although these disabilities are lifelong, the impact they have on current functioning changes over time. Therefore, your documentation needs to reflect the current status of your functional limitations and explain why you need the testing accommodations you requested. If documentation is more than five years old, it is not current and must be updated. Note that the currency requirement may differ depending on your particular disability or disabilities. For example, for ADHD, the standard is generally five years. For psychiatric disorders, the generally accepted standard is an update that is not more than twelve months old, submitted with the underlying evaluation report. See Documentation Update on LD/ADHD for more information.

What can a candidate do if he or she cannot afford an evaluation or an update of the last evaluation?

ETS is not responsible for the cost of an evaluation, but resources are available that might be able to help. If the disability documentation is dated or inadequate, the candidate can contact the local Division of Vocational Rehabilitation office and meet with a counselor. This is a free service available to any individual with a documented disability. The test taker can also contact their Disability Services (DS) coordinator or counselor on campus. See Updating Documentation for LD/ADHD for more information.

Review Process Questions

If a test taker is denied accommodations or disagrees with the accommodations that are approved, what can the test taker do?

ETS will send a letter of explanation if we do not approve a request. In some circumstances, it may be possible to update or supplement relevant portions of the documentation and prevent the need for a complete reevaluation. Whenever possible, Disability Services staff will provide test takers with specific information about the ways in which their documentation is inadequate and how it should be updated or supplemented. The test taker may correct any deficiencies outlined in the letter and resubmit the request. If the test taker has any questions about ETS's procedures, he or she may email us at or write to ETS Disability Services, P.O. Box 6054, Princeton, NJ 08541-6054.

See Reasons Why Documentation is Deemed Insufficient by ETS for more information.

Certification of Eligibility: Accommodations History Questions

Why can't the professional who diagnosed the test candidate's disability sign off on the Certification of Eligibility: Accommodations History (COE)?

ETS requires that a neutral party verify that the documentation is legitimate and conforms to ETS policy. ETS also seeks verification that the institution or place of employment granted the accommodations and that the test taker is using them.

If the test taker sends disability documentation along with a signed COE, will that increase the chance of receiving testing accommodations?

Sending disability documentation when it is not required will cause a considerable delay in processing a request due to the time needed to review documentation. A test taker who is eligible to be approved for accommodations on the basis of the COE alone should send only the appropriately completed COE without documentation.

Documentation Questions

What does ETS mean by a "functional limitation?"

Under the Americans with Disabilities Act Amendments Act (ADAAA), not every impairment is a disability. For an impairment to qualify as a disability under the ADAAA, it has to be "substantially limiting" to a major life activity (e.g., seeing, talking, hearing, learning, walking, etc.). Thus, having a disability or a diagnosis alone may not be sufficient to support the need for testing accommodations. The documentation needs to clearly establish that the functional limitations resulting from a disability significantly impact the way a person performs a major life activity, compared to the "average person," before an accommodation can be considered.

Why is there a need for test takers to send in cognitive and achievement testing for disabilities such as ADHD or psychiatric disabilities?

A disability or diagnosis alone, such as ADHD, obsessive-compulsive disorder or a generalized anxiety disorder, is not sufficient to support the need for testing accommodations. The ADAAA requires that the disability result in a substantial limitation to a major life activity. For ETS purposes, this means that the current functional impact of the disability on test taking must be clearly indicated. Objective cognitive tests that measure information processing, as well as memory, organizational and sequential thinking skills under both standard timing and extended-time conditions, can be very helpful in supporting the need for the requested accommodations. While the disability may not disappear over time, current academic achievement measures are necessary to determine whether the functional limitations in learning persist despite remediation, intervention or treatment.

What does complete disability documentation look like?

Guidelines for Writing Diagnostic Reports discusses in greater detail what comprehensive documentation might look like. For our purposes, the documentation should include the following:

  1. a specific diagnosis and rationale for it, supported by the diagnostic battery and/or clinical assessment that meets the DSM 5 criteria or ICD code
  2. historical information — developmental, educational and/or medical information that includes information on response to treatment (if applicable) relevant to the diagnosed disability
  3. evidence that alternative explanations are ruled out (e.g., differential diagnoses, motivational factors, personality issues)
  4. evidence of the current functional limitations resulting from the disability as supported by objective data from quantitative testing and qualitative self-report
  5. an appendix of actual score summaries of standard or scaled scores and percentiles for all subtests, including index and cluster scores for LD and LD/ADHD documentation.
A visual processing problem called Scotopic Sensitivity Syndrome (SSS) may affect reading ability. As an accommodation, will ETS allow a test taker with SSS to use a plastic overlay placed on top of a page?

SSS is a controversial visual processing problem that may or may not be due to a learning disability. In rare instances, ETS will approve the use of colored overlays on paper-delivered tests if the documentation supports the need. If the test is computer delivered, the test taker may be allowed to request selectable screen background and foreground colors.

What is the policy regarding LD and LD/ADHD documentation that is no longer current?

ETS is aware of the cost borne by test takers with LD or LD/ADHD whose documentation exceeds the five-year limit and who are seeking accommodations for our tests. These individuals may not have insurance to cover the cost of diagnostic reports. To address this concern, ETS has adopted a documentation update policy.

A documentation update is a report by a qualified professional that includes a summary of the original disability documentation as well as additional clinical data necessary to establish the test taker's current eligibility and the appropriateness of the requested accommodations. An update typically verifies the continuing strengths and weaknesses identified in prior evaluations and includes a discussion of current impact on academic performance in general and on test taking in particular. It should also include a history of the types of accommodations received and used and a discussion of the appropriateness of the requested accommodations. The updated evaluation need not include IQ measures if the previous IQ measures were obtained on the WAIS-IV or a comparable measure.

Why does ETS require academic achievement testing in the evaluation for ADHD when there is no underlying learning disability?

Academic achievement testing is needed in the ADHD documentation because it allows us to see the functional impact of the ADHD on the test taker's academic skills in a situation most similar to taking a standardized, high-stakes exam.

Why does ETS not accept documentation from a medical doctor for the diagnosis of ADHD?

Most medical doctors do not perform assessments that will show the functional limitations resulting from ADHD in a test-taking situation. However, some psychiatrists perform such assessments. Checklists of symptoms and the effectiveness of pharmacological interventions simply do not provide sufficient information to determine the amount of extended time required or what other accommodations a candidate may need.

Why is documenting Asperger's so complex?

The new terminology in the DSM-5 for Asperger's is Autism Spectrum Disorder (ASD). Documenting this disability is complex because individuals with ASD often have co-occurring psychiatric manifestations (e.g., anxiety, depression, etc.), ADHD and/or learning disabilities (LD) that may go along with their primary diagnosis. Often individuals with ASD exhibit behaviors affecting communication and social pragmatics. In addition, the use of medications has become increasingly common in the treatment of ASD. Disability documentation needs to address a variety of these co-occurring conditions that may impact the test-taking process. Please see ETS's policy statement for Documentation of Autism Spectrum Disorder in Adolescents and Adults.

Is an IQ test all I need to document intellectual disabilities?

Intellectual functioning is assessed using a comprehensive measure of intelligence, typically the Wechsler Adult Intelligence Scale (WAIS-IV) or some other measure of intellectual ability. In addition to a test of intellectual functioning, adaptive behavior must also be assessed in three domains: conceptual, social and practical. Please refer to ETS's policy statement for Documentation of Intellectual Disabilities in Adolescents and Adults. Appendix B includes a listing of clinical instruments in common use for documenting intellectual disabilities in adolescents and adults.

Is academic achievement testing required for all disabling conditions?

If the test taker is requesting devices such as a calculator or a spellchecker, achievement testing is necessary to determine the individual's functional limitations in the relevant academic area.

What documentation is needed if a candidate has multiple disabling conditions?

It is always best to provide the most complete packet of information possible when multiple disabling conditions are identified. A complete packet would be documentation of each of the conditions.

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