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Reasons Why Documentation Is Deemed Insufficient by ETS

The following lists some common reasons why disability documentation is deemed insufficient by ETS.

  1. The current functional limitations are missing from the report. Specifically, the documentation fails to show the impact of the disability on a major life activity.
  2. The report is limited in scope and content:
    • Documentation may be primarily based on an IEP or 504 Plan from high school. Scores may be missing from the report.
    • The diagnosis is based on a screening test, or the report presents a single subtest score from the WAIS-IV or the Woodcock-Johnson III that is discordantly low compared with the other subtests in the battery.
  3. The documentation does not establish that there is a disability under the Americans with Disabilities Act. It contains no clear statement of a diagnosis consistent with DSM or ICD.
  4. There is an insufficient description of history of a disability (e.g., childhood through college) and how it relates to current problems with academic performance or employment.
  5. The rationale for requested accommodations is lacking, even though a diagnosed disability exists.
  6. Accommodations recommended by the evaluator appear to be too sweeping and either over-accommodate the test taker or are based on preferences rather than disability-driven reasons.
  7. There is no accommodation history for a particular accommodation being requested and no compelling rationale as to why it is needed now.
  8. Documentation does not conform to ETS recency criteria for LD, ADHD or physical and psychiatric disabilities.
  9. The impact of the disorder appears to be more a relative weakness than a disability that is substantially limiting.
  10. It appears that the disability does not affect the client in multiple settings.

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