This post is the first installment of a two-part series on requesting accommodations. This post covers the SAT; the second post covers the ACT.
The path to obtaining accommodations for College Board (CB) exams can be complicated without the right guidance. CB devotes a good portion of its website to outline best practices, but the information is disorganized and does not have a clear target audience. Content on the site vacillates between topics relevant to students, school administrators, and parents, so it’s easy to get lost along the way.
Much of the confusion around accommodations requests is not CB’s fault. As a society, we have decided to lump profoundly varied groups of people into a single category, ‘disabled,’ and require both public and private institutions to sew together the mismatched pieces. This rings true for CB, whose Services for Students with Disabilities (SSD) must reconcile the needs of its diverse constituencies: students with learning disabilities, short-term medical issues, psychiatric ailments, significant cognitive and physical impairments, etc.
Given the uniqueness of students seeking accommodations and the necessary consistency of standardized tests, it is no wonder that requesting accommodations is a clunky affair. CB lists some helpful guideposts for making requests – which I elaborate below – but they refrain from providing a concrete, linear timeline that would be useful to most families. Consequently, this post is structured as a step-by-step guide that includes suggested timing alongside each step.
Finally, while compiling this article, I could not help but look beneath the surface of SSD and notice problems of equity and bias that undergird the accommodations process. If you are so inclined, click the Editorial Notes and Caveats sections beneath each step to learn more. In the final analysis, SSD is most adept at leveling the playing field for students with popularly defined deficits; it is less helpful in supporting outliers, especially gifted students.
Important Update: January 1st, 2017
At the start of 2017, College Board announced a couple significant updates to its accommodations policies:
- Students will not have to submit documentation with accommodations requests (see Step 3 below) if they currently have a formal accommodations plan implemented in school: e.g. an Individualized Education Plan (IEP), 504 Plan, or an equivalent specialized education plan at a private school.
- English language learners (ELL) will have access to language translation tools and extended time (if approved).
Step 1: Determine If Your Student Is Eligible
Timing: Families should consult with school officials and/or private evaluators by the spring of 10th grade to review the terms of eligibility and to schedule evaluations.
Broadly construed, if a student’s ability to perform to potential on a CB assessment is compromised by a disability, she may be eligible for testing accommodations. To ensure approval, the student’s request for accommodations should meet ALL of the following criteria:
- The disability is documented by formal testing completed by a certified evaluator (see Editorial Notes and Caveats for a list of professionals who can diagnose LDs/ADHD)
- The disability directly affects performance on CB’s assessments
- The requested accommodations are specifically needed to perform to potential on CB’s assessments
Although CB most commonly grants accommodations for extended time, additional breaks, large-print testing booklets, and the usage of nonstandard rooms (to name a few), applicants need not limit themselves to these options. According to the SSD site, CB will consider any potential accommodation for any documented disability. In my experience, however, requests that are easier to enact by test day coordinators are greenlighted over those that require more extraordinary effort.
If a family or an evaluator would like to preview the components of the accommodations request prior to testing, they may do some digging on the SSD site here. Oftentimes, evaluators will have particular testing accommodations in mind while framing their reports, which may increase the likelihood of approval down the line.*
*Making standardized testing the focal point of a costly and time-consuming evaluation is a short-sighted move. Beyond furnishing accommodations, educational testing should provide students with the tools to become more engaged, self-aware learners that can advocate for resources in high school and college.
Updated Policies for the New SAT
With the debut of the redesigned SAT in March 2016, CB made some significant changes to eligibility and administration policies:
- Students may be approved for accommodations on specific sections of the test rather than the entire test. For instance, if a student’s documentation only verifies a math-based learning disability, that student may be approved for extended time on the Math section but not for the Verbal (EBRW) or Essay sections. Conversely, a student with a documented disability that impacts performance on all sections – e.g. a reading disability, an anxiety disorder, distractibility issues, etc. – will likely receive extended time for the test’s duration.
- Students approved for extended time will also be provided extra breaks between sections.
- Qualified students may request an assistive technology-compatible test format, which is administered via computer and includes screen-reading software. An MP3-audio test format is also available for students with visual disabilities.
- Students with visual disabilities or specific processing issues may request a Regular Print Test Book with enlarged font.
- Qualified students may request a four-function calculator for use during the ‘non-calculator’ Math section.
Before getting too hung up on procedure, I think it’s important to look closely at the fundamental term that determines eligibility for accommodations: ‘disability.’ Although CB speaks definitively about who falls under the SSD umbrella, the term ‘disability’ is perennially debated by educators, psychologists, doctors, and other specialists. For instance, many educational therapists argue that common perceptions of the term ‘disability’ are negative and outdated; these perceptions derive from a deficit model of the human mind that emphasizes cognitive shortcomings over multiple models of intelligence.
Additionally, the term ‘disability’ often excludes students who meet developmental standards, but who have the capacity for more advanced tasks with the right supports in place. This is often the case for gifted students with tremendous cognitive horsepower who are simultaneously impaired by learning disorders. Because these students can ‘pass’ as typical learners, their struggles may not prompt parents or teachers to consider educational testing, and concomitantly, to request classroom or testing accommodations.
In my conversations with teachers, school administrators, and experts in child psychology, there is general consensus that students without observable deficits in schoolwork and test-taking, even with documented disabilities, have a harder time securing accommodations for CB’s tests. Because these students do not bear the hallmarks of a disability – poor academic performance and low test scores – there is concern that accommodations will provide an unfair advantage, especially if these supports yield top scores on high-stakes college admission tests.
The complicated questions I would like to pose to readers are: Do we carry tacit assumptions about the appropriate limitations and potentials of ‘disabled’ students? And how do these assumptions impact the approval of accommodations at an institution like College Board?
Who Can Diagnose a Learning Disability?
The chart below, pulled from Cal Poly’s Disability Resource Center, provides a comprehensive list of professionals (and their associated licensure) who can diagnose learning disabilities and/or ADHD:
STEP 2: Gather the Appropriate Documentation
Timing: Families should have all documentation prepared for submission by October of 11th grade. If updated testing is needed, families should schedule testing with their school district or a private evaluator between spring of 10th grade and fall of 11th grade.
Eligibility for accommodations hinges on two kinds of documentation: 1) educational and/or neuropsychological testing completed by a school official or a private evaluator, and 2) a record of the requested accommodation(s) implemented by the school.
To approve accommodations for students with learning disabilities, CB requires that all educational and/or neuropsychological testing be conducted within the last 5 years. Testing for other medical or psychiatric conditions must be completed within one year of the request, while testing for visual disabilities must be conducted within two years. If you are curious about the specific tests used to diagnose disabilities and the need for accommodations, CB includes a helpful list here.
In order for schools to release educational records to CB, families must complete a consent form, which the school maintains for safekeeping. In most cases, schools will have an onsite SSD coordinator who is responsible for the maintenance and sharing of educational records.
As it was mentioned in Step 1, documentation should provide specific evidence for the accommodation(s) requested. For example, if a student is requesting 50% extended time on CB exams, his documentation should define why extended time is beneficial given the nature of his disability. In the best case scenario, the student will have a history of using the same accommodation in school, which lends further credibility to his application.*
*CB requires applicants to specify whether or not they have received the accommodation in school for at least four months. Accommodations that have been implemented for less than four months will receive further scrutiny during the review process. Similarly, students enrolled at public schools without formal Individualized Education Programs (IEPs) or 504 Plans will be examined more closely.
Not all educational testing is created equal. The assessments selected by the evaluator and the interpretations she makes have a serious impact on diagnoses, proposed interventions, and which accommodations will be employed during standardized tests.
School-based Testing (Public)
Under federal law, students may request free educational testing from the student services office of their local school district. Typically, school-based testing consists of basic academic tasks, checklists regarding attention and distractibility, and broad cognitive assessments (e.g. the Wechsler Intelligence Scale for Children [WISC]); the results of which derive helpful but imperfect conclusions about a student’s learning profile.
Although the language and methods of educational testing appear immutable – with high-falutin statistics and acronyms bandied about – there is no cut-and-dry set of qualifiers, no perfect configuration of test scores that always point to ‘issue X.’ School-based evaluators do their utmost, but their insights and recommendations are limited to the potency of their tools. Additional analysis provided by private evaluators, especially neuropsychologists, may give families more calibrated assistance on the road to obtaining accommodations.
Neuropsychological Testing (Private)
Unlike the educational testing mentioned above, neuropsychological testing (NT) is able to more deeply examine the intersections among cognitive domains that may be at the root of academic challenges (e.g. emotion, memory, attention, visual/spatial processing, language, etc.). Private evaluations can be cost-prohibitive, but they provide a wealth of information that is not necessarily included in school-based evaluations. Another added bonus: private evaluations that use adult-scaled measures can be used for the attainment of accommodations in college.
Consider the following scenario:
A 14 year-old seeks educational testing from a school-based evaluator. The student gets average grades but significantly struggles in his English classes. The student’s testing reveals mediocre reading fluency; his pacing is deliberate and slow. Simultaneously, reading comprehension is subpar, and the student’s performance on tasks of short-term memory is poor. Enigmatically, the student scores sky-high on the WISC, an intelligence measure, which appears to be at odds with his unremarkable grades and other test results. The evaluator concludes that the student has a reading disorder and should be permitted extended time on future assignments. The student goes on to meet with a reading specialist, but this intervention fails to noticeably improve his reading skills.
Now imagine that this same student goes to a neuropsychologist for testing. The student performs similarly on all assessments of reading fluency, comprehension, memory, and intelligence. However, during testing, the neuropsychologist notes that the student’s affect is sluggish and distracted. The neuropsychologist goes on to administer tests of sensory integration and conducts exhaustive interviews to learn more about the student’s personal and academic history. Lo and behold, further investigation reveals that the student’s primary issue is emotional regulation. He often experiences acute anxiety during reading tasks, which prevent concentration and the correct encoding of information into memory. The student’s slow and deliberate reading was actually a coping strategy aimed at mitigating emotional and sensory disturbances.
Following NT, the student meets with a psychiatrist and is prescribed anti-anxiety medication. His reading fluency and comprehension gradually improve, and he never meets once with a reading specialist.
The moral of this story: educational testing can yield results that are interpreted in vastly divergent ways. Private and school-based evaluators may arrive at different conclusions that impact the nature of future interventions and accommodations. School-based and private evaluations are powerful tools, but NT can uncover more nuanced issues than traditional academic testing.
STEP 3: Submit a Request
Timing: Students planning to take the SAT with accommodations in March or May – the two most popular exam dates – should submit their requests by October of 11th grade. Ideally, news of approval will come in November or December, which will allow several months of test preparation with the specific accommodation in mind. If a student has a history of similar accommodations implemented in school, the turnaround time on requests can be significantly expedited.
The cornerstone of an accommodations request is the Student Eligibility Form (SEF). The form is essentially a ‘cover letter’ or ‘abstract’ of the request that lists identifying information, a description of the disability, desired accommodations, and a summary of documentation. Irritatingly, the form is not available for download. Families can either pick up a hard copy from their school counseling offices or ask CB to directly mail the form.
With SEF in hand, there are two ways a family can submit a request for accommodations:
Option 1: Submitting the request online with the assistance of a designated SSD coordinator at the student’s school. In this case, the SSD coordinator completes half of the SEF without the student.
Option 2: Independently submitting the request without the assistance of the school. In this case, the family will need to complete the bulk of the SEF themselves.
Although there are two options for submitting requests, CB makes it abundantly clear that submitting the request online with an SSD coordinator is preferable to independent submission. On the SSD section of the CB website, CB enumerates the reasons (5 of them!) why online requests are better than independent requests. Ultimately, CB’s preference boils down to the streamlined nature of online submissions.
As of January 1st, 2017, SSD coordinators may ‘pre-approve’ requests for students who have formal education plans in school, thereby avoiding the submission/review of documentation and greatly expediting the approval process. For students in public schools, Individualized Education Plans (IEPs) and 504 Plans satisfy the requirement for pre-approval. In private schools, students receiving specialized accommodations will have similar learning plans by different names.
Before submitting the request, the SSD coordinator simply responds to an online, two-question survey:
“Is the requested accommodation(s) in the student’s plan?” and “Has the student used the accommodation(s) for school testing?”
If the coordinator answers a resounding “yes” to both questions, the student will be automatically approved for most accommodations. If the coordinator answers “no” to either question, or, College Board feels that the requested accommodations are inappropriate, they will require the submission and review of documentation.
Families who decide to submit requests without an SSD coordinator must submit the SEF and all documentation via snail-mail. Unlike online submissions, whose statuses can be instantly viewed via the SSD portal, independent requests can only be tracked by phone and mailed notifications from CB. Typically, CB will only contact families by mail when there is a problem with eligibility/documentation or a decision has been made regarding the request.
Waiting for letters while a test registration deadline looms can be deeply anxiety-provoking. Unless there is good reason for not involving an SSD coordinator, families should plan to work with their schools.
When Should We Submit Our Request?
Unless the request is pre-approved by an SSD coordinator, College Board’s review of documentation is supposed to take around 7 weeks. In order to get ahead of potential denials and appeals, families should submit their requests several months prior to the targeted exam date. To be truly prepared, we recommend that families complete Steps 1-3 by October of junior year. Even if College Board mandates a formal review of the request, approval that arrives by November or December of 11th grade will allow ample opportunity for tutoring that precedes the most popular SAT dates in March and May.
CB specifies accommodations request deadlines for all of its tests, but these deadlines do not provide an adequate berth for comprehensive test prep. If it takes seven or more weeks to return decision letters to families, students will have only a few weeks (or less) to prepare.
STEP 4: Respond to Decision Letters or Make Appeals
Timing: If the accommodations request is submitted by October of 11th grade, decision letters should be mailed to families by December. If appeals are made to CB via SSD online or by mail, the review process is restarted and will take an additional 7 weeks.
Requests and their associated paperwork are reviewed by a panel of CB administrators and contracted experts, including testing specialists and psychologists.
If a student’s request for accommodations is accepted, the family will be mailed an SSD Eligibility Letter that stipulates the specific accommodations approved for all College Board Tests (i.e. PSAT, SAT, Subject Tests, and AP Exams). The letter will also include an SSD code, which the student must input while registering for all official test dates. Hold on tightly to your SSD code!
It is possible that the approved accommodations differ from those originally outlined in the SEF. If the family decides that the accommodations are suitable, the process is complete! However, if SSD denies the accommodation request or approves accommodations that the family deems unsatisfactory, the family must begin the appeal process.
Before jumping into appeals, readers should know that the two most common reasons for denied requests are:
- More information is needed. There are fields missing from the SEF, or, essential documentation was omitted.
- The documentation does not support the desired accommodations, and CB may require additional testing that better supports the diagnosed disability. In some cases, the request will be partially approved, and a modification to the original accommodation will be presented.
If a family decides to appeal a denied request, they should take care to rectify the issues underlying the original denial. It is not sufficient for a family to simply ask for a lesser version of the original accommodation in their appeal (e.g. less extended time).
Much like the submission process discussed in Step 3, CB goes out of its way to make the appeal process easier for SSD coordinators than for independent families. The SSD website explains how SSD coordinators can re-open denied requests via the online portal; however, there is NO information online about how families can appeal requests for themselves. CB asks that parents email or call their offices to discuss denials: 212.713.8333.
Be aware that once a denied request is reopened, it will take an additional 7 weeks to process the appeal.
STEP 5: Use Accommodations on Test Day
After registering for an official CB test with an SSD code, students can expect to have accommodations ready for them on test day. To err on the safe side, testers should bring their SSD Eligibility Letters to the test site. Occasionally there are miscommunications between CB and test day coordinators about the number of students approved for accommodations.
If a family had registered online for an official test before they received an Eligibility Letter, they should log into the student’s CB account and verify approved accommodations. If the accommodations are not listed, families should contact CB to make the adjustment.
I hope this post gave you a more useful ‘how-to’ for approaching the accommodations process. If you read the Editorial Notes and Caveats sections, you may also come away with a better understanding of how students with disabilities are viewed by CB, what educational testing entails, and how CB may tacitly streamline requests for certain applicants.
Should you have further questions, please do not hesitate to leave a comment or email me directly at firstname.lastname@example.org. As always, our Directors are ready to answer any of your specific testing questions.
If you have questions about ACT Accommodations, please read the second installment of this series.