Services for Students with Disabilities

ACT Policy for Documentation

To Support Requests for Test Accommodations on the ACT (No Writing) or ACT Plus Writing

Introduction

This document was developed by ACT to provide individual students, professional diagnosticians, and educational programs/schools with specific information about ACT's policies regarding documentation of an applicant's disability and the process for requesting accommodations on The ACT tests. The timely submission of proper documentation will help avoid delays in decisions related to providing accommodations and other services for candidates with disabilities.

The main section of this document discusses the following topics:

In preparing this policy document, ACT sought the counsel and advice of numerous professionals who test and diagnose individuals with disabilities. These diagnosticians also have experience with the preparation of documentation to support requests for accommodations when taking standardized tests. ACT acknowledges and appreciates their valuable contributions.

Permission is granted to reproduce these documents in their entirety for educational purposes, but not for sale, provided that the copyright notice appears in all reproduced materials.

Guiding Principles

ACT has long provided accommodations to students with disabilities and is committed to compliance with the requirements of the Americans with Disabilities Act (ADA). In this regard, ACT has adopted the following guiding principles for responding to requests from examinees for test accommodations:

  1. Requirements and procedures for test accommodations must ensure fairness for all candidates, both those seeking accommodations and those testing under standard conditions.
  2. Accommodations must be consistent with ADA requirements and appropriate and reasonable for the documented disability.
  3. Accommodations must not result in an undue burden, as that term is used under the ADA, or fundamentally alter that which the test is designed to measure.
  4. Documentation of the diagnosis must meet guidelines that are considered to be appropriate by qualified professionals and must provide evidence that the person's impairment substantially limits one or more major life activities. Applicants must also provide information about prior accommodations made in a similar setting, such as in academic classes and other testing situations.

Procedures for Implementation

Information on ACT's procedures for requesting test accommodations and its review and implementation process is provided to prospective testing applicants in test registration materials. For the ACT (No Writing) and ACT Plus Writing, information is provided on ACT's student website (www.actstudent.org) and in the registration booklet. In addition, two brochures are published annually—one for extended time testing on national test dates (PDF; 6 pages, 179KB) and the second for other requests for accommodated (special) testing (PDF; 6 pages, 66KB). These brochures explain what options are available, eligibility requirements, guidelines for documentation to be submitted to support the request, other important details about the process, and a printed request form to be completed and submitted to ACT for review.

Requests for accommodations are initially reviewed by trained ACT staff who look for specific information on the request form and in the accompanying documentation. If a staff member determines that some or all of the documentation is missing or inadequate, ACT will request the additional information. The ACT request form asks the applicant (and the student's parent or guardian, if the student is under 18) to sign a statement authorizing release to ACT of diagnostic and related information by school officials. On the basis of this release and in an effort to ensure timely processing, ACT frequently contacts the school official who completed the initial request form to request missing information, rather than the applicant.

If the initial reviewer determines that the request appears complete, it is submitted to a staff specialist for the next level of review. The specialist might:

  • approve the request and send it on for processing,
  • submit the request to an expert reviewer with specific training appropriate to the diagnosed impairment, or
  • determine that documentation is missing or otherwise insufficient.

Expert reviewers might be consulted to review documentation regarding cognitive or learning disabilities, for sight and hearing impairments, and for other physical conditions. If either the ACT specialist or the expert reviewer determines that documentation is lacking, the applicant is notified, usually by mail, and given the opportunity to submit additional documentation. If time does not allow for resolution prior to the requested test date, the applicant's request will be considered for a later test date.

If the only accommodation requested and approved for national testing is extended time, the examinee is notified on the admission ticket, and the test center is notified on a separate roster. If other accommodations are approved for national testing, ACT staff contact the test supervisor at the requested test center to determine whether the center will be able to provide the approved accommodations. If the requested test center is unable to provide all the approved accommodations, another test center (usually the applicant's indicated second choice) is contacted. Once the test center is assigned, a confirmation letter is sent to the test supervisor, identifying the examinee and confirming the reporting time, the reporting location, and the precise accommodations to be provided. The examinee is sent a copy of this confirmation letter.

Documentation Requirements

Qualified Diagnosticians

The administration of diagnostic assessments, determination of specific diagnoses, and recommendation of appropriate accommodations must be made by a qualified professional whose credentials are appropriate to the disability. The name, title, and professional credentials (e.g., degrees, areas of specialization, license or certification, employment) must be clearly stated in the documentation. For physical disabilities, documentation must be provided by a qualified physician.

Currency of Submitted Documentation

To best assess the current impact of an examinee's disability or functional limitations as they apply to the test-taking process, the documentation must be sufficiently current and appropriate to the particular disabling condition. For the ACT, the disability generally must have been diagnosed or reconfirmed by a qualified professional within the 3 academic years prior to the date of the request.

Students applying for accommodations on the ACT who have current reconfirmation of a diagnosis originally made early in the student's educational life and a history of accommodation on the basis of that diagnosis normally need not submit full documentation to ACT. Instead, ACT usually accepts the school's verification that appropriate documentation is on file at the school. However, in all cases, ACT reserves the right to request copies of documentation from the school to verify compliance. In cases where the initial diagnosis was made or the school accommodations plan was first effective less than 3 years prior to the request for accommodations on the ACT, full documentation must be submitted to ACT with the request for accommodations.

In addition to the diagnostic documentation, applicants are asked to submit information regarding whether accommodations have previously been provided in an academic setting or on other standardized tests due to the disability. For the ACT, documentation of prior accommodations often takes the form of a current Individual Education Plan (IEP) or Section 504 Plan. If the applicant has not had prior accommodations, full diagnostic documentation must be submitted with the request.

Substantiation of Diagnosis

Documentation must provide a comprehensive evaluation with objective evidence of an impairment that causes a substantial limitation to a major life activity. The documentation must also indicate how the impairment interferes with the person's ability to take the ACT, and the provide specific recommendations for test accommodations that are requested and an explanation of those recommendations. The information needed for each general category of disability is provided below.

  • Learning Disabilities: The applicant must provide the results of age-appropriate diagnostic testing performed by a qualified professional. Documentation, including all standard scores and percentiles (including subtests) that are reliable, valid, and standardized measures, must address the following:

    1. Description of the presenting problem(s) and its(their) developmental history, including relevant educational and medical history
    2. Neuropsychological or psychoeducational evaluation which includes results of an aptitude assessment using a complete and comprehensive battery
    3. Results of a complete achievement battery
    4. Results of an assessment of information processing
    5. Other appropriate assessments for consideration of differential diagnosis from co-existing neurological or psychiatric disorders
    6. Specific diagnosis and evidence that alternative explanations were ruled out
    7. Description of the functional limitations supported by the test results and a rationale for the recommended test accommodations specific to those functional limitations
  • Attention Deficit/Hyperactivity Disorder: The applicant must provide diagnostic results from an evaluation by a qualified professional. Documentation must address the following:

    1. Evidence of early impairment which, by definition in the Diagnostic and Statistical Manual of Mental Disorders (DSM-IV or DSM-5), is first exhibited in childhood and manifests itself in more than one setting
    2. Evidence of current impairment including:
      a. statement of presenting problem
      b. diagnostic interview
    3. A ruling out of alternative diagnoses and explanations
    4. Relevant testing using reliable, valid, standardized, and age-appropriate assessments
    5. Number of applicable DSM-IV or DSM-5 criteria and description of how they impair the individual
    6. Specific diagnosis
    7. Interpretive summary including a discussion of how the effects of ADHD are mediated by the recommended accommodation(s)
  • Psychiatric Disorders—Mood or Anxiety Disorders or Serious and Persistent Mental Illness: Documentation of psychiatric disorders generally includes:
    1. A review of the family history
    2. Age of onset and the course of the illness
    3. Psychological tests used (if any)
    4. The history of treatment for the disorder. Note: If the treatment includes medication, please provide evidence of continuing problems that, despite the benefits of medication, make test accommodations necessary for access to this examination.
    Please be specific as to how the disorder interferes with the person's ability to take a timed standardized test. Due to the variable nature of these conditions, documentation of a psychiatric disorder must be current (within the past year).
  • Visual Impairment: The applicant must provide diagnostic results from a complete ocular examination performed by an optometrist or ophthalmologist. Documentation must address the following:

    1. Chief complaint and history of impairment
    2. Test results, including visual acuity, complete ocular motility exam (versions, tropias, phorias, stereopsis), slit lamp exam, visual field, pupil exam, and optic nerve, and retina
    3. Specific ocular diagnosis
    4. Description of functional limitation and supporting evidence that the abnormality impedes functioning in settings such as standardized testing
    5. Discussion of the extent to which the limitation has been addressed through glasses, contact lenses, or other treatment or devices
    6. Specific recommendation for accommodation(s) and accompanying rationale
    7. If the condition is purported to affect reading, current measures of word identification, comprehension, and reading fluency or rate
  • Hearing Impairment: The applicant must provide diagnostic results from a full hearing test performed by a qualified professional. Documentation must also address the following:

    1. Relevant medical history, including date of hearing loss
    2. Related educational development, especially effect on reading ability and processing speed
    3. Specific diagnosis
    4. Description of functional limitation (with and without any hearing aids or other assistive devices or treatments)
    5. Specific recommendation for accommodation(s) and accompanying rationale
  • Other Physical Disorders: The applicant must provide diagnostic results from an appropriate medical examination that documents the relevant medical history, provides a description of functional limitation, and states a specific recommendation for accommodation(s) and accompanying rationale.

Each request for accommodation is evaluated on a case-by-case basis using the information described above. If a particular element of documentation is not provided, the diagnostician must explain why it is not included in the submission.

Recommendation for Accommodations

The diagnostic report must include specific recommendations for accommodations as well as an explanation of why each accommodation is recommended and how it alleviates the impact of the disability when taking a timed standardized test.

It is important to recognize that accommodation needs can change over time and are not always identified through the initial diagnostic process. Conversely, a prior history of accommodation does not, in and of itself, and without supporting documentation of a current need, warrant the provision of a similar accommodation. If no prior accommodations have been provided, the evaluator(s) and/or qualified school officials must include a detailed explanation of why no accommodations were used in the past and why accommodations are needed at this time.

If recommended accommodations are not clearly identified or supported in a diagnostic report, ACT will seek clarification and, if necessary, more information. ACT will make the final determination regarding appropriate and reasonable testing accommodations on the ACT (No Writing) or ACT Plus Writing for individuals with documented disabilities.

Confidentiality

All documentation submitted to ACT is kept confidential, and is used solely to determine the applicant's eligibility for test accommodations. Test supervisors are also instructed to treat as confidential all information they receive relative to the examinee's disability and accommodations. ACT Score Reports do not include any specifics about the disability or accommodations provided. The only exceptions are for those instances in which an applicant's accommodation-related documents and information are the subject of a subpeona or other court order, or an enforceable request from a government entity.

Top of page