This is the second installment of a two-part series that explains how to request accommodations for college admission tests. This post will review how to secure accommodations for the ACT. Review this post if you would like to learn more about SAT accommodations.
An Important Update
On June 15, 2016, ACT greatly modified its protocol for requesting testing accommodations. The Services for Examinees with Disabilities (SED) site has been parsed down to a single page of text and a handful of related pdfs that touch on different features of the request process. Although it is not stated outright on the SED site, the impetus for the update stems from years of criticism of ACT’s stringent accommodations policies. In early 2016, these criticisms came to a head as school districts across the country complained of discrepancies between students granted accommodations in school and those who qualified for accommodations on admission tests.
Prior to the June update, a cursory perusal of the SED site revealed the obvious weaknesses of the process. Most glaringly, ACT required all forms and documentation to be submitted in writing and shipped via snail-mail. If ACT’s reviewers noticed any missing fields in the request or wanted additional documentation from families, the organization would mail a letter back with instructions for filing a new request. An endless volleying of mailed correspondence would ensue, leaving parents, students, and tutors to handwringing until the next letter arrived from ACT.
ACT’s solution to its protracted review process arrives in the form of a new online management system for filing requests and monitoring their status: the Test Accessibility and and Accommodations System (TAA). As I will explore in this post, TAA is remarkably similar to College Board’s SSD interface (see part 1 of this series), especially in its reliance on school administrators to manage requests and affect decision-making.
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 ACT’s Policy for Documentation and to schedule evaluations if necessary.
One of the most helpful resources offered by ACT, which I suggest that parents, testing professionals, and school officials read cover-to-cover, is the Policy for Documentation. In this downloadable pdf, ACT stipulates its criteria for determining accommodations and describes how to properly substantiate a request with documentation.
In a nutshell, a student is eligible for accommodations if:
Her disability is diagnosed and documented by a credentialed professional
Her disability directly impacts performance on ACT’s assessments
Documentation for the disability includes information about current and/or prior accommodations made in similar settings, especially tests in school
After reviewing these criteria, families should consider the two different accommodations packages that ACT offers: National Extended Time and Special Testing. With these options in mind, families can better work with evaluators and school officials to amass supporting documentation (Step 2) and submit their requests (Step 3).
National Extended Time
This accommodations option is most appropriate for students who require no more than 50% extended time on standardized tests. Typically, National Extended Time exams are administered in rooms with less than 10 test-takers, which may be helpful for students who struggle with distractibility or anxiety. Students who require accommodations beyond extended time and smaller, quieter testing rooms should consider Special Testing.
When a student qualifies for National Extended Time, she is given time-and-a-half to complete the ACT in its entirety. With the writing section, this amounts to 6 hours of testing (5 hours without writing). She is also advised to complete the exam in full at her own pace, moving through sections in their predetermined order: English, Math, Reading, Science, and Writing. If a student finishes the exam before time is up, she should notify the proctor (who will mark the amount of time used) and ask permission to leave the testing room.
The one caveat: students with National Extended Time may not return to test sections that they have previously completed. Consequently, test-takers should feel satisfied with their answers before treading further into the exam.
National Extended Time exams are conducted at official test sites, which can be searched for and selected when creating an ACT account and registering online.
Special Testing
This accommodations option is a ‘catch-all’ for any support request other than 50% extended time. Because Special Testing is typically administered at the student’s school by a designated testing coordinator (TC), the student may obtain any number of reasonable accommodations that the TC and the school facility are capable of providing. This includes, but is not limited to: a private testing room, multiple-day testing, alternate test formats, 100% extended time, the presence of a support animal, etc.
The exact timing guidelines for Special Testing vary according to the student’s disability. For instance, a student with a visual processing disorder that severely limits reading speed may be permitted to take the ACT across four sittings, one test section per day with double-time. Another student who suffers from generalized anxiety disorder may be permitted to take the ACT across two days with 50% extended time.
EDITORIAL NOTES AND CAVEATS
As I mentioned in my previous post, College Board and ACT must contend with our society’s imprecision in defining the term ‘disability’ (see Editorial Notes and Caveats under Step 1 of previous post). A perfect emblem of our collective confusion is the disagreement in U.S. laws that support disabled individuals. Knowing these laws – understanding their powers and limitations – is essential to determining eligibility for accommodations in school and on college admission tests.
On the one hand, we have the Individuals with Disabilities Act (IDEA) which mandates ‘“equity, accountability and excellence in education for children with disabilities.” IDEA is best known for providing fully subsidized testing and individualized Education Plans (IEPS) to diagnose learning disabilities and institute accommodations in public schools. According to IDEA, disabled individuals are those who exhibit obvious developmental delays or impairments that lead to substandard performance relative to grade-level peers. If a student is assessed, and her results do not point to significant deficits, she is less likely to qualify for school-based accommodations.
On the other hand, we have the Americans with Disabilities Act (ADA) which protects individuals from being discriminated against because of a disability. ADA has its roots in employment and recruiting practices, prohibiting firing or refusing to hire individuals due to actual or perceived disabilities. The law also requires the implementation of reasonable accommodations for disabled people, which may extend to high-stakes tests that are “gateways to educational and employment opportunities.” According to ADA, an individual with a disability is a person who has a physical or mental impairment that substantially limits a major life activity (e.g. seeing, hearing, learning, reading, concentrating, or thinking). Testing accommodations are designed to alleviate the effects of the disability, so that the individual can demonstrate his full potential on the tested skill.
In other words, a disabled student does not have to bear IDEA’s hallmarks of a disability: falling far below the developmental norms of peers. In fact, ADA states outright that a person with a history of academic success may still be a person with a disability who is entitled to testing accommodations. This distinction is incredibly helpful, because it is inclusive of high-performing, gifted students who are tacitly impeded by a disability (often unbeknownst to parents and teachers).
Fortunately, ACT expressly aligns its accommodations practices with ADA’s policies rather than IDEA (College Board is less clear on this front.). Accommodations are granted when documentation reveals a disparity between a test-taker’s potential (demonstrated by cognitive and IQ measures) and actual performance (demonstrated by achievement tests and grades).
Unfortunately, access to free testing and IEPs furnished by IDEA, which SAT and ACT often rely upon to substantiate accommodations (Step 2), is not extended to students who do not meet IDEA’s definition of ‘disability.’
In summary, IDEA and ADA are not synchronized when it comes to college admission testing. Gifted students with learning disabilities do not fit within IDEA’s framework, so they will likely hire private evaluators to evidence the presence of a disability and support the need for testing accommodations.
STEP 2: Gather the Appropriate Documentation
Timing: Private or school-based evaluations should take place between spring of 10th grade and fall of 11th grade. Collect all necessary pieces of documentation by October of 11th grade, which will be necessary for submitting a request.
Eligibility for accommodations hinges on three types of documentation: 1) educational and/or neuropsychological testing completed by a school official or a private evaluator, 2) a record of the requested accommodation(s) implemented by the school (i.e. an Individual Education Program [IEP], 504 plan, or official accommodations plan*), and 3) optional teacher surveys that further evidence the use of accommodations in the classroom.
*Note: Private schools are not required to honor district-based evaluations (i.e. IEPs or 504 plans) and may devise an ‘official accommodation plan’ that includes some, all, or none of the supports recommended by a private or district-based evaluation. For more information on how students at private schools are served by disability legislature, please check out this page on the Individuals with Disabilities Education Act (IDEA) website.
Documentation must be no more than three years old to authorize accommodations for the following disabilities:
Learning Disabilities
Attention Deficit/Hyperactivity Disorder
Visual and Hearing Impairments
Autism Spectrum Disorder
Speech and Language Disorders
Medical Conditions and Traumatic Brain Injuries (TBI)
Documentation must be no more than one year old to authorize accommodations for psychiatric disorders (i.e. mood or anxiety disorders and persistent mental illness).
ACT indicates the disabilities eligible for testing accommodations (pp. 5-8 in the Policy for Documentation) and how these disabilities should be represented in an evaluation. This is incredibly useful for private evaluators who can frame their diagnostic reports with ACT’s best practices in mind, and, recommend accommodations that can be met by National Extended Time or Special Testing. The more neatly an evaluation maps onto ACT’s preferences for both documentation and accommodations, the greater the likelihood of approval down the line.
EDITORIAL NOTES AND CAVEATS
Not all evaluations are created equal. The testing battery selected by the evaluator and the interpretations he makes have a serious impact on diagnoses, recommended resources, and the accommodations granted on test day. Moreover, there are significant differences between the federally subsidized evaluations offered by a student’s school district and the costly, highly detailed evaluations provided by licensed clinicians. Please read the Editorial Notes and Caveats section under Step 2 in my previous post for more information. There I explain the strengths and weaknesses of school-based testing (public) and neuropsychological testing (private), which can yield divergent diagnoses and recommended interventions.
Report-Writing Strategies for Evaluators and Parents
Although ACT does an excellent job describing the diagnostic criteria for disabilities, I have amassed a checklist for report-writing, which will ensure that private and school-based evaluations pass muster during the review process. This list was developed with Dr. Krista Greenfield, a clinical psychologist and pediatric neuropsychology fellow, whose students are regularly approved for accommodations on the ACT and College Board exams:
For teens who eventually plan to take the ACT or SAT, be sure to add specific tests to the assessment battery that are preferred by the testing agencies (e.g. WAIS, Nelson-Denny Reading Test, TOWL-4, etc.).
Requests for accommodations should be substantiated by academic performance in school. Consequently, evaluators should spend extra time during intake interviews to get a clear timeline of the student’s academic history (e.g. course of symptoms, specific functional impact of disability on classroom tasks, accommodations received in school [If none, why not?]).
Obtain specific behavioral examples of the disability(s) from teachers. Evaluators should create a proprietary comment form that teachers can use to record their observations of students. ACT has a teacher survey form that serves this purpose as well.
Explain how the functional limitations of the student’s disability(s) are exacerbated by particular features of the ACT or College Board exams. For instance, a student with a visual processing disability who is particularly weak in spatial reasoning, may have difficulty sorting through the detailed tables, charts, and passages that pepper the Science section of the ACT. The evaluator may recommend that the student receive additional time on the ACT to more carefully sort through dense reading passages, especially those on the Science section that contain cluttered visuals.
As a point of reference, evaluators may want to use the Compass Guide to College Admission Testing, which meticulously explores the conceptual elements of the SAT, PSAT, ACT, and SAT Subject Tests.
Connect accommodation suggestions to specific cognitive data (test scores and percentiles). Do not expect that reviewers at College Board and ACT will be able to draw their own conclusions from raw test results. Spell it out!
STEP 3: Submit a Request
Timing: Students planning to take the ACT in February or April – two of the most popular exam dates – should register for the test and submit their requests for accommodations by October of 11th grade. Ideally, news of approval will come by December, which will allow several months of test prep with a specific accommodation in mind.
After having reviewed the terms of eligibility and compiled the necessary documentation, a family is now ready to file an accommodations request.
In order to begin the request process, ACT requires students to register for a specific test date and submit their formal request by the test registration deadline (usually 3-4 weeks prior to the official exam date). During the registration process, students must specify the type of accommodations for which they are applying: National Extended Time or Special Testing. When registration is done, ACT will automatically email instructions explaining how students should work in collaboration with a school administrator to submit an online accommodations request.
As I mentioned at the start of this article, ACT is transitioning from a paper-based request system to one that is entirely electronic. In years past, families would have to register for test dates in advance (by mail!) and submit pages-upon-pages of documentation to ACT’s headquarters in Iowa. The new system, currently titled the Test Accessibility and Accommodations System (TAA), replaces mailed correspondence with email notifications and online status updates.
Much like College Board’s SSD interface (see Step 3 of my previous post), TAA can only be accessed by appointed administrators at students’ schools. This means that students cannot apply for accommodations without the assistance of their schools.* School officials who train themselves to use TAA are known as Test Accommodations Coordinators (TACs). ACT will soon be releasing a digital manual that explains all of the features of TAA and best practices for use. In the interim, families and school administrators can examine the Request Process Overview section on page 3 of this downloadable form. According to the Request Process Overview, coordinators will be able to log into TAA and accomplish the following:
Submit requests for ACT accommodations on behalf of students
Check the status of multiple students’ requests
Review decision notifications
Request reconsideration of requests that were not approved initially, if applicable
In addition to monitoring happenings on TAA, TACs are responsible for collecting all students’ documentation and sending digital copies to ACT if requested (see Editorial Notes and Caveats below). ACT may also ask TACs to send school records and teacher evaluations. Families must sign an authorization form to allow TACs to release documentation and school records to ACT.
*Homeschooled students should contact ACT regarding accommodations requests: 319.337.1332 (select option 2).
When Should We Submit Our Request?
Once the request and supporting documentation are submitted via TAA, the review process is supposed to take around 6 weeks. However, if ACT requires additional documentation, or, if the original request is denied and warrants an appeal (Step 4), the process can take even longer. To be truly prepared, I recommend that families complete Steps 1-3 by October of junior year unless they are planning to take an official test with accommodations in the fall of 11th grade. In the unlikely event that a student is planning to peak on an official test this early, he or she should register and submit an accommodations request for the ACT in June of 10th grade before school is out and TACs leave for summer break.
A Note about Special Testing
If a student is applying for an accommodation that requires Special Testing, it is likely that she will be taking the ACT at her school and will be proctored by a school administrator or teacher. Schools that offer Special Testing will select their own administration dates within six 3-week testing windows throughout the school year. If a student’s school is not hosting a Special Testing date within the desired testing window, the student and her TAC may contact ACT via TAA regarding other options. School administrators who are interested in coordinating Special Testing at their schools should consult the Test Coordinator Policies for ACT Special Testing.
EDITORIAL NOTES AND CAVEATS
Earlier in this section, I noted that documentation is usually sent to ACT when an accommodation request is filed. Regardless of whether or not ACT actually inspects all documentation, families must submit paperwork to the appointed TAC for safekeeping.
The subtext here: ACT trusts TACs to make judgments about the validity of students’ documentation and the need for accommodations. If the TAC believes that the student is deserving, she can expedite the approval process and assure ACT that further scrutiny is unnecessary. Simultaneously, if the TAC deems the request suspect or in need of further review, she can pass along paperwork to ACT for an expert opinion.
Although I have not confirmed this with ACT, I speculate that the partial incentive for TAA and the use of school officials derives from the need to outsource clerical tasks to unpaid workers (TACs). The administrative bandwidth required to review mountains of documentation would be unmanageable if it were not for the efforts of TACs who will (hopefully) simplify the request process.
STEP 4: Respond to Decision Letters or Make Appeals
Timing: If the accommodations request is submitted by October of 11th grade, ACT should deliver decision notifications via TAA by December. If appeals are made to denied requests, the review process is restarted and may take an additional 6 weeks.
Requests and their associated paperwork are reviewed by a panel of ACT staff and contracted experts, including testing specialists and neuropsychologists.
Once a decision has been reached regarding the request, the TAC will receive a notification that contains the following information:
Examinee’s name
Examinee’s personal identification number (PIN) for TAA
Accommodations approved, or not approved, if applicable
Reason accommodations are not approved, if applicable
If accommodations are approved:
ACT has not yet specified how it will handle approvals via TAA.
In previous years, if the student had only applied for National Extended Time, he would be mailed an updated registration ticket that included the designation “Extended Time.” The test center would be notified and add the student to a special roster.
If the student had applied for Special Testing, he would be mailed an approval letter that included instructions for collaborating with a school official to take the ACT.
If accommodations are not approved:
Depending on the reasons for denial, a student may work with his TAC to submit additional documentation or apply for different accommodations. This is called a “reconsideration request.” After the reconsideration request is reviewed by ACT, the TAC will receive another email notification with the updated request status and further instructions.
STEP 5: Use Accommodations on Test Day
ACT has not yet explained how its new electronic system will affect what students do/bring on exam day. We anticipate that ACT will follow College Board’s lead, mailing hard copies of admission tickets or emailing printable tickets via TAA. This blog post will be updated once information regarding admission tickets is made publicly available.
Conclusion
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 ACT, what educational testing entails, and how ACT’s new electronic system will streamline requests for certain applicants.
Should you have further questions, please do not hesitate to leave a comment or email me directly at matt@compassprep.com. As always, our Directors are ready to answer any of your specific testing questions.
Be sure to check out my previous post on securing accommodations for College Board tests!