Morris Brown College is committed to providing equal access to all educational programs and ensuring compliance with applicable laws, including Section 504 of the Rehabilitation Act of 1973, and the applicable titles of the Americans with Disabilities Act (ADA) of 1990 for qualified students with disabilities.
We at Morris Brown College understand that the transition from K-12 for traditional students to college can be a significant adjustment for students with disabilities, given the differences in how accommodations are managed. Even for nontraditional students coming back who may be familiar with systems from their High School or GED Program.
The shift from the Individuals with Disabilities Education Act (IDEA) in K-12 to Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act (ADA) in higher education brings about changes in the way support is provided.
To summarize, the key differences include:
- Legislation: K-12 operates under IDEA, while universities follow Section 504 of the Rehabilitation Act and ADA.
- Identification of Needs: In K-12, the school district identifies students needing assistance. In contrast, at the collegiate level, students must self-identify and advocate for themselves.
- Role of the Institution: In K-12, the school plays a leading role in making decisions for the students. In higher education, the institution acts as a partner, assisting students in developing self-advocacy skills and supporting their success.
Michael Turner, LPC, CHt, DBT-I, TF-CBT
Director of Counseling & Student Accommodations
michael.turner@morrisbrown.edu
404-458-6085 Ext.2030
Section 504 (particularly subpart E) of the Rehabilitation Act of 1973
The Americans with Disabilities Act of 1990 (ADA)
To ensure that no otherwise qualified person with a disability be denied access to, or the benefits of, or be subjected to discrimination by any program or activity provided by any public institution or entity. (504/ADA) Anyone who meets the entry level-age criteria of the college and who can document the existence of a disability as defined by Section 504 and ADA.
Students are responsible for obtaining disability documentation from a professional who is qualified to assess their particular disability. Students are responsible for telling Disability Services staff that they have a disability, and for requesting accommodations for each class. Accommodations (not special education) are provided so students with disabilities can access the educational programs or courses used by other students. Students must be able to describe their disability, identify strengths and weaknesses, and identify any accommodations needed and how to be a competent self-advocate
The emphasis at the collegiate level is on fostering independence and self-advocacy, which are crucial skills for students’ long-term success. By understanding these differences, both students and faculty can work together to create an environment that supports growth and development.
Criteria for Disability Documentation
Students with disabilities who are requesting accommodations from Morris Brown College must submit documentation of their disability to the Counseling Services & Student Accommodations. Guidelines from the Association on Higher Education and Disability (AHEAD), Section 504 of the Rehabilitation Act of l973 and the Americans with Disabilities Act of 1990 state that qualified students with disabilities who meet the admission and academic standards of Morris Brown College are entitled to reasonable accommodations. Under these laws, a disability is defined as any physical or mental impairment that substantially limits a major life activity. Having a history of impairment, or being perceived as having impairment may also qualify one as an individual with a disability. It is the student’s responsibility to disclose his/her needs and provide appropriate documentation to Disability Services. Documentation costs are the student’s responsibility.
Counseling Services & Student Accommodations cannot accept documentation that is more than three years old (one year for psychiatric disabilities). Usually, documentation accepted by Counseling Services & Student Accommodations is valid as long as the student is continuously enrolled at MBC. However, updated documentation may be requested if a student leaves MBC and returns, or if a student experiences a significant change in physical, mental, or social situation.
Confidentiality of Information
Counseling Services & Student Accommodations is the only MBC office that has access to documentation and information related to a student’s disability. (Documentation is maintained securely and disability diagnoses are kept confidential.) In addition, confidentiality is maintained in all verbal conversations between Counseling Services & Student Accommodations staff members and registered students and faculty/staff. Generally, no information is released to anyone outside of Counseling Services & Student Accommodations without the student’s informed and written consent. Counseling Services & Student Accommodations may release information to MBC officials if there is a direct threat to the health or safety of MBC students, faculty, and/or staff. Documentation is destroyed seven years after the last semester students are enrolled at MBC.
When submitting documentation, please note that all reports should be typed on letterhead, dated and signed. A High School IEP, 504 Plan, and /or a letter from a physician or other professional will not be sufficient to document a learning disability. Medication cannot be used to imply a diagnosis.
Documentation Requirements for Learning Disabilities
All reports should be typed on letterhead, dated and signed.
A High School IEP, 504 Plan, and /or a letter from a physician or other professional will not be sufficient to document a learning disability. Medication cannot be used to imply a diagnosis.
The following must be included in a report:
I. Qualifications of the Evaluator – The evaluator’s name, title, and license/certificate credentials must be stated.
II. Current Documentation – Evaluation data must be no more than three years old.
III. Academic History – Academic history documenting impact of learning disability.
IV. Neuropsychological or psychoeducational assessments – Data should include subtest and standard scores to support conclusions, and should at least include most recent versions of a comprehensive intelligence battery and a comprehensive achievement battery. All reports must include an interpretation of test results. Test protocol sheets, handwritten summary sheets or scores alone are not sufficient.
Acceptable instruments – Aptitude / Cognitive ability
- Wechsler Adult Intelligence Scale III (or latest version). The WAIS is the preferred instrument
Woodcock-Johnson Psychoeducational Battery – Revised: Test of Cognitive Ability
- Stanford-Binet Intelligence Scale
Unacceptable instruments – Aptitude / Cognitive ability
- The Kaufman Brief Intelligence Test (KBIT) is not a comprehensive measure and is therefore not suitable for documentation purposes at MBC
- Wechsler Intelligence Scale for Children (WISC) – this instrument is not standardized for use with adults
Acceptable instruments – Academic Achievement
- The Woodcock-Johnson Psychoeducational Battery – Revised: Test of Achievement
- *Wechsler Individual Achievement Test (WIAT)
- *Standard Test of Academic Skills (TASK)
- *Scholastic Abilities Test for Adults (SATA)
- *Specific achievement tests such as Test of Written Language – 3 (TOWL-3), Woodcock Reading Mastery Tests – Revised, or the Stanford Diagnostic Mathematics Test
Unacceptable instruments – Academic Achievements
- *The Wide Range Achievement Test (WRAT)
- *Mini-Battery of Achievement (These are not comprehensive measures of achievement and are therefore not suitable for documentation purposes at MBC
V. Functional Limitations – Defined levels of functioning, limitations, and recommendations supported by evaluation data.
VI. Diagnosis – DSM-V code and clearly stated diagnosis of a learning disability based upon DSM-V criteria and supported by several subtest scores which show a significant discrepancy AND are at least approaching one SD below the mean of the test (in most cases, the mean is 100 with a SD of 15).
VII. Recommendations for Accommodations – The report must include specific recommendations for academic accommodations and the rationale for those accommodations. A history of accommodations does not, in itself, warrant the provision of similar accommodations at USA
Documentation Requirements for Mobility, Sensory, and Systemic Disorders
All reports should be typed on letterhead, dated and signed.
I. Qualifications of the Evaluator – The evaluator’s name, title, and license/certificate credentials must be stated.
II. Current Documentation – Evaluation data must be no more than one year old.
III. History to Support Diagnosis – A description of the duration and severity of the disorder must be included. In addition, relevant medical, familial, and social histories should be included.
IV. Assessment of Mobility, Sensory, and/or Systemic Disorder – A description of current symptoms and current treatments must be included. If the student is taking any medication related to the disability, the evaluator should describe the impact of that medication on the student’s ability to participate in an academic environment.
Statutory blindness is defined in the law as central visual acuity of 20/200 or less in the better eye with the use of correcting lens. An eye which has a limitation in the field of vision so that the widest diameter of the visual field subtends an angle no greater than 20 degrees is considered to have a central visual acuity of 20/200 or less.” (as required by the Social Security Administration Code of Federal Regulations § 404.1581).
Examples of acceptable documentation proving legal blindness would be an eye report from an ophthalmologist, a statement from a physician, certified vocational rehabilitation counselor or low vision specialist.
Statutory deafness is defined as a hearing impairment that is so severe that the individual is impaired in processing linguistic information through hearing, with or without amplification, that adversely affects a child’s educational performance.
V. Diagnosis – A SPECIFIC statement that the student is diagnosed with a particular disorder, including the DSM-V or ICD-10 diagnostic (numeral) code, is required.
VI. Substantial Limitation to Learning – Mobility, sensory, or systemic disability must limit a major life activity, such as walking, learning, seeing, or sleeping, and there must be a significant limitation relative to what is common to the ‘average’ person. The evaluator must describe the major life activity affected by the disability and describe how the disability presents a substantial limitation to academic performance.
VII. Recommendations for Accommodations – The report must include specific recommendations for academic accommodations and the rationale for those accommodations. A history of accommodations does not, in itself, warrant the provision of similar accommodations at MBC.
Documentation Requirements for Psychological Disorders
All reports should be typed on letterhead, dated and signed.
I. Qualifications of the Evaluator – The evaluator’s name, title, and license/certificate credentials must be stated.
II. Current Documentation – Evaluation data must be no more than one year old.
III. History to Support Diagnosis – A description of the duration and severity of the disorder must be included. In addition, relevant medical, familial, and social histories should be included.
IV. Assessment of Psychiatric Disorders – The evaluator should include specific evaluation data to support a diagnosis of a psychiatric disorder. Results of standardized assessments, rating scales, or checklists are important, but need not be the sole criterion for a diagnosis of a psychiatric disorder. A description of current symptoms and current treatments must be included. If the student is taking any medication related to the disability, the evaluator should describe the impact of that medication on the student’s ability to participate in an academic environment.
V. DSM-V or ICD-10 Diagnosis – A SPECIFIC statement that the student is diagnosed with a particular disorder, including the DSM-V or ICD-10 diagnostic (numeral) code, is required.
VI. Substantial Limitation to Learning – A psychiatric disability must limit a major life activity, such as learning, sleeping, or working, and there must be a significant limitation relative to what is common to the ‘average’ person. The evaluator must describe the major life activity affected by the psychiatric disability and describe how the disability presents a substantial limitation to academic performance.
VII. Recommendations for Accommodations – The report must include specific recommendations for academic accommodations and the rationale for those accommodations. A history of accommodations does not, in itself, warrant the provision of similar accommodations at MBC.
Documentation Requirements for Traumatic Brain Injury (TBI)
All reports should be typed on letterhead, dated and signed.
I. Qualifications of the Evaluator – The evaluator’s name, title, and license/certificate credentials must be stated.
II. Current Documentation – Evaluation data must be no more than three years old.
III. History to Support Diagnosis – A description of the duration and severity of the injury must be included. In addition, date of diagnosis, last contact with the individual, approximate date of onset, and symptoms should be included.
IV. Assessment of Cognitive Abilities and Educational Achievement – The evaluator should provide an assessment of the student’s cognitive abilities, including processing speed and memory (post-rehabilitation and within one year). Also, standard scores from individually administered, standardized achievement tests must be reported. The evaluator should assess reading comprehension, written language, spelling, and mathematical abilities. If the student is taking any medication related to the disability, the evaluator should describe the impact of that medication on the student’s ability to participate in a college environment.
V. DSM-V or ICD-10 Diagnosis – A SPECIFIC statement that the student is diagnosed with a neurological injury, including the DSM-V or ICD-10 diagnostic (numeral) code, is required.
VI. Substantial Limitation to Learning – The disability must limit a major life activity, such as walking, learning, or working, and there must be a significant limitation relative to what is common to the ‘average’ person. The evaluator must describe the major life activity affected by the disability and describe how the disability presents a substantial limitation to academic performance.
VII. Recommendations for Accommodations – The report must include specific recommendations for academic accommodations and the rationale for those accommodations. A history of accommodations does not, in itself, warrant the provision of similar accommodations at MBC.
Documentation Requirements for Attention Deficit Hyperactivity Disorder (ADHD)
All reports should be typed on letterhead, dated and signed. A High School IEP, 504 Plan, and /or a letter from a physician or other professional will not be sufficient to document a learning disability. Medication cannot be used to imply a diagnosis.
The following must be included in a report:
I. Qualifications of the Evaluator – The evaluator’s name, title, and license/certificate credentials must be stated.
II. Current Documentation – Evaluation data must be no more than three years old.
III. Evidence of early impairment – The condition must have been exhibited in childhood in one or more settings. Please include a brief academic history.
IV. Evidence of current impairment – In addition to the individual’s history, documentation of current difficulties must include the student’s clinically significant impairment in current social, academic, or occupational functioning. Must include evidence of impairment in two or more settings. Please include a description of how this individual is functionally limited in the classroom.
V. Historical Information, Diagnostic Interview, Psychological Evaluation
a. Developmental history, including history of symptoms
b. Duration and severity of the disorder
c. Relevant, developmental, historical, and familial data
d. Behavioral Assessment Instruments for ADHD normed on adults; these should include at least two ratings scales (with scores and summary data) completed by individuals other than parents (preferably teachers).
VI. Neuropsychological or psychoeducational assessments – Such assessments are necessary to determine the current impact of the disorder on the individual’s ability to function in an academic setting. Data should include subtest and standard scores to support conclusions, and should at least include most recent versions of a comprehensive intelligence battery and a comprehensive achievement battery. (Note: Assessments such as checklist and rating scales are very important, but checklists, scales or subtest scores should not be used as the sole criterion for a diagnosis of ADHD.)
All reports must include an interpretation of test results. Test protocol sheets, handwritten summary sheets or scores alone are not sufficient. Acceptable instruments – Aptitude / Cognitive ability
- Wechsler Adult Intelligence Scale III (or latest version). The WAIS is the preferred instrument
- Woodcock-Johnson Psychoeducational Battery – Revised: Test of Cognitive Ability
- Stanford-Binet Intelligence Scale
Unacceptable instruments – Aptitude / Cognitive ability
- The Kaufman Brief Intelligence Test (KBIT) is not a comprehensive measure and is therefore not suitable for documentation purposes at MBC
- Wechsler Intelligence Scale for Children (WISC) – this instrument is not standardized for use with adults
Acceptable instruments – Academic Achievement
- *The Woodcock-Johnson Psychoeducational Battery – Revised: Test of Achievement
- *Wechsler Individual Achievement Test (WIAT)
- *Standard Test of Academic Skills (TASK)
- *Scholastic Abilities Test for Adults (SATA)
- *Specific achievement tests such as Test of Written Language – 4 (TOWL – 4), Woodcock Reading Mastery Tests – Revised, or the Stanford Diagnostic Mathematics Test
Unacceptable instruments – Academic Achievements
- The Wide Range Achievement Test (WRAT)
- Mini-Battery of Achievement (These are not comprehensive measures of achievement and are therefore not suitable for documentation purposes at MBC)
VII. Diagnosis – A clear and specific statement that the student is diagnosed with ADHD and the accompanying DSM-V code(s) are required. Must include DSM-V criteria upon which this diagnosis was established. Alternative explanations and diagnoses must be ruled out.
VIII. Medication – Indicate whether or not the student is diagnosed while on medication, and whether or not the prescribed treatment produced a positive response. Medication alone cannot be used to support a diagnosis.
IX. Recommendations for Accommodations – The report must include specific recommendations for academic accommodations and the rationale for those accommodations. A history of accommodations does not, in itself, warrant the provision of similar accommodations.
Documentation Requirements for Emotional Support/Assistance Animal (ESA)
MBC is committed to providing reasonable accommodations in accordance with federal guidelines to qualified students with disabilities, and recognizes that some members of the MBC community with disabilities may require the use of service or assistance animals while at MBC. These guidelines are intended to help you and your provider in preparation of documentation. Please keep in mind that thoroughly addressing guidelines helps Counseling Services & Student Accommodations in determinations of disability and disability need for assistance animals. Requests for an assistance animal require complete documentation to be submitted before review and rendering of a decision and/or recommendation. Documentation must be dated within the last 12 months. The following should be included in the report:
- Student information including name, date of most recent evaluation
- The credentials and contact information of the evaluator(s);
- Assessment information: results and interpretation of specific evaluation data to support diagnosis;
- Length of time the provider and student have been in a therapeutic relationship;
- Clear statement of diagnosis including the DSM-5 or ICD-10 diagnostic code and a description of the diagnostic methodology used (monthly medication management, psychotherapy, case management, etc.);
- A description of the current functional limitations;
- A description of the expected progression or stability of the disability;
- A Treatment Plan for the past six months, outlining the goals and objectives for student, and the treatment role the Support Animal will play in the therapeutic process;
- A description of current and past accommodations, services and/or medications;
- Statement on how the animal serves as an accommodation for the verified disability;
- Length of time animal has been prescribed in care
- Evidence of reduced symptomology, improved functioning from assistance animal treatment role
- Statement on how the need for the animal relates to the ability of the resident/student to use and enjoy the living arrangements provided by the University
- Evidence of current impairment:
Description of how disability currently impacts the student in social, academic, or occupational settings
Description of how the disability will limit the student in a residential setting
Discussion of how the assistance animal is necessary for the resident to use and enjoy College housing as compared to a person without a disability
Note: Some websites sell certificates, registrations, and licensing documents for assistance animals to anyone who answers certain questions or participates in a short interview and pays a fee. The Housing and Urban Development Department notes that such documentation, by itself, is not sufficient to establish disability or disability related need for an assistance animal. In accordance with the Fair Housing Act, MBC expects requests for assistance animal accommodations be accompanied with sufficient documentation of a disability and a disability related need for an assistance animal. Please use caution when seeking assistance animal documentation from websites that claim to guarantee to provide all the documentation you need.