Differences Between High School and College Accommodations

Background: Federal Laws-Section 504, IDEA, ADA, and FERPA

There are a lot of differences in the laws that apply to accommodations in the K-12 setting and in college. It’s important for students and families to understand that the services, supports, and accommodations that you may have received in high school, may not be available in the college setting. There are three main laws that students and families should be familiar with.

The first is the Individuals with Disabilities Education Act (IDEA). This is a law that governs special education services for students with disabilities in grades K-12 and provides for free and appropriate public education and services. Students who are receiving accommodations under IDEA typically have an “IEP” (Individualized Education Program) that outlines their accommodations and services from kindergarten through high school graduation.

The next law is Section 504 of the Rehabilitation Act of 1973 (Section 504). It provides protection against discrimination on the basis of disability and applies to both high schools and colleges. K-12 students who receive accommodations under Section 504 may have a “504 Plan.” This is a plan that outlines what accommodations the student receives. Section 504 also applies to the college setting, however, a student’s 504 Plan from the K-12 environment may not directly transfer to the college setting in terms of the types of accommodations that a college offers. It’s important to note that private K-12 schools, have to adhere to Section 504 and remove barriers to education, but private schools do not have to provide accommodations and services under IDEA. Students in private schools might have an “access plan” or an “academic plan” that outlines their accommodations.

High School versus College

College accommodations are different from high school accommodations in a number of ways. In the college setting, IDEA is no longer an applicable law. Colleges provide “reasonable accommodations” for students with disabilities as defined by the Americans with Disabilities Act (ADA) and protection from discrimination as outlined in Section 504. Accommodations and services that were outlined in an IEP or a 504 Plan may not directly transfer over to college. The ADA and Section 504 have very specific guidelines around what are known as “auxiliary aids“ (Aids and Services for Postsecondary Students with Disabilities). This means that services such as occupational therapy, speech therapy, reading support, and para-educators, which may have been a part of your IEP, are not a part of college accommodations. Additionally, since many students live on a college campus, there may be additional accommodations to consider for housing, dining, and recreation, particularly if you are living with hydrocephalus and comorbidities such as epilepsy, spina bifida, and cerebral palsy, to name a few. Each college has different practices in place around the accommodations that they provide, and they may also offer services to support students. It’s important for you and your family to do their own research about each school.

The other difference is that in college you, as the student, have to be engaged in the “interactive process” and request your own accommodations, whereas in the K-12 setting, your parents are usually advocating and driving the conversations and requests. Parents no longer have a role in the accommodations process once you are in college. In fact, the Federal Educational Rights and Privacy Act (FERPA), prevents parents from being able to access academic progress and grade reports, financial information, dorm life, student activities, and any disciplinary actions. The expectation is that by the time you start college, you will be able to self-advocate and communicate effectively with university administrators. If the student and your parent agree to allow the parent access to this information, you will need to sign a FERPA waiver at the college.

Functionally, as many students will be living away from home and navigating their day-to-day on their own, this means that you will have to initiate conversations with university administrators and follow university processes independently.

It’s critical that students and parents understand the differences between the laws that govern high school and college, and begin to understand what the expectations are for students with medical conditions and/or disabilities in college. Starting the conversation early and identifying areas where students can develop skills is essential.

Accommodations in College

Every college has a Disability Support Office (DSO), or an administrator who is tasked with overseeing the accommodation request process and facilitating accommodations.

If you want to receive accommodations in college, you will need to contact the DSO to start that process once you are accepted. It’s a good practice to start the process well in advance of the semester starting. Additionally, if you are requesting housing accommodations there is typically a different timeline. Most housing accommodation requests are due in May or June prior to the first semester.

It’s important to contact the DSO and check their website to understand the process for requesting accommodations. At most schools, the process starts with the student contacting the DSO to request accommodations. The DSO may ask you to fill out a form or have a conversation with a counselor. Then you will need to submit documentation. For students with hydrocephalus, this will likely be a letter from your healthcare provider that outlines your condition, any comorbidities, functional limitations, and recommended accommodations. This may not be your neurosurgeon, particularly if you see medical specialists for other conditions. This could be your pediatrician, neurosurgeon, neurologist – choose the provider who best knows your entire medical history and needs. Many schools have documentation guidelines that students can give to their healthcare provider to help inform their letter.

If you also have a learning disability, you will need to provide a neuropsychological evaluation. Most colleges will only accept an evaluation that has been completed in the last 3 years. Be sure to check with the college.

If you have a psychological condition that may impact you at college, you should plan to get a letter from your psychiatrist or psychologist or a psychological evaluation.

You can also submit a copy of your IEP, 504 Plan, or academic plan from high school. It’s important to note that these documents are not typically accepted as documentation of a disability, however, they can provide the DSO with information that may inform the types of accommodations that you may be eligible for in college.

Once you submit the required documentation, it can take anywhere from 1-6 weeks for the DSO to evaluate the documentation. The DSO will then meet with you and discuss the request for accommodations. Once the accommodations are approved, you will get either a hard copy letter to give to each of your professors that outlines the approved accommodations, or the professor will receive an email with the accommodations listed. You, as the student, are still expected to have a conversation with each professor about how the accommodations will work for each class. If you receive test-taking accommodations, such as extra time or a distraction-reduced environment, you may also be responsible for making arrangements with the DSO to take the test when it is time.

Examples of the Differences

A lot changes in college when it comes to accommodations. In terms of how things differ from high school to college functionally, here are a few examples:

High School: The school takes the lead in arranging accommodations. For example, if the student gets extra time on tests, the school knows and makes those arrangements.

College: The student has to engage in the “interactive process” and request accommodations. The interactive process requires the student to meet with a counselor in the Disability Support Office (DSO) and provide documentation of a disability/health condition. Example: If the student needs extra time on tests, most colleges have a process to request to take an exam with extra time in a testing center which typically involves making the request at least 7 days prior to the exam.

High School: Teachers identify when the student needs support. Teachers can connect with parents and share information.

College: The student has to be proactive in seeking out support by going to office hours, hiring tutors, and taking advantage of the services the college offers. Additionally, professors and administrators are restricted by the Family Educational Rights and Privacy Act (FERPA), a federal law, which prevents university personnel from sharing information such as grades, class schedules, and disciplinary action, with parents. Students and families that opt to allow parents to access this information will need to sign a release form, typically with the college’s Registrar.

Families need to start preparing students early for this change so that students have the executive function and self-advocacy skills to be successful in college.

Self-Advocacy

Self-advocacy, the ability to understand and communicate one’s needs, is key. You will need to be able to effectively discuss your disability and explain your needs when you are in college. These are the essential self-advocacy skills that students need to support their successful transition:

• Knowledge of their medical condition(s) and disability(ies)
  • Able to name and describe condition(s)
    Example: I have a neurological condition called hydrocephalus where my body cannot absorb or circulate the cerebral spinal fluid in my brain. This can cause me to have headaches which often impact my ability to concentrate and focus. I also have a seizure condition and a visual impairment.
• Understand how their hydrocephalus and any other disabilities impact them in daily living
  • Able to discuss how their disability/ies impact their ability to participate in school, daily living, and programs.
    Example: Hydrocephalus impacts my ability to navigate campus – it may take me longer to remember where buildings and classrooms are located and walk for long distances. My hydrocephalus also impacts my sleep, and I often do not sleep well, leaving me fatigued the next day.
• Understand how their hydrocephalus and any other disabilities impact them academically
  • Able to discuss any learning disabilities and how they impact their ability to participate in the classroom.
    Example: I have been diagnosed with executive function challenges. I also have memory issues and ADHD. This impacts my ability to take notes and focus on lectures. I struggle with mental math and math, in general. Managing a lot of deadlines can often be a challenge.
• Know what accommodations they need (academic, residential, transportation, programmatic)
  • Identify their “functional limitations” and consider how they are impacted in each setting they may encounter in college, and identify accommodations that will support them.
    Example: Because I have trouble focusing, I will need a notetaker so that I can concentrate on the lecture. I will also need extra time for tests and quizzes, as well as extra time to complete assignments. In order to make sure I’m getting enough time for rest and recovery, I’ll need a single room or a room with fewer roommates.
• Able to communicate their needs
  • Able to identify who they should speak with and effectively communicate their needs
    Example: I need a notetaker so that I can focus on the class lecture and not have to capture notes at the same time. Recording the lectures is helpful, but it does not support my needs.
• Understand their rights and responsibilities under the law
  • A general knowledge and understanding of the Americans with Disabilities Act and Section 504, and the application of these laws in the college setting.

Here are some ways that you, your parents, and your high school academic team can help you develop your self-advocacy skills that will benefit you in college and in independent living:

• Involve students in their high school IEP and 504 Plan meetings. This can start as early as middle school. By the end of high school, the student should be leading the meeting and be the primary speaker.
• Support students to schedule, prepare, and communicate directly with health care providers. Visit our Transition Timeline.
• Assist students in developing processes for independent medication management, including getting, filling, and taking medications. Visit our Transition Timeline.
• Support students in creating routines and schedules for personal care.
• Support students in creating routines and schedules for academic work and extracurricular activities.

By working to develop self-advocacy skills early, you will be better prepared to navigate college and independent living.

Helpful Acronyms

• ADA: Americans with Disabilities Act
• IDEA: Individuals with Disabilities Education Act
• DSO: Disability Support Office
• IEP: Individualized Education Program
• FERPA: Federal Educational Rights and Privacy Act

Information you can trust! This article was produced by the Hydrocephalus Association, copyright 2021, in collaboration with Annie Tulkin, MS, of Accessible College.