An important part of determining the nature and impact of the student’s condition is documentation. While a student can speak to and is required to speak to their condition via a self-report in the meeting with SAS, it is also important to gain additional perspective on the nature and impact of the condition. Ultimately, SAS must determine if the person is a qualified individual with a disability and whether a condition “substantially limits one or more major life activity”. This is where documentation comes into play.
Provider Guidance: Submitting Documentation to SAS
There are a number of different potential sources of documentation. SAS considers general documentation in the following ways:
- Primary source - Student self-report
- Secondary sources – Secondary sources are supportive in determining accommodations, but alone are not sufficient
- Provider support letters
- Individualized Education Programs (IEPs)
- 504 Plans
- Previous accommodation letters
It should be noted that currently an IEP or 504 Plan is not considered sufficient to automatically establish the existence of a disability. An IEP or a 504 plan could meet the necessary criteria as later outlined, but it does not necessarily do so. However, in addressing testing within private entities, the Title III regulations notes:
Review Criteria for General Documentation
- Basic Criteria, documentation should:
- Be on official letterhead, dated, typed, and in English
- Be written by a licensed provider
- Must come from a professional with an existing relationship to the student
- Include information about the student diagnosis
- Include any current, objective assessment data to support the diagnosis
- Detail the functional limitations, including the severity of said limitations
- Discuss any relevant accommodation history
- Detail the connection between the functional implications and the accommodations being requested by the student
- Recency Criteria
- ADHD, LD, ASD, ID - generally within 5 years
- Psychological, TBI - generally within 1 year
- Health, Sensory - variable depending on condition permanence
Documentation standards as outlined by HUD are different than the documentation standards within the ADA and Section 504. SAS may request documentation for housing requests to help confirm the student’s condition. Within their assistance animal guidance, HUD provides a list of sources that would qualify as documentation:
- A determination of disability from a federal, state, or local government agency.
- Receipt of disability benefits or services (Social Security Disability Income (SSDI)), Medicare or Supplemental Security Income (SSI) for a person under age 65, veterans’ disability benefits, services from a vocational rehabilitation agency, or disability benefits or services from another federal, state, or local agency.
- Eligibility for housing assistance or a housing voucher received because of disability.
- Information confirming disability from a health care professional –e.g., physician, optometrist, psychiatrist, psychologist, physician’s assistant, nurse practitioner, or nurse.
- Documentation purchased from the internet generally does not meet documentation standards
In the scenario when documentation is needed, housing only documentation:
- Basic Criteria. Housing only documentation should:
- Be on official letterhead, dated, typed, and in English
- Must come from a professional with an existing relationship to the student
- Provide information about the specific functional impacts of the condition
- Detail the relationship between the condition and the accommodation request
- Regarding Emotional Support Animals (ESA) this can also include information on work the animal does, tasks performed, and type of assistance
- Recency Criteria
- ADHD, LD, ASD, ID - generally within 5 years
- Psychological, TBI - generally within 1 year
- Health, Sensory - variable depending on condition permanence
