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INFORMATION FOR STUDENTS: Documentation Guidelines for Mental Health Disabilities

Printable version of these guidelines


Introduction
Documentation Guidelines


Appendix A: Recommendations for Consumers
Appendix B:  Assessing Adolescents and Adults with Psychiatric Disabilities


Introduction

Under the Americans With Disabilities Act Amendments Act (ADAAA) and Section 504 of the Rehabilitation Act of 1973, individuals with disabilities are protected from discrimination and may be entitled to reasonable accommodations and rights to equal access to programs and services. A diagnosis of a disorder/condition alone does not automatically qualify an individual for accommodations under the ADAAA. To establish that an individual is covered under the ADAAA, the documentation must indicate that the disability substantially limits one or more major life activity, and supports the request for services, accommodations, academic adjustments, and/or auxiliary aids.

Accessible Education Office (AEO) recognizes that “mental health disabilities” is a generic term, referring to a variety of conditions involving psychological, emotional and behavioral disorders and syndromes, used for the purpose of determining eligibility for accommodations; and those symptoms must rise to the level of a disability as defined by 504/ADA. The two official nomenclatures designed to outline the criteria used in making these diagnoses are the Diagnostic and Statistical Manual, IV (DSM-IV) and the ICD-10.

This document provides guidelines necessary to establish the impact of mental health disabilities on the individual's educational performance and participation in other University programs and activities, and to validate the need for accommodations. In instances where there may be multiple diagnoses including learning disabilities and/or attention-deficit/hyperactivity disorders (ADHD), evaluators should consult the appropriate companion guidelines as found at learning disability documentation guidelinesfor learning disabilities andADHD clinical documentation guidelines for ADHD.

Information and current clinical documentation submitted by students to verify accommodation eligibility must be comprehensive in order to avoid unnecessary delays in decision making related to the provision of requested accommodations.

Sometimes students may be asked to provide updated comprehensive information if their condition is potentially changeable and/or previous documentation doesn't include sufficient relevant information.

This document contains information regarding four important areas:

  1. Qualifications of the evaluator;
  2. Recency of documentation;
  3. Comprehensives of the documentation to substantiate the current diagnosis of a mental health disability;
  4. Multiple Diagnoses

Appendices A and B, respectively, provide recommendations for consumers and suggestions for assessment.

Definitions:

Psychiatric Disabilities:  Comprise a range of conditions characterized by emotional, cognitive, and/or behavioral dysfunction. Diagnoses are provided in the DSM-IV-TR or the ICD-10. Note that not all conditions listed in the DSM-IV-TR are disabilities, or even impairments for purposes of 504/ADAAA. Therefore a diagnosis does not, in and of itself, constitute a disability necessitating legal accommodations under the ADAAA or 504 of the Rehabilitation Act of 1973.

Major Life Activity:  Examples of major life activities include: walking, sitting, standing, seeing, hearing, speaking, breathing, learning, working, caring for one’s self and other similar activities. In particular, individuals with mental health disabilities may also experience thinking disorders/psychotic disorders which may interfere with specific activities but not others.

Functional Limitations:  A substantial impairment to the individual’s ability to function in the “condition, manner or duration” of a required major life activity.

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Documentation Guidelines

1. A Qualified Professional Must Conduct the Evaluation

Professionals conducting assessments, rendering diagnoses of mental health disabilities, and making recommendations for accommodations must be qualified to do so.  Evidence of both comprehensive training and relevant experience in differential diagnosis in the full range of mental health disorders, as well as appropriate licensure/certification are essential.

Qualified evaluators are defined as those licensed individuals who are qualified to evaluate and diagnose mental health disabilities or who may serve as members of the diagnostic team. These individuals or team members may include psychologists, neuropsychologists, psychiatrists, clinical social workers, licensed counselors, and mental health nurse practitioners. Primary documentation may be provided from more than one source when a clinical team approach consisting of a variety of educational, medical, and counseling professionals has been used.

Diagnosis of mental health disabilities documented by family members will not be accepted due to professional and ethical considerations even when the family member is otherwise qualified by virtue and licensure/certification. The issue of dual relationships as defined by various codes of professional ethics should be considered in determining whether a professional is in an appropriate position to provide the necessary documentation.

Finally, the name, title, and professional credentials of the qualified professional writing the report should be included. Information about licensure/certification, as well as the area of specialization, employment, and state or province in which the individual practices should be clearly stated in the documentation.  All reports should be in English, typed on professional letterhead, dated and signed.

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2. Documentation Must Be Current

Due to the changing nature of mental health disabilities, it is essential that a student provide recent and appropriate documentation from a qualified professional. Since reasonable accommodations are based on the current impact of the disability, the documentation must address the individual’s current level of functioning and the need for accommodations (e.g., due to observed changes in behavior and/or performance or due to medication changes since previous assessment). If the diagnostic report is more than six months old the student must also submit a letter from a qualified professional that provides an update of the diagnosis, a description of the student’s current level of functioning during the preceding six months, and a rationale for the requested academic or residential accommodations.

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3. Documentation Necessary to Substantiate the Diagnosis Must Be Comprehensive

In most cases,documentation should be based on a comprehensive diagnostic/clinical evaluation meeting the guidelines outlined in this document. The diagnostic report should include the following components:

  1. A specific diagnosis (see 3.B)
  2. A description of current functional limitations in the academic environment as well as across other settings (see 3.A.5)
  3. Relevant information regarding medications expected to be in use and their anticipated impact on the student in this setting (see 3.A.4)
  4. Relevant information regarding current treatment
  5. Specific request for accommodations with accompanying rationale (see 3.D)

A.  Historic Information and Diagnostic Interview, and/or Psychiatric Assessment

The information collected for the summary of the diagnostic interview should include, but is not limited to, the following:

  1. History of presenting symptoms.
  2. Duration and severity of the disorder.
  3. Relevant developmental, historical, and familial data.
  4. Relevant medical and medication history, including the individual’s current medication regimen and compliance, side effects (if relevant) and response to medication.
  5. Description of current functional limitations in different settings with the understanding that a mental health disability usually presents itself across a variety of other settings in addition to the residential and academic domain and that is expression is often influenced by context-specific variables (e.g., school-based performance).
  6. As relevant to the residential domain, a description of observed behaviors which likely impact dormitory life, and progression or stability of the impact of the condition over time.
  7. As relevant to the test taking performance, a description of the expected progression or stability of the impact of the condition over time.
  8. As relevant to the test taking performance, information regarding kind of treatment and duration and consistency of the therapeutic relationship.

B.    Documentation Must Include a Specific Diagnosis

The report must include a specific diagnosis based on the DSM-IV-TR, or ICD-10 diagnostic criteria, and specific diagnostic section in the report with a numerical and nominal diagnosis from DSM-IV-TR or ICD-10 included. Evaluators are encouraged to cite the specific objective measures used to help substantiate the diagnosis. The evaluator should use direct language in the diagnosis of a mental health disorder, avoiding the use of such nonspecific terms as "suggests", "has problems with," or "may have emotional problems."

C.   Alternative Diagnoses or Explanations Should Be Ruled Out

The evaluator must also investigate, discuss, and rule out the possibility of other potential diagnoses involving neurological and/or medical conditions or substance abuse, as well as educational, linguistic, sensorimotor, and cross-cultural factors which may result in symptoms mimicking the purported mental health disability.

D.   Rationale for Requested Accommodations Must Be Provided

The evaluator must describe the current impact of the diagnosed mental health disorder on a specific life activity as well as the degree of impact on the individual.  A link must be established between the requested accommodations and the functional limitations of the individual that are pertinent to the anticipated academic and residential settings. Accommodations will only be provided when a clear and convincing rationale is made for the necessity of the accommodation. A diagnosis in and of itself does not automatically warrant approval of the requested accommodations. For example, test anxiety alone is not a sufficient diagnosis to support requests for accommodation. Given that many individuals may perceive that they might benefit from extended time in testing situations, evaluators must provide a specific rationale and justification for this accommodation. A prior history of accommodations, without demonstration of current need, does not in and of itself warrant the provision of accommodations. If no prior history of accommodation exists, the evaluator and/or the student must include a detailed explanation of why no accommodations were needed in the past, and why they are now currently being requested. Psychoeducational, neurospychological or behavioral assessments are often necessary to support the need for accommodations based on the potential for mental health disorders to interfere with cognitive performance.

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4.   Multiple Diagnoses.  Multiple diagnoses may require a variety of accommodations beyond those typically associated with one diagnosis, and therefore the documentation must adhere to AEO guidelines for other diagnoses found on this web site:

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Appendix A – Recommendations for Consumers

  1. For assistance in finding a qualified professional (See Section I for the definition of a qualified professional):
  2. Harvard students may contact the Bureau of Study Counsel, University Health Services (UHS), AEO or local Disability Coordinator for possible referral sources; or   
  3. Contact your physician who may be able to refer you to a qualified professional with demonstrated expertise in mental health disabilities.
  4. Considerations in selecting a qualified professional:
  5. Ask what experience and training he or she has had diagnosing adolescents and adults.
  6. Ask whether he or she has training in different diagnoses and the full range of mental health disorders. Clinicians typically qualified to diagnose mental health disorders may include clinical psychologists, psychiatrists, neuropsychologists, clinical social workers and other relevantly trained doctors.
  7. Ask whether he or she has ever worked with a post secondary disability service provider or with an agency to which you are providing documentation.
  8. Ask whether you will receive a comprehensive written report.
  9. Ask whether you will have an opportunity to discuss the information contained in the report.
  10. When working with the professional
  11. :
  12. Take a copy of these guidelines to the professional so he or she knows what to expect when preparing the evaluation.
  13. Be prepared to be forthcoming, thorough, and honest with requested information.
  14. As follow-up to the assessment by the professional:
  15. Schedule a meeting to discuss the results, recommendations, and possible treatments.
  16. Request additional resources, support group information, and publications if you need them.
  17. Maintain personal file of our records and reports.
  18. Be aware that any receiving institution or agency has a responsibility to maintain confidentiality.
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    Appendix B – Assessing Adolescents and Adults With Psychiatric Disabilities

    This appendix contains selected examples of tests which may be used to supplement the clinical interview and support the presence of functional limitations.

    1.  Neuropsychological and Psychoeducational Testing

    Cognitive, achievement and personality profiles may suggest attention or information processing deficits.  No single subtest should be used as the sole basis for a diagnostic decision.  Acceptable instruments include, but are not limited to:

    1. Aptitude/Cognitive Ability:
      • Wechsler Adult Intelligence Scale – III (WAIS-III)
      • Woodcock-Johnson Psychoeducational Batter – Revised: Tests of Cognitive Ability
      • Kaufman Adolescent and Adult Intelligence Test
    2. Academic Achievement
      • Stanford Test of Academic Skills (TASK)
      • Woodcock-Johnson Psychoeducational Battery – Revised: Tests of Achievement
      • Wechsler Individual Achievement Test (WIAT)
      • Or specific achievement tests such as:

      • Nelson-Denny Reading Skills Test
      • Stanford Diagnostic Mathematics Test
      • Test of Written Language – (TOWL-3)
      • Woodcock Reading Mastery Tests - Revised

    3. Information Processing
      • Detroit Tests of Learning Aptitude – 3 (DTLA-3) or Detroit Tests of Learning Aptitude – Adult (DTLA-A)
      • Information from subtests on WAIS-R or Woodcock-Johnson Psychoeducational Battery – Revised: Tests of Cognitive Ability
      • Other relevant instruments may be useful when interpreted within the context of other diagnostic information.

    4. Personality Tests
      • Minnesota Multiphasic Personality Inventory (MMPI)
      • Millon Clinical Multiaxial Personality Inventory-II
      • Rorschach Inkblot Test
      • Thematic Appreception Test (TAT)

    5. Rating Scales
    6. Self-rated or interviewer-rated scales for categorizing and quantifying the nature of the impairment may be useful in conjunction with other requested data.

      Selected examples include:

      • Yale-Brown Obsessive Compulsive Scale
      • Beck Depression Inventory
      • Beck Anxiety Inventory
      • Hamilton’s Depression Rating Scale
      • Zung Depression Rating Scale
      • Taylor Manifest Anxiety Scale

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    Adapted from Task Force on Psychiatric Disabilities © Educational Testing Service,July 2001. Stuart Segal, Co-chairperson, University of Michigan; Arunas Kuncaitis, Co-chairperson, Boston, Massachusetts; Phyllis Brown-Richardson, Long Island University; Patricia Carlton, The Ohio State University; Cyndi Jordan, University of Tennessee Center for Health Sciences, The Hutchison School; Nancy Pompian, Dartmouth College; Louise H. Russell, Harvard University; Deborah Taska, Arizona State University

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