You Asked! – Question 26

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Q26:  How can students with dyslexia receive accommodations for the SAT or ACT?

A:  College is an option for students with dyslexia, but preparing for College, College Board (SAT) and ACT exams should start as early as possible in high school.

Freshman Year – Sophomore Year:

•  Meet with the 504 Coordinator or Special Education Staff to ensure appropriate accommodations are documented in your student’s IEP or 504 Plan.   Sometimes students are given accommodations, but the accommodations are not documented in their plan. For example, students are allowed to use a calculator for math tests, but the accommodation of a calculator is not documented on the plan.

 To receive college accommodations, colleges may require testing to be current and comprehensive and include testing scores. In most cases, this means within the past three to five years. Families should ensure all accommodations that a student may need in college are included in their current assessment report. Students in Special Education mustbe evaluated at least every three years (Triennial Assessments1) and student’s with 504 Plans may be re-evaluated in accordance with IDEA regulations2. Therefore, you can request the district to re-evaluate your student.

•  What if your struggling student does not have an IEP or 504 Plan? The first step in determining if your student has a disability and requires special education services would be to make a written request to the district for an evaluation. Review DREDF Sample Letters and Forms and ACT’s Policy for Documentation.

Sophomore Year:

•  Schedule a meeting with the school’s Testing Coordinator to understand the process for each test. Plan on requesting accommodations for the exam(s) your student will take: PSAT/ NMSQT, ACT, SAT, PSAT 10, or AP Exams.

•  Assist your school’s Testing Coordinator and ensure your student will receive appropriate accommodations by gathering the necessary documentation (IEP, 504 Plan, Psychoeducational/Neuropsychological Evaluations). Describe the specific accommodations requested, and explain why they are needed. Include information about your student’s history of receiving school accommodations and current use of accommodations.

>  As of January 1, 2017, the College Board (SAT) will use a new streamlined process for requesting testing accommodations for students.  The new review process means that the College Board is allowing automatic approval of accommodations in more situations. In most cases this includes students with an IEP, 504 Plan or a formal school-based plan at a private school. The school Testing Coordinator submitting requests for accommodations will only need to answer two questions: Is the requested accommodation(s) in the student’s plan? Has the student used the accommodation(s) for school testing?

If the answer to both of the above questions is yes, eligible students can be approved to receive most accommodations on College Board tests.

>  The accommodations your student may be eligible to receive will vary based on his/her needs and situation. Review examples of College Board Accommodations.

»  The four-function calculator accommodation must be approved and is appropriate for students who have a disability that impacts their ability to perform mathematic calculations.

>  Because the SAT/ACT accommodation approval process may include a thorough review of all information provided, it can take approximately 2-7 weeks. The process can take even longer if a request for testing accommodation(s) has not been fully approved or if it requires additional documentation.

>  The student’s history of receiving accommodations in school is important in the SAT/ACT review of requests for accommodations. Teacher Survey forms can help substantiate a student’s need for accommodations when it is not listed on their plan. ACT Teacher Survey Form and College Board Teacher Survey Form.

 If your student has an IEP, their Transition Planning Services must start by the time the student reaches 16 years of age and should be updated annually. The Transitional IEP3 should include appropriate measurable postsecondary goals relating to education and, if appropriate, college goals.

 The PSAT and PLAN/Pre-ACT can help students determine the test that best suits them. The summer before Junior year, students should take practice SAT/ACT. SAT Practice Test and ACT Test Prep Resources.

Junior Year-Fall Senior Year:

•  Schedule to take the SAT and/or ACT. Ensure that the correct accommodations are in place every time your student takes the exam. Don’t wait until test day to find out that a necessary accommodation has not been requested! To be safe, students should bring their Accommodation Eligibility Letters to the test site.

 By the Junior or Senior year, if your student has a diagnosed disability, but does not have an IEP or 504 Plan, it may be difficult to receive the necessary SAT/ACT accommodations. Meet with your Testing Coordinator and provide all relevant documentation. You can still make a request to the school district for a comprehensive assessment to determine eligibility for special education or under Section 504. It may be necessary to consult with an outside private evaluator.

>  To be eligible for accommodations on College Board exams, a student should have documentation showing evidence of the following:

»  The disability

»  The degree to which the student’s activities are affected (functional limitation)

»  The need for the specific accommodations requested

>  Documentation Tips:

»  Do provide detailed documentation supporting your student’s need for the specific accommodation requested, not only the student’s diagnosed disability.

»  Don’t rely on doctor’s notes or IEPs. These are not sufficient to substantiate a request for accommodations. Provide conclusive statements with supporting information documenting your accommodation.

»  Do provide test scores, including subtest scores, where applicable.

•  Fall of Senior year is the last chance to take ACT/SAT tests before regular college application deadlines.

*Important College Board (SAT) Updates:

 English language learners (ELL) will have access to testing supports and extended time (if approved). For more information contact: Western Regional Office.

*Important ACT Updates:

 Starting in 2018, ACT will begin offering students the opportunity to take the ACT test in the summer. The first ACT summer test date will take place July 2018, increasing the number of national ACT test dates from six to seven.

 Starting in the fall of 2017, ACT will begin providing supports on the ACT test to U.S. students who are English language learners (ELL). Refer to ACT Policy for Supporting ELL.

Links to Helpful Forms and Documentation:

ACT Teacher Survey Form and College Board Teacher Survey Form

ACT 3 Step Checklist for Student and Parents Requesting Accommodations 

ACT Quick Start Quick for Requesting Accommodations

ACT Accommodation Information

ACT Policy for Accommodations Documentation

ACT Test Accessibility and Accommodations

ACT Preparing for the ACT Test Special Testing

College Board Accommodation Information

College Board Western Regional Office

DREDF Sample Letters and Forms

28 CFR Section 36.309 – Examinations and courses

ADA Testing Accommodations


1 Triennial Assessments [CA Education Code Section 56381]

2 [Source: U.S. Department of Education, Office for Civil Rights: Protecting Students With Disabilities-  Frequently Asked Questions About Section 504 and the Education of Children with Disabilities, Question #29.]

3 Transition Services [34 CFR Section 300.320(b)]

Author: Lori Chang, Parent Advocate

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You Asked! – Question 21

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Q21:  We suspect dyslexia but the school wants to delay assessing and they say my student won’t be eligible for special education as he is not two years behind.  Is this correct?

A:  This is an unfortunate “urban legend” that has been repeated so many times that many school personnel believe it to be true.  There is nothing in federal or California education law that states that a student must be two or more years behind in school to be found eligible for special education.  If this were the case, it would be impossible for a student in kindergarten or first grade to ever be found eligible as they haven’t been in school for two years and it would be very difficult for even a second grader to be found eligible.

So where did this incorrect information originate? 

As far as we can tell, it seems to be a result of confusion regarding use of the “severe discrepancy” model in identifying students as having a “Specific Learning Disability” for special education eligibility.

Under California law, there are three possible methods of determining whether a specific learning disability exists. One method allows for the use of a severe discrepancy model [5 CCR 3030(b)(10)(B)].  A severe discrepancy is defined as a difference between academic achievement and intellectual ability (“IQ”) of 1.5 standard deviations or more (adjusted by 1 standard error of measurement).

Let’s look at an example using a standard bell curve.  Assume this student has an average IQ of 100 (standard score).  In order to have a severe discrepancy, the student would have to receive a standard score in basic reading skills of 78 (or less) in order to have a standard deviation of 1.5 (or more).  [This would also apply to oral expression, written expression, reading comprehension, mathematical calculation or mathematical reasoning scores].

In its most simplistic form, you can take your student’s IQ* standard score and subtract 22.5 points. The difference (IQ-22.5) is the standard score that would result in a 1.5 standard deviation score (adjusted by one standard error of measurement, not to exceed 4 points). You can then compare this number to the standard scores your student received on standardized academic achievement testing in order to determine whether there is a severe discrepancy or not. Any scores at or below this number would indicate the presence of a severe discrepancy.

In our example, a student would have to perform very poorly to have this much of a gap between achievement and IQ so perhaps this has been incorrectly interpreted to mean a “two-year gap”.

However, there are a few critical things to note:

  1. In California, the use of severe discrepancy may be considered but must not be required. [5 CCR 3030(b)(10)(B)], 34 CFR 300.307(a)(1)].
  2. There are two other methods for determining a Specific Learning Disability – student doesn’t make sufficient progress when using Response to Intervention (“RTI”) [5 CCR 3030(b)(10)(C)(1) and 5 CCR 3030(b)(10)(C)(2)(i) or the student exhibits a “pattern of strengths & weaknesses” [5 CCR 3030(b)(10)(C)(2)(ii)].
  3. In addition, even if standardized tests don’t reveal a severe discrepancy the IEP team may still find that one exists [refer to 5 CCR 3030(b)(10)(B)(2) or 5 CCR 3030(b)(10)(B)(3).

So, the next time you hear the “must be two years behind” statement, request in writing that the school district show you where this is reflected in the education code. [Spoiler Alert:  It won’t be found.]

It can be helpful to ask the IEP team to provide documentation of the eligibility criteria they used in determining whether a Specific Learning Disability (SLD) exists and to walk you through their analysis.  There are often  “Specific Learning Disability Team Determination of Eligibility” forms that need to be completed and you should request a copy for your records. [IEP meetings discussing special education eligibility can be very complicated and may feel overwhelming to some parents. It is a good idea to audio record your student’s IEP meetings so you can listen again to any sections that were confusing.  You just need to provide 24-hour advance notice in writing that you will be doing so.]

In addition, please refer to You Asked! question 23 as to why the use of severe discrepancy should be abandoned.

* –  Please be advised that in California, IQ testing of African-American students is prohibited [refer to Larry P. v. Riles, 495 F. Supp. 926 (N.D. Cal 1979), 793 F. 2d 969 (9th Cir. 1984), 37 F. 3d 485 (9th Cir. 1994).  Also, see article from CA Association of School Psychologists (CASP Today Spring 2013 – Larry P. Edition, pgs. 7, 17)].

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