New ACT Accommodations Application Regime: More Efficient but also More Rigorous

The ACT, Inc. has made significant changes to its accommodations application system, resulting in a more efficient but also more rigorous process.

The ACT announced in May that it was migrating the accommodations process to a new online system, known as the Test Accessibility and Accommodations System (TAA). The new platform enables students to first register online and then work with their designated school official to complete an online accommodations request form. Once this form is complete, the school official is prompted to submit the specific documentation necessary to support the student’s request. The TAA platform is intended to help manage the surge in applications for ACT testing accommodations, and should hopefully expedite the review process. The TAA is also designed to help increase transparency, giving schools more ready access to application progress updates.

But efficiency and transparency, while certainly critical, are only part of the story. The ACT’s current Policy for Documentation sets forth rigorous standards for the type of support that must be provided along with an accommodations request, and the TAA enables the ACT to very efficiently communicate these specific documentation requirements to each applicant. While the level and type of documentation required for each applicant may vary, the ACT now has a targeted system for ensuring that each applicant’s school knows exactly what is required to substantiate the request. According to our school-based counselor contacts, the ACT has toughened up significantly, not only demanding more documentation, but also declining more requests than they have in the past.

Historically, the ACT has been more generous than the College Board in granting accommodations, claiming to approve 92 percent of accommodation requests, compared to 85 percent for the College Board. In 2013, the ACT granted special accommodations to almost 5% of students who took the test. In the same year, the College Board granted accommodations to only 2.3% of SAT takers: a rate more than fifty percent below that of the ACT. For years, counselors have reported that the ACT’s application process was relatively less onerous than the SAT’s process, particularly when it came to supporting documentation.

High school counselors on the frontlines of this process are beginning to tell us a very different story about what supporting documents are required and how the ACT will respond if such documents are not submitted. It seems the ACT is moving towards the College Board’s more rigorous model for evaluating applications: putting greater emphasis on psychological testing and formal school accommodation plans as evidence of the need for the requested accommodations.

Greater focus on psychological testing and documentation

To qualify for accommodations on the SAT or ACT, a student must present evidence of a professionally diagnosed disability and document how the student’s limitation impacts both daily functioning and the ability to take standardized tests. In the new world of ACT accommodations, the documentation of the disability is more important than ever. In most cases, the student must demonstrate a functional limitation through up-to-date testing (e.g., the Wechsler Adult Intelligence Scale, Woodcock-Johnson Tests of Cognitive Abilities, or a comprehensive neuropsychological evaluation). Teacher observation forms can certainly support a request, but a student could submit 20 teacher observation forms from grades 9-12 and be denied the accommodation if there is no current psychological testing on file.

The recency of the testing is also critical; indeed, the ACT’s standards here are more stringent than the College Board’s. While the College Board accepts five-year old testing, the ACT expects psychological testing to have taken place within three years of the request for accommodations. Students with out-of-date testing who have been receiving accommodations consistently on standardized tests (e.g., End of Course Tests) still have a shot of securing an accommodation, but the odds are significantly higher with current cognitive and academic testing.

Students may have a medical diagnosis of ADHD, a common diagnosis used to seek accommodations, but that’s insufficient to receive an accommodation. Students will typically need a cognitive test (e.g., the Wechsler) and an academic test (e.g., the Woodcock Johnson) to demonstrate their functional impairment and need for an accommodation. One of the most important factors is how their untimed performance compares to their timed performance on cognitive tasks. An ADHD diagnosis coupled with evidence of processing speed deficits will be much more likely to secure the accommodation.

Increased emphasis on formal school-based accommodations plans

The College Board and ACT want to see that the there is a formal accommodation plan in place at the high school: an Individualized Education Program (IEP), 504 Plan, Response To Intervention (RTI) plan, or other school-generated formal plan. Having a testing plan on file at the school with evidence that the student has been using the accommodation for at least four months will help the student. The ACT’s Policy for Documentation states that students who have not received accommodations in school must submit an explanation for why no accommodations were provided in the past and why they are now needed. As with the psychological testing component, the required evidence of school plans can play a significant gatekeeping role for students seeking accommodations on the ACT.

The emphasis on formal school plans is so significant that some outside advocates are pushing parents to seek out official 504 plans for their student’s disability, in hopes that a 504 could carry more weight and potentially enhance a student’s chances of attaining an SAT or ACT accommodation. Testing coordinators and counselors are pushing back against granting every student a 504 plan, which, in their eyes is often unnecessary, but they are facing highly motivated parents and a continuing trend towards the emphasis placed on formal school plans. The College Board has been surveying school counselors and disability coordinators regarding potential changes to its own accommodations procedure. The general sense is that College Board may soon place greater emphasis on school-based formal accommodation plans. School judgement about what a student needs is playing an increasingly important role in the process.

Final thoughts

The ACT has adopted a more rigorous accommodations process, which accentuates professionally documented diagnoses and evidence of a formal school-based accommodations plan. With heightened rigor comes greater transparency and efficiency through the new TAA. Both the College Board and ACT make it clear what documentation they require for specific disabilities. When students apply for ACT accommodations with the required documentation in place, the approval can be quick. Families and schools that come to the process well aware of its requirements will benefit the most from the new-found efficiency that the TAA has to offer.