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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:
- Qualifications of the evaluator;
- Recency of documentation;
- Comprehensives of the documentation to substantiate
the current diagnosis of a mental health disability;
- 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. back to top
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:
- A specific diagnosis (see 3.B)
- A description of current functional limitations in the academic environment as well as
across other settings (see 3.A.5)
- Relevant information regarding medications expected to be in use and their anticipated impact on the student in this setting (see 3.A.4)
- Relevant
information regarding current treatment
- 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:
- History of presenting symptoms.
- Duration and severity of the disorder.
- Relevant developmental, historical, and familial data.
- Relevant medical and medication history, including the individual’s current medication regimen and compliance, side effects
(if relevant) and response to medication.
- 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).
- 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.
- As relevant to the test taking performance, a description of the
expected progression or stability of the impact of the condition over
time.
- 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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- For assistance in finding a qualified professional (See
Section I for the definition of a qualified professional):
- Harvard students may contact the
Bureau of Study Counsel, University Health Services (UHS), AEO or local
Disability Coordinator for possible referral sources; or
- Contact your
physician who may be able to refer you to a qualified professional with
demonstrated expertise in mental health disabilities.
- Considerations in selecting a qualified
professional:
- Ask what
experience and training he or she has had diagnosing adolescents and
adults.
- 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.
- 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.
- Ask whether you will
receive a comprehensive written report.
- Ask whether you will have an opportunity to discuss
the information contained in the report.
- When working with the professional
:
- Take a copy of these guidelines to the professional
so he or she knows what to expect when preparing the evaluation.
- Be prepared to be
forthcoming, thorough, and honest with requested information.
- As follow-up to the assessment by
the professional:
- Schedule
a meeting to discuss the results, recommendations, and possible
treatments.
- Request additional resources, support group information, and
publications if you need them.
- Maintain personal file of our records and reports.
- Be aware that any
receiving institution or agency has a responsibility to maintain
confidentiality.
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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:
- 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
- Academic Achievement
- 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.
- Personality Tests
- Minnesota Multiphasic Personality Inventory (MMPI)
- Millon Clinical Multiaxial Personality Inventory-II
- Rorschach Inkblot Test
- Thematic
Appreception Test (TAT)
- Rating Scales
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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