If you have a child who is planning to go to college, approaching the end of high school can be both exciting and daunting. As parents who have spent years learning the intricacies of special education, IEPs, and/or 504 plans, you now have to prepare your student for an entirely new educational environment — and a new set of rules when it comes to accessing support for students with disabilities.
The good news is that a great deal of support is available on college campuses for students who are academically able to complete a college degree but may have challenges navigating the college curriculum and environment — including students with autism, visual impairment, or some learning disabilities, or who are deaf or hard of hearing. (There are also great options for students with intellectual disabilities for whom a traditional college degree program is not a good fit — for more information, see our article College for Students with Intellectual Disabilities).
But college is different from high school, in terms of what a school’s obligations are, the types of support they provide, and the ways to access that support. It’s important for parents and their college-bound kids to understand those differences.
To learn more, we spoke with Elizabeth C. Hamblet, a learning disabilities specialist with more than 20 years of experience educating families and professionals on how to prepare students with disabilities to navigate the transition to college. In addition to her day job working in a college disability services office, she is a speaker and author of Seven Steps to College Success: A Pathway for Students with Disabilities. To learn more from a legal perspective, we also spoke with Bryan C. Winn, a special education attorney with 18 years of experience helping families, including those navigating the transition from high school to college.
As you and your child begin to think about what college may look like for them, it’s important to understand some basic facts up front.
First, there are no IEPs in college. Eligibility for the Individuals with Disabilities Education Act (IDEA) — the federal law that requires schools to provide IEPs — ends when a student graduates high school. Therefore, IEPs do not exist in college. A student’s high school IEP will not transfer to the college environment, nor will the college create a new IEP for the student. There is no special education in a college degree program.
Second, contrary to what you may have heard, your student’s 504 plan also will not transfer to the college environment. Misconceptions about 504 plans arise out of the fact that postsecondary schools — just like K-12 schools — are subject to Section 504 of the Rehabilitation Act. Section 504 is a federal law that prohibits discrimination on the basis of disability by any programs or activities that receive federal funding, including publicly funded schools.
You may have heard reference to this law in discussions of your student’s 504 plan. What many parents may not realize is that Section 504 is divided into different subparts, which outline different legal requirements for postsecondary schools than for K-12 schools. Subpart D of Section 504 applies to K-12 schools, and requires them to identify and assess students’ needs and to develop 504 plans for accommodating those needs, with collaboration between parents, teachers, and school staff. Subpart E of Section 504, on the other hand, applies to postsecondary schools, including vocational and career programs, colleges, and universities. It requires postsecondary schools to provide reasonable accommodations but does not require schools to develop 504 plans, nor to involve parents.
In sum, colleges are not required to honor your student’s high school 504 plan or provide a new 504 plan. What colleges are required to do is to work with any student who registers with their disability services office, review the student’s accommodation request, and if the student is found eligible, provide and implement accommodations as appropriate. This is true at all publicly funded colleges and universities, including UC, California State Colleges, and California Community Colleges, as well as private colleges and universities, which also receive federal funding.
Hamblet says confusion about 504 plans is understandable because the laws don’t spell out when these plans, or IEPs, expire. “Just like in IDEA, there is no sentence anywhere that says, ‘And when your student graduates, the plan no longer has any legal validity. It's not applicable. It doesn't ‘travel,’ or whatever phrase you've heard.” But, she says, “That is the effect.”
Since your student’s IEP or 504 will not carry over to college, you might wonder whether your child should disclose their disability when applying.
Disclosing a disability during the application and admissions process is always voluntary; colleges aren't allowed to ask students if they have a disability. You’ll see that there is no question about disability on The Common Application (an online platform that allows students to apply to multiple colleges at once). Your child also doesn’t have to disclose their disability when applying to college in order to later access accommodations once enrolled. And under the Americans with Disabilities Act (ADA) and Section 504, colleges are not legally allowed to discriminate if you do disclose a disability.
Further, disclosing a disability does not put your child at a disadvantage for scholarships. Colleges are not legally allowed to discriminate on the basis of disability for financial assistance (in fact some scholarship opportunities are available specifically for students with disabilities) or for campus employment. It’s also important to note that the ADA applies not only to people living with a disability but also to people who have a history or record of such an impairment (such as cancer that is in remission) and those who are perceived by others as having such an impairment (such as a person who has scars from a severe burn), who could also face discrimination on these bases.
Because disclosing disability is voluntary, Hamblet encourages students to make the decision for themselves. “My opinion is that a student should do whatever they want to do. [If] they think it's something important that the college should know about them or that they're proud of and that they want to share, then they should share that. And if they just would rather use their limited space [in the application] to tell the college something else, then they should not feel obligated to share their disability.”
Winn, an attorney who has worked with many students transitioning to college, believes that disclosing a disability during admissions can be empowering for some students. “I would say the best time to disclose that is during the interview process. Even when you're submitting your application, tell that story about the issues you've had and maybe how you've overcome a lot of things.” Winn says that talking about one’s disability during or prior to the application process can also put the student in a better position to assess what resources the college has and whether it is the best fit for their needs.
Your student must be the one to initiate the process of getting accommodations in college. This is a fundamental change from elementary and secondary school, where the school is obligated to identify and assess the needs of students with disabilities.
“What's really important to know is, students have to initiate this process,” says Hamblet. “We do not go to the freshman dorms and knock on all the doors and say, ‘Hey, kiddo, do you have a learning disability? You want to come register with us?’” Staff from a college’s disability services office staff may be present at freshman orientation, and their materials may be part of the school’s admissions packet. But it is up to the student to seek out accommodations and follow through on completing the process to access them.
It’s also important to remember that postsecondary schools are not required or expected to involve a student’s parents in the process of determining the student’s accommodations. This is a major difference from K-12 school, where the laws require schools to afford parents the opportunity to participate in planning their child’s individualized education. In college, the student makes the request and must actively participate in an interactive process with college staff to establish eligibility and implement their accommodations. The college will communicate directly with the student throughout this process and will not contact parents.
Colleges and universities are required to provide reasonable accommodations as necessary to enable students with disabilities to participate in school programs, which include not only academics but everything from housing to library services to recreational activities. Accommodations may include modifications or adjustments to school rules or policies, or specific supports and services provided to students. Below is a list of potential accommodations that college should offer to a student enrolled in a degree program.
These are common examples of reasonable accommodations. Some colleges may provide other or additional accommodations based on individual need.
General educational accommodations
Testing accommodations
Accessible supports and services
Colleges may also offer services such as:
Service animals
Schools do not provide exhaustive lists of the modifications and accommodations they provide (such a list wouldn’t be possible, because the varieties of individual accommodations are essentially limitless). In determining what accommodations to request, one of the most important resources may be your student’s IEP or 504 plan from high school. While these plans expire at graduation and do not carry over into college, Winn says they can be “instructive” as to the types of accommodations that have worked well for the student in the past. Some college disability services offices will therefore take the expired plans into consideration when deciding which accommodations to approve for a student in college. Students can also research college disability accommodations and other academic supports on their own, as Hamblet demonstrates here.
Colleges must also provide accommodations for student housing. The same general standards for “reasonableness” apply to housing as to other accommodations. Examples of possible housing accommodations include:
Finding the right housing is often a top concern for any college freshman. Under the ADA, colleges are required to make reasonable housing accommodations for students with disabilities. They must consider students’ requests for specific housing arrangements if such arrangements are reasonable and necessary to ensure equal access to student housing. Depending on the school, housing accommodations may include requests for single occupancy rooms, placement in a quiet dorm, or consideration of the student with disability’s specific needs (e.g. matching the student to a dorm that will accommodate the use of a CPAP machine).
Under federal housing laws, colleges are also required to allow students to have emotional support animals in student housing, as well as service animals (as noted above, colleges are not required to accommodate emotional support animals in academic settings, but different laws apply to housing).
As with other types of accommodations, students should follow their college’s procedures for requesting housing accommodations and make the request timely. Depending on the nature of the disability, students may be required to provide documentation to verify the disability and the need for accommodation.
The law outlines some general requirements for the accommodations colleges are not required to make. They are not obligated to provide modifications that would create an undue financial or administrative burden on the school. They are not obligated to provide services or devices of a “personal” nature; this means the college does not have to provide personal attendants, individually prescribed devices, readers for personal use or study, or other personal devices or services, such as tutoring, laptops, or iPads.
Further, colleges are not required to provide accommodations that fundamentally alter the program or service, nor are they required to modify or waive core aspects of a program. For example, for a student majoring in chemistry, labs may be an essential part of the program, and therefore students may not be permitted to substitute other courses. Likewise, a student studying to be a phlebotomist might secure an accommodation allowing extra time on written exams, but probably would not be given extra time on a practical skills test that requires them to draw a patient’s blood, because doing so could cause the patient discomfort or harm.
Experts recommend requesting accommodations as early as possible because the process may take time.
To make the request, students should contact their school’s student disability services office. (These offices sometimes go by other names, such as office of accessibility services or accessibility resource center.) The student may be required to fill out a form describing their disability and what accommodations they are seeking. They will likely be asked to provide documentation of their disability as well. (More on the types of documentation below.) They may also be asked to attend meetings with disability services staff or other staff. The experts we spoke to said that the process is typically not difficult if the requested accommodations are within what the law considers reasonable and if the student provides the requested documentation of their disability.
Your student’s role in getting accommodations doesn’t end at making the request. Getting accommodations in college is an interactive and ongoing process between the student and the school. Experts advise that it is important for the student to continue to participate in the process of identifying accommodations and then implementing them.
For example, if a student has an accommodation permitting extra time or an alternative location for exams, the school may require the student to notify the disability services office of their exam schedule in advance to ensure the accommodation can be set up. The disability services office may have to contact and coordinate with the professor or locate and reserve an exam space, and all of this can take time. Students who do not follow through on the steps required to access their accommodations will not receive them until they complete the process. Hamblet explains that if they finish the process too close to an exam, they won't get accommodated for that exam, but they still have the right/ability to have them on the next exam (they just have to follow procedures).
While a student doesn’t have to disclose their disability during the admissions process, Hamble explains, “When registering with the student disability services office to request accommodations, a student will usually be asked to provide documentation of the disability. The standard for proving eligibility is the Americans with Disabilities Act, which defines a disability as a physical or mental impairment that substantially limits one or more major life activities. While it's not likely to be an issue for many students, be aware that some colleges won't find students eligible for accommodation, even if they have a history of being accommodated, based on the evidence they see in the student's documentation. The laws in place don't provide guidance for how colleges interpret ‘substantial,’ so this can vary from college to college. For instance, if a student was accommodated in high school because of a discrepancy between their very high full scale IQ and their average reading scores, their college might not consider that discrepancy itself to be evidence of a substantial impairment. They might consider only scores below the average range to meet their idea of what ‘substantial’ means.”
The kind of documentation required will vary depending on the disability and the school. Different colleges have different requirements. The school may require medical documentation, such as a doctor’s note, psycho-educational testing, or another diagnostic report. Students are not required to provide their full medical records or history, only sufficient documentation to prove they have a disability. The Department of Education states that, assessment information, evaluation reports “and other material used to develop an IEP or Section 504 plan may be helpful to document a current disability or the need for an academic adjustment or auxiliary aids and services,” as well as the summary of the student's academic achievement and functional performance.
Hamblet and Winn both said that some colleges, though not all, will accept an IEP or 504 plan as documentation. However, Hamblet adds, “Colleges that don't accept an IEP or 504 plan will likely require testing for students seeking eligibility for accommodations for a learning disability. (They may also require it for ADHD, even if students haven't needed it before.) The requirements for how recent this testing varies across colleges. If your district will do comprehensive testing for their triennial, that can provide them with the best chance that, no matter where they go to college, their documentation will be found sufficiently current.” Winn adds, “A continued, consistent history of documentation of getting accommodations is the best thing you can do.”
The experts we spoke to say it is not common for students to be denied accommodations — in general, colleges have come a long way and have well-developed processes and extensive experience providing accommodations for students with disabilities.
Students can be proactive in ensuring their rights by:
If your student runs into difficulty — if they are denied reasonable accommodations or experience discrimination — they have options.
If the school fails to respond adequately, students do have other options. They can:
Because students must be the ones to disclose their disabilities and seek out accommodations, it is important that your student know what their rights are and how to make use of them in college. They should know the following:
The changes from high school to college are significant. As parents, the more time we can give our kids to prepare, the better. Start talking with your child early about what their rights and responsibilities will be as college students, and help them practice the independence that will be required of them in college. This may mean weaning them off certain kinds of support they’ve had in high school that they won’t be able to have in college, such as extended deadlines, or individual assistance with organizing their time or setting intermediate deadlines for big projects (some colleges do have resources and staff available to help students with time management, but the student remains primarily responsible for managing their time).
Hamblet says that making these changes, though difficult at first, will give our kids the confidence to face the changes ahead. “I think you build confidence by building competence, and students can't build competence if they're not required to do certain things.”
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