When we build strong Individualized Education Programs (IEPs), we focus on creating layers of support at school to ensure that our child receives a free, appropriate public education (FAPE). Two important tools we can use to make this happen are accommodations and modifications. But there are some big differences between the two, and some gray areas in how they’re used. So how are they different, and why are these differences so important? We reached out to special education attorney Grace Clark, special education advocate (and owner of Know IEPs) Dr. Sarah Pelangka, BCBA-D, and Ricki Sabia, J.D., Senior Education Policy Advisor with the National Down Syndrome Congress (NDSC).
Sabia describes accommodations as “how you learn or how you show what you know, but you are using the same material to learn the same content.” For example, if a student cannot write due to a disability that affects their fine motor skills but needs to complete an essay, having a scribe would be considered an accommodation because it doesn’t change the content. An accommodation can address how a student is provided with information, how much time they’re given to complete work, how they will show content mastery, what supports they use to access content (for example, an audio version of written material), and in what settings.
On the other hand, Sabia explains, a modification is “when you change the expectations for what the student will actually learn of the grade-level content.” For example, a teacher may modify an essay-writing assignment by making it significantly shorter or about a less complex topic. “Adjusting expectations on the grade level content standards and assignments to have less breadth, depth, or complexity would be considered a modification,” Sabia says. “See Core Content Connectors as examples of modified stepping stones toward grade-level content that should be used in an individualized way based on each student’s needs and abilities.”
Simply put, an accommodation adjusts how a student learns, while a modification adjusts what they learn. Dr. Pelangka explains the difference in this clip:
Let’s look at some of the gray areas. Dr. Pelangka begins with this example: “If the class is working on multiplication but a student is working on number identification through that same assignment while in class, that would be an example of a modification. They’re not working toward the same standard. An accommodation for multiplication could be masking half of the worksheet and showing them half of it at a time.”
However, offering a shorter assignment to that student can also be considered an accommodation, depending on how it’s done. For example, Dr. Pelangka tells us that a shortened math worksheet is not considered a modification as long as the student is receiving the same array of problem types and difficulties. “They’re still doing the same types of work; they’re still showing they can produce the same responses, just not as many times,” she explains.
Whether something is considered an accommodation versus a modification will depend on whether or not the student is showing mastery of the grade-level standard. For example, if the objective is to comprehend a particular novel, having a child listen to an audiobook would be considered an accommodation, and using an abridged version could be a modification. According to Dr. Pelangka, “It all comes down to this: is the student being held accountable to the same standards as the other students?”
Sabia points out that how an assignment is structured can also make a difference in whether an adjustment is labeled as a modification. It’s important to have that conversation with the child’s teacher, and ask, “What is the purpose of this lesson?” For example, if the objective is to learn about the themes of a particular novel, is it necessary for the child to read the full, unabridged version if they can learn the content in another way? In this case, a parent could argue that reading a shorter version of the same novel will allow their child to meet the grade-level expectations. It is essential to think outside the box and break down the assignment to its true purpose.
You can read more about the types of accommodations that can be included in your child’s IEP in our article, Accommodations for IEPs and Section 504s.
According to IDEA 300.116(e), “A child with a disability is not removed from education in age-appropriate regular classrooms solely because of needed modifications in the general education curriculum.” As Sabia explains, “The need for modifications is not a reason to separate a student from the regular education classroom.”
One vital component of IDEA is the legal requirement that a child be educated in the least restrictive environment (LRE), and that the IEP team consider what supports and services a child will need to be successful in a general education classroom. By using Core Content Connectors and Essential Understandings, a teacher can adapt materials and content using both accommodations and modifications as needed.
For Clark, this highlights the importance of students learning alongside their same-aged peers. “The purpose of a modification is really to allow a student with a disability to participate in something they wouldn’t be able to participate in otherwise,” she says. “That’s the whole point of the modification.”
Sabia adds that for LRE, “being educated in the regular education classroom is a legal presumption.” Placement should not be determined by whether a child takes the standard state assessment or an alternate state assessment to show mastery of a particular subject, because the law concerning LRE “does not tie assessment to a placement. In fact, the law says general educators, as well as special educators, should be able to administer alternate assessments.”
When students are taking high school advanced placement (AP) courses, however, modifications can become more complicated. As Dr. Pelangka points out, accommodations are allowed in college, whereas modifications are not. “Teachers sometimes confuse the two terms,” she says. “Parents come to me upset because their child’s AP teacher claims they cannot ‘accommodate’ the student’s work.” Some students who take college prep or AP courses can receive college credits for doing so; therefore, Pelangka explains, “if the content or test is modified, [the student] wouldn’t be able to receive the college credit.”
Dr. Pelangka says that whether a student uses modifications, and what assessments that student will take, is ultimately up to the IEP team, including the parent. Generally speaking, if a student with significant cognitive impairment meets eligibility requirements to take alternate state assessments (for California, see California Alternative Assessments), districts are likely to recommend they do so.
Sabia says, “Having modifications by itself is not supposed to be enough to [lead to] an alternate assessment. There are more criteria than that.” These include:
Whether the child has a “significant cognitive disability”
Whether “the student is learning content linked to (derived from) the Common Core State Standards (CCSS)”
Whether the child requires “extensive, direct individualized methods of accessing information in alternate ways.”
It’s also important to note that being given a state’s alternate assessment does not mean that a student should be given “alternate curriculum.” This brief from the TIES Center (which Sabia co-authored) was written to help parents make sure their children are provided with meaningful access to the general education curriculum, and “addresses the myth that students with the most significant cognitive disabilities who take the state’s alternate assessment based on alternate academic achievement standards (AA-AAAS) need an alternate curriculum.” As Sabia explains, “Students must work on (participate and make progress in) the enrolled grade-level general ed curriculum — modifications, accommodations, and adapted materials are allowed — but based on individual needs and not some lock-step alternate curriculum for all students who take alternate assessments.” (She also notes that “alternate curriculum” is not a legal term.)
Sabia recommends that parents find the alternate assessment participation criteria on their state’s Department of Education website. If possible, it is a good idea to become familiar with the criteria before an IEP meeting so you have the information you need to decide whether or not your child should take an alternate assessment. (See guidance on California’s alternate assessment criteria here.)
She adds, “It’s not a given that because you have some modifications, you’re definitely [participating] in the alternate assessment. You’re supposed to check all the boxes.” However, having curriculum modifications “and the degree of modifications is certainly a factor.”
Dr. Pelangka says it’s important to remember that this decision should never be made without discussion; it is not an “if this, then that scenario.” And while state assessments help keep schools accountable and provide teachers — and parents — with a measure of a student’s progress, she reminds us that a student has the option of opting out of state testing altogether.
Sabia says, “The bottom line is learning, so if a student needs curricular modifications and truly needs them to learn,” then the modification should be considered. However, it is essential to evaluate whether a modification is necessary, or if your child can succeed “with adapted materials in addition to the regular materials.” If you find that your child still needs more support, modifications can be added to their IEP later.
According to IDEA 300.160, a state should “not preclude a student with the most significant cognitive disabilities who takes an alternate assessment aligned with alternate academic achievement standards from attempting to complete the requirements for a regular high school diploma.”
While the IDEA makes it plain that using modifications should not mean that a student is prevented from earning a diploma, it is all too often the reality. Dr. Pelangka tells us that when students are using modified curriculum in high school due to a significant cognitive impairment and are not working toward the general education standards, they will not graduate with a diploma. Dr. Pelangka believes that parents should be made aware of this as early as when their student is first referred for a modified curriculum. The earlier this referral happens, the larger the gap will be in terms of a student’s ability to access the general education curriculum. As the years progress, she reminds us in the clip below, the academics only become more rigorous.
However, she says, there are “examples of smaller-scale modifications that technically could happen in a gen ed class that wouldn’t necessarily bump a student to a certificate track. So long as the student can reflect mastery of the grade-level standards, they can access their diploma.” She adds, “Being in a general education class in and of itself doesn’t constitute being on a diploma track. Just like any other student who accesses a diploma, students have to be able to show mastery of the coursework to the level that’s required.”
According to Clark, “Vast discretion is given to school districts about what qualifies for graduation requirements, and beyond that, there are minimum requirements provided by the state. A student with an IEP gets more time (until age 22) to work toward graduation requirements, but still needs to meet the standards required by the classes that are required for a diploma.”
However, if a student has not been able to meet the standards for a course that is required for graduation, Clark says there is a workaround. “Students, along with their school, can petition for a waiver under California Education Code section 56101. For example, it could look like this: A student who had been on a modified math curriculum and was not able to pass Algebra I, despite support and remediation from their school, still receives a high school diploma after obtaining a waiver for Algebra I.” She explains that while this strategy depends on each individual student, it can be used to help students who receive modifications obtain diplomas.
Clark adds that when considering whether a child should pursue a diploma, it’s essential to weigh “the likelihood that the child can meet all the standards necessary to graduate with the benefits of working at a pace that is appropriate for them, among same-aged peers.” What is best for your child will depend on their strengths, needs, and individual goals.
The Every Student Succeeds Act (ESSA) regulations include a provision — 200.6 (d) — which says the state must “promote, consistent with requirements under the IDEA, the involvement and progress of students with the most significant cognitive disabilities in the general education curriculum that is based on the State’s academic content standards for the grade in which the student is enrolled.” As Sabia explains, “The important piece of the ESSA provision is that they should be allowed to work toward [a diploma] and go as far as they can go — even if they don’t meet the requirements in the end, they will get a more individualized, standards-based education.” And, she adds, the ESSA regulations “have the force of law.”
For this reason, Sabia suggests making sure your child isn’t taken off the diploma track prematurely because “you just don’t know what a student is going to be able to accomplish.” She points out that states often give students with IEPs more time to graduate, and graduation requirements evolve over time. While parents should be aware of the implications of using modified curriculum in elementary and middle school, Sabia feels that high school is the best time to make diploma decisions. “The more we keep kids on grade-level content and try to find entry points for them on that, they further they’re going to go.”
Dr. Pelangka adds that if a student receives alternate report cards, it could indicate that they are not being held to grade-level standards, making it less likely for them to earn a diploma. “Just look for those little details within the IEP and ensure that your kid is being held to grade-level standards and that they are being promoted based on grade-level criteria,” she says. In this clip, Dr. Pelangka also explains that accommodations and modifications should be clearly outlined in the IEP:
When you review your child’s IEP, pay attention to the section on modifications and accommodations — you can see if your child receives a regular or alternate report card and if they meet regular district criteria for promotion. However, Dr. Pelangka reminds us that in California, every IEP template will look different depending on the SELPA (Special Education Local Plan Areas) or district.
It’s also important to note that every state has its own requirements regarding diplomas, and parents should research what classes children are required to take in high school, and what standards they need to meet. In California, students will not only need to meet state-mandated graduation requirements, but district requirements as well, which can vary from district to district.
Clark says that it’s a good idea to become familiar with “how to word accommodations and modifications in an IEP so the intention of the team is accurately reflected in the document.” Check out our guide to write IEP goals and these common accommodations for tips. She also reminds us that providing the needed accommodations or modifications is part of a school’s offer of FAPE. The school cannot tell a parent that they are unable to provide an accommodation or modification; they are “legally required to find the right person” who can provide the supports a student needs.
Finally, should a parent and the IEP team be unable to reach an agreement, a parent has the right to resolve disputes with the IEP team through mediation, a resolution session, due process hearings, alternative dispute resolution (ADR), or by filing a complaint with the state. (For more on this, read about what to do if your IEP isn’t being followed.)
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