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Pima County Community College District Standard Practice Guide

SPG Title: Disability Documentation Requirements: Establishment of Eligibility for Services under ADA/Section 504
SPG Number:  SPG-1501/AF
Effective Date:  3/9/04
Approval Date: 3/9/04
Review Date(s):   1/5/15           
Revision Date(s): 
Schedule for Review & Update:  Every three years
Unit Responsible for Review & Update:  Office of the Provost
Sponsoring Unit/Department:  Office of the Provost
Regulation Title & No.: Equal Opportunity, ADA, Non-Discrimination and Anti-Harassment, RG-1501/A
Board Policy Title & No.:  Equal Employment Opportunity, ADA, Non-Discrimination and Anti-Harassment (including Sexual Harassment), BP-1501
Legal Reference:  American with Disabilities Act of 1990 and Americans with Disabilities Act Amendments (2008); Section 504 of Rehabilitation Act of 1973, as Amended
Cross Reference:   Resolution Directing Americans with Disabilities Act Compliance; Personnel Policy Statement for College Employees, BP-4201; Competitive Employment, RG-4201/A; Disabled Student Resources, BP-3603; Disabled Student Resources (DSR) Program, RG-3603/A


The purpose of these guidelines is to set standards for determining which students qualify for disability-related accommodation and the nature of accommodation that will be provided, when appropriate. The guidelines define the respective roles and responsibilities of College personnel and students in the determination process.


The determination of whether a student qualifies for accommodation and the nature of the accommodation must be made on a case-by-case basis. 

The DSR Specialist and the student shall engage in an interactive process to determine whether the student has a qualifying disability, identify barriers to educational opportunities related to the disability, and what constitutes reasonable and effective accommodations

2.1     Responsibility of the Student to Provide Supporting DocumentationA student seeking accommodation has the responsibility to provide sound supporting documentation that helps establish that (1) he or she has a disability and (2) the requested accommodations will be reasonable and effective. Supporting documentation should provide a basic description of the individual’s disability and enough information to reveal the impact of the disability on the student’s interaction with the College’s educational environment including but not limited to courses, testing methods, student services, built environment, web content, and program requirements.

2.2     Standards for Supporting Documentation
          a.   Essential Elements of Documentation Provided by the Student
                i.  Documentation should be generated by a licensed or otherwise properly credentialed professional.  The name, credentials and/or professional training of the diagnostic or medical professional, and the location and contact information of the practice must be included in the documentation.
                ii. The credentials of the individual making the diagnosis must be appropriate for a professional making the diagnosis and understanding the particular condition being reported. 
               iii.  Documentation should include a clear diagnostic statement that describes:
                     a.  the functional impact of the condition,
                     b.  the expected progression or prognosis of the condition,
                     c.  the severity, frequency, and pervasiveness of the condition, 
                     d.  the method of diagnosis.

            d.   Type of Documentation – Record of Interactive Process
                  The record of the interactive process between the student and Program Specialist may also be considered a piece of documentation for establishing eligibility for accommodations.  To be considered documentation, this record, however, must include all of the following:
                  1.  Student self-report/disclosure,
                  2.  Specialist observations,
                  3.  A description of relevant information in any documentation provided by the student
                  4.  A summary of conclusions based on the Program Specialist’s professional judgment as to how the evidence relates to eligibility for services and the need for accommodation. 
                  5.  Copies of the documentation provided by the student and used by the Program Specialist in his or her summary.

DSR Specialists may accept third party suggestions for service accommodations at their discretion. In general, however, the College also reserves the right to reject suggestions for accommodations For cases in which such third party materials are received, primary consideration will be given to original diagnostic documentation that established qualification for service accommodations under the ADA and 504.  The College will not accept formal documentation, such as formal assessments and evaluations, generated by relatives of the student.

3.1     Documentation Required in Other Post-Secondary Institutions and K-12 School Systems vs. Pima Community College

It is important to recognize that higher education constitutes a special environment: one that is legally, logistically, and educationally different from that experienced by students at the K-12 levels. 

As a result, documentation required and accommodations provided at Pima Community College may be different from the K-12 setting.  It should be noted that documentation policies differ from one institution to another. The Disabled Student Resources documentation policy is designed to fit the Pima Community College campus climate. If a student attends another institution after attending Pima Community College or takes a standardized test (GED, GRE, MCAT, etc.) administered by an outside agency, the student is responsible for researching those documentation policies and should investigate requirements at least six months prior to an anticipated start date or test date.  Students retain full responsibility for obtaining documentation required for any non Pima Community College need.
3.2     Contradictory Diagnostic Information and Secondary Documentation
If documentation is provided that offers contradictory information relative to functioning, substantial limitation, or service accommodations, DSR Specialists shall defer to that documentation which  is more fully based on specific diagnostic tests and scores, which is more clearly elucidated and based on evidence, and/or which yields diagnostic conclusions most clearly congruent with data available. Documentation that does not corresponds to these guidelines or is less aligned with best practice standards for diagnostics for the particular field may be considered secondary, or may be rejected altogether as insufficient and non-qualifying.

3.3     Documentation Not Readily Available
Students should not delay meeting with a DSR program specialist out of concern for not having the appropriate documentation. Determinations on individual documentation needs will be made during the initial meeting with the student, which may or may not involve the need to provide additional documentation.



  1. The existence of a condition that is variable, chronic, progressive, or which may or may not constitute a qualifying disability
  2. The age of the documentation,
  3. The age of the test results,
  4. Changing environmental/academic conditions (e.g., Student switches from traditional classroom to on-line only).

4.2     Contact with Healthcare Providers or Diagnosticians for Clarification
DSR Specialists may, at their discretion and with written permission from the student, obtain additional information from healthcare providers or diagnosticians to clarify a student’s disability and/or need for accommodation.
If additional documentation is required, the Program Specialist will clearly identify the type of additional documentation required, the reason additional documentation is required, and provide a date by which the student needs to provide the additional documentation.  The Program Specialist will also make it clear that the continued provision of approved accommodations is conditioned on the receipt of the additional documentation.  If additional information is requested.
DSR Specialists may require additional diagnostic information at the student's expense if the documentation is deemed to be insufficient, or if the student requests accommodations not clearly supported by the documentation available.

DSR Specialists may accept third party suggestions for service accommodations at their discretion, particularly when they are congruent with primary documentation.

5.1     Consistency of Analysis and Acceptance of Documentation by DSR SpecialistsThe DSR Specialists shall maintain consistent approaches to analysis, acceptance, and decisions regarding accommodations pursuant to these guidelines.  The DSR Program Specialists as a group in consultation with the DSR Director may modify specific procedures and standards for documentation review, based on best practices and/or on institutional need or changes in case law, via memorandum to be posted on the DSR website and incorporated into the SPG during the next review period.

5.2     Resolution of Disagreements Regarding DSR Determinations
If there is a dispute regarding the process for determining eligibility for "otherwise qualified students with a disability", the student and/or the student's DSR Specialist will present the issues to the Lead DSR Program Specialist and/or DSR Director.  If the issue cannot be resolved at this level, then the concern must be brought to the College 504 Coordinator who will provide notification of final resolution per SPG.

All disability documentation is treated in a confidential manner and shared with College personnel only on a need-to-know basis or as required by law.
Depending on the situation, an instructor may need to know about the nature of the disability in order to assist in developing reasonable accommodation options.  That may or may not include knowing a specific diagnosis, but could certainly include detailed information about limitations or additional challenges the student may face due to a physical or mental condition.  While information should be limited to a need to know basis, there needs to be some flexibility about who that might include, depending on the specific circumstances of each case.