AHEAd welcomes the finding of the Equality Aurhority in its

AHEAD, the Association for Higher Education Access and Disability –
Submission to the State examinations Advisory Group to review
policy and practice in the area of reasonable accommodations
provided for candidates in the certificate examinations.
May 2007
Recommendations on Reasonable Accommodations to the SEC Review Group:
1. To produce a national policy on reasonable accommodations based on a
clear statement on the principles of social inclusion and rights of the
student with disability to develop their potential.
2. This Review Group should strongly recommend the use of positive
language about disability and be clear about the role of reasonable
accommodations in dealing with the impact of disability in an examination
situation.
3. To adopt a consistent approach to verification of disability across different
levels of the education system, or at least ensure that second level system
is informed by the demands and requirements of third level.
4. The Review Group should consider moving away from standardized tests
towards a system of universal design based on the assessment of core
skills and knowledge and which utilizes a broad range of alternative
assessment designed to meet the assessment needs of candidates with
disabilities.
5. It is vital that this review ensures that there is a cleaner and more
transparent mechanism of getting assistive technology into classrooms
and that the system of application for reasonable accommodations is as
transparent and as user friendly as possible, (or at lease not unnecessarily
complicated as it is currently).
6. The review group should examine how assistive technology is used to
ensure equality of learning and assessment experience for many students
with disabilities in particular students with specific learning difficulties and
students who are blind or visually impaired. For many of these students
technology makes education possible, but they need to allow for additional
training and a more streamlined means of using the technology in
examinations.
AHEAD welcomes the opportunity to make a submission to the Examinations
Commission and to inform policy on reasonable accommodations for students with
disability in examinations.
AHEAD has a membership of all higher education institutions and conducts research
into the participation and experiences of students with disabilities both in second third
level. We work collaboratively with all third level institutions and the HEA in highlighting
issues which need to be addressed in ensuring equality of experiences for students with
disability.
1. Students with disabilities in higher education:
There has been a dramatic increase in the numbers of students with disabilities
attending third level in recent years, up from 400 in 1994 to 3,000 in 2004/5. While this
is a very positive trend, students with disabilities still remain significantly underrepresented in comparison with their peers. Currently the participation rate in Ireland is
2.7% while it should be 4-7% if compared with OECD rates see chart 1 below.
Unfortunately many students are still very disadvantaged and these figures mask the
unacceptable fact that there has been no real increase in the participation rates of many
able students with sensory impairments and significant physical impairments and these
ABLE students and are not progressing from second level on to third level and remain
very under-represented. This is indeed a lost opportunity for those students with
disabilities who are missing from third level particularly as research in many colleges
indicates that students with disabilities do extremely well when supported in their
studies.
Holland
12%
Canada
9%
Ireland
UK
Canada
Holland
Increase in Participation Rate of
Students with Disabilities (Ireland)
UK
4%
Ireland
.5%
1993/94
Ireland
1.25%
1998/99
Ireland
2.04%
2003/04
Chart 1 Percentages of undergraduates with disabilities in higher education by type of
disability in the academic years 98/99 and 2004/05
As chart 2 below indicates the greatest percentage of students with disability are
students with specific learning disabilities and the rte is increasing year on year... All
levels of education are seeing an increase in the numbers of students with specific
learning disabilities due to more accurate diagnostic tools, an increased level of
resources at primary levels and more awareness of the issues amongst parents. In
order to study on an equal footing with all other students, these students may need
supports or accommodations including examination accommodations. .
60
50
40
98/99
2004/05
30
20
10
0
Mobility
Blind
Deaf
SLD
Other
Health
Chart 2 SLD stands for students with specific learning difficulties
AHEAD research 2004/5
1.1 Students with Specific Learning Difficulties:
Students with learning disabilities such as Dyslexia make up to 54% of students with
disabilities in higher education (in DIT it is 72%) and is increasing also in second level.
Dyslexia is one of several distinct learning disabilities which is a specific language based
disorder characterized by single word decoding, usually reflecting phonological process,
these difficulties are often unexpected in relation to other cognitive and academic
abilities. Dyslexia cannot be cured but students can learn coping mechanisms and study
skills and learning strategies to help them deal with the academic demands of a course.
The typical impact of this impairment in an exam is that could look like this:
“John’s psychological report notes his problems with word recognition, spelling and
comprehension skills. Timed assessment s cause huge anxiety which in itself increases
his spelling mistakes. He takes considerable longer than his peers to read test and has
to go over a passage several times to help his comprehension. He has to concentrate
and is easily distracted, loses his place and has to go back over the text. He finds it
hard to pick out key words.
When writing he is slow and uses font 14 with double spacing, he misses mistakes when
proof reading. He has severe spelling difficulties and voice software is a vital component
in spellchecking. He spends longer by 40% n his assignments than his peers and uses
mind maps to plan and help make his main points. His hand writing is slow and finds it
easier to use a keyboard”.
Accommodations in an examination for this student would include, using a separate
examination centre, additional time, use of a computer and software such as text-help
gold and inspiration.
2. What is a reasonable accommodation?
A reasonable accommodation can be any piece of equipment or support that will enable
the student with disability to demonstrate his/her ability, skills and competence.
It
recognizes the disadvantage caused by the impairment and seeks to redress the
balance and enable the student to compete in examinations on an equal footing with
other students. Reasonable accommodations are different for every individual student
and even within the same type of disability we cannot assume that the same
accommodations will be needed by all students, they won’t. Two students with visual
impairments will need different accommodations to enable them to demonstrate their
abilities. In higher education reasonable accommodations are identified by a detailed
needs assessment carried out by the Disability or Access Officer and matches the
disadvantage caused by the impairment with the academic demands of the course...
There is a myth often expressed that to provide a student with a disability with additional
supports, such as extra time or the use of a computer in an examination gives them an
advantage which is unfair to other students. But this is to miss the point. All students
would of course benefit from supports, but for a student with a disability they are a life
line without which they would not succeed. The aim of reasonable accommodations is
to enable a student to deal with the impact of the impairment and to ensure that the
student is not treated less favorably than their peers. The language used in the current
SEC guidelines is very negative and suggests that the student could be getting an
advantage. It is an unnecessary statement as the sole purpose of an accommodation is
to deal with the disadvantage of disability and demonstrate their ability. This statement
confuses reasonable accommodations with an inaccessible learning environment; a lack
of achievement is more likely to be caused by an inaccessible learning environment,
unsuitable teaching materials or lack of learning materials such as Braille books, but
never by an accommodation.
The achievement of the student will be measured by an
examiner against the examination standards and outputs and is a very different issue.
Examination standards have to be met by the candidate and this matter is decided and
verified by an independent examiner.
Whether or not the candidate had
accommodations is a different issue and does not affect his or her performance in
arriving at the standards expected.
4. “Reasonable accommodations are designed to assist a candidate in demonstrating
his or her achievements in an examination setting.
They are not designed to
compensate for a possible lack of achievement arising from a disability.”
SEC Guidelines on
reasonable accommodations, 2005 no 4.
Suggested revision:
Reasonable accommodations are designed to assist the candidate in
demonstrating his or her achievements in an examination setting.
The
purpose of an accommodation is to enable the candidate to deal with the
disadvantage caused from the impact of their disability thus enabling them
to operate on an equal footing with other candidates.
1. To produce a national policy on reasonable accommodations based on a
clear statement on the principles of social inclusion and rights of the student
with disability to develop their potential.
3. Issues arising for students in progressing to third level:
3.1 Verification of disability:
Verification of disability is a necessary part of the process of gaining accommodations
and in third level all students must produce a documented psychological report or
consultants report to verify their disability.
There is a real difficulty created by the
apparent shortage of NEPs Psychologists which leaves many students with SLD without
the full psychological assessment report they require for verification of disability at third
level, which in turn means they are not eligible to apply for supports.
2. It is recommended to the Review Group that a consistent approach to
verification of disability is taken at different levels of the education system, or at
least that one level of the system is informed by the demands and requirements of
the next level..
3.2 Inaccessible Standardized Tests:
The standardized test systems such as the leaving certificate were not designed to meet
the needs of students with disability and exclude many candidates with disabilities. The
greatest challenge is to go back to the drawing board and design a broader system of
assessment methods that would meet the needs of all students including students with
disabilities.
In the meantime it is vital to ensure that examination policies recognize that they are
inadequate as an assessment tool for many disabled students to demonstrate their
abilities.
3. A recommendation to the Review Group is move away from standardized tests
towards a system of universal design that includes the assessment needs of
candidates with disabilities and respects their right to reach their potential like
every other student.
4. RACE Application for Reasonable Accommodations in Examinations:
There has been a significant increase in the number of reasonable accommodations
granted by the state examinations commission leaving certificate, between 2001 and
2005 in there was an increase of 463 additional scribes and 429 spelling waivers. This
trend will continue as the numbers of students with disabilities are identified in
mainstream education.
While this reflects the growing number of students with
disabilities moving through the system, it shows a considerable difference in the use of
technology between second and third levels of education. Over half of applications to
the ESF fund are from students with Specific Learning Difficulty and Technology is the
most common support.
In third level technology has made a significant improvement to the access enabling the
disabled student to independently access information and to demonstrate their abilities
and knowledge on an equal basis with other students.
4. The review group should examine how assistive technology is used to ensure
equality of learning and assessment experience for many students with
disabilities in particular students with specific learning difficulties and students
who are blind or visually impaired. For many of these students technology makes
education possible, but they need to allow for additional training and a more
streamlined means of using the technology in examinations.
4.1 Application System for Reasonable Accommodations:
AHEAD research on the experience of students with visual impairments, (to be
published) indicates that the application system for reasonable accommodations for the
leaving certificate is confusing and requires parents to negotiate many different levels of
complexity in order to secure accommodations.
“The system and its associated administrative and procedural elements is an extremely
complex architecture of validations, confirmations certifications and approvals”. Ahead
research 2007
There are at least eight distinct procedures to be completed by school managers. In
addition the process is not transparent to parents and the process of application
presents so many barriers that it undermines the eligibility of children to supports, (see
flow chart appendix 2)
Parents are concerned that requested accommodations are delivered on time as there
appear to be many logistic errors with the transfer end collection of examination papers.
5. It is vital that this review ensures that there is a cleaner and more transparent
mechanism of getting assistive technology into classrooms and that the system
of application for reasonable accommodations is more transparent and as user
friendly as possible, (or not unnecessarily complicated).
5. Principles underpinning reasonable accommodations:
The Examinations Review should include in its policy principles which underpin the role
of reasonable accommodations:
Reasonable Accommodations are based on the following Principles

The right of the student to accommodations enshrined in legislation.

Verification of disability, all requests must have appropriate documentation, in
third level this is a consultants report.

An Individual Assessment of accommodation and support needs in examinations

Core skills and knowledge, a clear understanding of what is being assessed and
an identification of alternative assessment methods designed to assess that
specific skill or knowledge.

No diminution of standards: students with disabilities who have accommodations
are expected to reach the same standards as other students in relation to course
requirements, it is the mechanism of assessment that is different

Principles of Independent Learning, dignity and respect, it is vital that the student
is encouraged to select supports and accommodations that will maximize
independence.

Clear and transparent communication of policy and procedures
6. A recommendation is that the SEC Review Group has a clear statement in its
policy on the principles of social inclusion and rights of the student with disability
which underpin its policies.
5.1 Alternative assessment Methods:
The Singleton report on dyslexia in the UK states that
“The first step in addressing the problem of examination provision for students with
dyslexia is not the consideration of the examination, nor of the student but of the course
itself.
Having clear course aims and objectives helps to clarify what methods of
examination and assessment would be the most appropriate
When addressing the problem in this manner we must ask the question about the most
appropriate assessment method for all students? Perhaps the written test is not the
most appropriate but continues to be used because it is traditional, effective and
convenient.
7. The SEC review group should ensure a broad range of alternative assessment
methods are built into policy on reasonable accommodations and are available to
students with disabilities
In an examination, accommodations and supports are used counteract the disadvantage
of the examination system and experienced by the student with disability and to attempt
to level the playing field for the student. For example a blind student needs to use
JAWS to read back and edit his/her work.
Case study A Leaving certificate student:
“On the day of my exam I was not only nervous but shocked to discover that my English
Paper had not been enlarged on top of this my modified Biology paper did not arrive and
I got a modified geography paper a subject I did not take in the leaving cert.” AHEAD
research
For details of reasonable accommodations in third level see the AHEAD examination
guidelines enclosed.