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Accommodating College Students with Learning Disabilities: How Much is Enough?


Innovative Higher Education, Vol. 22, No. 22, Winter 1997

Sally S. Scott

ABSTRACT: Individuals with learning disabilities are attending institutions of higher education in greater numbers than ever before. In attempts to accommodate these students in the classroom, faculty often have the ethical concern of balancing the rights of students with learning disabilities with the academic integrity of the course, program of study, and institution. In order to dispel misinformation, a brief description of learning disabilities and federal law is provided. The ethical concern of "how much is enough?" is examined, and recommendations are provided for the informed and active participation of faculty in accommodating college students with learning disabilities.

A student approaches a faculty member after the first day of class and informs her that he has a learning disability and will need extended time on all exams. Another student meets with her advisor to explain that her language-based learning disability made it impossible for her to learn a foreign language. She will need to substitute other coursework for this requirement. What is the role of faculty in these scenarios? Do students have civil rights that supersede the discretion of faculty in the classroom? Must faculty provide all accommodations that are requested by students with learning disabilities? Just how much is enough?

Faculty across the country are dealing with these and similar questions on a daily basis. In fact, students with learning disabilities are the fastest growing disability group on college campuses. National longitudinal data on first-time, full-time entering college freshmen indicate that the number of students with learning disabilities had more than doubled between 1988 and 1994 (Henderson, 1995). In 1996, the most recent year for which longitudinal survey results are available, students with learning disabilities accounted for 3.1 percent of all freshman on the nation's two and four-year college campuses (This Year's Freshmen, 1997). Similarly, the U.S. Department of Education (1989) reported that approximately 3% of all college students have learning disabilities. Other incidence figures indicate numbers vary by type of college, e.g., the presence of students with learning disabilities may be as high as 11% in small liberal arts colleges (Cohen, 1984) and 5% in professional schools (Parks, Antonoff, Drake, Skiba, & Soberman, 1987).

The particular dilemma if providing accommodation for this growing population of students arises from the fact that learning disabilities are "invisible" disabilities, which by definition, affect cognitive areas of functioning. Requests for reasonable accommodations are not the straightforward tasks of providing a ramp for a student in a wheelchair of arranging for an interpreter for a student who is deaf. Accommodation of the needs of students with learning disabilities frequently involves academic adjustments in faculty teaching and evaluation of learning. Accommodation requests that are typically deemed reasonable might include, for example, the provision of a notetaker for class lectures; extended time on exams or class assignments; use of a spell-check, grammar-check, and/or proofreader on written tasks; tests in alternate formats, such as an oral rather than written exam; and other forms of accommodation based on individual student profiles and needs.

Endeavors to accommodate college students with learning disabilities have given rise to a range of responses on the part of faculty. Some faculty respond passively, providing whatever accommodation is requested. Other faculty adamantly dig in their heels and refuse to provide any academic adjustments or what they perceive as "differential treatment." Most faculty responses, however, fall between these extremes. Surveys of faculty attitudes reveal that the large majority of faculty members are willing to accommodate students with learning disabilities but struggle with ethical concerns in balancing the rights of students with learning disabilities with the academic integrity of the course, program of study, and institution (Leyser, 19989; Matthews, Anderson, & Skolnick, 1987; McCarthy & Campbell, 1993; Nelson, Dodd, & Smith, 1990; Nelson, Smith, & Dodd, 1991; Satcher, 1992).

For example, in a survey of faculty at a small public university, Matthews, et al. (1987) found that the majority of faculty were willing to provide 74% of a range of possible accommodations listed for students with learning disabilities. The researchers noted, "It seemed clear that they [faculty members] wanted to treat the learning disabled as much like non-handicapped students as possible. They would accommodate to a point, but not to the extent of lowering certain course standards" (p.49). Similarly, in another faculty survey Nelson, Dodd, & Smith (1990) noted that faculty were generally willing to accommodate students with learning disabilities but "only if they could be assured that it would not lower academic standards" (p. 188). Faculty surveys consistently note similar concerns for maintaining standards, yet fail to describe how faculty actually make the distinction as to how much is enough in accommodating students with learning disabilities.

Comments provided by respondents on various faculty surveys provide insight on more specific areas of faculty interest and concern. Responses range from positive insights to disparaging remarks. Some faculty note the importance of considering individual student abilities and attitudes in the accommodation process; others express interest in learning new methods to meet the needs of students while maintaining academic excellence (Nelson, Dodd, & Smith, 1990). Some faculty lament accommodation and access requirements as illustrated by such comments as "Why dilute a college education any more than it already has been by accepting less than capable students?" (Matthews et al., 1987, p.50) "I am trained to teach bright students, not handicapped ones" (Minner & Prater, 1984, p.228).

From this assortment of responses it appears that, although most faculty understand that they have an obligation to provide accommodation, ethical questions remain. Upon examining these concerns more closely, it becomes apparent that regardless of the tenor of the faculty comment- whether accommodation is viewed as a positive challenge or a negative burden- the core question for many faculty appears to be the ethical issue of "how much is enough?" in accommodating college students with learning disabilities.

The purpose of this article is to examine this perplexing question. As evidenced by faculty comments, some "ethical" debate on accommodating students is founded on misinformation about learning disabilities. Other "ethical" concerns reveal a lack of understanding of the requirements of federal law. A brief description of both learning disabilities and federal law is provided, therefore, to dispel some common misunderstandings about learning disabilities and to provide an accurate context for discussion of ethical issues. Finally, the ethical concern of "How much is enough?" is examined, and recommendations are provided for the informed and active participation of faculty in accommodating college students with learning disabilities.



A learning disability is a generic term for a heterogeneous group of disorders that affect how individuals receive, encode, store, and retrieve information. Learning disabilities are found in individuals with average of above average intelligence but who, because of presumed central nervous system dysfunction, have significant difficulties in any of a variety of achievement areas such as reading, mathematics, spelling, written expression, and oral language. Often students with learning disabilities also have difficulty with organization, time management, and/or attention. Learning disabilities may occur concomitantly with other disabilities (such as sensory impairments or psychological disabilities) or environmental influences (such as cultural differences or insufficient instruction), but learning disabilities are not the direct result of those influences. (See, for example, Hammill, Leigh, McNutt, & Larsen, 1987 for the definition of learning disabilities developed by the National Joint Committee on Learning Disabilities).

A learning disability is a life-long condition that may manifest itself differently over time depending on the context and related demands (Learning Disabilities Association of America, 1990; National Joint Committee on Learning Disabilities, 1985). It is not uncommon in a college setting to have students who experiences and received services for a learning disability in elementary school, yet who received no special services throughout high school. Often, these intelligent students developed adequate compensation strategies during their high school years and had no need for special education support. Upon entering college, however, the increased academic demands as well as the premium placed on organization, time management, and independence may have caused existing compensation strategies to break down, resulting in the resurfacing of the learning disabilities. Other individuals may be diagnosed with a learning disability for the first time in college, once again because of the strenuous academic and organizational demands placed on students in the context of a college education. (See Ross-Gordon, 1996, for a discussion of issues related to previously unidentified adults with learning disabilities.) Depending on the individual profile of the student and the context demands, the deficit in cognitive processing may be apparent in only one academic area, such as math or foreign language, or it may affect an area such as reading or written language that will have an impact on classroom performance across many areas of study.

Given these characteristics of learning disabilities, it becomes apparent that some ethical concerns of faculty are based on inaccurate information. For example, in the faculty member's comment "I am trained to teach bright students, not handicapped ones" (Minner & Prater, 1984, p. 228) the faculty member reveals the misperception that students are not capable of college level work. Students with learning disabilities, however, like students without disabilities, present a range of abilities and levels of intelligence. By definition, students with learning disabilities have an average or above average intelligence. Some college students are actually diagnosed as both gifted and learning disabled, demonstrating high academic ability accompanied by specific processing deficits. When provided appropriate accommodations, these students have been observed to succeed in such competitive academic environments as Harvard, Brown, Yale and Stanford (see, for example, Crooks, 1990).



Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990 (ADA) stipulate that colleges may not discriminate against individuals with disabilities and must provide them with meaningful education access. An individual with a disability is one who has a "Physical or mental impairment which substantially limits one or more major life activities" including learning (Subpart A, 104.3(J)(1)(i)). Section 504 applies to recipients of federal financial support, including student financial aid and contains specific implementing regulations pertaining to the context of higher education. The ADA applies to public and private college through Title II and Title III, respectively, and serves to reinforce and slightly expand the mandates for Section 504 in the context of postsecondary education. Virtually all colleges in the country are accountable under these nondiscrimination mandates. As institutional representatives, faculty also share in the responsibility for "assisting these institutions in satisfying their compliance obligation" (Heyward, Lawton, & Associates, 1995, p.1).

Section 504 and the ADA stipulate that otherwise qualified students with learning disabilities must be provided reasonable accommodations that do not change the essential nature of a course or program. A qualified student is one who can meet the academic and technical standards of the institution both in admission and in subsequent student performance. Reasonable accommodations are based on individual student needs and may include such areas as academic adjustments, provision of auxiliary aids, or program modifications. Essential requirements of a course or program may be established by the college and may be met by the student with or without accommodation. The basic premise of these laws is that institutions must provide programmatic and physical access, but they are not required to lower standards or to create special programs in the process (Heyward, 1993). The implementing regulations of Section 504 (Subpart E, section 104.4) clarify that virtually all areas of higher education are covered under this mandate for access including, among other areas, admission and recruitment, treatment of students, and academic requirements and instruction.

Equal access in admission and recruitment means that students with disabilities may not be excluded from recruitment activities and that qualified students with disabilities may not be denied admission on the basis of disability. The institution is prohibited from making pre-admission inquiry about the disability and is required to make the admission decision based on the student's ability to meet the academic and technical standards of the institution. Nondiscrimination in general student treatment means that, once admitted, the student with a disability is to be a full and active participant in the full range of programs and activities of the institution including any academic, research, occupational training, health insurance, counseling, transportation, or extracurricular activity. Equal access in academic requirements and instruction refers to the institution's obligation to provide reasonable accommodations that do not compromise essential course or program requirements, this may include modification in length of time permitted for completion of degree requirements, substitution of specific courses, or adaptation for the manner in which courses are conducted and evaluated. The institution must also assure that students with disabilities are not discriminated against because of the absence of auxiliary aids (including such services as tape-recorded text books, notetakers, and readers).

Once again, some "ethical" concerns of faculty can potentially be diffused with accurate information. For example, the faculty member's question "Why dilute a college education any more than it already has been by accepting less than capable students? (Matthews et al., 1987 p.50) reveals frustration with standards within higher education and assumes that students with learning disabilities have been admitted under lowered admission requirements. In actuality, the law states that students with disabilities must be able to meet academic and technical standards of the institution in admission as well as in subsequent performance and evaluation.



In light of the characteristics of learning disabilities described and the context of accurate legal requirements provided, some ethical concerns voiced by faculty may be alleviated. Dispelling misinformation allows the focus of this discussion to shift to the truly persisting ethical issues of how faculty can accommodate students with learning disabilities while maintaining academic standards and integrity. As seen in the previous, the terminology used in federal law is quite broad and potentially ambiguous. Phrases such as "otherwise qualified", "reasonable accommodations", and "equal opportunity" pepper legal regulations. Though perhaps frustrating at times, this broad language is intended to establish wide-reaching principles of nondiscrimination that are to be applied to individuals in specific contexts (Heyward, 1992). What information do we have on how to apply and individualize these tenets of nondiscrimination? Case law provides a primary source of guidance. A seminal Supreme Court finding is presented, and recommendations are made for applying this guidance in the college classroom.

Guidance from Case Law
Attempts to individualize and implement the broad parameters of federal law on a case-by-case basis have led to disagreements over the roles and responsibilities of the student and the institution or its faculty representatives. As a result, case law has burgeoned. Although many issues have been addressed in lower courts, only one Supreme Court ruling provides guidance pertaining to higher education access for students with disabilities. While this case focused on the concerns of a student with a hearing impairment, the Court's methodology in weighing the rights of the student and the institution is equally instructive in considering the access needs of students with learning disabilities.

In Southeastern Community College v. Davis (1979) Frances Davis, a licensed practical nurse with a hearing impairment, applied to the registered nurse program at Southeastern Community College. The school denied her admission because the nursing faculty felt that she would require either extensive individual supervision in or exemption from the clinical phase of the nursing program in order to ensure patient safety. Davis brought suit under Section 504, alleging that she had been discriminated against and denied admission solely on the basis of her impairing impairment. In finding for the institution, the Supreme Court stated that: 1) postsecondary institutions have the right to establish and maintain academic and technical (nonacademic) standards that are essential to a course or program: 2) the student's physical and mental abilities must be considered on an individualized basis as they relate to the specific program (stereotypes about disabilities are not permissible); and 3) a wide range of accommodations that might permit the individual to participate in the program must be considered. Patient safety and undue administrative hardship were areas the Court examined in weighing the accommodation requests. It is important, too, that Southeastern (1979) was established before the implementation of the more stringent ADA in 1990. If this case were brought to the courts today, it may be that technological and other advances in the field would lead to a different finding by the court. Regardless, the procedures of examining essential requirements, individual student needs and abilities, and a range of potential accommodations still provides a valuable framework for weighing the rights of all involved and considering equitable accommodation.

Implications for Faculty
Implications of such a framework are obvious-faculty have a voice in determining reasonable accommodations for students with learning disabilities in the classroom. Accommodating students with learning disabilities is not intended to be a rote process of student notice and faculty subservience. Nor, however, may faculty refuse to consider the needs of students with learning disabilities. As King and Jarrow (1990) noted, " whether or not an accommodation is made is negotiable" (p.8).

Active Participation. One outcome suggested by the Court's procedures is the importance of allowing all involved parties to voice their perspectives on what is a reasonable accommodation in a particular circumstance. It has been suggested that weighing accommodation requests should be viewed as a "thought process" (Scott, 1990) balancing the essential requirements of a course or program with the individual needs of a student with a learning disability. Brinckerhoff, Shaw, and McGuire (1993) have characterized this interaction as best occurring as a "negotiation" between faculty, student, and if appropriate, the institutional provider for learning disability services. Whether viewed as a thought process or a negotiation, faculty who are concerned that a requested accommodation will compromise the academic standards of a course or program should actively participate in a discussion with a student (and institutional provider of learning disability services if appropriate) of what is reasonable. An effective institutional provider of learning disabilities services can be an extremely valuable resource to faculty in deliberating accommodation issues. However, existing institutional supports vary widely (Scott, 1996) and faculty may or may not have this resource available.

Informed Participation. Another outcome suggested by the Court and numerous subsequent court rulings is that these standards must be determined and applied in a nondiscriminatory manner (Heyward, 1992) although faculty have a voice in maintaining academic standards. An integral part of active faculty involvement, therefore, is that faculty need to be informed participants in the process.

One of the most important contributions faculty can make to the discussion of reasonable accommodations is to review carefully and articulate the academic and technical (nonacademic) standards that are essential to a course or program of study. The purpose of defining these essential requirements is to establish a nondiscriminatory baseline of course content, methods, and expectations that are required of all students and form the essence of the course. Heyward (1992) reported that the courts have repeatedly shown deference to the professional judgment of educators in making such distinctions. Heyward (1992) also cautions, however, that process, or how that essential requirement is derived, is of utmost importance. Institutions or their faculty representatives must be prepared to explain why requirements are essential and how this determination was reached. Based on an extensive review of the literature, Scott (1990) recommended a series of questions for faculty to consider in establishing nondiscriminatory essential requirements in a course or program of study. The following guiding questions and discussion are drawn in large part from these recommendations:

1) What is the purpose of the course?
This is certainly not a new question for faculty in establishing or teaching a course. It does, however, play an important role in defining responses to subsequent responses.

2) What methods of instructing are absolutely necessary? Why?
In considering this question it is important for faculty to closely examine whether current methods of instruction are integrally linked to the purpose of the course. For example, utilizing classroom and laboratory components in a biology course may be deemed absolutely necessary because of the designated purpose of conveying content information and providing hands-on application of concepts in the course. Similarly, class participation in a counseling course may be an essential part of the designated learning process. In contrast, traditional class lecture as a sole means of conveying information may be harder to support as essential to the purpose of the course. This does not imply that lecture, as a method of instruction should not be used. It does suggest that altering the method of instruction will not compromise the purpose of the course. Based on student need and accommodation request, therefore, faculty may need to consider creative ways of augmenting such oral instruction.

3) What outcomes are absolutely required of all students? Why?
Faculty are encouraged to articulate what specific knowledge, principles, concepts, and skills they believe must be mastered by students. These areas will most effectively be drawn directly from the purpose of the course. In some coursework, such as lower level introductory courses, there will likely be more consensus in the field as to appropriate outcomes and expectations. In other coursework where there is a higher likelihood that individual faculty perspectives will vary, it is particularly important for faculty to consider and articulate why specific outcomes are required.

4) What methods of assessing student outcomes are absolutely necessary? Why?
Once again, faculty are called to critically examine what may be long-standing tradition in higher education and consider whether methods of assessing student outcomes are integrally tied to the purpose and essential outcomes of the course. For example, in an English composition course it would likely be deemed essential for students to submit written products for grading. This process is integrally linked to the purpose of the course. In a French conversation course an oral component in assessing student outcomes would likely be essential to the stated purpose of the course. In contrast, upper level courses in many disciplines routinely require students to compose written essays for exams with such designated tasks as "describing," "comparing or contrasting," or "applying" particular theories, trends, or concepts. For some courses, a written essay may indeed be essential to assessing student outcomes. If, however, the purpose of the course and its related exams is for students to demonstrate knowledge, understanding, and application of certain principles, for example, faculty may need to revisit whether this knowledge can be demonstrated by means other than the traditional written essay. For example, if a student, based on a specific disability profile, requested an oral tape-recorded essay exam, would this compromise the purpose of the course?

5) What are acceptable levels of performance on these student outcome measures?
In keeping with other grading practices, faculty may decide on levels of performance that must be achieved for varying grades in a course. Adjusting or changing grades is not an accommodation required by law or a recommended practice. Faculty may need; however, to consider carefully how to evaluate student outcome measures that have been accommodated or provided in alternative, nonessential formats such as an essay exam presented orally. The impetus is placed on faculty to articulate how acceptable levels of performance will be examined and weighed across accommodated formats.

Many of the preceding questions are not novel considerations for faculty in course development and instruction. However, defining essential requirements in a nondiscriminatory fashion may require more in-depth consideration for some faculty in areas that may be adjusted and accommodated differently than on the past. The purpose of the reflective questions is to prompt faculty to clarify course expectations-not change them. Similarly, departments might articulate the program's purpose, the skills or competencies needed in the field after graduation, and the requirements for licensing or professional accreditation as a nondiscriminatory baseline for all students. Similar to the questions guiding course requirements, faculty should consider what skills or competencies students must demonstrate, to what level of expertise, and whether these competencies must be demonstrated in a specific way based on the specific nature of the program. Some faculty may respond to the level of accountability in articulating essential requirements in courses or programs of study as exceeding traditional demands of higher education. A frequent concern is the additional time required for such accountability. Other faculty may welcome the opportunity for clarity in expectations as beneficial for all students, not just students with learning disabilities. As noted by Sheridan (1990), "if attention to dyslexic students leads to a heightened consciousness of the importance of skillful teaching, then the presence of these students on our campuses will have made a significant contribution to the improvement of higher education" (p.19).

From this baseline of essential requirements, a nondiscriminatory standard is established for all students. Faculty are then free to consider reasonable accommodations for individual students that do not compromise essential methods of instruction or evaluation. The courts have noted that weighing specific accommodation requests also includes a "reasonable person standard: "Would a reasonable person, agree reviewing the facts of the case, conclude that discrimination occurred?" (Heyward, 1992, p. 4) in considering such areas as safety factors (Doe, 1981; Kling, 1985; Southeastern, 1979), or whether the request for accommodation was of a personal nature (specified in Section 504 regulations as not required by law). (See Scott, 1994 for an examination of the construct "reasonable accommodation.")



How much is enough in accommodating students with learning disabilities? As seen inn the preceding discussion this persisting ethical question requires professional examination and reflection incorporating faculty content expertise within an informed nondiscriminatory thought process. Realistically, faculty often face the task of asserting essential requirements in response to an immediate request for accommodation by a student currently enrolled in a course or program. To some extent awareness of essential requirements will already be available through the process of regular course and program development. For essential components of content or pedagogy not already articulated, faculty will need, on a short-term basis, to apply their best professional judgement in defining the essential elements of a course or program. Over time, however, this process should perhaps best be viewed as an on-going dialogue for professional examination within disciplines, a topic to be consciously incorporated into course development and curricular discussions. Such targeted discussions within the various disciplines will allow a more balanced voice for weighing the construct of nondiscrimination in institutions of higher education.

Once a nondiscriminatory standard is established, the professional judgement of faculty is also require in respecting and creatively responding to the access needs of students with learning disabilities. In a survey of college students with disabilities describing professors who were considered outstanding, Fichten et al. (1990) noted that "professors considered outstanding by their students with disabilities took an active role by engaging their students in dialogue, discussing how problems can be resolved, and talking about how they might help the student succeed" (p. 120). Depending on the number of students with learning disabilities in a particular course (or across courses) and the realities of a large teaching load or other faculty time constraints, this level of interaction may not be feasible for all faculty with all students with learning disabilities. The student comment does, however, suggest that it may be preferable to approach the question "how much is enough?" as a dialogue between faculty and student rather than viewing accommodation as a negotiation process. As active and informed participants, faculty should approach such conversations with an awareness of areas they are not asked to compromise, but also open to a range of creative alternatives for students with learning disabilities who wish to benefit from the same standards of higher education as other students.



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"Happy work is best done by the man who takes his long-term plans somewhat lightly and works from moment to moment 'as to the Lord.' It is our daily bread that we are encouraged to ask for. The present is the only time in which any duty can be done and any grace received."
-C.S. Lewis; Learning in Wartime, The Weight of Glory