Accommodation and Compliance Series 

Higher Education Accommodations: 

Students with Mental Health 

Impairments 

Accommodation and Compliance Series
Practical Solutions • Workplace Success 

2 

Preface 

The Job Accommodation Network (JAN) is a service of the Office of Disability 

Employment Policy of the U.S. Department of Labor. JAN makes documents available 

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Updated March 23, 2010. 
Practical Solutions • Workplace Success 

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JAN’S ACCOMMODATION AND COMPLIANCE SERIES

Introduction 

JAN’s Accommodation and Compliance Series is designed to help employers and 

educators determine effective accommodations and comply with Title I of the Americans 

with Disabilities Act (ADA). Each publication in the series addresses a specific medical 

condition and provides information about the condition, ADA information, 

accommodation ideas, and resources for additional information. 

The Accommodation and Compliance Series is a starting point in the accommodation 

process and may not address every situation. Accommodations should be made on a 

case by case basis, considering each student’s individual limitations and 

accommodation needs. Educators and students are encouraged to contact JAN to 

discuss specific situations in more detail. 

For information on assistive technology and other accommodation ideas, visit JAN's 

Searchable Online Accommodation Resource (SOAR) at http://askjan.org/soar. 

Information about Mental Health Impairments 

What are mental health impairments? 

Mental health impairments, also called "mental illnesses," refer collectively to all 

diagnosable mental disorders. Mental disorders are health conditions that are 

characterized by alterations in thinking, mood, or behavior (or some combination 

thereof) associated with distress and/or impaired functioning (Goldman, 1999). 

How prevalent are mental health impairments?

Recent studies estimate that about 20 percent of the U.S. population is affected by 

mental health impairments during a given year. This estimate is based on surveys that 

defined mental health impairments according to the Diagnostic and Statistical Manual of 

Mental Disorders (DSM-IV and DSM-IV-TR) (Goldman, 1999). 

What are some common mental health impairments? 

Generalized Anxiety Disorder: Generalized anxiety disorder is characterized by the 

feeling of constant worry and tension that lasts 6 or more months. This exaggerated 

worry and tension appears to have no cause and the individual may feel stressed and 

unable to relax (APA, 1994). 

Bipolar Disorder: Bipolar disorder (manic depression) is a brain disorder involving 

episodes of mania and depression. It affects more than two million American adults. 

Effective treatments are available that greatly reduce the symptoms of bipolar disorder 

and allow people to lead normal and productive lives (APA, 1994). 
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Depressive Disorder: Depressive disorders are serious illnesses that affect a person's 

mood, concentration, sleep, activity, appetite, social behavior, and feelings. Depressive 

disorders come in different forms, the most common being major depression (uni-polar 

depression). Major depression, the leading cause of disability in the U.S., affects over 

nine million adults annually. Despite its disabling effects, depression is highly treatable 

(APA, 1994). 

Obsessive-Compulsive Disorder: People with obsessive-compulsive disorder (OCD) 

experience recurrent unwanted thoughts (obsessions) or rituals (compulsions), which 

they feel they cannot control. Rituals such as hand washing, counting, checking, or 

cleaning are often performed in hope of preventing obsessive thoughts or making them 

go away. Performing these rituals, however, provides only temporary relief, and not 

performing them can increase anxiety. Left untreated, obsessions and the need to 

perform rituals can take over a person's life. OCD is often a chronic, relapsing illness 

(APA, 1994). 

Panic Disorder: Panic disorder is characterized by unexpected and repeated episodes 

of intense fear accompanied by physical symptoms that may include chest pain, heart 

palpitations, shortness of breath, dizziness, or abdominal distress. These sensations 

often mimic symptoms of a heart attack or other life-threatening medical conditions 

(APA, 1994). 

Post-Traumatic Stress Disorder (PTSD): PTSD is a condition that can occur after 

exposure to a terrifying event or ordeal in which grave physical harm occurred or was 

threatened (e.g., rape or mugging, natural or human-caused disasters, accidents, or 

military combat). Many people with PTSD re-experience the ordeal in the form of 

flashbacks, memories, nightmares, or frightening thoughts, especially when they are 

exposed to events or objects reminiscent of the trauma or on the anniversaries of the 

event. People with PTSD also experience emotional numbness and sleep disturbances, 

depression, anxiety, irritability or outbursts of anger, and guilt (APA, 1994). 

Schizophrenia: Schizophrenia is a severe and chronic brain disorder that impairs a 

person's ability to think clearly, manage emotions, make decisions, and relate to others. 

People with schizophrenia experience terrifying symptoms that often leave them fearful 

and withdrawn. Schizophrenia is highly treatable, and new discoveries and treatments 

are continually improving the outlook for people with this disorder (APA, 1994). 

Seasonal Affective Disorder (SAD): SAD is caused by seasonal natural light variation 

that affects humans’ circadian rhythm. Symptoms of SAD include depression, excessive 

eating and sleeping, and weight gain during the fall or winter months. Full remission 

from depression occurs in the spring and summer months (APA, 1994). 

What treatments exist for mental health impairments? 

Effective treatments include psychotherapy, cognitive behavioral therapy, relaxation 

techniques, and biofeedback to control muscle tension. Medication, most commonly 

anti-anxiety drugs, may be required in some cases (NIMH, 2000). 
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Mental Health Impairments, the Americans with Disabilities Act, and 

Section 504 of the Rehabilitation Act

How do the ADA and section 504 of the Rehabilitation Act apply to students in 

higher education? 

The Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990 both 

ensure that students with disabilities have equal access to educational opportunities in 

higher education. Both laws require colleges and universities to offer a wide range of 

services, accommodations, and auxiliary services for students with disabilities. These 

services are typically individually designed, and based on the specific needs of each 

student as identified by the school’s Disability Service Providers. 

Are mental health impairments considered disabilities under the ADA and Section 

504 of the Rehabilitation Act?

The definition of disability is the same under both laws. Neither law contains a list of 

medical conditions that are covered disabilities. Therefore, some students with mental 

health impairments will have a disability covered under the ADA and some will not. This 

means that some students with mental health impairments will be eligible to receive 

services from the school’s Disability Service Providers, and some will not. 

A student has a disability if he/she has a physical or mental impairment that 

substantially limits one or more major life activities, a record of such impairment, or is 

regarded as having such impairment (EEOC, 1992). To be covered by the ADA, the 

impairment must substantially limit one or more major life activities. These are activities 

that an average person can perform with little or no difficulty. Examples are: walking, 

concentrating, seeing, speaking, hearing, breathing, learning, performing manual tasks, 

caring for oneself, and working. These are examples only. Other activities such as 

sitting, standing, lifting, or reading are also major life activities (EEOC, 1992). 

Most courts have agreed with the activities listed by the EEOC, and have gone further 

to expand on other activities and impairments. For example, in Coons v. Department of 

the Treasury, 383 F.3d 879 (9th Cir. 2004), the court held that “depression and panic 

disorders (emotional or mental illnesses) are impairments” (Fram, 2007). However, the 

EEOC has stated that “common personality traits, such as being irresponsible or 

showing poor judgment, are not impairments.” In addition, the EEOC and various courts 

all agree that traits like “irritability and chronic lateness are not themselves impairments” 

and “an inability to tolerate stressful situations is not an impairment under the ADA” 

(Fram, 2007). 

For more information about how to determine whether a person has a disability under 

the ADA, visit http://askjan.org/corner/vol02iss04.htm. 
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Accommodating Students with Mental Health Impairments 

Note: Some students have mental health impairments such as depression, bipolar 

disorder, or severe anxiety. Mental health impairments complicate many areas of life, 

including education. Every case is different, but there are some commonalties in the 

academic experiences of students with mental health impairments (University of 

California, Berkeley Disability Services, 2007).

Students with mental health impairments may develop some of the limitations discussed 

below, but seldom develop all of them. Also, the degree of limitation will vary among 

individuals. Be aware that not all students with mental health impairments will need 

accommodations in school and many others may only need a few accommodations. 

The following is only a sample of accommodation possibilities available. Numerous 

other accommodation solutions may exist. 

Questions to Consider: 

1. What limitations does the student experience? 

2. How do these limitations affect the student’s ability to perform in the classroom or 

participate in college activities? 

3. What accommodations are already available to help reduce or eliminate the problems 

caused by the student’s limitations? 

4. Are all possible resources being used to determine accommodations? 

5. Can the student provide information on possible accommodation solutions? 

Special note about housing: Students with mental health impairments may need 

housing accommodations, such as a private room, permission to use a service animal, 

modified door/window locks (for additional safety), or special room location (nearest to a 

bathroom, nearest/farthest from entrance). 

Factors surrounding housing accommodations for students with mental health 

disabilities include cost (single student in a double-occupancy room), documentation 

that supports the need for housing accommodations, and issues of direct threat. While 

schools are justified in denying housing to students who pose harm to themselves or 

others, schools are currently reviewing their “suicide policies” in light of recent court 

rulings against George Washington University (2006) and Hunter College (2006). It may 

be a violation of the ADA or other laws to automatically exclude students from housing 

who attempted suicide, particularly when the students can provide medical 

documentation showing they are not currently a risk of harm to themselves or others, 

and can safely return to dorm-living and academic life. 
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Accommodation Ideas: 

Time Management: Students with mental health impairments may experience difficulty 

managing time, which can affect their ability to mark time as it passes incrementally by 

minutes and hours. It can also affect their ability to gauge the proper amount of time to 

set aside for certain tasks. It may be difficult to prepare for, or to remember, activities 

that occur later in the week, month, or year. 

 Divide large assignments into several small tasks 

 Give ample time to complete in-class and out-of-class assignments 

 Provide a checklist of assignments 

 Assist students with their own techniques for time management: 

o Emphasize due dates on the syllabus 

o Develop a color-coded system (each color represents a task, or event, or 

level of importance) 

o Help students add entries on their calendar or PDA, or double-check 

entries to ensure dates and times were entered correctly 

Memory: Students with mental health impairments may experience memory deficits, 

which can affect their ability to complete tasks, remember personal responsibilities, or 

recall daily actions or activities. 

 Provide written instructions 

 Allow additional time for new tasks 

 Offer use of note-taker 

 Allow audio or video recording of the class or lecture 

 Provide copy of instructor’s notes or slides 

 Provide outline or list of key words for each class session 

Maintaining Concentration: Students with mental health impairments may experience 

decreased concentration, which can be attributed to auditory distractions (that can be 

heard) and/or visual distractions (that can be seen). 

 To reduce auditory distractions: 

o Purchase a noise canceling headset 

o Hang sound absorption panels 

o Provide a white noise machine 

o Relocate student’s workspace away from audible distractions 

o Redesign student’s workspace to minimize audible distractions 

 To reduce visual distractions: 

o Install space enclosures (cubicle walls) 

o Reduce clutter in the student’s classroom environment 

o Redesign student’s workspace to minimize visual distractions 

o Relocate student’s workspace away from visual distractions 
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Organization and Prioritization: Students with mental health impairments may have 

difficulty getting or staying organized, or have difficulty prioritizing tasks and activities for 

school. 

 Develop color-code system for files, projects, or activities 

 Use chart to identify class activities and assignments 

 Use college advisor to help schedule classes each semester 

 Use a tutor, upperclassman, or volunteer to reinforce organization skills 

 Assign prioritization of assignments for the student 

 When possible, assign new project only when previous project is complete 

 Allow work to be completed in groups, making each person in the group 

accountable for a portion of the project 

Social Skills: Students with mental health impairments may have limitations in 

adaptive skills, such as communicating with others, or exhibiting appropriate social 

skills. This might manifest itself as interrupting others, demonstrating poor listening 

skills, not making eye contact when communicating, or inability to correctly read body 

language or understand innuendo. 

 Demonstrate appropriate behavior in the classroom 

 Develop a simple, but appropriate, code of conduct for your classroom: 

o Rules for tardiness or leaving early 

o Rules for engaging in debate or discussion 

o Rules for good classroom citizenship 

 If possible, make class attendance optional 

 Encourage students to minimize personal conversation, or move personal 

conversation away from classroom 

 Promote sensitivity training (disability awareness) in the classroom 

 Encourage all students to model appropriate social skills 

 Adjust teaching techniques to better fit the student’s needs 

 Allow the student to complete work online 

 Adjust method of communication to best suit the student’s needs 

Completing Course Requirements: Students with mental health impairments may 

need adjustments to, or modifications for, course or degree requirements. Many 

solutions exist, including: 

 Course substitution 

 Reduced course-load 

 Spread out course-loads that include summers or an additional academic year 

 Independent study 

 Online courses 
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Taking Tests: Students with mental health impairments may need accommodations 

when taking tests. 

Lack of Concentration or Organization: Test-takers may be distracted or 

disorganized when taking a test. Possible accommodations include: 

 Testing in a private room 

 Providing extended time 

 Providing a reader 

 Providing the test on tape 

 Reducing/eliminating distractions 

 Allowing breaks 

 Seating test-taker away from doors or windows, and other distractions 

Reading Print Material: Test-takers may be unable to read test materials. 

Possible accommodations include:

 Providing a reader for the test-taker 

 Providing test on tape/cd-rom 

 Providing extended time 

 Administering test in private room 

 Giving instructions in bold print 

 Allowing the use of a line guide or ruler to keep place in test book or 

answer sheet 

 Testing on computer with voice output 

 Using symbols or pictures where appropriate 

 Color-coding test by sections or subjects 

 Putting multiple choice in bold 

Panic Attacks: Test-takers may experience panic attacks during test 

administration. Test-takers who may need the following accommodations include 

people with ADD and psychological impairments. Possible accommodations 

include:

 Allowing frequent breaks 

 Extending time 

 Providing a private room 

 Providing a regular room – sit in back of room so test taker can leave if 

necessary 

 Allowing test-taker to become familiar with test environment 

 Allowing test-taker to choose own seat 

 Having a plan of action for test administrators to deal with emergencies 

such as passing out, having seizure, or conduct problems 

For information regarding testing accommodations, see: 

http://askjan.org/media/testingaccomm.html 
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Resources 

Job Accommodation Network 

West Virginia University 

PO Box 6080 

Morgantown, WV 26506-6080 

Toll Free: (800)526-7234 

TTY: (877)781-9403 

Fax: (304)293-5407 

jan@askjan.org 

http://askjan.org 

Office of Disability Employment Policy 

200 Constitution Avenue, NW, Room S-1303 

Washington, DC 20210 

Toll Free: (866)633-7635 

TTY: (877)889-5627 

Fax: (202)693-7888 

http://www.dol.gov/odep/ 

Anxiety Disorders Association of America 

8730 Georgia Avenue 

Suite 600 

Silver Spring, MD 20910 

Direct: (240)485-1001 

Fax: (240)485-1035 

http://www.adaa.org 

Center for Psychiatric Rehabilitation 

Boston University 

940 Commonwealth Avenue West 

2nd Floor 

Boston, MA 02215 

Direct: (617)353-3549 

Fax: (617)353-7700 

http://www.bu.edu/cpr 

Judge David L. Bazelon Center for Mental Health Law 

1101 15th St. NW 

Suite 1212 

Washington, DC 20005 

Direct: (202)467-5730 

Fax: (202)223-0409 

http://www.bazelon.org 
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Mental Health America 

2000 N Beauregard Street, 6th Floor 

Alexandria, VA 22311 

Toll Free: (800)969-6642 

Direct: (703)684-7722 

TTY: (800)433-5959 

Fax: (703)684-5968 

infoctr@nmha.org 

http://www.nmha.org 

National Institute of Mental Health 

Science Writing, Press, and Dissemination Branch 

6001 Executive Blvd, Room 8184, MSC 9663 

Bethesda, MD 20892-9663 

Toll Free: (866)615-6464 

Direct: (301)443-4513 

TTY: (866)415-8051 

Fax: (301)443-4279 

nimhinfo@nih.gov 

http://www.nimh.nih.gov 

National Mental Health Consumers' Self-Help Clearinghouse 

1211 Chestnut Street 

Suite 1207 

Philadelphia, PA 19107 

Toll Free: (800)553-4539 

Direct: (215)751-1810 

Fax: (215)636-6312 

info@mhselfhelp.org 

http://www.mhselfhelp.org 

Obsessive Compulsive Foundation Inc. 

PO Box 961029 

Boston, MA 02196 

Direct: (617)973-5801 

http://www.ocfoundation.org 
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References 

American Psychiatric Association. (1994). Diagnostic and statistical manual of mental 

disorders (4th ed). Washington, DC. 

Bazelon. Student and university settle lawsuit on mental health issues. Retrieved 

November 6, 2008, from: http://www.bazelon.org/newsroom/2006/10-30-06NottSettle.htm 

Bazelon. Hunter College settles lawsuit by student barred from dorm after treatment for 

depression. Retrieved November 6, 2008, from: 

http://www.bazelon.org/newsroom/2006/8-23-06-hunter-settlement.html 

Equal Employment Opportunity Commission. (1992). A technical assistance manual on 

the employment provisions (title I) of the Americans with Disabilities Act. 

Retrieved November 6, 2008, from http://askjan.org/links/ADAtam1.html 

Fram, David. (2007). Resolving ADA workplace questions: How courts and agencies 

are dealing with employment issues. National Employment Law Institute 

Publication, 22nd edition. 

Goldman, H.H., Rye, P., & Sirovatka, P. (Eds.) (1999). Mental health: A report of the 

surgeon general. Retrieved November 6, 2008, from 

http://www.surgeongeneral.gov/library/mentalhealth/home.html 

National Institute on Mental Health. Depression. Retrieved November 6, 2008, from 

http://www.nimh.nih.gov/publicat/depression.cfm#ptdep5 

University of California, Berkeley Services to Students with Disabilities. Practices for the 

documentation and accommodation of students with psychological disabilities. 

Retrieved November 6, 2008, from: 

http://www.disability.uci.edu/policies_procedures/UC_psych_guide11-02.pdf 
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This document was developed by the Job Accommodation Network, funded by a 

contract agreement from the U.S. Department of Labor, Office of Disability Employment 

Policy (DOL079RP20426). The opinions expressed herein do not necessarily reflect the 

position or policy of the U.S. Department of Labor. Nor does mention of trade names, 

commercial products, or organizations imply endorsement by the U.S. Department of 

Labor.