Higher Education and Disability: Education Needs a Coordinated Approach to Improve Its Assistance to Schools in Supporting Students
Published: 2009-10-28T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Research suggests that more students with disabilities are pursuing higher education than in years past, and recent legislative changes, such as those in the Higher Education Opportunity Act and Post-9/11 Veterans Educational Assistance Act of 2008, have the potential to increase the number and diversity of this population. GAO was asked to examine (1) what is known about the population of postsecondary students with disabilities; (2) how postsecondary schools are supporting students with disabilities; (3) what challenges, if any, schools face in supporting these students; and (4) how the Department of Education is assisting schools in supporting these students. To conduct this work, GAO analyzed federal survey and some state data; conducted site visits; interviewed agency officials, disability experts, school officials, and students; and reviewed laws, regulations, and literature.
section_title: What GAO Found
paragraphs: Students with disabilities represented nearly 11 percent of all postsecondary students in 2008, according to a federal survey. Moreover, this population appears to have grown, based on selected federal and state data. Also, in 2008, students with disabilities were similar to their peers without disabilities with regard to age, race, and the schools they attended. Students reported having a range of disabilities in 2008, and the distribution of disability types had changed since 2000. For example, the proportion of students that reported having attention deficit disorder had increased from 7 to 19 percent. Postsecondary schools use different approaches and accommodations to support students with disabilities. Schools are required to provide reasonable accommodations, such as note takers and extended time on tests, tailored to individual students' needs. Further, some schools offer enhanced or more comprehensive services than are required by law. For example, some schools GAO visited provided support on time management and study skills. Other schools offer specialized programs, such as one designed to help students with learning disabilities transition to meet college-level reading and writing requirements. Assistive technology has expanded the educational opportunities for students with disabilities. For example, voice recognition software can help students prepare papers by "talking" to the computer. Schools face a broad range of challenges in supporting students with disabilities as they transition to higher education. For example, schools face challenges in supporting students who are unaware of their rights and responsibilities regarding accommodations and in providing services that involve specialized knowledge. Another challenge schools reported was a lack of awareness among some faculty members regarding legal requirements for supporting students with disabilities. Schools also anticipate facing challenges in supporting two growing populations of postsecondary students: veterans with newly acquired disabilities and students with intellectual disabilities. Education has provided some assistance to postsecondary schools to support students with disabilities through three offices. However, the agency has no mechanism to systematically share information across offices and coordinate their technical assistance efforts. These offices--Office for Civil Rights (OCR), Office of Special Education and Rehabilitative Services, and Office of Postsecondary Education (OPE)--have different missions and priorities, focus on different clients, and provide different types of assistance to schools. Although OCR's primary role is enforcement, it has taken the lead in providing assistance to postsecondary schools regarding disability topics. OPE has focused its technical assistance primarily on those 47 schools that received grants in 2008 related to students with disabilities. According to OPE officials, the office does not provide broader technical assistance on disability issues because it lacks expertise in this area. School officials told GAO they need more guidance and information about serving students with disabilities.

section_title: Letter
paragraphs: Research suggests that more students with disabilities are pursuing higher  education than in years past, and recent legislative changes have the  potential to increase the diversity and numbers of these students. More  specifically, the Higher Education Opportunity Act (HEOA) added new  provisions to the Higher Education Act of 1965 (HEA) to support  postsecondary students with disabilities; the Americans with Disabilities  Amendments Act of 2008 (ADA Amendments Act) amended the  Americans with Disabilities Act of 1990 (ADA) to provide broader  coverage; and the Post-9/11 Veterans Educational Assistance Act of 2008  (Post-9/11 GI Bill) expanded education benefits for members and veterans  of the military who served on or after September 11, 2001, many of whom  may have acquired disabilities. Under the laws that prohibit discrimination  on the basis of disability, postsecondary schools are required to provide  equal access to education to qualified students through academic  adjustments and auxiliary aids and services, such as extending time  allowed for taking tests and providing sign language interpreters. In  addition, postsecondary schools must ensure physical access to buildings  on campus. The Department of Education (Education) is responsible for  enforcing postsecondary schools’ compliance with disability laws.
Given your interest in this population and how these students are  supported, we examined: (1) what is known about the population of  postsecondary students with disabilities; (2) how postsecondary schools  are supporting students with disabilities; (3) what challenges, if any,  postsecondary schools face in supporting students with disabilities; and  (4) how the Department of Education is assisting postsecondary schools in  supporting the needs of these students.
To answer question one, we reviewed federal data sources and identified  10 surveys or studies with relevant information on students with  disabilities (see app. I). For each data source, we determined the purpose  of the study or survey, its design parameters, and the focus of questions  and variables related to students with disabilities. We conducted a more  in-depth analysis of data from four of these sources to report descriptive  statistics. We selected these four sources because they contain detailed  information about students with disabilities participating in higher  education and they represent a range of data collection methodologies and  estimates. We relied heavily on one source, Education’s National  Postsecondary Student Aid Study (NPSAS), because it specifically focuses  on the population of postsecondary students and affords the opportunity  to look at changes in the population over time. All of the estimates from  the national data bases are from samples and have sampling errors  associated with them. The percentages from the states are for the  populations within those states. To answer questions two and three, we  conducted site visits to 14 postsecondary schools, where we interviewed  school disability officials and students and conducted telephone  interviews with officials from 11 more schools. During our school site  visits, we obtained information on schools’ efforts pertaining to students  with disabilities and these students’ experiences, collected documentation  of schools’ relevant policies and procedures, observed different types of  accommodations, and toured the schools’ assistive technology  laboratories. We selected these 25 schools because they offered a wide  range or high levels of services to students with disabilities, and they  represented institutional variety in terms of geographic location, public  and private institutions (including proprietary schools), 2-year and 4-year  schools, and schools that have participated in Education’s demonstration  grant projects involving students with disabilities. We focused on schools  that serve a broad range of students and therefore we did not include  schools designed exclusively for students with disabilities. In addition, we  did not focus on programs and services that are designed specifically for  students with intellectual disabilities. We relied on suggestions from  disability associations, experts, school officials, Education officials, and  reference literature in identifying schools. To supplement the student  interviews conducted during site visits, we interviewed representatives of  national groups for students with disabilities. We also reviewed relevant  federal statutory and regulatory requirements and legal articles and  interviewed representatives of national disability and higher education  associations to collect information about how schools support students  with disabilities. To answer question four, we interviewed Education  officials and reviewed policies, procedures, and other documentation  related to Education’s grant programs, technical assistance, research, and  enforcement of laws pertaining to postsecondary students with  disabilities.
We conducted this performance audit from July 2008 to October 2009, in  accordance with generally accepted government auditing standards. Those  standards require that we plan and perform the audit to obtain sufficient,  appropriate evidence to provide a reasonable basis for our findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives.
subsections: section_title: Background
subsections: section_title: Legal Requirements Regarding Postsecondary Schools Supporting Students with Disabilities
paragraphs: Postsecondary schools are prohibited from discriminating against students  on the basis of disability under two federal laws. Section 504 of the  Rehabilitation Act of 1973 (Rehabilitation Act) prohibits entities that  receive federal financial assistance, which includes institutions of higher  education, from discriminating against otherwise qualified individuals with  disabilities. The Americans with Disabilities Act of 1990 (ADA) also  protects individuals with disabilities from discrimination and covers a  broader range of schools. Whereas the Rehabilitation Act applies to  schools that receive federal funds, the ADA applies to state and locally  funded and private-sector schools, with the exception of those that are  controlled by religious entities. The Rehabilitation Act and ADA define  individuals with disabilities as an individual who has a physical or mental  impairment that substantially limits one or more major life activities, has a  record of such impairment, or is regarded as having such an impairment.  The ADA Amendments Act rejected several Supreme Court decisions  which had narrowed the definition of an individual with disabilities. In  addition, the ADA Amendments Act set out guidelines for determining who  qualifies as an individual with disabilities and provided a non-exhaustive  list of “major life activities,” which includes learning, reading,  concentrating, and thinking.
Federal regulations implementing the Rehabilitation Act in the context of  postsecondary education provide that qualified students may not be  subjected to discrimination in recruitment or admissions to postsecondary  institutions. Also, they may not be excluded from participation in, or  denied the benefits, services, or aid related to academic programs,  research opportunities, occupational training, housing, health insurance,  counseling, financial aid, physical education, athletics, recreation,  transportation, other extracurricular activities, or other postsecondary  education programs. The regulations also further outline the categories of  academic adjustments (e.g., extended time on tests and reduced course  load) and auxiliary aids and services (e.g., notetakers and sign language  interpreters), commonly referred to as accommodations, that schools  must provide to ensure that qualified students with disabilities can  participate in higher education. However, laws and regulations cannot  address the specific accommodations a school must provide for each  student with a disability. Instead, these depend on the limitations of each  student’s disability and take into account factors like where the student’s  classes will be held and the academic requirements of the chosen course  of study on a case-by-case basis.
While schools are required to provide reasonable accommodations to  qualified students and bear the costs, schools are not required to provide  accommodations that would fundamentally alter the nature of a program,  lower or waive essential academic requirements, or result in undue  financial or administrative burdens. Also, schools are not required to  provide personal devices and services, such as wheelchairs or attendants,  individually prescribed devices (e.g., eyeglasses), tutoring, or readers for  personal use or study.
Students with disabilities beginning higher education face a different  situation regarding their rights and responsibilities than they did during  their elementary and secondary education. Under the Individuals with  Disabilities Education Act (IDEA), states and school districts must  identify, locate, and evaluate children who may have a disability and  provide special education and related services to eligible children and  youth with disabilities. The Rehabilitation Act regulations governing  elementary and secondary education also require that children with  disabilities be identified, located, and evaluated. However, unlike in  elementary and secondary school, it is the responsibility of postsecondary  students to identify themselves as having a disability, provide  documentation of their disability, and request accommodations and  services. Although the general procedure for obtaining accommodations is  often similar across schools, the particular steps of the process may vary  s may vary  among postsecondary schools. (See fig. 1 for example.)  among postsecondary schools. (See fig. 1 for example.)
Postsecondary schools are required to have an individual who coordinates  the school’s compliance with the Rehabilitation Act and ADA. The school  must also have grievance procedures that include steps to ensure a  student can raise concerns fully and fairly and provide for the prompt and  equitable resolution of complaints.
section_title: Federal Agency Responsibilities
paragraphs: Education is responsible for enforcing the Rehabilitation Act, Title II of  ADA, and various other anti-discrimination laws. The Department of  Justice (Justice) delegated to Education responsibility for investigating  complaints relating to elementary, secondary, and postsecondary schools  under Title II of the ADA, which applies to public entities. Justice is  responsible for enforcing Title III of ADA to ensure that private entities,  including private colleges and universities, provide appropriate  accommodations and do not discriminate on the basis of disability. Justice  and Education share enforcement jurisdiction if a private school receives  federal funding. Justice also has jurisdiction pertaining to testing entities,  such as for college admissions tests and law and medical school exams.
Education’s strategic plan includes objectives to increase success in, and  completion of, quality postsecondary education and to prepare individuals  with disabilities for higher education. To carry out this mission, Education  provides technical assistance, funding for grants, and regulatory guidance.  Education’s Office of Postsecondary Education (OPE) is responsible for  formulating federal postsecondary education policy and administering  programs that support its mission to increase access to quality  postsecondary education. In addition, Education’s Office of Special  Education and Rehabilitative Services (OSERS) is responsible for  providing a wide array of supports to parents and individuals, school  districts, and states in three main areas—special education, vocational  rehabilitation (VR), and research—to help prepare students for  postsecondary education. Education’s Office for Civil Rights (OCR)  carries out its enforcement activities by investigating complaints, initiating  compliance reviews, monitoring the resolution of complaints and  compliance reviews, and providing technical assistance. OCR investigates  complaints it receives and carries out its other activities with its remaining  resources. Education is also responsible for implementing new provisions  in the HEOA related to postsecondary students with disabilities.
Other federal agencies provide services and support for individuals with  disabilities, including postsecondary students. The Social Security  Administration (SSA) administers the Supplemental Security Income (SSI)  program, a means-tested entitlement program that provides monthly  benefits to the aged, blind, or individuals with disabilities who have very  limited income and assets. SSI beneficiaries who are under the age of 22  and regularly attending school can qualify for the earned income  exclusion, in which a certain amount of monthly earned income is  excluded for SSI benefit computation purposes. This student earned  income exclusion is intended to help defray the cost of educational  training. In addition, SSA beneficiaries may obtain a Plan to Achieve Self  Support (PASS), which allows them to set aside income and/or assets to  support efforts like higher education in the pursuit of work goals. Further,  the Department of Health and Human Services administers the Medicaid  program, which can provide medical benefits to individuals with  disabilities. Finally, the Department of Veterans Affairs provides services  and benefits to veterans with disabilities, including VR services and  student financial aid under the Post-9/11 GI Bill.
section_title: The Population of Postsecondary Students with Disabilities Appears to Have Increased and, Demographically, Closely Mirrors Students without Disabilities
paragraphs: The NPSAS pertains to school years 1999-2000, 2003-2004, and 2007-2008. Note that data  from the 2008 NPSAS are preliminary and may be subject to change. The item response  rates for the NPSAS 2000 and 2004 data we report are at least 66 percent. Item response  rates for the data we report for NPSAS 2008 are not available as of October 2009. through Education’s Integrated Postsecondary Education Data System  survey, will provide a new vantage point to examine the population’s size.
Beyond looking at size, the portrait of students with disabilities appears to  closely mirror that of their peers without disabilities, i.e., students who did  not report having a disability, according to 2008 NPSAS data. Women  represented about 57 percent of both students with disabilities and their  peers. There were some small differences among both populations with  regard to race. White students represented 67 percent of students with  disabilities and 63 percent of their peers. Conversely, Hispanic or Latino,  Black or African American, and Asian students represented slightly  smaller groups among students with disabilities than among their peers  (see app. II, table 5). Also in 2008, the average age of students with  disabilities was about 26 years old, or about 1 year older than their peers.  This represents a substantial change from 2000, when students with  disabilities were, on average, 30 years old and 4 years older than their  peers. Moreover, in 2008 a larger proportion of postsecondary students  with disabilities than in 2000 had begun higher education relatively soon  after completing high school, as opposed to delaying by 1 or more years.
Students with disabilities and their peers were also similar in some  respects regarding the types of schools they attended—public versus  private—according to NPSAS data. Like their peers, nearly 70 percent of  students with disabilities attended public schools in 2008 (see app. II, table  6). However, for those students who attended private schools, students  with disabilities were enrolled at proprietary (for-profit), as opposed to  not-for-profit, schools at a slightly higher rate than their peers.
There were some small differences in attendance patterns (e.g., full-time  versus part-time) among students with disabilities and their peers. While  the majority of both groups attended school part-time and/or for part of  the year, this pattern was somewhat more prevalent among students with  disabilities (see fig. 2). One contributing factor may be that some students’  disabilities hinder them from taking as many credits per semester as their  peers, according to several disability experts and school officials we  interviewed.
In addition, the level of schools—2-year or 4-year—is another area in  which there were some small differences among these two populations.  According to the 2008 NPSAS, students with disabilities attended 2-year  schools at a higher rate than their peers and 4-year schools at a lower rate  (see fig. 3). This relative difference was also true in the 2000 NPSAS (see  app. II, table 6). Some literature suggests that community colleges may  offer more specialized services for students with disabilities and provide  better access for these students than other types of institutions. One  community college expert we interviewed said that students with  disabilities can particularly benefit from these schools’ relatively smaller  classes and more personal attention from faculty.
NPSAS data also showed that students reported having a wide range of  disabilities; however, the distribution of disability type has changed in  some notable ways over time (see fig. 4). In 2008, the largest proportion  of students with disabilities, 24 percent, reported having either a mental,  emotional, or psychiatric condition, or depression. Attention deficit  disorder (ADD) was the next most common type, accounting for 19  percent of such students. With regard to physical disabilities, 15 percent  reported that they had an orthopedic or mobility impairment. Interestingly,  in the 2000 NPSAS, more than a quarter of students reported an orthopedic  or mobility impairment as their main disability and only 7 percent cited  ADD (see app. II, table 7).
For a variety of reasons, NPSAS data on type of disability differed from  studies that have examined the population of students with disabilities before  they reached college age. According to two longitudinal studies that began  when students were in secondary school, learning disability was the main  type for about 70 percent of those who were in postsecondary school when  the data we analyzed was collected. In contrast, in the 2008 NPSAS, fewer  than 10 percent of students with disabilities reported having a specific  learning disability, such as dyslexia. One reason for the differences is that the  two studies, the National Longitudinal Transition Study-2 (NLTS2) and the  Education Longitudinal Study of 2002 (ELS), were designed for different  purposes and have different populations than the NPSAS. Also, in these  studies, the school districts identified these students and their disabilities, i.e.,  those who were eligible for special education services under the IDEA. In  contrast, in the NPSAS, students self-reported whether or not they had a  disability and its type. Furthermore, in the NPSAS, students with disabilities  may have chosen not to disclose that they had a disability.
section_title: Schools Use Different Approaches and Accommodations to Support Students with Disabilities
paragraphs: Postsecondary schools provide a wide range of accommodations to  students with disabilities. These accommodations can include academic  adjustments (such as extended time on tests and a reduced course load)  and auxiliary aids or services (such as notetakers and sign language  interpreters). Several factors play a role in determining what  accommodations schools provide for individual students. Schools are  required to provide reasonable accommodations tailored to an individual  student’s needs to allow equal access to higher education. The school  determines which accommodations to provide on a case-by-case basis,  based on documented needs. Such documentation generally includes a  disability diagnosis and the implications of the disability on a student’s  ability to fully participate. Schools are required to assume costs incurred  for providing accommodations to students with disabilities, unless doing  so would result in an undue burden or a fundamental alteration of the  program. In addition, under federal law, schools are required to ensure  that facilities of the postsecondary environment, such as campus  buildings, student housing, physical equipment, and transportation  systems, are accessible for students with disabilities. For example, schools  may provide desks and tables sized so that students in wheelchairs can use  them. See figure 5 and table 1 for examples of academic adjustments,  auxiliary aids, and other services for students with disabilities.
Some schools offer enhanced or more comprehensive services than are  required by law. These schools generally have a structure in place with  trained staff, such as a disability services office, to provide and facilitate  services for students with disabilities and coordinate with faculty and  other campus offices, such as counseling and academic support centers.  Enhanced services may include having specialized and trained  professionals, disability screenings and assessments, counseling and  tutoring, additional accommodations that promote the full participation of  these students in campus life, and monitoring of student progress. For  example, some school officials we interviewed told us their schools  offered a variety of workshops or courses that addressed study skills, time  management, and social interaction skills. Other schools offered mentors  and coaches for students with disabilities to help them navigate campus  culture, both academically and socially. In addition, some schools also  offer more comprehensive accommodations to promote the full  participation of students with disabilities in campus life. For example, two  schools we visited provided on campus dorms staffed with personal  attendants for students with severe physical disabilities. In addition, one of  these schools also had an underground tunnel system that provided easy  access for students with physical disabilities to get across campus,  especially in inclement weather (see sidebar).
Some schools also offer specialized programs to supplement academic  instruction. For example, one school we visited had established a Learning  Services Program to help students transition from secondary to  postsecondary school (see sidebar). In addition, a few schools are  designed exclusively for students with a specific type of disability, such as  Gallaudet University in Washington, D.C., for deaf and hard of hearing  students and Landmark College in Vermont for students with learning  disabilities and attention deficit hyperactivity disorder (ADHD).
In addition to supports provided by schools, some private organizations  offer personalized fee-based services, such as coaching, mentoring, and  personal advocacy to students with disabilities. Some of these groups  work in cooperation with postsecondary schools while others work  independently. For example, one private community organization provides  support, for a fee, to postsecondary students with ADD, high-functioning  autism, or a non-verbal learning disorder who are attending one of its  participating schools. This program is specifically designed to address  students’ social, communication, and organizational challenges and to help  students develop individualized strategies to manage their college careers  independently.
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School and association officials we interviewed emphasized the  importance of school disability services offices collaborating with other  campus offices, such as academic departments, counseling centers,  financial aid, housing, student activities, special events, and career  services, to provide the full range of services that students may need. Such  coordination and collaboration is one of the disability services office’s  primary roles, according to school officials we interviewed. For example,  these offices may coordinate with the counseling center to arrange for  treatment of students with psychological disabilities. Some schools have  efforts in place to help students understand the various sources of aid that  may help pay for tuition, books, adaptive technology, or other services.  For example, the disability services office at one school we visited  employed a financial aid liaison specifically for helping students with  disabilities. According to research and school and disability association  officials we interviewed, students with disabilities often have additional  expenses related to their disability. For example, these students may need  to pay for testing to document their disability, personal services (such as  personal care attendants), assistive equipment, transportation, and  medical expenses related to their disability. Also, these students may take  more time to finish their degree and face additional room and board  costs. Further, like all students, they may be ineligible for the maximum  amount of federal financial aid if they take a reduced course load,  withdraw from classes, or take longer to finish their degree.
In addition, school disability services offices also coordinate with other  groups in the community to provide services for students with disabilities.  For example, disability services offices may refer students to local VR  offices that can provide postsecondary support for individuals with  disabilities in the form of funding for tuition, books, and auxiliary aids,  such as assistive technology. However, past GAO work has found that VR  agencies varied substantially in their frequency of providing certain  services, and a few students we interviewed described inconsistencies in  receiving VR funds.
Technological advances have expanded the educational opportunities for  students with disabilities. In fact, assistive technology tools are among the  most frequently provided accommodations for students with disabilities,  according to school officials we interviewed (see table 2). For example,  voice recognition software can help students prepare papers by “talking”  to the computer instead of using the keyboard. Moreover, some schools  have an assistive technology specialist and/or separate assistive  technology labs on campus. In addition, to improve faculty technology  skills, some schools offer specialized training for faculty. For example, the  community college system in California has developed a High Tech Center  Training Unit that provides training to faculty and staff of 114 community  colleges to improve their skills related to assistive computer technology,  alternate media creation, and Web accessibility.
Schools are also becoming more aware of the benefits of, and are  increasingly using, the universal design model in curriculum development  and delivery, according to school and association officials. Universal  design in education is based on the premise of making learning inclusive  for all students, not just those with disabilities. It is an approach to  designing all products and services to be usable by people with the widest  possible range of functional capabilities. For example, a professor could  provide course materials using several different methods, such as by  lecture, in power point slides, and in narrative to accommodate the  different learning styles of students. Another goal of universal design is to  make the environment, such as buildings and transportation systems,  accessible to all individuals.
section_title: Schools Face a Broad Range of Challenges in Supporting Students with Disabilities, and New Challenges Are Likely to Emerge as the Population Changes
subsections: section_title: Schools Face Challenges during Students’ Transition to Postsecondary School
paragraphs: The transition students with disabilities face regarding their rights and  responsibilities when beginning higher education can have implications  for schools if students are not fully prepared for it. Postsecondary schools,  unlike secondary schools, are not required to identify students with  disabilities and are not responsible for documenting students’ needs.  Instead, if students want disability-related services in postsecondary  school, they are responsible for disclosing to the school that they have a  disability, providing the required documentation, and requesting  accommodations and services. Schools generally explain what  documentation is required and how current the documentation must be.  However, schools can face challenges if a student is not aware of these  responsibilities or does not understand how to obtain accommodations.  Some schools have responded to this challenge by proactively conducting  outreach to students with disabilities and their parents to explain the shift  in rights and responsibilities. For example, school officials told us they  offer “college nights” at local high schools and “summer bridge” or  orientation programs to provide information about disability services and  how to navigate the campus system. In addition, at some schools we  visited, the disability services offices had made efforts to help students  develop self-advocacy skills, such as having students personally deliver  their accommodation request forms to professors rather than the disability  services office handling this. School officials told us that they also rely on  OCR’s publications and other technical assistance related to transition  issues.
A related challenge for schools is providing services to students with  disabilities who did not initially disclose their need for accommodations.  Some students choose not to disclose their disability, even when they are  aware of available services, according to school officials and disability  experts. While a student is not obligated to inform a school that he or she  has a disability, in order for the school to provide an academic adjustment  or another disability-related service, the student must identify himself or  herself as having a disability. Any initial nondisclosure may become  problematic for schools when students disclose and request  accommodations after they fall behind academically. For example, a  school may find it difficult to provide timely accommodations to a student  who disclosed a visual or learning disability in the middle of a semester  because of the time required to convert text books into electronic format.  School and disability group officials told us that some students choose not  to register with the disability services office and request accommodations  for a variety of reasons. For example, they said some students, especially  those with “hidden” disabilities, such as learning disabilities, are reluctant  to disclose because they want a fresh start in higher education without the  label of having a disability.
section_title: Providing the Range of Services Needed Poses Challenges to Schools
paragraphs: Schools face challenges in acquiring and providing some services for  students with disabilities, in particular, those services that involve  specialized knowledge and resource-intensive accommodations. School  and disability association officials told us that recent increases in specific  populations of students with disabilities, for example, those with  psychological disabilities (such as bipolar and anxiety disorder), autism,  or chronic medical conditions (such as cancer or gastrointestinal  disorders), have placed additional demands on schools. In particular,  school disability officials and researchers reported the need for staff with  specialized expertise to appropriately support these students. For  example, school officials told us that their counseling centers were not  designed to support the types of psychological disabilities they now  encounter among students. To address this, some schools have hired staff  with expertise in mental health counseling.
In addition, some school disability officials told us they lack experience in  supporting the needs of students with autism, in particular those who need  coaching in social skills and assistance in organization and time  management. Some schools have specific programs on campus and  training for faculty to support the needs of this population (see sidebar).  Schools can also face challenges in supporting students with chronic  medical conditions, such as severe allergies, who may need less traditional  accommodations that schools are not accustomed to providing, such as  dietary modifications or chemical-free classrooms.
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Disability association and school officials noted challenges related to  having resources available to provide accommodations to students,  particularly those that are costly or staff intensive. For example, providing  sign language interpreters is expensive and may strain disability services  office budgets. At one school we visited that served about 1,500 students  with disabilities, officials reported they devoted about 25 to 30 percent of  the disability services office budget to interpreters for six students who  are deaf. In addition, some school officials said that converting course  materials into accessible formats, such as electronic text or Braille, is  costly and time consuming, particularly materials including graphics,  mathematical equations, and foreign languages. To minimize the cost and  resources needed, schools in several states have established online  clearinghouses to share materials already converted into accessible  format. Moreover, the HEOA contained provisions to improve accessibility  of course materials. However, publishers can be reluctant to make  textbooks available in electronic formats, according to a 2009 report by  the National Council on Disability. Further, some school disability services  officials reported that they lack sufficient staff and space to provide  certain accommodations, such as proctors and distraction-free rooms for  test taking. For example, officials from one school told us the need for  space has changed over time with more students with ADD/ADHD  requesting separate testing areas and that the disability services staff  proctored over 200 exams in 1 day.
Another challenge schools face is a lack of awareness among some faculty  members regarding legal requirements for supporting students with  disabilities, according to schools officials we interviewed and research.  Disability associations and school officials told us that while faculty are  generally receptive to supporting these students, some faculty members  showed resistance to providing accommodations. School officials and  research cited faculty lack of awareness and understanding of the legal  requirements as key factors. Faculty members generally define academic  standards through development and delivery of course requirements and  materials, and some believe that accommodations may undermine their  academic authority and compromise academic standards and values,  according to school and association officials we interviewed and research.  Further, some faculty members are unwilling to modify lectures or course  materials to make them accessible and some view commonly-accepted  accommodations, such as extended time on exams, to be a fundamental  alteration of their course. Some disability services staff told us they  provide information sessions and written materials to faculty to help them  understand the legal requirements.
In addition, some schools face challenges related to lack of faculty  experience in supporting students with disabilities. Several school officials  we interviewed told us that some faculty members have not had much  experience teaching students with disabilities and are not yet  knowledgeable about instructional techniques or technologies that can  assist them in teaching students with disabilities. For example, faculty may  not be used to students with chronic medical or physical conditions who  may need to take breaks from class, reschedule tests, miss class to attend  treatment, or have personal attendants with them. To enhance faculty  understanding and skills, many schools conduct faculty training related to  students with disabilities, according to higher education association  officials. For example, some schools have participated in OPE  demonstration projects to enhance the skills of faculty and administrators  in working with students with disabilities. Such projects include faculty  training in using assistive technology, professional development, technical  assistance workshops, distance learning, and research.
section_title: Growing Numbers of Veterans with Disabilities and Students with Intellectual Disabilities May Pose New Challenges for Schools
paragraphs: The needs of emerging populations of students with different types of  disabilities can present challenges to schools that lack experience  supporting these populations. In addition to increasing numbers of  students with autism, psychological disabilities, and chronic medical  conditions, schools are expecting more veterans with disabilities. School  officials told us they anticipate an increase in the number of veterans  returning from Iraq and Afghanistan seeking postsecondary education,  especially with the recent enactment of the Post-9/11 GI Bill. Some of  these veterans have acquired mental or physical disabilities (such as  traumatic brain injury (TBI), post-traumatic stress disorder (PTSD), and  amputations) that could result in them needing accommodations.  According to disability association officials, the need for accommodations  may not become apparent until veterans are in the classroom, given the  difficulty in diagnosing some disorders, such as TBI. For example, short- term memory loss associated with TBI may not surface until a student is  taking classes. Further, according to school disability officials, veterans  may be reluctant to disclose a disability and request accommodations for a  variety of reasons. For example, some veterans are reluctant to disclose a  disability because they think other veterans with more severe impairments  need more help or they are not sure how disclosure will affect their  military career. Even when veterans do disclose disabilities, many schools  lack experience in accommodating the needs of veterans with disabilities.
Some schools are recognizing the need to adapt their support approaches  by working closely with veterans groups on campus and providing  resources to disability staff and faculty to help them understand how the  military experience affects a student’s transition to campus life. For  example, one school official we interviewed described a recently- implemented military outreach program that pairs faculty with students to  provide support to veterans and their families coming to the school. Other  schools have initiatives specifically related to helping veterans acclimate  to campus life and obtain accommodations they need (see sidebar). One  recent study showed that some schools are planning to train counseling  staff to assist veterans with PTSD and other health issues.
Another challenge that more schools will be facing in the future is  supporting the needs of students with intellectual disabilities seeking  higher education—a student population that is expected to increase.  Officials from one organization that focuses on students with intellectual  disabilities explained that these students generally have different goals  and needs than their peers. For example, some students with intellectual  disabilities attend postsecondary classes as part of their overall work or  career plan but may audit classes instead of working toward a degree. In  another example, some students with intellectual disabilities attend  classes designed to address life skills, such as functional math or reading,  financial skills, or employment training. Increased attention has been  placed on this student population as shown by new HEOA provisions  that include authorizing grants to postsecondary schools to develop model  transition programs to higher education, establishing a center to provide  schools assistance in developing these programs, and authorizing financial  aid eligibility for these students. While some schools already have  programs in place to meet the needs of students with intellectual  disabilities, other schools may consider developing new programs to  support this student population, according to Education officials.
section_title: Various Education Offices Provide Assistance to Schools but Lack a Coordinated Approach
subsections: section_title: Education Provides Assistance to Schools in Supporting Students with Disabilities
paragraphs: Education has provided assistance to postsecondary schools to support  students with disabilities through three different offices. The three  different offices—OCR, OSERS, and OPE—have different missions and  priorities, focus on different clients, and provide different types of  assistance to schools; however, all three offices have a role in promoting  access for students with disabilities in postsecondary education.
Although OCR’s primary role is enforcement, it has taken the lead among  the three offices in providing information and assistance directly to  postsecondary schools to help them comply with legal requirements and  informing students, parents, community groups, and others of their rights  and responsibilities. According to OCR officials, the difference in legal  rights and responsibilities of students with disabilities in secondary versus  postsecondary school has often resulted in confusion for both schools and  students. OCR has taken the initiative to provide assistance in a variety of  ways, such as issuing publications and conducting presentations to inform  schools, students, parents, community groups, and others about the  students’ legal rights and the requirements of the federal disability laws  related to postsecondary education. According to OCR officials, there is a  great demand from students, parents, teachers, and parent-teacher  associations for information about the transition from secondary to  postsecondary school for students with disabilities. For example,  determining what accommodations a postsecondary school is required to  provide to students with disabilities is complex, and school officials are  often unclear about what is considered a “reasonable” accommodation. To  respond to this information need, OCR published a pamphlet for students  entitled Students With Disabilities Preparing for Postsecondary  Education: Know Your Rights and Responsibilities and a guide for high  school faculty entitled Transition of Students With Disabilities to  Postsecondary Education: A Guide for High School Educators. In  addition, in 2007 and 2008, OCR issued “Dear Colleague” and “Dear  Parent” letters to schools and parents about the legal rights and  responsibilities of students with disabilities as they transition from  secondary to postsecondary education. These letters explain the role of  postsecondary schools with respect to students with disabilities. OCR’s  publications and letters are available on OCR’s Web site as well as by mail,  upon request. According to OCR officials, the office relies on external  sources, such as schools, parents, news media, interest groups, and the  general public, to identify topics to cover in its technical assistance efforts.  In addition, OCR relies on suggestions from OCR regional staff to identify  issues based on its ongoing work.
OCR has also conducted technical assistance presentations about a wide  range of topics related to postsecondary students with disabilities in  response to requests from schools and other groups, such as parent- teacher associations. In fiscal year 2008, OCR presented about 130  technical assistance presentations that focused entirely or partly on  disability issues. In both fiscal years 2007 and 2008, the presentation on  students with disabilities transitioning to postsecondary school was  among the most frequently offered disability presentation. In addition,  OCR recently identified veterans with disabilities seeking higher education  as an emerging issue, and in July 2008, OCR issued letters to notify schools  and veteran students about its new Wounded Warrior Initiative to assist  veterans returning from Iraq and Afghanistan with disabilities who are  seeking postsecondary education. According to OCR officials, wounded  warriors who have recently acquired a disability may not be aware of  accommodations available in postsecondary education. To support the  needs of this emerging population, OCR has conducted presentations  about wounded warriors for postsecondary schools. OCR also offered  presentations on a range of other topics such as academic adjustments,  auxiliary aids, Web accessibility, assistive technology, food allergies as a  disability, grievance procedures, and complying with disability law. In  addition, OCR staff answer questions about disability issues from students,  parents, school officials, and other interested stakeholders who contact  OCR.
OSERS serves a broad range of clients; however, the office’s initiatives  related to postsecondary students with disabilities have been focused  primarily on providing direct support to states and indirect support to  schools and students. OSERS has provided this support through  technical assistance centers, state vocational rehabilitation agencies, and  research initiatives. Within OSERS, the Office of Special Education  Programs is dedicated to improving results for infants, toddlers, children and youth with disabilities by providing leadership and financial suppor t  to assist states and local districts; however, the office has supported three  technical assistance centers with narrow focuses related to transi tion and  postsecondary education that support states and schools:  the National Secondary Transition Technical Assistance Center and the  National Post-School Outcomes Center assist states in collecting data  related to post-secondary school transition planning and post-school  outcomes for youth with disabilities, respectively, and  the Postsecondary Education Programs Network is a national network of  regional centers that provide resources, information, and training to  schools focused on improving services and access for certain students  only—those who are deaf or hard of hearing.
Also, OSERS’s Rehabilitative Services Administration funds grants to state  VR agencies to provide a variety of services to individuals with disabilities,  including helping postsecondary students with disabilities pay for a range  of services, such as counseling, tuition, books, housing, transportation,  and assistive technology. Finally, OSERS’s National Institute on Disability  and Rehabilitation Research (NIDRR) has funded grants to schools and  other groups for research studies related to students with disabilities,  including studies focused on students with intellectual disabilities,  psychiatric disabilities, and autism, as well as other studies with broader  scopes. NIDRR has recently put in place a system of sharing information  between grantees and state VR agencies to establish a better link between  research results and practice in the field.
Education’s office with primary responsibility for focusing on  postsecondary education issues and schools is OPE; however, it has  provided limited technical assistance to schools on disability issues. OPE  funds two grant programs for postsecondary schools—one for training  faculty and another for supporting students with disabilities. OPE’s  technical assistance has been focused on the schools that receive these  grants. In fiscal year 2008, OPE provided technical assistance to the 23  postsecondary schools that received demonstration project grants for  improving faculty skills and abilities in working with students with  disabilities. Specifically, OPE has hosted an annual conference and  monthly conference calls for these demonstration grant recipients to ask  questions about the projects, discuss their progress, and share best  practices based on project results. In addition, OPE has provided some  assistance to the 25 postsecondary schools that received grants through  the federal TRIO program’s Student Support Services (SSS) program to  support students with disabilities, for example by providing tutoring or  counseling. According to agency officials, OPE also provided assistance  through responding to e-mail inquiries, conducting conference calls, and  attending conferences to assist these postsecondary schools that host  TRIO programs. OPE also awards grants to other entities to provide  training on the TRIO programs and identifies priorities for this training.  For example, one nonprofit group—the Council for Opportunity in  Education—has used TRIO grant funds to conduct annual conferences and  seminars to provide information and assistance to postsecondary schools  that have received SSS grants.
According to OPE officials, the office does not provide broader technical  assistance on disability issues to postsecondary schools because the office  lacks expertise in this area. However, according to the Education Web site,  OPE is responsible for developing federal postsecondary education policy  and administering programs that support the mission to increase access to  quality postsecondary education. More specifically, OPE has lead  responsibility for administering programs that identify, prepare, and  facilitate access of students with disabilities to higher education institutions  and their successful completion of programs at their maximum levels of  ability.
In the future, OPE will have the lead role in implementing several new  initiatives authorized by the HEOA that are designed to provide additional  assistance to postsecondary schools regarding students with disabilities.  Specifically, the HEOA added provisions to the HEA requiring the  Secretary of Education to establish two centers to provide technical  assistance and information to students, parents, and schools. HEOA also  added provisions regarding postsecondary students with particular types  of disabilities. For example, the Act authorized an advisory commission  and model demonstration programs to improve accessibility to  instructional materials for students with print disabilities. In addition, the  Act authorized the Secretary to provide grants for model transition  programs for students with intellectual disabilities in higher education.  Finally, in reauthorizing the demonstration grant projects to support  postsecondary faculty and staff in educating students with disabilities,  HEOA requires Education to report to the Congress on the activities and  program performance of these projects and provide guidance and  recommendations on how effective projects can be replicated. As of  October 2009, Congress has not provided funding specifically for those  HEOA initiatives that require it.
section_title: Education Does Not Have a Coordinated Approach for Assisting Schools
paragraphs: While Education’s three offices have collaborated in some cases to  provide technical assistance to postsecondary schools to meet their needs  for information about disability issues, the agency has not developed a  coordinated approach to guide its technical assistance efforts.  Coordination efforts among Education offices to provide assistance to  schools about students with disabilities have generally been informal and  in response to specific issues. For example, according to Education  officials, OCR and OSERS have collaborated on some postsecondary  disability issues, including OSERS staff sharing their disability expertise  with OCR staff in preparing technical assistance publications for schools,  such as the transition guide for high school educators and the Dear  Colleague letters. In addition, both OSERS and OCR have had limited  coordination with OPE on disability issues and coordinate on an as- needed basis when specific issues arise. For example, OSERS and OPE  issued a joint letter to public postsecondary schools and state VR agencies  encouraging these entities to establish interagency agreements to guide  their collaboration in providing VR services to students with disabilities.  Also, OPE invited OCR to attend the annual conference for schools that  received demonstration grants to give a presentation and answer questions  about supporting postsecondary students with disabilities.
School and disability association officials told us that schools need more  guidance about postsecondary disability issues. Although some school  officials we interviewed told us they had used Education’s publications,  attended presentations, and contacted OCR with specific disability-related  questions, many school officials told us they had limited contact with  Education related to students with disabilities. Instead, school officials  said they often relied on sources outside Education for technical  assistance in this area, such as regional and national disability and  education associations and other schools. According to both school and  association officials, schools need more information and technical  assistance related to supporting postsecondary students with disabilities.  Several school officials told us they needed more assistance in general on  complying with disability laws and the transition from secondary to  postsecondary school. Other school and association officials indicated the  need for more guidance in specific areas, including assistive technology,  use of service and comfort animals on campus, and supporting emerging  student populations, such as those with autism, psychological disabilities,  and veterans with disabilities. Several school and association officials  expressed the need for Education to disseminate information about best  practices and results of successful demonstration projects that may have  wide applicability across schools. School officials and disability experts  suggested several ways Education could share information with schools,  such as establishing a clearinghouse to share best practices, posting  answers to frequently asked questions on the agency Web site, maintaining  a listserv, and developing online videos or Webinars on how school  officials can support students with disabilities—especially for schools that  are unable to attend Education conferences.
Although each of these Education offices has provided some assistance on  disability issues to postsecondary schools, with OCR taking the lead, the  agency has not developed a strategy to address the needs of schools. More  specifically, Education has not developed a structure for these offices to  coordinate in identifying the needs of schools and the best way to meet  these needs, including the type of assistance and who should provide the  assistance. OPE has not regularly collaborated with OCR and OSERS  regarding disability issues, even though these two offices have experience,  expertise, and data related to these issues that OPE does not. While  OSERS officials told us that OPE could benefit from OSERS’s expertise on  disability issues, the two offices have had only informal discussions about  collaborating in the future. These three offices have not coordinated their  technical assistance efforts to systematically leverage expertise and  resources to meet the needs of postsecondary schools in this area.
In addition to this lack of strategic coordination described above, in July  2009 we issued two reports that found that Education lacked  departmentwide mechanisms to share information and coordinate efforts  in its support of elementary and secondary school teacher quality  programs. More specifically, in one report we found that Education lacks  coordination in sharing of information among the six Education offices  that provide funding and other assistance that can help general classroom  teachers instruct students with disabilities and English language learners.  In the other report we also found little sustained coordination and no  strategy for working systematically across nine Education offices that  administer programs that provide billions of federal dollars for teacher  quality improvement efforts. In both reports we recommended that the  Secretary of Education develop and implement mechanisms to ensure  more systematic or sustained coordination among program offices that  support teacher quality efforts. Such coordination could help facilitate  information and resource sharing as well as strengthen linkages among  teacher quality improvement efforts to help states, school districts, and  postsecondary schools in their initiatives to improve teacher quality. In  response to our recommendations, Education agreed that coordination is  beneficial and will explore the benefits of creating such mechanisms.  However, Education also pointed out that such efforts do not always  prove useful, indicating that it favors short-term, issue-specific  coordination. In our response to Education in these reports, while  acknowledging that the department faces some challenges to  coordination, we emphasized that we continue to believe that Education  needs to develop a strategy for sustained coordination to ensure that  different offices routinely become involved in sharing information and  resources, as well as facilitating linkages among teacher quality  improvement efforts.
section_title: Conclusions
paragraphs: The number of students with disabilities pursuing postsecondary  education is growing and this will further challenge current thinking about  how to support them and schools’ capacity to effectively meet their  educational needs. Education has played a key role in working to ensure  equal access to higher education for students with disabilities, in part, by  providing technical assistance to schools to help them meet the needs of  this diverse population. However, the management and delivery of this  assistance is spread among Education offices with limited coordination.
This informal technical assistance delivery structure inhibits the regular  sharing of information and expertise related to students with disabilities  among offices and does not result in these offices thinking more globally  or strategically about the information needs of schools and the best way  for the agency to meet these needs. Without a more coordinated approach  among the offices that provide technical assistance, schools may not fully  benefit from the disability expertise and experiences that are currently  dispersed among various Education offices. As a result, Education may  miss opportunities to leverage agency resources to help better meet the  information needs of schools and students. Further, OCR and OSERS have  expertise that, through coordinated efforts, may better position OPE to  carry out its new responsibilities under the HEOA.
section_title: Recommendation for Executive Action
paragraphs: To improve access to quality higher education for students with  disabilities, we recommend that the Secretary of Education develop and  implement a coordinated approach to optimize agency resources and  knowledge in providing technical assistance to institutions of higher  education in supporting students with disabilities. For example, Education  could develop a plan for routinely and systematically sharing information  related to supporting postsecondary students with disabilities.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Department of Education. We also  provided to the Department of Justice and Social Security Administration  selected sections that specifically pertain to programs these two agencies  administer. Education provided a written response to this report (see   app. V). Education, SSA, and Justice all provided technical comments,  which we incorporated throughout the draft as appropriate.
In its formal comments, Education agreed with our recommendation and  plans to develop and implement a coordinated approach to providing  technical assistance to postsecondary schools through a work group, to  include the Office of Vocational and Adult Education, the Office of  Postsecondary Education, the Office for Civil Rights, and the Office of  Special Education and Rehabilitative Services. In addition, Education  noted that the same knowledge, resources, and information useful to  postsecondary schools might be equally of interest and utility to students  and potential students with disabilities, family members, secondary  schools personnel, and counselors, among others. Education plans to  explore making information on higher education and individuals with  disabilities available in a more centralized and user-friendly manner on its  Web site, www.ed.gov.
We are sending copies of this report to appropriate congressional  committees, the Secretary of Education, and other interested parties. In  addition, the report will be available at no charge on GAO’s Web site at  http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  at (202) 512-7215 or scottg@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff that made major contributions to this report are  listed in appendix VI.
section_title: Appendix I: Technical Appendix
paragraphs: This appendix discusses in more detail our review of federal data on  postsecondary students with disabilities for question one: what is known  about the population of postsecondary students with disabilities. To  obtain information on this population, we identified 10 federal datasets  that are administered by the Department of Education, the Department of  Commerce (U.S. Census Bureau), and the National Science Foundation  (see table 3). We selected these datasets, in consultation with GAO  methodologists, because they are widely known, national datasets that  would most likely contain information about students with disabilities  related to higher education. We examined the datasets to determine the  purpose of the study or survey, the population described, the sample  surveyed, data collection methods, and the focus of questions and  variables related to students with disabilities. We evaluated these data and  studies for methodological rigor, as well as to determine the extent to  which the data could be used to offer a national perspective on students  with disabilities in higher education. The data we reported are reliable  enough for our purposes. For four of these datasets, we assessed the  quality, reliability, and usability of the data for reporting descriptive  statistics on student population characteristics (e.g., age, gender, and type  of disability) and characteristics of the schools they attend (e.g., school  size and type). Because the four surveys followed a probability procedure  based on random selections, each sample is only one of a large number of  samples that might have been drawn. Since each sample could have  provided different estimates, we express our confidence in the precision  of the particular sample’s results as a 95 percent confidence interval (e.g.,  plus or minus 4 percentage points). This is the interval that would contain  the actual population value for 95 percent of the samples we could have  drawn. All percentage estimates used in this report have 95 percent  confidence intervals of within plus or minus 4 percentage points, unless  otherwise noted. After analyzing the relevant data from these four  datasets, we relied heavily on one, Education’s National Postsecondary  Student Aid Study (NPSAS), for primarily two reasons. First, the NPSAS  specifically focuses on the population of postsecondary students and the  schools they attend, which allowed us to report information on many  topics related to postsecondary students. Second, it affords the  opportunity to look at changes in the population over time, specifically  from 2000, 2004, and 2008. Although the American Community Survey also  provides annual snapshots of the population, we were not able to report  trend information because the relevant data were first reported in 2006.
section_title: Appendix II: Data on Students with Disabilities
section_title: Appendix III: Postsecondary Schools, Associations, and Experts Interviewed
paragraphs: Appendix III: Postsecondary Schools,  Associations, and Experts Interviewed American Association of Colleges for Teacher Education (AACTE)
American Association of Community Colleges (AACC)
American Council on Education (ACE)
Association on Higher Education and Disability (AHEAD)
Center for the Study and Advancement of Disability Policy  Delta Alpha Pi International Honor Society  Disability Access Information and Support (DAIS)
HEATH Resource Center at George Washington University  Institute for Community Inclusion (ICI)
National Council on Disability (NCD)
National Secondary Transition Technical Assistance Center (NSTTAC)
National Youth Leadership Network (NYLN) (Student Group)
section_title: Appendix IV: Postsecondary Schools That Received Education Grants to Support Students with Disabilities in FY 2008
paragraphs: FY 2008 demonstration project grantees   San Diego State University Research Foundation  Board of Regents, University of Nebraska, University of Nebraska/ Lincoln  Northampton County Area Community College  Temple University of the Commonwealth System of Higher Education  Texas A&M University  University of Texas/ Pan American  University of Vermont and State Agricultural College  Board of Regents of the University of Wisconsin System (University of  Wisconsin/ Milwaukee)
section_title: Appendix V: Comments from the Department of Education
section_title: Appendix VI: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the contact above, Harriet Ganson (Assistant Director),  Linda Siegel (Analyst-in-Charge), Jennifer Cook, Jeffrey DeMarco, and  Alison Grantham made significant contributions to this report. Karen  O’Conor, Ying Long, and Jay Smale assisted with the data analysis and  methodology. Jessica Botsford provided legal support. Mimi Nguyen  assisted with graphics. Susan Bernstein and Jessica Orr assisted in report  development.