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

Letter

Background

Legal Requirements Regarding Postsecondary Schools Supporting Students with Disabilities

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.

Federal Agency Responsibilities

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.

The Population of Postsecondary Students with Disabilities Appears to Have Increased and, Demographically, Closely Mirrors Students without Disabilities

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.

Schools Use Different Approaches and Accommodations to Support Students with Disabilities

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.

Schools Face a Broad Range of Challenges in Supporting Students with Disabilities, and New Challenges Are Likely to Emerge as the Population Changes

Schools Face Challenges during Students’ Transition to Postsecondary School

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.

Providing the Range of Services Needed Poses Challenges to Schools

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.

Growing Numbers of Veterans with Disabilities and Students with Intellectual Disabilities May Pose New Challenges for Schools

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.

Various Education Offices Provide Assistance to Schools but Lack a Coordinated Approach

Education Provides Assistance to Schools in Supporting Students with Disabilities

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.

Education Does Not Have a Coordinated Approach for Assisting Schools

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.

Conclusions

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.

Recommendation for Executive Action

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.

Agency Comments and Our Evaluation

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.

Appendix I: Technical Appendix

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.

Appendix II: Data on Students with Disabilities

Appendix III: Postsecondary Schools, Associations, and Experts Interviewed

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)

Appendix IV: Postsecondary Schools That Received Education Grants to Support Students with Disabilities in FY 2008

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)

Appendix V: Comments from the Department of Education

Appendix VI: GAO Contact and Staff Acknowledgments

Staff Acknowledgments

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.