10.03 Policies and Procedures for Students with Disabilities

Policy Statement

Harvard Medical School (HMS) is committed to ensuring a supportive environment for students with disabilities by providing the opportunity for full participation in the HMS community. HMS complies with federal and state law prohibiting discrimination against any applicant or enrolled student on the basis of disability, in accordance with its obligations under the Americans with Disabilities Amendment Act of 2008 and Section 504 of the Rehabilitation Act of 1973. 

A person with a disability is someone who has a physical or mental impairment that limits substantially one or more major life activity, such as caring for one's self, performing manual tasks, learning, walking, seeing, hearing, breathing and working; has a record of such an impairment; or is regarded as having such an impairment.

Although students with temporary illness or injury are not considered disabled by law, every reasonable effort to accommodate their needs will be exercised.

All requests for accommodation (e.g., use of a computer, extra time and/or separate room for exams, reduced caseload, access to note-takers, taped books, etc.) are evaluated on a case-by-case basis. This evaluation includes the review of clinical documentation and a determination of the reasonableness of the accommodation requests. Primary clinical documentation or other diagnostic information held by the HMS and HSDM Director of Disability Services (see Procedure for Review of Accommodation Requests, below) is kept confidential and is released to a third party only with the student's written permission or as required by law. General information about a student's disability and accommodation request(s), however, may be shared with other Harvard officials or, in limited circumstances, with third parties who have a legitimate need to know. The student's disabilities file is maintained by the Director and is held separately from the student's official academic record.

Accessibility Information 

Procedure for Review of Accommodation Requests

HMS students are expected to be actively responsible for all aspects of their enrollment. Students requesting accommodations must take the initiative to seek assistance, comply with deadlines and agreements, and participate in the following procedure:

1. Contact the Director of Disability Services
   HMS students requesting accommodations should contact Tim Rogers, Director of Disability Services for HMS and HSDM, 260 Longwood TMEC Suite 347, Boston, MA 02115; telephone: 617-432-9198. This contact should take place at least three weeks prior to the start of an academic block, course, or clinical clerkship or immediately following an injury or illness, in order to initiate the accommodation process. 

2. Provide documentation
   In initiating the accommodation process, the student must submit current clinical documentation that supports the request for accommodation(s).
   Learning, Attentional Disabilities: Acceptable clinical documentation for learning disabilities (LD) and attentional disabilities (e.g., attention-deficit hyperactivity disorder [ADHD]) includes a comprehensive diagnostic interview/consultation and neuropsychological or psycho-educational evaluation plan, which typically should be completed within three to five years of entering Harvard Medical School. The three to five year currency requirement may be waived upon application and in appropriate circumstances. (See the Guidelines for Documentation of LD and Attentional Disabilities related to ADHD, below.)
   Other/Non-learning Disabilities: Acceptable documentation for other types of disabilities (e.g., medical, psychological, etc.), either permanent or temporary, includes report from the appropriately licensed individual describing the nature of the disability, suggested accommodation(s), and requested accommodation(s). (See the Guidelines for Documentation of Medical and Psychological Disabilities.) In all cases, the School reserves the right to request additional diagnostic information and assessment when, in its opinion, such additional information is needed to indicate the need for accommodations in the educational or clinical settings of Harvard Medical School.
   The Director of Disability Services works in close collaboration with other Harvard-based resources designed to evaluate and address architectural and programmatic access in each particular setting. Although a student's accommodation history is important, other factors are considered as well in determining what, if any, accommodations are appropriate at HMS; the receipt of particular accommodations in a previous setting does not automatically indicate that accommodations will be provided at HMS.

3. Complete a "Request for Disabilities Services/Accommodation" form 
   Along with submitting documentation, the student will complete a Request for Disability Services/Accommodation form (the student will receive this form when he/she meets with the Director of Disability Services.) The Director will make an initial evaluation of the request with respect to the completeness of the documentation submitted. The Director's evaluation may include consultation with at least one clinical consultant in addition to a meeting with the student before final determination of services can be made. With the student's written permission, the Director may need to consult with the original evaluator when documentation guidelines have not been followed or information is otherwise unclear.

   Sometimes a student may be asked to provide updated documentation, if the previous information does not include sufficient relevant support for the requested accommodation(s). Last-minute submission of documentation may result in delays in consideration of requested accomodations and support services. As medical school training may include a variety of settings – classroom to clinical – accommodations granted on admission may not be appropriate for all settings; the Director, in collaboration with appropriate HMS faculty, staff. or administrators, may review with the student, as needed, accommodations for each class or setting as the student progresses through the medical school curriculum, to avoid compromising or altering fundamentally the essential components of a particular course or program.

4. Implementation of Accommodations in Courses and Clerkships and Student's Responsibilities
   The HMS Director of Disability Services will communicate by letter the students approved accommodation(s) to the appropriate course or clerkship director before the start of the course/clerkship. The student has the responsibility to anticipate the need for such letters in his/her various courses/clerkships. The student is also responsible for ensuring that the letters have been received in a timely manner by the course/clerkship directors. If any problem arises in the receipt of such a letter by the course/clerkship director, the student must promptly notify the HMS Director of Disability Services to ensure that the necessary steps are taken to guarantee that the paperwork is in place.

5. Yearly review of Course/Clerkship Accommodations with Disability Services
   The student is encouraged to review and renew this process each year with the HMS Director of Disability Services to check for possible adjustments of accommodations in new training settings (e.g., from preclinical classrooms to clinical clerkships in hospital settings). In this yearly review, the HMS Director of Disability Services may consult with at least one clinical consultant in addition to meeting with the student to assist in final determination of services, if changes are considered necessary.

For nonacademic accommodations (e.g., related to transportation, housing or technology assistance), the Director of Disability Services will consult with the Vanderbilt Hall Facility Manager, the Director of Media Services, or other Harvard officials involved in facilitating the accommodation. The Director will then make and record a decision regarding the request.

For academic accommodations (e.g., related to curriculum modifications within a course or clerkship), the student should first meet with the Director of Disability Services to discuss and review their accommodation request.  The Director of Disability Services in consultation with the course/clerkship director(s), and with other appropriate Harvard faculty, staff and administrators,  will determine the appropriateness of the requested accommodation for the student and for the course/clerkship. In the event that a determination is reached that the requested accommodation would result in lowering academic standards or altering the program substantially, the Director of Disability Services in conjuction with the course/clerkship director(s), will consider whether any feasible alternative accommodations exist that would take into account both the legitimate interests of the school and the student. 

Appeal Procedure

A student has the right to appeal any accommodation decision by filing a written explanation and petition for reconsideration. The Director of Disability Services will first attempt to mediate with the student and faculty/staff member.

If the Disability Coordinator is unable to resolve the matter, she will present the student's petition to the Council of Academic Societies (CAS), chaired by the Dean for Students, which meets twice monthly (see Section 3.06). In adherence to confidentiality policies, the Disability Coordinator will obtain the student's written permission prior to distributing primary clinical documentation to members of the CAS, if relevant to the petition.

Members of the Council of Academic Societies will discuss the case and offer recommendation(s) for a solution. Within three school days following the CAS meeting, the Disability Coordinator will notify the student and faculty/staff member of the CAS recommendation(s).

If the CAS resolution is still unsatisfactory, the student may appeal in writing to:

The Director/504 Coordinator
Harvard University Disability Services (or designee)
Suite 727W 
Smith Campus Center
1350 Massachusetts Avenue
Cambridge, MA 02138
disabilityservices@harvard.edu
617-495-8520 (FAX)

The University Disability Services Office decision will be final. 

Harvard Medical School expressly reserves the right to make changes to its written policies, rules, and regulations that are consistent with its legal obligations of nondiscrimination and reasonable accommodation. The above information is not intended, and should not be construed, to give rise to contractual rights and obligations.

Guidelines for Documentation of Medical, Learning, Attentional and Psychological Disabilities

Before any accommodation can be granted, students must submit documentation as well as meet with the HMS Director of Disabilities Services. To ensure complete documentation, we suggest that students give a copy of relevant guidelines to clinicians for use in writing reports supporting the need for accommodations. Students are also advised to keep a copy of any documentation materials they give to the Disability Services Office. In instances of multiple diagnoses students and their treatment providers should consult the appropriate companion guidelines to ensure adequate documentation for the accommodations is provided. 

Documentation for Medical Disabilities

The following guidelines for medical disabilities (including mobility, chronic health, manual, and sensory disabilities) and conditions resulting from temporary illnesses and injuries are provided to assist students who plan to submit documentation to the HMS Director of Disability Services. Please see separate guidelines for learning, attentional, and psychological disabilities:

• The clinician must be qualified to make the diagnosis in the area of specialization and may not be a member of the student's family.
• The evaluation is written on professional letterhead, is current, usually within 3 months, and contains the date of the last appointment with the student.
• The clinician provides a clear diagnosis.
• Documentation includes relevant medical and treatment history.
• The evaluation contains a description of current medications, treatments, and assistive devices and technologies with estimated effectiveness in ameliorating the impact of the disability (i.e., extent of effectiveness of corrective lenses, use of crutches, etc.) and history of medication side effects known to have affected the student.
• A description is included of the functional limitations resulting from the disability that addresses specifically a graduate educational setting and, if relevant, reference to allowable activities.
• The documentation clearly supports the direct link to and need for the requested accommodations.

Documentation for Learning Disabilities (LD)

The evaluation must be conducted by a qualified professional who:

• has comprehensive training and relevant experience with an adolescent and adult LD population;
• has competence in working with culturally and linguistically diverse populations; and
• is not a member of the student's family.

Documentation must be recent, which, in most cases, means that testing has been conducted within the past three to five years. Documentation should include:

• a summary of a diagnostic/clinical interview;
• assessment of the major domains of cognitive and academic functioning;
• a list of tests administered, including all standard scores (Appendix B of detailed version);
• expert interpretation of the results;
• a clear diagnosis and statement of disability;
• discussion of functional limitations and academic functioning levels; and
• recommendations.

The diagnostic/clinical interview summary listed above should include:

• a description of the presenting problem(s);
• a developmental history of language and speech acquisition and early motor skill development;
• relevant medical history, including the absence of a medical basis for the present symptoms;
• academic history, including areas of uneven academic achievement and results of prior standardized testing taken with or without accommodations;
• reports of unevenness in classroom performance and behavior;
• relevant family history, including primary language of the home and the student's current level of fluency of English;
• relevant psychosocial history;
• relevant employment history;
• a discussion of dual diagnosis, preexisting or coexisting behavioral, medical, neurological, and/or personality disorders, along with any history of medication use, past or current, that may affect the student's learning;
• a description of auxiliary aids, services, and accommodations used; and
• exploration of possible alternatives that may mimic a learning disability when, in fact, a disability is not present.

Neuropsychological or psycho-educational assessment must provide clear evidence that a specific LD does or does not exist. Objective evidence of substantial limitation to learning must be provided. Assessment must consist of a comprehensive, individualized, standardized and adult-normed assessment battery. Any resulting diagnosis must be based upon a pattern of performance across the battery. A list of acceptable tests is included in Appendix B of the detailed version of these requirements, available from the HMS Director of Disability Services. Any factors influencing the validity of the testing must be described (e.g., whether the test taker withheld or took regular medications on the day of testing).

At a minimum, the domains to be addressed in a psycho-educational report must be the following:

• aptitude/cognitive ability: a valid intellectual assessment with all subtests and standard scores;
• academic achievement: a comprehensive academic achievement battery that assesses basic and higher order skills of reading, writing, verbal expression and math as well as fluency (timed performance) in these academic areas;
• cognitive and information processing that includes memory, processing speed and cognitive fluency, attention, sensory-perceptual functioning, executive functioning, motor functioning, visual acuity and possible need for prescription eye glasses;.
• informal measures, including classroom tests, informal assessment procedures, and observations that may be integrated with information from formal assessment measures to help rule in or rule out the learning disability, to differentiate it from coexisting neurological and/or psychiatric disorders, or to support a recommendation for a specific accommodation;
• error analysis of specific errors in performance on relevant assessment measures and other informal areas with a narrative description, discussion and interpretation of the kinds of errors made by the student; and
• behavioral observations, including signs of anxiety, fatigue or motivational issues.

The documentation must include a specific learning disability diagnosis in the official nomenclature of the Diagnostic and Statistical Manual, IV (DSM-IV) and/or the ICD-10 and describe both the nature and severity of the learning disability. The evaluator must describe the impact the learning disability has on major life activities, including the significance of this impact on the student's learning.

A clinically interpretive summary must be provided that includes:

• evidence that the evaluator ruled out alternative explanations for academic problems, such as limited education exposure, poor motivation and/or study skills, emotional problems, attentional problems and cultural/language differences;
• evidence of how patterns in cognitive ability, achievement, and information processing are used to determine the presence of a learning disability;
• evidence of the substantial limitation to learning presented by the learning disability and the degree to which the disability affects the student in the learning context for which accommodations are being requested;
• evidence of why specific accommodations are needed in this current educational setting and how the effects of the specific disability are mediated by the accommodation;
• an accommodation that is clearly identified (if an accommodation is not clearly identified in the diagnostic report, the HMS Director of Disability Services or his/her designee reserves the right to seek clarification and/or additional information from the evaluator. The HMS Director will make the final determination as to whether accommodations are warranted and can be provided for the student. If no prior accommodation(s) has been provided, the qualified professional and/or the student should include a detailed explanation of why no accommodations were used in the past and why an accommodation is needed at this time);
• additional sources of documentation that can be used to corroborate the functional limitations and build a case for the requested accommodation(s). Relevant information from these sources should be summarized by the evaluator in the current documentation and/or included as an attachment by the student.

HMS will not release any part of the documentation without the student's informed consent or under compulsion of legal process.

Documentation Guidelines for ADHD

The evaluation must be conducted by a qualified professional who:

• has comprehensive training in the differential diagnosis of ADHD,
• has direct experience with an adolescent or adult ADHD population, and
• is not a member of the student's family.

Documentation must be recent, which, in most cases, means that testing has been conducted within the past three to five years.

• A comprehensive assessment should include a diagnostic interview, neuropsychological and/or psycho-educational testing, and third party interviews when available.

Diagnostic interview should include:

• History of presenting attentional symptoms, including evidence of ongoing impulsive/hyperactive or inattentive behavior that has significantly impaired functioning over time;
• Developmental history;
• Family history of ADHD and other educational, learning, physical, or psychological difficulties deemed relevant by the examiner;
• Relevant medical and medication history, including the absence of a medical basis for the symptoms being evaluated;
• Relevant psychosocial history and any relevant interventions;
• A thorough academic history of elementary, secondary, and postsecondary education;
• Review of prior psycho-educational test reports to determine whether a pattern of strengths or weaknesses is supportive of attention or learning problems;
• Relevant employment history;
• Description of current functional limitations pertaining to an educational setting and that are presumably a direct result of problems with attention; and
• Relevant history of prior therapy.

Assessment must not only establish a diagnosis of ADHD, but also demonstrate the current impact of the ADHD on a student's ability to take tests under time pressure. In addition, neuropsychological or psycho-educational assessment is important in determining the current impact of the disorder on a student's ability to function in academically related settings.

• All data (selected test and subtest scores from measures of intellectual ability, memory functions tests, attention or tracking tests, continuous performance tests, checklists and/or surveys, clinical observations, etc.) must reflect logically a substantial limitation to learning for which the individual is requesting accommodation.

Documentation must include a specific diagnosis of ADHD based on the DSM-IV diagnostic criteria.

An interpretive summary must be provided that includes:

• Demonstration that the evaluator has ruled out alternative explanations for inattentiveness, impulsivity and/or hyperactivity as a result of psychological or medical disorders or non-cognitive factors;
• Indication of how patterns of inattentiveness, impulsivity, and/or hyperactivity across the life span and across settings are used to determine the presence of ADHD;
• Indication of whether or not the student was evaluated while on medication and whether or not a positive response to the prescribed treatment occurred;
• Indication and discussion of the substantial limitation to learning presented by the ADHD and the degree to which the ADHD has an impact on the student in the learning context for which accommodations are being requested;
• Indication as to why specific accommodations are needed and how the effects of ADHD symptoms, as designated by the DSM-IV, are mediated by the accommodation(s).

Documentation Guidelines for Psychological Disabilities

The evaluation must be conducted by a qualified professional who:

• has comprehensive training and relevant experience in differential diagnosis in the full range of psychiatric disorders,
• has appropriate licensure/certification, and
• is not a member of the student's family. 

Documentation must be current. Because of the changing nature of psychiatric disabilities, documentation must address the student's current level of functioning and the need for accommodations (e.g., resulting from observed changes in behavior and/or performance or from medication changes since previous assessment). If the diagnostic report is more than six months old, the student must also submit a letter from a qualified professional that provides an update of the diagnosis, a description of the student's current level of functioning during the preceding six months, and a rationale for the requested academic or residential accommodations. 

Comprehensive assessment is necessary to substantiate the diagnosis and must include data from historical information, diagnostic interview and/or psychological assessment. Psycho-educational, neuropsychological or behavioral assessments are often necessary to support the need for accommodations because of the potential for psychiatric disorders to interfere with cognitive performance. The evaluation should include:

• History of presenting symptoms;
• Duration and severity of the disorder;
• Relevant developmental, historical, and familial data;
• Relevant medical and medication history, including the student's current medication regimen and compliance, side effects (if relevant) and response to medication;
• Description of current functional limitations in different settings, with the understanding that a psychiatric disability usually presents itself across a variety of other settings—in addition to the residential and academic domain—and that expression of the disability is often influenced by context-specific variables (e.g., school-based performance);
• As relevant to the residential domain, a description of observed behaviors that are likely to have an impact on dormitory life as well as progression or stability of the impact of the condition over time;
• As relevant to academic performance, a description of the expected progression or stability of the impact of the condition over time; and
• As relevant to academic performance, information regarding kind of treatment and duration and consistency of the therapeutic relationship.
• Documentation must include a specific diagnosis based on the DSM-V or ICD-10 diagnostic criteria, and a specific diagnostic section in the report with a numerical and nominal diagnosis from DSM-V or ICD-10 should be included. Evaluators are encouraged to cite the specific objective measures used to help substantiate the diagnosis. 
• Alternative diagnoses or explanations should be ruled out. The evaluator must also investigate, discuss and rule out the possibility of other potential diagnoses involving neurological and/or medical conditions or substance abuse as well as educational, linguistic, sensorimotor and cross-cultural factors that may result in symptoms mimicking the purported psychiatric disability. 
• Rationale for the requested accommodations must be provided. The evaluator must describe the current impact of the diagnosed psychiatric disorder on a specific life activity as well as the degree of impact on the individual. A link must be established between the requested accommodations and the functional limitations of the individual that are pertinent to the anticipated academic and residential settings. A diagnosis in and of itself does not automatically warrant approval of the requested accommodations. 
• Multiple diagnoses may require a variety of accommodations beyond those typically associated with one diagnosis and, therefore, the documentation must adhere to the HMS Director of Disability Services' guidelines for other diagnoses.

Last updated 11/26/18