How Much Is The ADA Costing Your Organization?

When credentialing organizations budget for the cost of providing test accommodations under the Americans with Disabilities Act, they generally include such items as administrative costs for processing and reviewing requests and fees to test vendors, proctors and other staff for provision of additional "seat time" in the test center, production of extra time forms and large print paper versions, and specialized software and assistive aids that may need to be purchased or rented for exam administrations. Some organizations also allow for the cost of using outside experts to review ADA documentation.

These are the obvious costs of ADA compliance for testing and certifying organizations. However, there are a number of "hidden" costs which may impact your exam and ultimately, the value of the professional credential you issue.

The first of these "hidden" expenses is the risk to the utility of your examination. Credentialing exams are developed at substantial effort and expense to measure the knowledge base and practical skills of individuals in your profession. However, when a credentialing organization provides accommodations to a non-disabled examinee, the validity of the exam for all test-takers is compromised. So, too, is the meaning of the score of each non-disabled test-taker who tests under standard conditions.

Why does this happen? The premise of ADA test accommodations is to provide access to the exam for individuals who-because of physical or mental limitations-are not able to access the exam, e.g., vision, hearing, physical limitations or lack of reading skills. Because there is a verified disabling condition as defined by the law, the accommodations serve to equalize the effect of the limitation, allowing everyone "a place at the starting line."

However, providing accommodations to those who don't meet the clear-cut ADA definition of disability allows non-disabled examinees the opportunity to achieve a different score than what they might have earned under standardized conditions. Thus, you create a false cohort, a sub-group testing under non-standard conditions whose inflated performance skews the meaning of the scores. Even with annotation, which many organizations do not use, a reported score is viewed by score recipients as a "true" score, representing the true measurement of the test.

The most commonly requested accommodation is additional testing time and the limited research available has generally shown that there is a likelihood of increased scores with additional testing time for all takers, not just those with ADA-recognized disabilities1.

The hidden cost, then, is that some non-ADA disabled examinees will pass-and thus become eligible for your credential-who may not have otherwise.

A second hidden cost is the loss of your "trust factor" - the belief that those who pass your credentialing exam have all met the same standard. We know that credentialing organizations use an examination as a means of winnowing out those who are competent to practice a profession from those who don't "measure up." The granting of a professional credential by a certifying authority means that the individual meets a professionally established level of knowledge and competence held against a standard common to the profession. The hidden cost of providing ADA accommodations to those who do not meet the ADA requirement is the erosion of the "trust factor" for your examination and ultimately for the value of your professional credential.

Is the trade-off worth it? Organizations which grant accommodations to all or most applicants without subjecting them to a rigorous ADA-based review are risking a great deal for little in return. They hope to minimize the threat of a legal complaint or to avoid the cost of expert review, but in reality they are subjecting their exam and their professional credential to a much greater-and more expensive-hazard, the certainty of degrading the meaning and value of their credential in the professional community.

How can an organization protect its examination and its credential against these hidden costs?

Do Your Homework Assess your current accommodations policy to determine its effectiveness. Does your current published information clearly explain what information ADA applicants should submit? Do your internal procedures deliver the level of compliance you need?

Build A Strong Foundation Develop comprehensive and easy to follow internal procedures. Train staff. Establish relationships with appropriate expert practitioners, such as physicians, psychologists, etc., so that expertise is readily available when you need it.

Ensure that all forms of external (and internal) communication - such as procedure manuals, publications, websites and help lines - reflect the same content and that all directions and requirements are clear. Requirements and deadlines for applicants seeking accommodations must be equal for all test applicants - you may need to revise your overall testing schedule to allow for appropriate review and response time.

Work toward consistent, clear, defensible decisions that reflect ADA requirements and established case law. Will you need to "grandfather in" repeat test-takers or applicants previously granted accommodations as you enhance your standards?

Prepare in advance for any possible disputes and litigation. Be sure that your policies and procedures adequately address the major issues of documentation and that they properly protect applicant confidentiality.

You will more successfully protect your organization and your credential by applying professionally recognized standards of diagnosis and the legal standard of disability. Following a model of review designed to foster defensible decision-making is the least expensive and most cost-effective approach to Americans with Disabilities Act compliance. Best practices may seem to be costly until the true costs must be paid.

This article, written by Shelby Keiser, president of Keiser Consulting, appeared originally in NOCA News, November, 2004.

1Zuriff, G.E., Extra Examination Time for Students With Learning Disabilities: An Examination of the Maximum Potential Thesis, Applied Measurement in Education 13(1) 99-117, 2000.


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