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Briefing Paper: Reauthorization of the Higher Education Act (HEA): The Implications for Increasing the Employment of People with Disabilities

Tuesday, May 19, 2015

HEA Reauthorization Policy Brief Highlights

  • Approximately 11 percent of undergraduates have a disability – 2 million students.
  • Students with disabilities are attending postsecondary education at rates similar to nondisabled students, but their completion rates are much lower (only 34 percent finish a four-year degree in eight years), indicating the possibility of inadequate or inappropriate supports and services.
  • While currently only 32 percent of working-age people with disabilities are employed, those with a college education are more likely to be employed and are earning a higher average wage than those without a college education.
  • Most of the disability-related guidance and support to campuses is coming from the U.S. Department of Education’s Office for Civil Rights and Office of Special Education and Rehabilitative Services/Office of Special Education Programs (OSEP) rather than more appropriately coming from the Office of Postsecondary Education (OPE).
  • OPE has focused its disability-related technical assistance on 47 schools receiving specific grants related to services for students with disabilities, instead of finding ways to reach more of the 5,827 U.S. campuses serving students with disabilities.
  • Students are not provided adequate guidance regarding the interaction between vocational rehabilitation and traditional forms of financial aid, and do not have access to reliable information about the interplay among these financial resources and other benefits programs upon which students with disabilities may rely. Additionally, financial aid offices rarely understand the need to include disability-related costs as a “cost of attendance” when determining eligibility for financial aid. 
  • Several provisions of the Higher Education Opportunity Act (HEOA) of 2008 regarding Universal Design for Learning in teacher education, reporting percentages of disabled students in College Navigator, and inclusion for students with intellectual disabilities have been implemented, and some have had a positive impact beyond the original intent of Congress.
  • HEOA created the Advisory Commission on Accessible Instructional Materials (AIM Commission) that made 18 robust recommendations – however none have been implemented.
  • NCD recommends that Congress exercises oversight of federal agency implementation of prioritized AIM Commission recommendations, requires creation of an interagency working group (with Secretarial level participants ) to diminish complex processes, possible duplication of efforts, and funds key demonstration projects, a national technical assistance center, and large-scale research on higher education and students with disabilities.
  • NCD recommends that the U.S. Department of Education and other appropriate federal entities (e.g., U.S. Department of Justice; U.S. Access Board) address legal and policy guidance on access; and that the Department of Education re-establishes an intra-agency/internal Secretarial-level working group, including higher education graduates, current students with disabilities and other stakeholders to oversee requirements and progress in disability and higher education; and aggressively and creatively builds the  Office of Postsecondary Education’s (OPE) capacity to address disability issues.


The National Council on Disability (NCD) issues this policy brief and makes substantive recommendations for the impending Congressional reauthorization of the Higher Education Act (HEA).[1] NCD urges policymakers to use the reauthorization as an opportunity to fully fund disability initiatives that were authorized but never implemented in the 2008 Higher Education Opportunity Act (HEOA) as well as maintain the disability provisions in HEOA that were operationalized and have proven successful. NCD further urges that policymakers to resolve the immediate need to create a robust system for gathering information that is critical to improving higher education outcomes for students with disabilities. There are significant gaps in the information available about the prevalence of disability among students in higher education, their access to academics and disability services, and outcomes for these students. Currently, the data are described as piecemeal and limited. Some figures are based on reports from disability services offices, students who had special education IEPs in high school, or demographic statistics reported in isolation, without any data related to experiences of college as students with disabilities. Finally, policymakers should include provisions regarding Universal Design for Learning (UDL) and interagency collaboration and grants in the reauthorization.

With the caveat of the aforementioned notes on gaps in available data, the existing figures show that students with disabilities are a considerable, but often-overlooked component of the evolving diversity of higher education, with at least 11 percent of undergraduates reporting a disability[2] (approximately 2 million students).[3] However, these students experience significant barriers in preparing for college, transitioning to college services, and moving through degree programs into their careers. A college education is a critical component in addressing the unacceptably high rate of unemployment and underemployment of people with disabilities, yet only 34 percent of students with disabilities are completing their degrees,[4] and very little research is available to guide professionals who wish to improve students’ experiences and outcomes. A small sampling of barriers students with disabilities may experience in higher education includes:

  • Provision is low for academic accommodation that students with disabilities may need. Where 87 percent of students with learning disabilities had academic accommodations and supports in K-12, only 19 percent continue getting support at the college level.[5
  • Students with disabilities who receive services through the Individuals with Disabilities in Education Act (IDEA) often receive a “special” diploma which is not the same as an accredited high school diploma. This means many students will be foreclosed from accessing financial aid[6] and from attending many postsecondary technical and vocational programs that require a regular high school diploma.[7]
  • Even 25 years after the Americans with Disabilities Act (ADA), many parts of college campuses remain architecturally inaccessible to students with disabilities.  Boston College spent millions of dollars on campus renovations, but may have made the campus less accessible in the process, which is now under investigation by the Office for Civil Rights.[8] At other campuses, students, faculty, and administrators are at odds about how “access” and “compliance” should be defined, or how to make historical buildings accessible.[9]
  • Many universities fail to consider whether or not their educational materials are accessible to students with a variety of sensory and other print disabilities, leaving students in a position of seeking access assistance after a course has already begun. In a recent example, the National Association of the Deaf has filed suit against Harvard University and MIT for not captioning public educational materials.[10]
  • Many students with disabilities rely on benefits programs that are critical to their very survival, not to mention success in an academic environment. These other sources of support may include SSI, SSDI, Medicaid, Medicaid waivers, Section 8 housing vouchers, and food stamps; yet students often report that there is little or no communication or coordination among these agencies and the financial aid offices where they attend college or with their VR counselor. Students often have no one to advise them appropriately about the interaction among these programs and the various forms of financial aid they may access including VR funding, subsidized and unsubsidized loans, Pell grants, scholarships and work-study.[11]
  • Many other issues that are beyond the scope of this paper (e.g., data on student depression,[12] sexual assaults[13] and violence on campus, lack of information about accommodations in community services). Yet, such issues may reflect the overall limited major research on whether campuses and/or community resources are even accessible to students with disabilities.[14]

It is critical to close the research gap on education access and accommodation issues faced by postsecondary student with disabilities to properly inform budget and policy decision making. The disability-related provisions of HEOA that were funded have made an impact on student success, access, and employment, but the majority of HEOA’s disability-related requirements remain unfunded. At the federal level, little coordination or communication exists around disability and higher education issues. In the wake of HEA reauthorization, NCD calls upon Congress to maintain and fully fund the disability provisions of HEOA, to expand research on higher education of students with disabilities, and to mandate better interagency collaboration on postsecondary disability issues.

General Background

With the current reauthorization of HEA, Congress has an opportunity to improve postsecondary educational access and opportunities for students with disabilities, while also strengthening the U.S. workforce through better preparation of all people, including people with disabilities, for professional highly skilled employment. While there does not exist any large-scale studies investigating students’ academic and disability-related experiences in higher education, researchers do know that the proportion of college undergraduates with disabilities has increased from approximately 6 percent in 1999[15] to 11 percent of all college students in 2012.[16] That 11 percent represents a significant proportion of our country’s future engineers, doctors, computer scientists, teachers, lawyers, and business owners.[17] In 2013, the National Governors Association raised this issue, noting that supporting education and employment for people with disabilities would likely boost the U.S. economy, and more inclusive companies have already been reaping benefits through increased productivity and earnings.[18]

Looking to the future, the number of college students with disabilities will likely continue to rise, making this issue more urgent. Further increases may partially result from the impact of the Individuals with Disabilities Education Act (IDEA) (PL 94-142)[19] and returning veterans. IDEA guarantees eligible students with disabilities will receive a free and appropriate public education through completion of high school.[20] Around 47 percent of high school students receiving special education[21] and related services hope to attend college, and an additional 40 percent want to attend postsecondary vocational training programs.[22] Indeed, 60 percent of special education students do attend some kind of postsecondary educational program after high school, a rate only slightly lower than nondisabled peers (at 67 percent).[23] However, despite attending postsecondary education at rates just ten percent less than nondisabled students, students with disabilities fail to complete postsecondary education at much higher rates than nondisabled peers, as discussed below. It remains unknown whether college attendance rates are similar for the increasing numbers of students with disabilities who have 504 plans[24] instead of Individualized Education Programs (IEPs). Students with 504 plans are still covered under Federal nondiscrimination laws, but only recently have campus disability services offices begun including students with 504 plans as “students with disabilities” who are eligible for services.[25]

For other students with disabilities, accessing higher education is foreclosed or hampered by a lack of access to financial aid. For example, students with Specific Learning Disabilities made up 41 percent of all students served by IDEA in 2011, and numbered more than 2.2 million. Among them, only 68 percent graduated with a regular diploma, meaning approximately 704,000 students with learning disabilities may have been ineligible for federal financial aid. In addition to higher education, these students may also be ineligible for a variety of post-secondary educational, vocational and training programs. Students with intellectual or developmental disabilities in particular are either unlikely to receive a diploma or are likely to receive an unaccredited diploma.[26]

In addition to more students with disabilities going from high school to college in the last 40 years since initial passage of IDEA, returning veterans with disabilities are attending college in greater numbers, and students with intellectual and developmental disabilities are now also taking advantage of inclusive higher education programs and auditing options.[27] Disability services offices have also expanded their definition of who is eligible to be served since the language of the 2008 ADA Amendments Act helped clarify who is entitled to reasonable accommodations.[28]

After arriving at college and identifying as a student with a disability, many students remain unprepared to manage their own disability accommodations and independently seek out and work with college disability services offices, even if they had special education transition planning in high school.[29] Provisions in Section 504 of the 1973 Rehabilitation Act[30] and the amended Americans with Disabilities Act (ADA)[31] address discrimination on the basis of disability and require campuses to provide reasonable disability accommodations. But IDEA does not apply to college students, which means many intensive individualized services readily available in high school, like tutoring or speech therapy, are not available.[32]

Further, the names of colleges’ disability services offices and the types of assistance they offer vary greatly from campus to campus. The names of some offices do not readily identify what services they provide. Also, there are no degree or certification programs for disability services professionals. Many of the disability services offices are under-funded and under-staffed, so provision of accommodations and services vary considerably at each campus.[33] Students with disabilities and their families may also have difficulty negotiating the maze of financial aid, which can be far more complex for them than for nondisabled students. For example, student grants and loans must be braided with Social Security and Vocational Rehabilitation funding and students with disabilities often have substantial out-of-pocket expenses related to their disabilities.[34] All of these issues may partly explain why students with disabilities who attend college have low completion rates – only 34 percent of students with disabilities are able to complete a four-year degree within eight years, compared to 51.2 percent of the general population.[35] The reauthorization provides an opportunity to begin to address the current status of no degree and formal training programs, licensure or certification systems for disability services professionals, despite their critical role in providing services and accommodations, working with faculty and staff, and ensuring compliance with federal laws.[36

A college degree can make a real difference in the work life of students with disabilities. On average, only one-third of working-age people with disabilities (32 percent) are employed compared to over two-thirds of people without disabilities (72.7 percent).[37] However, in one research sample, 83 percent of former special education students with a postsecondary education were working compared with only 54 percent of peers (who received special education and related services) whose highest level of education was high school.[38]

Four key efforts could improve higher education outcomes for students with disabilities. First, an emphasis on innovation is needed. Several colleges have demonstrated what is possible in this regard by working on their own to enhance retention and employability of students with disabilities. For example, the University of Georgia and the Georgia Institute of Technology have created a virtual reality mentoring program for students with disabilities interested in STEM fields.[39] California State University, Fullerton has developed a course to develop career skills,[40] and Western Nevada College has worked with state agencies to create a job placement and retention program.[41] Colleges in general are improving access to study abroad programs, with 5.1 percent of all study abroad students reporting a disability (up from 0.1 percent the previous year),[42] although this general trend is no comfort in the cases of stark exception. These are positive examples that could be scaled up to make systemic improvements in higher education with the provision of a national technical assistance center and federal funding for research.

Second, a comprehensive approach to research is needed. Most of what is known about students with disabilities is based on the National Longitudinal Transition Study (NLTS-2), which only looks at students with disabilities who received special education services in high school. Other research is based on statistical data reported by disability services offices instead of students[43] or demographic information gathered for the study of factors unrelated to disability (e.g., financial aid).[44] Disability services offices vary considerably in the data they collect and how they collect it[45] and many students with disabilities do not use disability services at all. One large-scale study in Canada found that 90 percent of students with disabilities in Canada were not using disability services offices,[46] and a U.S. study suggested that two-thirds of special education students do not consider themselves “disabled” after high school.[47] This means that the experiences of large scores of students with disabilities would not be included in statistical data reported by disability services offices, thus limiting the utility of the data available through them.

Third, there is a lack of proportional attention to postsecondary disability issues at the federal level, given that college students with disabilities are an increasing proportion of students in higher education. The U.S. General Accounting Office (GAO) has called for greater attention to disability issues in higher education, more interagency collaboration at the federal level, greater disability-related technical assistance to students and campuses, and a stronger role for the Office of Postsecondary Education (OPE). In their report, GAO noted that the U.S. Department of Education’s Office for Civil Rights (OCR) and Office of Special Education and Rehabilitative Services (OSERS)/Office of Special Education Programs (OSEP) provide most of the disability-related guidance and support to campuses. Conversely, OPE, the primary Office responsible for administering postsecondary education programs and support,  claims a lack of expertise, limiting its disability-related technical support to the needs of 47 campuses with OPE grants for students with disabilities, instead of finding ways to address the needs of all 5,827 Title IV campuses in the U.S. that have students with disabilities.[48] In addition, OPE is not reporting how eight TRIO[49] programs are serving students with disabilities in any program except the Student Support Services program TRIO’s eight programs are designed to identify and provide services to low-income students, first-generation college students, and students with disabilities.[50] Reports on other TRIO programs, including the McNair Achievement Program, Talent Search, and Upward Bound programs, also do not contain any information disaggregated by disability status. HEOA attempted to address some of these concerns, but the necessary collaboration and major cross-disability initiatives remain unfunded and unimplemented, as described below.

Fourth, students with disabilities and their families need to be provided with relevant information and meaningful assistance navigating the mazes of financial aid and federal benefits. While financial tools such as the recently passed ABLE Act and existing work incentives through Social Security may make it possible for more students with disabilities to access higher education and plan for a future of financial independence, it can be difficult to figure out through which door to go. Additionally, these programs often interact with financial aid in complex ways that many individuals and families find confusing and discouraging.

Limited Impact of HEOA on Disability Issues in Higher Education

This section describes the limited impact of HEOA on disability issues in higher education. When provisions of HEOA were funded and implemented, the results on higher education inclusion of students with disabilities, universal design elements, postsecondary education statistics, and the work of the prescribed advisory committee regarding accessible instructional materials were noteworthy. Some of the positive outcomes for the higher education system as well as transitions from higher education to employment for pockets of individuals with disabilities are described in the subsections which follow.

Students with intellectual disabilities are included in higher education more than in the past. Throughout history, students with intellectual disabilities were traditionally excluded from higher education. However, commendably, HEOA focused on college-based transition programs for high school students up to age 21 who have intellectual disabilities[51] it funded model transition programs as well as a national coordinating center to oversee implementation of such programs, provide program evaluation, and to set national standards for future inclusive transition programs.[52] There are currently 27 programs funded by the Transition and Postsecondary Education Program (TPSID) grantees on 44 college and university campuses (some are consortia with multiple locations), and the National Coordinating Center is based at Think College in Boston, Massachusetts.[53] These programs have made an impressive difference. Of the 838 students in TPSID programs in 2012-2013, 36 percent had paid jobs, and 82 percent of those jobs were paid at or above the minimum wage even though 42 percent of the students had never had a paid job before entering their college program.[54] These innovative programs are working, and making demonstrable improvements in the employability of individuals with significant disabilities; funding should be provided to continue expanding and replicating these programs. And while these programs should receive praise for their successes, it is important to note that 53% of students in these programs privately paid the cost of tuition in 2011-2012. Many families cannot afford this expense, and increasing access to financial assistance for students who would benefit from these programs is likewise critical.[55] The inclusive higher education movement continues to grow, with the number of campus-based programs for students with intellectual disabilities more than doubling from before HEOA to the present time, from 113 in 2006 to 233 in 2015.[56] Since the higher education programs tend to vary considerably as it pertains to advising, access to courses, and employment training, the National Coordinating Center has also established credentials for these programs to continue the trend toward greater inclusion, better education, and improved employment outcomes.[57]

HEOA defined Universal Design for Learning (UDL) and encouraged teacher education programs to include UDL in their curricula. UDL advocates for students to have a variety of ways to learn and to be more engaged in their learning.[58] As students with disabilities enter more rigorous inclusive courses, UDL is one way to be sure their needs are addressed. Just as it is cheaper, easier, and more aesthetically pleasing to design an accessible building rather than adding access features later, UDL gives teachers strategies for designing curricula for diverse learners from the get-go, instead of continually adjusting instruction for each type of “different” learner (including those with disabilities).[59] HEOA required teacher education programs to address UDL and report on their progress when applying for grants or making annual report cards about courses.[60]

Despite some initial confusion about definitions of UDL and resistance to modeling it in higher education courses,[61] the National Center on Universal Design for Learning has created a “UDL on Campus” website to increase the use and understanding of UDL in higher education.[62] Even though HEOA targeted teacher education programs, many colleges and universities are implementing UDL on a campus-wide basis.[63] UDL improves instruction for all learners (not only those with disabilities). It also reduces the need for individualized disability services and accommodations, since it changes instruction to make it more accessible for everyone (e.g., all students may have digitized print materials and use e-books instead of only students with visual impairments or dyslexia having access to these as “special” services).[64] So even though HEOA’s requirement was for teacher education programs, it has the potential to reduce the workload of disability services offices and to increase learning and retention for all students at the higher education level. One way to increase the campus-wide application of UDL would be for the Department of Education (ED) to provide that if a campus activity is funded by an ED grant, the cost to make the program accessible to employees and students who are participating in it be an indirect cost that could be funded by the grant money itself.

Disability statistics are included in the Integrated Postsecondary Education Data System (IPEDS). Prior to 2008, colleges were not required to report the percentage of students using disability services. HEOA required all colleges and universities to report the percentage of undergraduates registered with disability services,[65] and this information is included in the College Navigator website.[66] This is a good way for colleges to document how many students are using disability services on campus, which can affect determinations of disability services staffing and funding levels.[67] Students and their families may also use this data to compare campuses. The drawback is that the website currently provides minimal information and there has been no research to determine its use or efficacy for this purpose.

The U.S. Department of Education (ED) created an Advisory Commission on Accessible Instructional Materials in Postsecondary Education for Students with Disabilities (AIM Commission). The purpose of the AIM Commission was to advise the Secretary of Education and Congress on policies to improve the accessibility of college and university instructional materials for students with dyslexia, visual impairments, and other print-related disabilities.[68] The AIM Commission met for 14 months and published its final report on December 6, 2011 with 18 recommendations for campuses, businesses, and government agencies.[69] The report noted that even between passage of HEOA and the issuance of the commission’s report, access to educational materials had improved somewhat, but students, faculty, and staff with disabilities continued to experience significant barriers for receiving timely, cost-effective instructional materials.[70] The Commission made several recommendations to which NCD calls attention in this paper, including that Congress authorize funding to establish accessible instructional materials guidelines;[71] discretionary demonstration of system-wide AIM best practice models;[72] and that working groups internal to ED and external or cross agency be involved in developing a unified and consistent approach to federal initiatives.[73] To benefit students in transition from secondary school to college, during their campus matriculation, and into the workplace after completion of their studies the agency also was recommended to work routinely with other federal agencies funded to address accessibility in postsecondary institutions.[74] As of the writing of this report, none of the Commission’s recommendations have been implemented.[75]

The Technology, Education, and Copyright Harmonization (TEACH) Act (H.R. 3505, S. 2060), introduced in the last Congress, would have addressed many AIM recommendations[76] by reinforcing existing laws, and by making innovative digital instruction (e.g., distance learning software, “flipped classroom” lectures, and digitized textbooks) accessible to people with disabilities. However, despite its bipartisan base of support in both chambers and its endorsement by many national disability rights groups, this bill was not taken up in the 113th Congress and has yet to be reintroduced in this Congress.[77]  

Despite the limited provisions that were implemented, several disability-related HEOA provisions that could make a real difference for students with disabilities remain unfunded and unimplemented. The provisions involve funding needed for accessible instructional materials and a technical assistance center, as explained below.

Demonstration programs to improve campuses and improve access to instructional materials. HEOA replaced “Demonstration Projects to Ensure Students with Disabilities Receive a Quality Higher Education” with the “Demonstration Projects to Support Postsecondary Faculty, Staff, and Administrators in Educating Students with Disabilities” program.[78] At least two grants for this program were to focus on students with learning disabilities; other demonstration projects would improve the capability of higher education to provide disability services, to enhance accessibility of distance education programs, and to promote disability-related careers.[79] HEOA also called for model demonstration projects focused on access to postsecondary instructional materials.[80] Neither of these programs has received funding since the passage of HEOA, even after the AIM Commission specifically requested funding for demonstration projects in its 2011 final report.[81]

A National Technical Assistance Center for all students with disabilities regardless of type of disability, age, or level of education.As OCR notes, “a big factor in [students’] successful transition from high school to postsecondary education is accurate knowledge.”[82] One example of the kind of information that is needed is accurate information regarding the impact of disability-related expenses on financial aid eligibility, as well the interaction of financial aid with other benefits programs often accessed by students with disabilities. Additionally, students must have information about their right to accommodations when they are engaged in non-academic aspects of higher education such as internships, clinical programs, study-abroad programs and extracurricular activities. HEOA authorized a National Center for Information and Technical Support for Postsecondary Students with Disabilities, intended to provide assistance to students and their families, as well as institutions of higher education.[83] The center has not been funded, even though HEOA required the Secretary of Education to issue regular biannual reports to Congress about the implementation and success of the center beginning in 2011.[84] In the absence of such a center, some organizations have created information about higher education for students with disabilities, but these are often limited in scope, focusing on one type of disability or only on young college students up to age 25. There are no centers that provide a central clearinghouse of information related to all disabilities and all aspects of disability and higher education.  There is no organization doing large-scale outreach and technical assistance to faculty teaching students who have disabilities. A national center could create one centralized resource point for students, parents, and professionals, while bringing together groups working in the field, developing materials to address emerging needs, and conducting outreach to ensure stakeholders have access to its resources.

NCD Recommendations for the Current Reauthorization of HEA

It is clear that provisions of HEOA had a far-reaching impact when they were funded. Further, positive outcomes often extended beyond the target populations, such as the way UDL provisions for teacher education programs expanded UDL programs across entire campuses in multiple states. Likewise, new programs for students with intellectual disabilities have been leading to better employment rates and wages for this population. As described above, funded HEOA provisions have made a difference for students with disabilities. Other authorized benefits have never been funded and recommendations of the Government Accountability Office and the AIM Commission to Congress and federal agencies have never been implemented.

Disability issues are not merely academic but also economic. If students with disabilities are not fully accessing or completing higher education at acceptable rates comparable to nondisabled students, the U.S. is losing or under-employing a significant group of potential workers and professionals. Investments in currently unfunded HEOA programs to improve educational and employment outcomes comes at a much lower cost than the corresponding increase in Social Security payments that likely result from a lack of access to higher education and postsecondary supports by students with disabilities. It is for these reasons that NCD makes the following recommendations:

NCD Recommendations to Congress

  1. Fully fund HEOA’s National Technical Assistance Center and innovative demonstration projects with annual reporting requirements from the Secretary of Education. This is consistent with several recommendations from the GAO and AIM Commission to begin coordinating postsecondary disability-related initiatives and information. The demonstration projects from the last reauthorization already have a focus on employment and vocational development for students with disabilities, among other priorities, and these should carry into the current reauthorization, and this time be funded. 
  2. Require the U.S. Department of Education to establish and administer a demonstration project focused on improved quality and consistency of higher education student disability services, with the goal of improving outcomes for students with disabilities, mandating (a) participation of OPE, OCR, OSERS/OSEP, and the Rehabilitation Services Agency (RSA), and (b) partnership with the Department of Health and Human Services / Administration on Community Living/National Institute on Disability, Independent Living, and Rehabilitation Research. As noted above, no licensure requirement exists for student disability services personnel, and thus services at the college level may vary considerably and not be concomitant with college rankings or consistent for students with all types of disabilities. Student disability services personnel must be prepared not only to assist students with accessing needed accommodations on campus, they must also be prepared to assist students in navigating the complex web of financial aid and benefits systems that may provide necessary services and supports to students with disabilities. Demonstration projects to improve disability services could investigate service delivery approaches that may lead to better outcomes for students with disabilities, as well as areas of professional development needs for disability services providers. These could lay the groundwork for a future licensure system. 
  3. Include improving the quality of financial aid services and information provided to students with disabilities and their families in any initiatives aimed at improving financial aid services generally. The 114th Congress held several hearings that highlighted the unnecessary complexity of the financial aid system and the lack of useful information provided to students and their families. This problem is even more acute for students with disabilities, whose disability-related expenses may significantly increase the cost of attending college or whose access to important government benefits such as Social Security and Medicaid might be impacted by their financial aid decisions. Financial aid offices must be better prepared to provide timely and accurate information to meet the unique needs of students with disabilities and their families, including information about the interaction between financial aid and disability benefits programs. 
  4. Create requirements and funding for large-scale longitudinal data reporting.

    1. Fund a longitudinal National Postsecondary to Employment Transition Study through the U.S. Department of Education Office of Postsecondary Education (OPE) that would follow college students with disabilities through eight years after college graduation. Protocols for such a study could be similar to OSERS/OSEP’s National Longitudinal Transition Study established by Congress to track students with disabilities transitioning out of high school; or the National Center on Educational Statistics’ National Longitudinal Study of 1972 that compared middle and high school students from 1980, 1988, and 2009. These would include students with different kinds of disabilities, students who are not using disability services, and other students who acquire disabilities during college. With large-scale data, recommendations can be made about adoption of best practices for services, retention and degree completion. Further, with reliable data, Congress should consider scaling up strategies that lead to more effective secondary school transition services and to post-college employment of students with disabilities during this reauthorization.
    2. Require OPE’s TRIO programs to issue annual reports disaggregated by disability status. HEA can and should hold the Department of Education / OPE accountable for including students with disabilities in its programming; require the development of expertise on disability in higher education; and report its progress to Congress on a specific schedule. 
  5. Prioritize and address select congressional recommendations of the AIM Commission report. Specifically, NCD suggests Congress address the AIM Commission’s recommendations that include authorizing legal and policy guidance by the U.S. Access Board; appropriating campus-wide demonstration project funds through the U.S. Department of Education; and requiring the development of ADA and Rehabilitation Act guidance developed jointly by the U.S. Departments of Justice and Education. 
  6. The innovative Transition and Postsecondary Education Program (TPSID) programs are working and are improving the employability of individuals with significant disabilities. Funding should be provided to continue expanding and replicating these programs. Additionally, students wishing to participate in these programs should have access to financial aid and housing options just as those options would be available to other students looking to explore post-secondary opportunities for which they are qualified.

NCD Recommendations to the U.S. Department of Education (ED) and other federal agencies

  1. Appropriate federal agencies should prioritize and address relevant recommendations of the AIM Commission report.

    1. Internal collaboration – Address the recommendation that ED improve intra-agency collaboration in order to meet the postsecondary education needs of students with disabilities. Re-establish ED’s intra-agency working group. Participants should include managerial level staff who will oversee all HEA disability-related requirements and the annual reporting of results for the Secretary’s HEA Implementation report to Congress. 
    2. Disability documentation guidance – The U.S. Departments of Justice and ED should determine what guidance is needed and then develop guidance about ADA Titles II and III and Rehabilitation Act Section 504 for disability documentation for postsecondary education and training. 
  2. The U.S. Department of Education should use existing grant programs to support students with disabilities.On May 11, 2015, ED announced its final priorities for development and validation grants under the First in the World program, which is designed to “support the development, replication, and dissemination of innovative solutions and evidence for what works in addressing persistent and widespread challenges in postsecondary education for students who are at risk for not persisting in and completing postsecondary programs.”[85] In the notices, ED notes that students with disabilities are considered both “at-risk” for not persisting in or completing higher education and also “high-needs” students. The validation grant notice includes “Absolute Priority 3: Improving Student Support Services.”[86] Although it remains to be seen whether applicants may address disability student services directly, the grant program does present an excellent opportunity to address some of the persistent problems identified in this brief that may be preventing students with disabilities from achieving the same level of success in higher education as their non-disabled peers. 
  3. The U.S. Department of Education should allow higher education grantees to use a negotiated amount of their higher education grants to cover the indirect costs of making their programs accessible to employees, students, and other participants. Since providing accommodations and making grant activities accessible are costs of doing business, these activities should be considered “indirect costs” that can be paid for directly out of the grant funding. This would encourage grantees to make sure that grant-funded projects are carried out in work environments that are accessible to individuals employed using grant funds as well as to individuals who participate in the grant-funded activities at all levels. 
  4. Build capacity to address OPE’s concerns about being able to address disability in higher education. NCD encourages the U.S. Department of Education to develop aggressive and creative approaches to remedy this problem, while also contributing to increased education and employment of students with disabilities. For example, OPE could offer internships, postdoctoral fellowships, and job training programs to undergraduate and graduate students interested in higher education and disability, learning about disability first-hand while also improving the postsecondary education system. The intra-agency working group could also fund research studies on an ad hoc basis, addressing short-term critical needs (e.g., addressing recent media attention on whether autism and mental illness are associated with campus violence, or whether campus renovations may negatively affect disability access). OPE must become better educated about disability issues in higher education and take responsibility for implementing HEA mandates and requesting appropriations to that end. 
  5. The U.S. Department of Education should take steps to simplify the administration of the provisions authorized in HEOA that allow ID/DD students who did not receive a traditional diploma to receive federal student aid and access work study options. Students who do not receive an accredited diploma are ineligible to receive federal financial aid for any postsecondary educational opportunities, including career and technical certificates in the occupations and trades—such as childcare, auto repair, culinary arts. This practice locks students without a regular high school diploma out of almost any opportunity for workforce training that will allow them to build an independent life outside of poverty. While it is possible for states to establish that their “special” diploma meets criteria that would allow these students to access financial aid, to date only a single state has done so.[87] ED should work with state departments of education to enable students receiving a “special” diploma to access financial aid.

These NCD recommendations for Congress, the U.S. Department of Education, and other federal agencies are made to provide college students with disabilities in the current and future generations’ equal access to the knowledge and skills U.S. higher education has to offer. Barriers must be eliminated and various pathways to self-determination and economic improvement must be available to each person equally. In this, the 25th anniversary year of the ADA, it is vital that campuses and programs at colleges and universities go beyond mere compliance with federal laws, and are open and welcoming to all students with disabilities so that they are prepared to enter and strengthen a diverse 21st century workforce.

[1]Higher Education Opportunity Act, §762.

[2] U.S. Government Accountability Office (GAO), “Higher Education and Disability: Education Needs a Coordinated Approach to Improve its Assistance to Schools in Supporting Students,”(Washington, DC: Author: 2009), 8, accessed April 10, 2015. 

[3] NCES reported 18.1 million undergraduates; the 2 million figure is 11 percent of this total. Some comparisons with state data have also suggested these numbers may be under-representing actual totals; U.S. Department of Education, Institute of Education Sciences (IES), National Center for Education Statistics (NCES), “Fast Facts: Enrollment,” accessed March 22, 2015,; The latest figures for 1999-2000 suggest approximately 7 percent of graduate students have disabilities,” U.S. Department of Education, IES, NCES, accessed March 22, 2015,  Numbers of faculty and staff with disabilities are unknown.

[4] Newman et al., The Post-High School Outcomes of Students with Disabilities, quoted in Betsy Brand, Andrew Valent, and Louis Danielson, Improving College and Career Readiness for Students with Disabilities (Washington, DC: American Institutes for Research, 2013), 3, accessed March 22, 2015,

[5] Dennis Pierce, “How Colleges Can Better Serve Students with Learning Disabilities,” Campus Technology, accessed December 18, 2014,

[6] Betsy Hammond, “Oregon special education graduates declared eligible for federal financial aid,” The Oregonian, April 10 2014, accessed May 12, 2015,

[7] National Council on Disability, “National Disability Policy: A Progress Report,” October 2014, accessed May 15, 2015,/progress_reports/10312014.

[8] Associated Press, “Boston College Under Investigation Over Access for People with Disabilities,” Huffington Post, accessed February 18, 2015,

[9] Charlie Bartlett, “Morris Buildings Cause Accessibility Debate,” Minnesota Daily, February 24, 2015,; Megan Kallstrom, Sariel Friedman, and Jenna Beers, “Access Denied: Exploring the Experiences of Physically Disabled Columbians on Campus,”Columbia Spectator, February 25, 2015, accessed May 14, 2015,; Vivian Wang, “Students in Wheelchairs Find Campus Inaccessible,” Yale Daily News, February 24, 2015, accessed May 15, 2015,

[10] National Association of the Deaf, “NAD Sues Harvard and MIT for Discrimination in Content,” February 12, 2015,

[11] Rebecca Moore, “Students with Disabilities Face Financial Aid Barriers,” September 15, 2003, accessed May 12, 2015. This publication, a product of the NCD Youth Advisory Committee, is available in an archived HTML format only. (Archived HTML)

[12] Jessica Glenza, “More US College Freshmen ‘Depressed’ than at Any Time in the Past 30 Years,” The Guardian, February 5, 2015, accessed April 16, 2015,

[13] Azmat Khan, “The Hidden Victims of Campus Sexual Assault: Students with Disabilities,” Aljazeera America, February 12, 2015, accessed April 17, 2015,

[14] Jill Harkins, “Study: Increased Demand, Inadequate Resources for College Mental Health Services,” Pittsburgh Post-Gazette, February 7, 2015, accessed April 16, 2015,

[15] Statistics from the Postsecondary Education Quick Information System (PEQIS).  Disabilities, Opportunities, Internetworking, and Technology (DO-IT), “Statistics,” DO-IT, University of Washington, accessed March 22, 2015,

[16] U.S. Department of Education, IES, NCES, Statistics from the National Postsecondary Student Aid Survey, “Fast Facts: Students with Disabilities,” accessed March 22, 2015,

[17] Wendy S, Harbour, “How Can More of You Get Here?” in Thomas Hehir and Laura A. Schifter, How Did You Get Here? Students with Disabilities and Their Journeys to Harvard, (Cambridge, Harvard Education Press, 2015), 216.

[18] Lauren Stewart, Elise Shanbacker, & Meghan Wills, A Better Bottom Line: Employing People with Disabilities: Blueprint for Governors, (Washington, DC: National Governors Association, 2013), 6-8,

[19] Individuals with Disabilities Education Improvement Act of 2004 (IDEA), 20 U.S.C § 1400 et seq. (2004).

[20] A free appropriate public education (FAPE) under IDEA applies to all students between ages 3 and 21, inclusive, or their graduation from high school (whichever happens first). IDEA 2004 Regulations, §300.101(a).  

[21] When this document refers to “students in special education,” this means students with Individualized Education Programs (IEPs) meeting eligibility requirements for and receiving special education and related services under the provisions of IDEA.  It does not include students with 504 Plans, even though they have disabilities and may receive some services or accommodations through special education and related service providers. (Please also see Endnotes 22 and 24 for more on IEPs and 504 plans.)

[22] Reneé Cameto, Phyllis Levine, and Mary Wagner, Transition Planning for Students with Disabilities: A Special Topic Report of Findings from the National Longitudinal Transition Study-2 (NLTS2) (Menlo Park, CA: SRI International, 2004), 2-2, accessed March 22, 2015,; Each student with a disability who is found eligible for special education and related services must have an Individualized Education Programs (IEP), which in brief is a prescribed written statement developed, reviewed, and revised in a team meeting about his/her service and support needs. Among other specifications, beginning no later than at the first IEP in effect when the individual turns age 16 ( or younger if the IEP team determines it appropriate), the student also must have secondary school transition assessments and planning for post-high school life (including training, any postsecondary education, employment, and where appropriate, independent living skills). IDEA 2004 Regulations, §300.320.

[23] Lynn Newman, et al., The Post-High School Outcomes of Young Adults with Disabilities Up to 8 Years After High School. A Report from the NLTS2 (Menlo Park, CA: SRI International, 2011),16, accessed March 22, 2015,

[24] 504 Plans are for students who have disabilities, illnesses, or other conditions that are not significant enough for special education eligibility; they and their parents also do not have due process rights or transition planning options like students with IEPs. Students with 504 Plans are still covered under the Americans with Disabilities Act and Section 504 of the 1973 Rehabilitation Act, as amended and have a right to receive reasonable accommodations and protection from discrimination based on a disability. Understood Editors, “The Difference between IEPs and 504 Plans,” Understood for Learning and Attention Issues, accessed March 22, 2015,

[25] The Association on Higher Education And Disability (AHEAD) guidelines for disability services offices encourage disability services providers to accept 504 Plans as disability documentation in determining eligibility for postsecondary services. Association on Higher Education And Disability, Supporting Accommodations Requests: Guidance on Documentation Practices (Huntersville, NC: Association on Higher Education And Disability, 2012), 6, accessed March 22, 2015,

[26] Generated from 2011-12 IDEA Part B Exiting Data, accessed May 14, 2015,

[27] U.S. Government Accountability Office, Higher Education and Disability, 24-25.

[28] U.S. Equal Employment Opportunity Commission, “Questions and Answers on the Final Rule Implementing the ADA Amendments Act of 2008,” accessed March 22, 2015,

[29] James E. Martin, Juan Portley, and John W. Graham, “Teaching Students with Disabilities Self-Determination Skills to Equalize Access and Increase Opportunities for Postsecondary Educational Success,” in Preparing Students with Disabilities for College Success: A Practical Guide to Transition Planning, eds. Stan F. Shaw, Joseph W. Madaus, and Lyman L. Dukes (Baltimore, MD: Paul H. Brookes Publishing Co., 2010), 37-64; U.S. Government Accountability Office,Higher Education and Disability, 65-83.

[30] Rehabilitation Act, 29 U.S.C. § 701 (1973).

[31] Americans with Disabilities Act, 42 U.S.C. § 12102 (1990), amended by the Americans with Disabilities Amendments Act, Pub. L. No. 110-325 (2008).

[32] Joseph W. Madaus, “Let’s Be Reasonable: Accommodations at the College Level,” in Preparing Students with Disabilities for College Success: A Practical Guide to Transition Planning, eds. Stan F. Shaw, Joseph W. Madaus, and Lyman L. Dukes (Baltimore, MD: Paul H. Brookes Publishing Co., 2010), 37-64.

[33] Wendy S. Harbour, Final Report: The 2008 Biennial AHEAD Survey of Disability Services and Resource Professionals in Higher Education (Huntersville, NC: The Association on Higher Education And Disability, 2008), 37-57; U.S. Government Accountability Office, Higher Education and Disability, 13-19.

[34] Thomas R. Wolanin, “Students with DisabilitiesFinancial Aid Policy Issues,” Journal of Student Financial Aid 35, no. 1 (2005): 17-26. 

[35] Newman et al., The Post-High School Outcomes of Students with Disabilities, as cited in Betsy Brand, Andrew Valent, and Louis Danielson, Improving College and Career Readiness for Students with Disabilities (Washington, DC: American Institutes for Research, 2013), 3, accessed March 22, 2015, Data on rates of graduation may also be flawed if it does not adequately account for students leaving college for significant amounts of time (but graduating later), or students transferring to other campuses to complete their degrees.  Christine M. Keller, “Written Testimony of Christine M. Keller, Ph.D.” at the Hearing on “Strengthening America’s Higher Education System,” (Washington, DC: Subcommittee on Higher Education and Workforce Training, House Education and the Workforce Committee, March 17, 2015),

[36] Harbour, Final Report, 13-19.

[37] Figures are based on 2010-2012 data. See U.S. Department of Labor (DOL), Office of Disability Employment Policy (ODEP), Economic Picture of the Disability Community Project: Key Points Document (Washington, DC: DOL,ODEP, 2014), 1, accessed May 14, 2015,

[38] Newman, et al., The Postschool Outcomes of Young Adults with Disabilities, 56.

[39] Lindsey Conway, “Virtual Reality Program Provides Support for Students with Disabilities,” The Red & Black, February 4, 2015,

[40] Leonardo Romero, “Collaborative Course Aids Post College Life,” Daily Titan, February 9, 2015,  

[41] WSteve Yingling, “Western Nevada News & Notes: Carson City’s WNC’s ‘Career Connect’ Helps Students with Disabilities,” Nevada Appeal, March 1, 2015,

[42] Mobility International USA (MIUSA), “Statistics on U.S. College-Level Study Abroad Students with Disabilities,” accessed March 22, 2015,

[43] For example, see Kimberly Raue, Laurie Lewis, and Jared Coopersmith, Students with Disabilities at Degree-Granting Postsecondary Institutions. First Look. (NCES 2011-018), (Washington, DC: U.S. Department of Education, Institute of Education Sciences, National Center for Education Statistics, 2011), 3, accessed March 22, 2015,

[44] One example is the NCES “Fast Facts: Students with Disabilities,” in Endnote 16.

[45] Harbour, Final Report, 11. 

[46] Catherine S. Fichten, Shirley Jorgensen, Alice Havel and Maria Barile, “College Students with Disabilities: Their Future and Success,” Adaptech Research Network, 2006,

[47] Newman et al., The Post-High School Outcomes of Students with Disabilities, xv.

[48] Number of campuses serving students with disabilities is determined by calculating 88 percent of the total number of Title IV campuses. U.S. GAO, Higher Education and Disability, “Highlights,” 28-29; Percentage of campuses serving students with disabilities is from Kimberly Raue, et al., Students with Disabilities at Degree-Granting Postsecondary Institutions, 3; Total number of Title IV campuses is from NCES, Fast Facts: Educational Institutions (Washington, DC: U.S. Department of Education, IES, NCES, 2011), accessed March 22, 2015,

[49] U.S. Department of Education, OPE, “Federal TRIO Programs – Home Page,” accessed March 22, 2015,

[50] Ibid.

[51] Higher Education Opportunity Act, §760(1).

[52] Ibid, §777(b).

[53] Meg Grigal, et al, Annual Report on the Transition and Postsecondary Programs for Students with Intellectual Disabilities, Year 3 (2012-2013), (Boston, MA: Institute for Community Inclusion, Think College, 2014), 1-2, accessed March 22, 2015,

[54] Ibid, 2-3.

[55] THINK College National Coordinating Center, “Annual Report of the Transition and Postsecondary Programs for Students with Intellectual Disabilities Year 3 (2012-2013), accessed May 12, 2015,

[56] 2006 figures from Meg Grigal, Amy Dwyre, and Helena Davis, Transition Services for Students Aged 18-21 with Intellectual Disabilities in College and Community Settings: Models and Implications of Success,” Information Brief: Addressing Trends and Developments in Secondary Education and Transition 4, no. 5 (2006), 2, accessed March 22, 2015, 2015 figures from Think College, “Find a College,” Think College! College Options for People with Intellectual Disabilities, March 22, 2015,

[57] Meg Grigal, Debra Hart, and Cate Weir, Think College Standards Quality Indicators, and Benchmarks for Inclusive Higher Education (Boston, MA: University of Massachusetts Boston, Institute for Community Inclusion, 2011), accessed March 22, 2015,   

[58] Center for Applied Special Technology (CAST), “About Universal Design for Learning,” CAST, 2015,; Anne Meyer, David H. Rose, and David Gordon, Universal Design for Learning: Theory and Practice, (Wakefield, MA: CAST Professional Publishing, 2014), 4, accessed on March 22, 2015,

[59] Ibid,3.

[60] Higher Education Opportunity Act, §202 (d1), §205 (a1).

[61] Kim M. Sopko, Universal Design for Learning: Policy Challenges and Recommendations, (Alexandria, VA: National Association of State Directors of Special Education (NASDSE), Project Forum, 2009), 6, accessed March 22, 2015,

[62] CAST, “UDL on Campus: Universal Design for Learning in Higher Education – A Guide,” accessed March 22, 2015,

[63] CAST, “Postsecondary Institutions with UDL Initiatives,” UDL on Campus: Universal Design for Learning in Higher Education – A Guide, accessed March 22, 2015,

[64] For more examples of UDL in higher education courses, see Sheryl E. Burgstahler and Rebecca C. Cory (Eds.),Universal Design in Higher Education: From Principles to Practice (Cambridge, MA: Harvard Education Press, 2008); David H. Rose. “Universal Design for Learning in Postsecondary Education: Reflections on Principles and Their Applications,”Journal of Postsecondary Education and Disability 19, no. 2 (2006):135-151.

[65] Higher Education Opportunity Act, §132(i(1i)).

[66] U.S. Department of Education, IES, NCES, “College Navigator,” accessed March 22, 2015,

[67] Harbour, Final Report, 52-53.

[68] Higher Education Opportunity Act, §772.

[69] Advisory Commission on Accessible Instructional Materials in Postsecondary Education for Students with Disabilities,Report of the Advisory Commission on Accessible Instructional Materials in Postsecondary Education for Students with Disabilities, (Washington, DC: U.S. Department of Education, 2011), 1-174, accessed March 22, 2015,

[70] Ibid, 12-13.

[71] Ibid, 42.

[72] Ibid, 84.

[73] Ibid, 79.

[74] Ibid, 80.

[75] Lauren McLarney, “Five More Years of Inaccessibility?” WCET: Frontiers, accessed March 22, 2015,


[76] Association on Higher Education And Disability, “The TEACH Act – A Need for Clarification Regarding the Opposition to the Proposed TEACH Act Legislation,” Association on Higher Education And Disability (AHEAD), accessed March 22, 2015,

[77], “H.R. 3505 (113th): TEACH Act,”, accessed March 22, 2015,

[78] Higher Education Opportunity Act, §762.

[79] Ibid, §762.

[80] Ibid, §773.

[81] Advisory Commission on Accessible Instructional Materials in Postsecondary Education for Students with Disabilities,Report of the Advisory Commission, 83-85.

[82] Office for Civil Rights, “Transition of Students with Disabilities to Postsecondary Education: A Guide for High School Educators,” Office for Civil Rights, U.S. Department of Education, 2011, accessed March 30, 2015,

[83] Higher Education Opportunity Act, §777(a).

[84] Ibid, §777(a(4E)).

[85] 80 Federal Register 27057 (May 11, 2015).

[86] Ibid.

[87] Betsy Hammond, “Oregon special education graduates declared eligible for federal financial aid” The Oregonian, April 10 2014, accessed May 12, 2015,

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