CSAS policies and procedures difficult to navigate, cause discrimination concerns

More than 325 students use the Center for Student Academic Support every year, but not everyone leaves with the best impression of TU’s disability services.

The most common accommodations given are for testing, whether that means extra time on tests or taking tests in a distraction reduced environment.
However, getting academic accommodations is a complex process.

While CSAS is technically compliant with the Americans with Disabilities Act (ADA), having to maneuver the system has stirred up feelings of discrimination.

Student Stories
Kaitlyn Counter was diagnosed with ADHD in the spring of 2016, as a sophomore. After the diagnosis she took her problems to CSAS because “everybody talks it up like they’re really going to help you.”

“I got a letter from my psychiatrist stating the accommodations that I need, what he thinks would help me … he did all of this paperwork that [CSAS] gave me to give to him. Basically they laid it all out for me and they were like ‘this is what you need,’ and I brought it back to them,” she said.

Counter’s documentation went before the Eligibility Committee, who denied her accommodations and sent her an email which said there was insufficient evidence of her disability.
Counter is still working to gain accommodations this semester, as a senior.

Counter went back to CSAS and was told she needed to take a 6-8 hour formal assessment with a licensed professional, which included an interview and a series of aptitude tests, with an estimated cost of $2,000.

“I asked if they had any resources or if they offered that testing —and they didn’t point me in the direction of any places that would offer it, but they said could give me the names of some psychiatrists’ offices,” which Counter said she already had access to.

Counter was told by her employer that the True Blue Neighbors Behavioural Health clinic offered the assessment she needed for free, so she contacted the clinic. However, Counter was turned away due to a legal conflict of interest for any TU-affiliate to provide documentation that CSAS would use to make their determination.

“They have the resources to give students this assessment that they require for ADHD accommodations, and they just don’t allow you to use it,” Counter said.

“I feel like my case wasn’t handled at all, honestly. It’s easiest for people to do nothing and that’s exactly what happened when I went to CSAS to request accommodations,” Counter said.
“I felt like I was always getting the runaround and no matter what documentation I presented them with, there was always another form I needed.”

“I’ve talked to quite a few other students here at TU who have an ADHD diagnosis from a licensed professional and they all have the same complaints I do; it’s near impossible to get accommodations if you’re too broke or too busy,” Counter said.

Counter has since received the necessary testing from OSU’s psychological services center in Stillwater for less than the $2,000 she was initially quoted.
“I paid $150 for the evaluation plus $12 in tolls … plus whatever the cost of gas was,” Counter said.

She hopes to hear back from the Eligibility Committee with her results within the coming weeks.

“I’m still nervous that I’m going to get an email from CSAS saying they don’t think I need accommodations even though I turned in the official documentation they requested. That would be devastating,” Counter said. “I’ve spent so much time, effort, and money to get the required testing; I even had to skip class to make my final trip out to Stillwater to get my official documentation. And I did all of this because I need an extra 25 minutes on exams. If I get my accommodations, my complaints will still stand.”

Jay Newman, a junior, had a similar experience. Newman suffers from anxiety, depression and PTSD and has been medicated for her anxiety since high school.

As a freshman, Newman said, “I was having a really rough time, and there were some repressed memories coming back up,” referencing a time when her class watched “Boys Don’t Cry”, a docudrama about a trans-male being bullied and abused.

“I had a really difficult time coping and getting to a point where I was able to go to classes and be okay,” she said.

Her counselor suggested she go to CSAS for accommodations to excuse absences. Newman carpools to school each day, so she can’t roll out of bed and get to class as easily as most students and she can’t leave campus mid-day if she feels an oncoming attack.

Newman’s accommodation would allow her to have more than the three standard absences if she had a doctor’s note excusing the absence.

“I’ll take the blame for the three days I take off if I get sick, but if I have a panic attack or something triggers my PTSD, I can’t control that,” Newman said.

“It really sucks when that happens in a circumstance where you have to be at work or you have to be in class — where you have to be a functional member of society.”

When Newman went in to CSAS ready to lay out problems, she was disappointed by the lack of emotional support she was given in the meeting. Newman recounted how she felt as though she was treated dismissively in the exchange and was told ‘I’m not a counselor,’ when Newman tried to explain why she needed the accommodations.

Newman was told she needed a letter from her psychologist explaining her condition, but that she couldn’t get that letter from her regular psychologist at the Alexander Health Center because of its affiliation with TU.

“It’s kind of ridiculous,” Newman said. “You can go over the health center to get a diagnosis, but they can’t write you a letter. They can help you, but they can’t give you documentation.”

Newman’s psychiatrist suggested he write a letter to her general practitioner explaining Newman’s mental health so that the general practitioner could then write a letter to CSAS. However, Newman’s general practitioner refused to do that because he didn’t feel comfortable accepting a third party diagnosis and could not diagnose her himself.

“It ended up being a stalemate, and I still to this day do not have accommodations,” Newman said, recounting that she went through a catastrophic withdrawal for that semester so as not to fail her classes due to absences.

“It was so easy for me to just quit, but they made it so difficult for me to get help,” Newman said.

Since then Newman has enrolled in 12 credit hours each semester and will be in school for a total of five years.

“It has gotten a lot better, but I could have done so much better academically,” Newman said.

To make matters worse, Newman said “I’m here on scholarship, and my scholarships end after eight semesters, so I’ll have to pay out of pocket for my last year.”

“There is no reason that doing what you need to do for your mental health should negatively impact your college performance,” Newman said. “Everybody should be able to get their education and better themselves.”

Emily Harris went to CSAS for the first time last year to waive a lab because she has a condition which doesn’t allow her to stand for long periods of time. As a veteran, CSAS had Harris bring in her full VA medical record.

Harris inquired about what accommodations were available and recounted, “they were like ‘well what do you need?’ and I was like, ‘no, what do you have so I know what I can choose from.’”
Since then, she has received a handful of additional accommodations, including her service dog, Stevie, but she lamented the length of the process and a feeling of hopelessness while navigating the paperwork.

“Every time I go in there I have an anxiety attack, I dread going in there,” Harris said.

“It takes them a month to get the process going,” Harris said, recounting a specific instance where she was waiting to hear back from CSAS before she decided to drop a second lab, and by the time they got back to her, it was too late to drop the class without a W on her transcript.

Harris was also concerned about the Eligibility Committee. “All these people I don’t know are meeting to determine if I have a condition the doctor has already told me I have,” she said.

“I have appointments at the VA, and I have anxiety attacks from PTSD, and if I have something going on, I’m not going to go to CSAS all the time, because I don’t trust them to help,” Harris said.

Megan Lowry, a student veteran who worked in President George W. Bush’s security detail, has also been less than satisfied with her interactions with CSAS. Lowry suffers from a traumatic brain injury she acquired while in military service.

Lowry did receive temporary note taking accommodations and then eventually permanent accommodations, but has serious concerns with way CSAS handles its business.

“They requested that I bring in my entire medical record, and they wanted me to tell them what accommodations I wanted,” Lowry said, explaining that she was not given any idea of what the available options were before being told to say what she wanted.

“They were also giving me grief about my prescriptions, they wanted me to write down all of my prescriptions, what I was taking, and what it was all for,” Lowry said. “That is not something I should have to disclose to the school, because I don’t take them during the day, it doesn’t effect my schooling, so why should I have to disclose that information?”

“They don’t have counseling skills, so I shouldn’t have to go into any of my mental health stuff with them, they are not doctors so why do I have to tell them the specifics of my disabilities? What makes them safe to tell?” Lowry questioned.

“Then I find out, after all of this, that it goes to a board where somebody from my college is going to know what my disabilities are,” Lowry said. “I feel like that’s a violation of privacy.”

CSAS granted Lowry temporary accommodations for two months pending her bringing in her medical record.

“During the two semesters in which I had temporary accommodations, I had other health problems come up,” including, among other issues, a broken jaw.

“I was having trouble getting excused absences, so my professor sent a note to CSAS,” Lowry said. “CSAS told me that if I gave my professor all the notes saying I went to the doctor, I made that appointment, and what the diagnosis was, then they would excuse that absence.”

“[My professors] don’t get to know that either, that’s a hard no … I feel like that’s a huge violation,” Lowry said.

Do to her injuries, she has trouble reading for long periods of time, which makes understanding other people’s notes and reading the books assigned for class difficult. She noted that the accommodations she has received don’t actually help with her problem areas.

“Honestly, at this point it is more of a hassle than it’s even worth to try to reserve time for prolonged testing … some of my teachers give pop quizzes, how am I supposed to navigate stuff like that,” Lowry said. “Why go all through this grief if they don’t help? I just don’t get it.”

Overall the process was long and painful, Lowry said. “I felt really revictimized and retraumatized having to go through everything with them.”
Each of the girls noted that individual professors have been more accommodating than CSAS in many cases.

“I love TU, I love the professors because all of them have been really accommodating,” Counter said, “but it’s just stuff like this that doesn’t ever work.”

Some professors have allowed Counter come in early and start taking the test before other students got there, however this is problematic because schedules change, she gets easily distracted by others in the room, which could be avoided with the ability to test privately which CSAS accommodations provide, and she has received nasty looks from students who wonder why she gets special treatment.

When it comes to alternative methods of getting accommodations, “basically the only other thing you can do is explain the situation to your professor and hope they take pity on you,” Newman said.

“A lot of my professors are more accommodating than CSAS is, which shouldn’t be the case,” Harris said.

In addition to these specific student stories, the Collegian had previously reported incidents with CSAS in January 2016 and April 2015.

The Rules

The CSAS vision statement says “The Center for Student Academic Support strives to serve as a leader in exemplary academic support programming and initiatives through inclusive and affirming practices that will position all students on a path to lifelong learning and success.”

Tawny Rigsby, the director of CSAS, explained the process.

When a student meets with a CSAS representative for the first time, Rigsby said, they are questioned about their specific circumstances, walked through the application process and asked to provide sufficient documentation of their disability so that the Eligibility Committee can tailor accommodations to meet the student’s specific needs.

“We try to talk to people in person. We ask a lot of questions to try to understand their individual needs,” Rigsby said.

When it comes to getting the proper documentation from students, “the ADA says we need a diagnosis and we need functional limitations at a minimum,” Rigsby said.
However documentation guidelines for diagnosing certain disabilities often differ by profession.

“We’re looking at documents from medical doctors, DMs, psychologists, clinical psychologists, counselors. I mean, there are all different professions that can write documentation, and they all have different standards that they follow,” Rigsby said.

According to the official 504/ADA Accommodations Policy, which can be found on the CSA’S webpage on the University of Tulsa site under “Forms & Policies”, the student is responsible for providing “documentation of the testing procedures followed, the instruments used to assess the disability, the test results and the interpretation of the results.”

One of these forms to be completed by the certifying professional is the Disability Verification Form, which asks for the license type and number of the professional; each of the diagnoses with a date of onset and anticipated duration; the frequency of their visits with the student; the various diagnostic tools, processes and results; the medication, treatment and prescribed aids and “other information relevant to this student’s academic adjustment that will aid in making appropriate decisions about accommodations.”

In addition, “diagnosis of some disorders must meet specific criteria, for example, the diagnosis of Learning Disabilities, Attention Deficit Disorder or similar conditions.”

For example, the ADHD documentation guidelines are a separate five page document outlining which professionals are qualified to submit documentation, a ten point list of components that must be included in the submitted reports, requiring a summary in writing of “a clear history of the impact of the disorder in at least two settings,” a list of recommended tests of aptitude and achievement and requiring the professionals recommendations for accommodations.

The Eligibility Committee consists of representatives from CSAS, the Alexander Health Center and someone from the college in which the student resides, usually the Associate Dean.
Sometimes a representative from housing or athletics or a specialist in the field of the disability will also be invited to weigh in on the process depending on the specific needs of the student.

Rigsby said the extensiveness of the process is designed to give students the most individualized care possible.

“Everyone’s test results differ, and if you were to just look at the diagnosis everyone would be treated the same, and that’s not what the ADA wants,” Rigsby said. “We want to look at each person individually and help them based on their individual needs and functional limitations.”

The Eligibility Committee meets every two weeks, Rigsby said, and in some circumstances temporary accommodations can be granted immediately, or it could take close to three weeks to get results.

According to the accommodations policy, “within 20 working days … of receiving the written request and all pertinent documents, a written response will be issued.”

Rigsby said that accommodations are rarely denied (about 1-3 times a semester), and when they are it is because their is not enough evidence to prove a disability or because the student was seeking accommodations for a temporary issue.

“Just having a diagnosis alone is not really enough for us to treat them as an individual, which is what ADA wants us to do. Sometimes they might just have the functional limitations, and the doctor left off the a diagnosis,” Rigsby said. “We have to have both of those things, and if we don’t we might do temporary to give them time to get documentation submitted that gives those things.”

Temporary accommodations are granted about 30 times a semester, Rigsby said.

According to the accommodations policy, TU specifically does not offer “diagnostic evaluation for disabilities,” which is understood to be because doing so would legally constitute a conflict of interest.

Legal and Financial Concerns

CSAS is legally bound by the Americans with Disabilities Act (ADA), section 504 of the Rehabilitation Act (504) and the Family Education Rights and Privacy Act (FERPA).

The ADA prohibits discrimination and ensures equal opportunity for those with disabilities in employment, State and local government services, public accommodations, commercial facilities and transportation.

Section 504 states, “No otherwise qualified individual with a disability in the United States … shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.”

FERPA prevents universities from releasing a student’s educational information, including disability accommodations, without written permission from the student unless there is a legitimate educational interest.

There is no evidence to suggest that CSAS has broken these laws. However, the students who have spoken out against CSAS so far feel as though they are experiencing de facto discrimination by virtue of the additional time, effort and money they must invest to receive accommodations.

The financial and time costs of formal testing can be significant.

Most students on campus have student health insurance, unless they choose to opt out. With TU health insurance treatment at the student health center is 100 percent covered, including prescriptions and testing.

However, any testing done by a TU-affiliate cannot be used for CSA’S documentation.

The students next step is to try to find an in network doctor or specialist, for which TU insurance offers a $20 copay.

To find in network providers a student would go to www.uhcsr.com/tulsa and click on “Find Providers”. However, just to get to that point you have to navigate the University of Tulsa website to the Alexander Health Center page then scroll down to student health insurance.

Once there you have to know what you are looking for to narrow the search results.

Narrowing the search results to master level clinician in the area of Attention Deficit Disorders within five miles of Tulsa with express access that are accepting new patients turned up only two results.

For a licensed psychiatrist in the areas of anxiety and depression within five miles of Tulsa that are accepting new patients there were 21 options. However, none were express access, so there were no options for same-week appointment, and only the three branches of OU Physicians Tulsa provided and kind of psychological testing.

What’s more, due to the nature of negotiations between healthcare and insurance providers each year, in network providers are subject to change from one year to the next.
This process only increases in difficulty for students on their own or on their parents’ health insurance.

The school is under no legal obligation to provide free, affordable or easy-to-access testing to expedite the accommodations process for students with disabilities. However, doing so would further distance the university from any accusation of de facto discrimination.

Newman recommended, “That all could have been avoided if they had an outside medical professional located at the Alexander Health Center.”

Defense Against Student Accusations

The concern that students don’t know going in what accommodations are available has been recently addressed by an application for academic assistance which lists eight common accommodations to choose from and three spaces to write in other accommodations you think you may need.

“It’s not an all-inclusive list because there are new things every time. You think you’ve figured out every type of accommodation someone might want an something new comes up,” Rigsby said.
Responding to students who felt the questioning process was re-traumatizing or anxiety-inducing Rigsby was understanding.

“It gets kind of in depth, just because we want to know what is affecting you personally,” Rigsby said. “I think students sometimes are confused because they haven’t thought through this before, especially if they didn’t have accommodations in highschool, this can be very unique.”

Addressing concerns about the anonymity of the Eligibility Committee, Rigsby clarified that the person from the student’s college was always someone within the Dean’s office, never anyone they would be interacting with on a day-to-day basis.

Rigsby also said students have a right to know who sat on their committee and are free to ask for their names.

In addition, Rigsby assured that each of the members of the committee are legally bound by FERPA not to disclose any of the students private medical information.

“People on the Eligibility Committee have a right to know [the specifics of disabilities], otherwise they wouldn’t know what kind of accommodations to give,” Rigsby said. “Sometimes, if the issue deals with housing for example, housing needs to know they have that accommodation in order to be able to implement. We share some limited information with offices that need it to be able to implement those accommodations.”

In response to Lowry’s concern about having to tell her professors the diagnoses of her doctor’s appointments to redeem absences, Rigsby said, “You’ll have to ask that teacher. That’s not something we are a part of. There is not a CSAS policy that covers that, that is up to the instructor.”

In response to complaints that it is particularly difficult to get accommodations for mental disabilities Rigsby said “anxiety, depression and ADHD are probably the most common issues we accommodate.”

Addressing the concerns, especially of the two veterans, that they were being asked to provide too much of their personal information, Rigsby said that CSA’S doesn’t require their entire medical record.

“Sometimes students do bring that whole thing in and we go through and try to find the diagnosis and the functional limitations,” Rigsby said. “A lot of times Veterans are sort of overwhelmed trying to find that themselves, so they bring it in and we help them go through it. We don’t need that whole thing by any means, and we have no copies of that entire document for anybody.”
Getting a list of medications, Rigsby said, is a common part of the process to see what more needs to be done.

“It’s not to be invasive, and it’s not shared with irrelevant people. We don’t share any of the diagnoses or medical stuff with faculty, they have no right to that information,” Rigsby said.
Rigsby was concerned about these students’ complaints, and wanted to remind students that their is a grievance policy if they feel their situation has been handled incorrectly. She also welcomed students to come in and talk about their issues.

“There are a lot of mental health issues now, and we have students in crisis multiple times every week,” Rigsby said. “Trying to help get them connected is critical, otherwise they aren’t going to be able to make it, they aren’t going to do well. Things just can snowball, especially in an academic environment where it is very stressful. We don’t want people to leave her and not get fully helped.”

Post Author: Kayleigh Thesenvitz