Disability Accommodations vs Modifications
A College Transition Reality Check
Two experts writing from two sides of the bridge: Kelley from the world of high school IEPs and 504s, and Elizabeth from college disability services.
“Not all modifications modify the curriculum.” Hmmmm…
Kelley: I was in a Facebook group where somebody made this statement in a thread. Whether you’re a parent or a professional, if you participate in online groups, you know what happened next—some people confidently insisted that a support is only a modification if it changes the curriculum.
The definitional chaos continued. One group member raised the example of a student only being required to complete 50% of the problems on a homework assignment and receiving the same amount of credit as peers who completed the whole thing. Some educators and advocates jumped in to say, “That’s an accommodation.” Others said, “No, that’s a modification.” In the end, people talked past one another while using the same words and missing the nuances and facts that actually matter for students and families.
This is a nuanced discussion for a reason. The terms “accommodation” and “modification” get used constantly in K–12 schools, but they are not explicitly or neatly defined in the Individuals with Disabilities Education Act (IDEA 2004), which applies to special education in public schools for students ages 3–21. They are also used interchangeably in the laws that apply at the college level (Section 504 of the Rehabilitation Act of 1973, or Section 504, and the Americans with Disabilities Act, or ADA).
I shared this story with my friend and colleague Elizabeth Hamblet, and she suggested we co-write this article because she has spent decades on the college side of this transition. Elizabeth is the author of Seven Steps to College Success: A Pathway for Students with Disabilities and has worked in college disability services for more than 20 years. In our recent joint Substack Live, one theme kept arising—students can appear “successful” in high school for many different reasons, but that success does not always translate once they arrive at college. (Watch it here.) Having work expectations modified is one of those reasons, and reducing the number of problems a student completes is an example of such a modification.
This article is our attempt to make the distinction clearer, explain why the debate keeps happening, and outline what students should understand and practice before they arrive on campus.
Authors’ Note
This post is for educational purposes only. It doesn’t provide legal or medical advice and shouldn’t be construed as providing either of these. (Please see a qualified professional for such advice.) However, we’ve linked to the relevant parts of the laws.
Why the words get confusing
Kelley: In K–12, we often use the terms “accommodation” or “modification” as if they are formal legal categories with crisp, agreed-upon definitions. Again, IDEA does not define the terms in a clear way or provide useful distinctions between them. Some clarity is provided by the National Center on Educational Outcomes, which defines accommodations as adjustments that do not alter what the assessment measures, distinguishing them from modifications that do change expectations. Even when schools do not use this precise language, the distinction itself is critical.
A practical way to think about the distinction is this:
· Accommodations provide access to the educational program, instruction, or assignment without changing what is being taught or what the student is expected to know and do. An example of this that is granted at both the high school and college level is providing text in an accessible format so that it can be read by a speech-to-text program for students with reading or visual disabilities.
· Modifications change expectations by altering what a student is required to learn or demonstrate. They may lower, replace, or fundamentally alter the learning target, the performance standard, or what is being measured. Because of that, they are closely tied to specially designed instruction, where something about the content, method, or expectations needs to be fundamentally altered to meet the student’s individualized needs and support meaningful progress. An example that might be approved at the high school level but would not be in college would be allowing the student to read a version of a book where the content was changed or grade level was reduced, or allowing the student to read an entirely different book than their classmates.
Elizabeth: At the college level, disability services (DS) offices’ approach to determining the distinction between accommodations and modifications may be informed by the exceptions written into the relevant laws. As I note in Step 1 of my book, Section 504 says (at §104.44 [a]), “Academic requirements that the recipient can demonstrate are essential to the instruction being pursued by such student or to any directly related licensing requirement will not be regarded as discriminatory…” And the ADA says (at § 12182 [b][2][A][ii]) that colleges and other entities don’t have to make modifications in “policies, practices, or procedures” that would “fundamentally alter” any part of their programs. Because of these exemptions, DS offices generally don’t approve accommodations that they believe would fundamentally alter assignments, tests, etc. because they defer to professors’ judgment on what is “essential to the instruction” provided in classes.
The debate that keeps coming up
Kelley: In that Facebook thread, a newer layer emerged, raised by a colleague who is trained as both a special educator and an advocate: “If the assignment includes multiple items assessing the same skill, and you remove only the redundant items, that can be an accommodation. But randomly shortening an assignment, especially when it removes standards, is a modification.”
The problem is that—no matter what the rationale for reducing the number of problems is—doing so and grading the student on the basis of that reduced work, as though they’d completed the whole assignment, is modifying the performance expectations for that student. And there is an assumption that the teacher’s assignment for students to demonstrate mastery over multiple attempts is not an appropriate or reasoned standard.
The realities of the college environment
Elizabeth: No matter what kind of nuance might be applied to this kind of decision at the high school level, at the college level, it’s unlikely there would be a debate about how many problems could be eliminated in an assignment because a request to reduce the amount of work a student completes would probably not be approved. Professors get to set the evaluation standards for their classes, including what and how much work students have to do. While DS offices always have to consider students’ requests, this doesn’t mean they have to approve them.
In my long experience as a member of a professional association of other DS professionals, I don’t remember anyone ever saying they approve assignment modifications that reduce the amount of work students have to do. (To be clear—this represents what is said by those who respond consistently to queries about this; there may be colleagues who do offer such approvals but don’t say so in that forum or who don’t even belong to our association.)
But to go beyond that anecdotal information, here’s the data from a large longitudinal transition study showing the rate of receipt of certain modifications at the high school v. college level.**
Modified or alternative tests: 37% received this in high school v. <1% in college
Shorter or different assignments: 30% received this in high school v. 3% in college
Modified grading standards: 29% received this in high school v. 1% in college
As you can see, shorter assignments were rarely approved for the students in that study. And it’s not only adjustments to length that were rarely approved — students also didn’t get approved to do different kinds of assignments than their peers.
For example, I’ve heard colleagues mention that when a professor assigns students to give a presentation to the class, DS won’t typically tell the professor they have to let a student with a severe anxiety disorder write a paper or submit a creative project instead. (There’s no data on the approval rate for this, so I am just providing anecdotal information here.) They may speak to the professor to see whether the student could give the presentation to a smaller group, or present just to the professor. But the student likely will have to give the speech, and it likely will have to be done live, rather than be recorded and submitted later, as part of the assignment is likely to include managing oneself in front of an audience, and maybe responding to attendees’ questions.
What obligations do colleges have when students have received modifications like the kind we’re describing while they were in high school?
Elizabeth: This is a good time to be clear about a very important point.
Whether students have a high school IEP or 504 plan, neither kind of plan “transfers” or “travels” to college. It’s not that colleges don’t have to provide accommodations—they do. But IDEA (under which students in public schools receive IEPs) doesn’t apply to colleges, so the plans don’t either.
And while Section 504 applies to all educational settings, K-12 schools are subject to Subpart D and colleges are subject to Subpart E. Therefore, 504 plans also don’t create any obligations for colleges. Both IEPs and 504 plans can be said to essentially “expire” once students graduate from high school or age out of the system.
So, to go back to our much earlier example, even if a student’s IEP or 504 provided an “accommodation” exempting them from completing “redundant” problems, that plan would hold no legal obligation for their college to approve the same thing. And, as you can see from the comparison data, they rarely do.
Why this matters
Kelley & Elizabeth: There is a reason we chose to write this Substack. This is not just a debate about language (even though we have talked a lot about semantics). The difference between accommodations and modifications—and a student’s clear understanding of which they need—has real consequences once students leave K–12 education.
If a student is consistently completing less work than peers, demonstrating fewer skills, or being assessed on a reduced set of expectations, the student needs to be aware that this is happening (and why). They also need to understand that this kind of modification is unlikely to be approved in college. This doesn’t mean they should stop receiving modifications in high school. It does mean they need clear self-awareness about what skills they have developed, what skills still need strengthening, and what supports will realistically be available after graduation.
Preparing students for college does not mean simply removing support. It means being intentional about which supports are in place, gradually reducing unnecessary ones, and being honest about what will and will not exist after K–12. Most importantly, it means helping students build the skills to function with the supports that are actually available. That includes understanding their disability, explaining what helps in plain language, managing forms and deadlines, and recognizing when expectations have changed.
This is where self-determination becomes critical. Students should be informed that reduced workload or altered academic standards are unlikely to be approved in college and be invited into a real conversation: Do they want to continue modified work now, or use available supports to work toward meeting the same standards as their peers? Planning teams should consider what direct instruction is needed to help them manage full assignments. While grades may initially dip when expectations increase, the long-term benefit is stronger preparation for postsecondary demands.
Transition Planning Implications
If a student’s high school success depends heavily on modifications, students and families need to pause and think carefully about what comes next. That may include whether a particular college path is the right fit right now, what skills still need to be built before launch, what supports they can realistically access in higher education, and whether a bridge step such as community college, a lighter course load, or a structured transition program, might better support readiness in the immediate future.
We encourage students to request any accommodation they think they need once they enroll at a college. (We never want to be responsible for dissuading students from requesting something that may get approved.) We just want to make sure they have a realistic view of the shifting expectations long before they get to college so they can make informed choices about how they want to prepare while they’re still in high school.
We know some readers will be disappointed to learn about the kinds of supports and adjustments colleges don’t have to provide. (See Step 7 of Elizabeth’s book for a detailed discussion of these or watch her on-demand webinar on this topic.) Remember, K-12 education is mandatory, and college is optional. Colleges are allowed to set the standards students will meet. For instance, they’re not required to alter their admission requirements for students with disabilities.* And once they’re admitted, colleges don’t have to alter their graduation requirements. (Learn more from posts and videos linked to on this page.)
Final Thoughts
If families remember one thing, let it be this: the goal can’t be guaranteed success. The goal has to be preparing students to succeed with supports they can realistically access. Sometimes that means adjusting the plan or the timing of students’ start to college. That is not failure. It is thoughtful, responsible transition planning.
*This information is provided for educational purposes only. It is not and should not be construed as legal or medical advice. Please see a qualified professional if you require such advice.
**Newman, L. A., & Madaus, J. W. (2014). Reported Accommodations and Supports Provided to Secondary and Postsecondary Students With Disabilities: National Perspective. Career Development and Transition for Exceptional Individuals, 38(3), 173-181. https://doi.org/10.1177/2165143413518235
Get more information
Learn practical strategies for making sure students with disabilities develop the skills they’ll need for college success. Explore Kelley’s Substack and be sure to subscribe for future posts. Also explore her website, where you can inquire about her services for families and book a presentation.
Learn more about the changes students with disabilities will find in the college environment.
Find lots of free content about preparing students with disabilities for college success on Elizabeth’s main blog and Youtube channel. To learn much more, read Seven Steps to College Success: A Pathway for Students with Disabilities, watch my on-demand videos, read her concise 6-page guide, or hire her to speak to your school, group, or district.
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