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Dual Enrollment Nov/Dec, 2000, Part 2, Volume IV, Nos. 11-12D A I S A newsletter from Disability Access Information & Support Providing information and technical assistance regarding issues of disability in higher education ------------------------------------------------------------------------ Nov/Dec, 2000, Part 2, Volume IV, Nos. 11-12 4. DUAL ENROLLMENT -- THROWING OUT THE RULE BOOK! "You are traveling through another dimension... a dimension not only of sight and sound but of mind. Look, there's a sign post up ahead. Your next stop is the TWILIGHT ZONE. (eerie music...)" I thought this quote was a fitting way to open our discussion of students with disabilities who are under dual enrollment status (i.e., taking college courses while still enrolled in high school). Had I chosen to use a movie theme, rather than a TV focus, I would probably have led with the famous tag line for the movie Jaws... "Just when you thought it was safe to go back in the water!" Everything you know, all the procedures you have carefully mapped out, and all thoughtful decisions you have made regarding reasonable accommodation and how much is too much MAY NOT COUNT when you enter the Twilight Zone of dual enrollment issues. What follows is my PERSONAL review of some of the problems engendered in such arrangements, and my PERSONAL suggestions for appropriate response. To the best of my knowledge, there is no definitive case law in this area, and there is little guidance available from OCR decisions that can help us on our maiden voyage. We are in uncharted water here, folks. So grab a life vest, hold your breath, and let's take the plunge together! * What Kind of Arrangements Are We Talking About? * Part of the problem in developing navigation guidelines for dual enrollment situations is that there are lots of different kinds of articulation agreements in place between secondary and postsecondary settings. Recognizing that we are going to concentrate our discussion on the ramifications of such arrangements for students with disabilities, these are some of the options that come immediately to mind: (A) The student is enrolled in a school district that offers any high school senior who meets certain eligibility requirements (GPA, number of credits accumulated, and so on) the opportunity to take one course per semester at a local college. As a qualified student in Senior standing, our student with a disability chooses to enroll in a college course; (B) The student is enrolled in a school district that offers the option of taking a course(s) at a local college. The student's IEP team decides that this is an excellent opportunity to see if the student is ready for college-level work, and writes his enrollment in the college course into the (C ) The school district contracts with a local college to have one or more college course delivered by college faculty to their high school students. The course is offered AT the high school, taught college personnel. As an alternative, the course may be offered through a TV hook-up with the instructor on the college campus and the students viewing the feed at the high school. In either case, the student with a disability is simply one of a few dozen students at the high school who are taking this class; (D) -- SPECIAL CIRCUMSTANCE -- The college offers a class or activity that is particularly targeted to youngsters as part of an enrichment program. These kinds of activities are often carried out during the summer months (Science Camp, Summer Writer's Workshop, Gifted and Talented programs). An eligible student with a disability chooses to participate in the program. There are four examples. There are lots of variations on the theme. Even within these options, there may be differences in how they are constituted based on credit arrangements. In some cases, the student receives BOTH college and high school credit for the course. In some cases, the student receives college credit for the course even though he/she is not (technically) enrolled in the college, only in this one class. In some instances, the student receives high school credit for the course, but NOT college credit. And in some instances, there is no credit involved at all -- the activity is considered it's own reward! Let's remove Scenario D from consideration for the moment (we'll come back to it later). When we are speaking of options A, B, or C, some puzzling questions come to mind that must be addressed. Who has the legal responsibility for attending to the student's disability-related needs? What kind of accommodations will be provided? Who will provide the accommodations, under what rules? How will you resolves issues of confidentiality and documentation? Let's talk... * Who Has the Legal Responsibility? * I think the answer to this question, as related to Scenarios A, B, and C is "Everybody!" Both the secondary and postsecondary institution have some obligation to a student with a disability. The extent of that obligation may vary with the scenario, and the specific assignment of responsible parties(much less of accommodations!) may be done through contract or letter of agreement. But both entities have some legal responsibilities here. If the class is being held on the college campus, the postsecondary institution has the same responsibility for assuring non-discrimination in programs/services that it has to any other student or visitor on campus. The obligation is the same -- but how that obligation is discharged may be different (keep reading!). If the class meets at the high school, the faculty member, in representing the college, needs to be sure that the course is fully accessible to students with disabilities, but that may simply mean that the faculty member cooperates with the high school authorities who are responsible for putting necessary accommodations in place. If the student is enrolled in high school and is functioning under an IEP, WHETHER OR NOT participation in the college-level course is written into the IEP, the school district has some level of responsibility to that student under IDEA. If the student is functioning under a 504 Plan, the school district probably STILL has some responsibility to the student, but it gets even murkier. If the class is being held on the college campus, the school district's responsibility under EITHER an IEP or 504 Plan may be pretty limited (with the exceptions noted below). If the course is to be offered at the high school, the school district probably has sole responsibility for delivering accommodations -- within the limits imposed by contract/agreement(does anyone else feel we are wading in deeper and deeper?). " What Kind of Accommodations Will Be Provided? * I don't suppose I could simply say, "appropriate accommodations" and leave it at that, huh? I didn't think so. Alright, let's try to sort this out. The problem comes from the fact that the K-12 system and the postsecondary system tend to use the same word with (often) very different meanings. In this case, the word is "accommodation." We are pretty clear on the purpose of an accommodation at the postsecondary level. In fact, we spend long hours explaining the equal-access nature/intent of the accommodations we provide to students, to institutional faculty (who need to be reminded that giving accommodation means leveling the playing field, not giving an advantage and not watering down the curriculum), and to parents and K-12 special educators who continue to be confused by why the student is NOT entitled to the same thing in college as he/she was getting in high school. The answer, we tell them, is because the provisions made for them in high school were under a different set of rules (that is, IDEA v. 504), and the old rules are not applicable to At the high school level, the IEP is likely to be driven by a plan for success AT LEAST as much as it is driven by an obligation to access. IEP's and 504 Plans often include a myriad of supports/services/arrangements that are provided to help THIS student make it through the curriculum in some fashion (I have ranted and raved on the evils of inclusion more than once in I've just spelled out the problem. I don't have any firm answers. The best I can suggest is that the institution approach such circumstances with a clear understanding of where the lines are to be drawn, and a willingness to compromise when/if it is appropriate to do so. Some things are NOT negotiable, but some things may be. If the student will be receiving college credit for the course, then grading policies, workload, and attendance policies are not negotiable in my book. If the student is going to earn whatever grade is received, it will be because he/she has demonstrated the same level of mastery AND responsibility as any other student in that class receiving the same grade. If the student is receiving ONLY high school credit for the class (that is, their participation is more in the form of an audit of that college-level course), I might be prepared to be more flexible If the student's IEP calls for one-on-one tutoring that is not available on your campus, and the school district wants to provide that tutoring for the student, either when he/she returns to the high school or by paying a student on your campus to tutor the student with a disability, don't argue with 'em! Simply facilitate the arrangement and let them work it out from there. If there is adaptive testing to be done (extended time, quiet proctored setting, use of a word processor, and so on), I would say that responsibility falls to the postsecondary institution. An easy litmus test might be for the postsecondary DSS provider to ask himself/herself, "would I provide this accommodation to a disabled student enrolled solely on this campus, given appropriate documentation?" If the answer is "yes," I would opt for YOU providing that accommodation to the high school student while on your campus. BUT... your administrator's might not see it my way. It is easy to make sole decisions when you are talking about extended time or adaptive testing space. What if you are talking about sign language interpreters? Who is going to pay for the interpreter for a high school student enrolled in a class on the postsecondary campus? The high school? The college? VR? My best suggestion is that you think it out in advance and have a plan for dividing up not only responsibility for accommodation but COST of accommodations, before the need arises. Whatever arrangements you make, it should be IN WRITING as part of the letter of understanding between the high school/district and the college. Recognize, that you (the DSS provider or administrator responsible for DSS services) are NOT likely to be the first person they think to consult when they are drawing up such letters. Make sure SOMEBODY knows there is very real, dollars-and-cents (sense?) issue that must be resolved. * Who Will Provide the Accommodations, and Under What Rules? * In discussing what accommodations are to be provided, I suggested compromise and flexibility when it could be offered. There isn't a lot of"give" in our steadfast refusal, at the postsecondary level, to jeopardize the academic integrity of coursework offered in our name by watering down the curriculum or lowering the evaluation standards used to assess student On the campuses I know, students with disabilities have the responsibility of identifying themselves to the DSS office (or appropriately designated unit on campus) and providing documentation of their status as a person with a disability and of their accommodation needs. Students typically are then responsible for notifying their instructors in some active manner of their need for accommodation and negotiating arrangements for those accommodations with the faculty member. All of those steps are in place, in part, to help foster student development, self-advocacy, and independence, and I approve of them wholeheartedly. And I think they are all negotiable in the circumstances we are discussing, as well! I don't care what you require of typical students who are enrolled on your campus... these are not typical students. Their circumstances are different, and their level of maturity is likely to be different, too. I would be inclined to accept, as notification of disability and need for accommodation, a letter/report from an appropriate source at the high school (team leader, resource room teacher, etc.). I would be willing to contact the faculty member on behalf of the students, sort out the arrangements for receiving accommodation, and follow up to some extent with the students directly to assure they understand what they are to do, and when. Remember, the high school has some level of responsibility to make sure the student has a viable chance for success while in your environment. Such actions help the high school, as well as helping the student (of course, the fact that your intervention now will probably save you a lot of headaches later is beside the point!). If you want the high school people to understand your limits and work effectively in sorting out overlapping responsibilities, I think it is appropriate to meet them half way. You can do these things without jeopardizing anything that is important to either your program or your philosophy. Bend a little!!! * Issues of DOCUMENTATION and Confidentiality * Now we come to the "D" word. Whose rules are your going to use regarding what constitutes appropriate documentation of disability for WHATEVER accommodations you agree to give? At regular intervals, on the DSSHE-L, someone gets on the list and laments (or rants/raves, depending upon the mood) about the cruddy documentation they receive from the K-12 system regarding the student's disability and asks for suggestions as to how to politely, but firmly, tell the student that what they used in high school, and what was provided BY the high school, just isn't up to our standards. Routinely, in these discussions, someone will get on the list to remind others that the K-12 system collects information/documentation for different I know some of my readers are gonna hate this, but I'll say it anyhow. I don't care what kind of guidelines you have adopted, or how stringently or loosely you choose to follow them when determining eligibility/accommodations for typical students on your campus. When it comes to students with disabilities who are involved in such dual enrollment options, I think you should be gracious to your K-12 counterparts and take their word for the diagnosis AND the need for accommodation. You can make all the disclaimers you feel are appropriate: you can remind everyone three times, in writing, that should the student choose to fully enroll at the college following his/her high school career, further documentation will be required; you can remind the student (and parents!) in writing that you are providing these accommodations as part of an articulation agreement with the high school and that they do not constitute any kind of precedent for what accommodations you would provide should the student matriculate to your campus after HS graduation; and you can (SHOULD!) be staunch in your refusal to provide any accommodation that is inappropriate at the postsecondary level, regardless of the request from the high school side. But I don't believe you have anything to gain by forcing someone through the documentation process you have established for typical students when this student is, by definition, just passing through. And THAT brings us to... ...the issue of confidentiality of disability-related information. It never fails to surprise me, in my conversations with service providers, to find that people can get the big stuff right and then get hung up on the small stuff. I have heard of situations in which the DSS folks were prepared to be more intrusive on behalf of the high school student, to make the arrangements with the profs, to accept the need for accommodations on the basis of good faith -- only to have the K-12 folks turn around and refuse to share what information they DO have regarding the student and the disability. That makes no sense to me. I think this comes under the heading of "compromise" on their end -- if they want the student to receive the best support possible, they must be prepared to share with you as much information as possible so that you can translate that information into a practical approach to the student's time on campus. ON THE OTHER HAND, I also have spoken with DSS providers who are irate because the school district has asked the DSS office to provide them with information about the student's progress or how well/effectively they are using the accommodations. The DSS folks get on their white chargers and read the riot act to the K-12 folks about the highly confidential nature of disability-related information, and the option that the person with a disability has as to whether to share any/all information with someone else, since they are adults. Guess what, folks. These kids are NOT adults. So long as the student is still enrolled in high school, both the school district AND the parents have rights to some information that would not be true for a student covered under Subpart E. EVERYONE is best served by a comfortable two-way flow of information. Don't make things harder than they need to be. (ASIDE… this Fall, I had a lengthy correspondence with a college DSS provider about the subject of high school students enrolled in college courses. For the first half dozen posts, we were using the subject line of "Duel Enrollment." Eventually, I suggested that the appropriate spelling was "DUAL." Sometimes, I'm not so sure!!!) *Scenario D -- A VERY Special Circumstance * (D) -- SPECIAL CIRCUMSTANCE -- The college offers a class or activity that is particularly targeted to youngsters as part of an enrichment program. These kinds of activities are often carried out during the summer months (Science Camp, Summer Writer's Workshop, Gifted and Talented programs). An eligible student with a disability chooses to participate in the program. The rules we live by, concerning our responsibilities to students with disabilities on campus, are based on what is stated (and what had evolved over time) from Subpart E of Section 504 -- the subpart entitled Postsecondary Education. There is some question as to whether the students involved in programs such as those identified above are covered under Subpart E… or whether they are, in fact, covered under Subpart D (Pre-school, Elementary, and Secondary Education). The program MAY be a program/activity of the postsecondary institution, or it may be an activity of some other entity HOUSED at the postsecondary institution. Coverage MAY be dependent upon the place or it MAY be dependent upon the individual. There are no clear distinctions here. If we separate such programs from any overlap of disability issues, it seems pretty obvious that different rules are generally in place regarding such students' presence on your campus. Parental permission slips are necessary for transportation, housing, and activities. Organizers rely on the parents, not the students, for medical information. Curfews are imposed on the comings and goings of such students, and residence hall staff assume a much more responsible role in monitoring the whereabouts and activities of their charges. Recognizing that we use DIFFERENT rules for these students in almost every other aspect of their presence on campus, I don't think it is surprising that we should need to re-examine our disability-related support services. A case in point… colleges and universities have long held that they are NOT in the business of providing personal care attendants for students with disabilities. It isn't our job. The rules say we are NOT responsible for providing services or equipment of a personal nature. Uh… wait a minute. Subpart E says we are not responsible for providing services or equipment of a personal nature. If a student who needed attendant care was attending an outing as part of their high school enrollment, and needed attendant care in order to have full enjoyment of the opportunity, the school district WOULD be responsible for (at the very least) helping to make those arrangements. Is the school district responsible for such things if the student is still in high school but attending a program on your campus? Is whomever organized the program HOUSED at your institution responsible for providing such services? Is the institution responsible for providing a level/type of service to NON-students that it would not provide to students? I don't know… and I'll bet you don't, either. About the only definitive statement I can make at this point is that until you have sorted through the ramifications/concerns/needs surrounding such unique circumstances, on a case-by-case basis, you won't know what to recommend, either! * Summing It All Up * Let's see… we started this discussion with quotes from TV and the movies. Is there an appropriate way to sum up our discussion? Ah, yes… one of my favorite Broadway musicals, The King And I, provides the answer in a song -- "…'TIS A PUZZLEMENT!!!!" |
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