ASUW Student Disability Commission

Email: asuwsdc1@uw.edu
Website: sdc.asuw.org

DISABILITY SERVICES
IN HIGHER EDUCATION
FOR STUDENTS WITH
INVISIBLE DISABILITIES

Devon Sheehan, Christine Lew, Claire Murphy, and Lukas Illa

 1
TABLE OF CONTENTS

EXECUTIVE SUMMARY........................................................................................... 2
DEFINITIONS ........................................................................................................... 4
INTRODUCTION
What are Invisible Disabilities?........................................................................ 5
Invisible Disabilities in Higher Education ...................................................... 6
Methodology..................................................................................................... 8
Policy Framework.............................................................................................. 9
ANALYSIS OVERVIEW........................................................................................... 11
STRUCTURAL BARRIERS
Disability Documentation .............................................................................. 12
Case Study: University of Arizona and University of Washington ............ 15
ATTITUDINAL BARRIERS
Attitudes of Professors ................................................................................... 17
Culture of Disability Services Offices ........................................................... 18
INTERSECTING IDENTITIES
Race and Medical Diagnoses ........................................................................ 19
Gender and Diagnoses Disparities .............................................................. 20
RECOMMENDATIONS
Universal Design ............................................................................................. 21
Accommodations Model Adjustments and Supports ............................... 22
Disability Sensitivity Training ........................................................................ 25
Resources for Disability-Specific Communities ......................................... 25
Increased Research on Intersecting Barriers .............................................. 26
CONCLUSION ...................................................................................................... 27
REFERENCES ........................................................................................................ 28
 EXECUTIVE 2

SUMMARY

The contents of this policy brief regard the issues pertaining to the lack of access
to sufficient disability services that students with invisible disabilities face in higher
education institutions. The need for recognition and accommodations for students with
invisible disabilities is prevalent.

Barriers to the access of students with invisible disabilities are both attitudinal and
structural and can include:

• Accessing accommodations
• Medical documentation requirements
• Expenses relating to testing and obtaining medical documentation of a
disability
• Emotional cost of obtaining medical documentation
• Underfunded disability resource services
• Inclusivity of invisible disabilities in understanding disability
• General distrust of a disability that cannot be perceived (from professors
and disability services staff)
• Intersecting identities, such as race and gender, creating increased barriers
in accessing disability documentation

In order to address the needs of students with invisible disabilities on college

campuses, and to live up to their promises of inclusivity and equity, higher education
institutions need to change the ways in which disability accommodations are obtained.
Throughout this policy brief, we provide a series of recommendations as to how higher
education institutions can do this. This should include, at a minimum:

• A Universally Designed campus

• Using AHEAD documentation guidelines to structure disability resource
centers
• Hiring clinically trained service providers who are familiar with invisible
disabilities such as psychological and learning disabilities
• Providing financial and logistical support in seeking medical
documentation
• Providing disability sensitivity training to faculty
• Providing resources to specific disability related communities
• Researching more on the intersectionalities of disability
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EXECUTIVE
SUMMARY, CONT.

A suggested solution includes creating universally designed campuses and

pedagogy practices. This will ensure that all students, regardless of having an invisible
disability or not, receive the accommodations that help improve learning and
academic success. Another suggestion includes the accommodations model
adjustments and supports. This solution suggests using different models and
frameworks to understand the need for accommodations and what type of support is
needed to put a person with invisible disabilities on an equal playing field as those who
do not have an invisible disability. There is also the solution of providing disability
sensitivity training to all faculty and staff on campus. Instead of changing the written
code and conduct that surround receiving accommodations, training on how to be
more accommodating, disability friendly and understanding could be helpful in
reducing attitudinal barriers and the barriers that come with having an intersectional
identity. Another suggested solution is to provide resources for disability-specific
communities. This may be providing the financial resources to receive medical
documentation or having on campus groups dedicated to providing academic help to
students with specific invisible disabilities. These solutions are designed with the
intention of softening the burden and decreasing barriers for students with invisible
disabilities. The final recommendation that the brief poses is to increase research on
intersecting identities that come along with invisible disabilities. As there is not much
research on this topic, it is difficult to create inclusive and sensitive accommodations
processes without knowing other barriers that students with invisible disabilities face.

While there is certainly a need for further research (both qualitative and
quantitative) into the specific experiences of students with invisible disabilities at
colleges and universities of differing cultures, sizes, types, our case studies of the
University of Arizona and University of Washington stand as our current examples as to
why there is a problem present. Therefore, we conclude that this brief will be
informative of the needs of students with invisible disabilities, the barriers they face on
college campuses, the legal frameworks that make our research credible and the
solutions that we wish to see implemented for the benefit of all students with invisible
disabilities.
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DEFINTIONS

This policy brief will be

utilizing the medical
model and social model
of disability frameworks in
its analysis. For reference,
the comparison table
between the two models
is provided here.

This policy brief will also

be utilizing the
accommodations model
and Universal Design
model frameworks. For
reference, the
comparison table
between those two
models is provided here.
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INTRODUCTION

What are Invisible Disabilities?

Roughly 1 in 4 Americans live with a disability that impacts their day-to-day life
(Okoro, 2018). While some of these disabilities can be visible upon first glance,
approximately 74% of adults with disabilities in the US have what are known as
‘invisible’ or ‘hidden’ disabilities (“Survey of Income and Program Participation (SIPP)”,
1995). Invisible disabilities are defined as disabilities that are not immediately
apparent, whether to the public or to the person with the disability, and can include
things like chronic illnesses, sleep disorders, autism, ADHD, and mental health
conditions. Like visible disabilities, invisible disabilities can range in severity and cause
varying levels of disablement.

“In simple terms, an invisible disability is a physical, mental, or

neurological condition that is not visible from the outside, yet can
limit or challenge a person’s movements, senses, or activities.”

-The Invisible Disabilities Association

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INTRODUCTION

Invisible Disabilities in Higher Education

While the presence of disability stretches to the beginning of time, people with
disabilities remain one of the more neglected populations in our society. They still
lack many basic rights and face constant forms of discriminatory behavior. This
oppression is often further heightened for people with invisible disabilities, where
people can often “pass” as non-disabled and struggle to access disability
accommodations because of it. One of these highly affected populations is college-
level students (students in higher education). In the 2015–2016 academic year,
approximately 19% of all enrolled undergraduate students in the United States
reported having a disability (US Department of Education, 2019). A study done in
1999 showed that around 69% of those disabilities from students in higher education
were considered ‘hidden’ (learning disabilities, ADHD, traumatic brain injury,
psychological disorders, etc.) but that number could be much higher today (Lewis et.
al., 1999). Although students in higher education are highly impacted by invisible
disabilities, access to university/college accommodations remains an entirely
complicated, strenuous, and faulty process.
In this policy brief, we will analyze how the college/university disability service
systems tend to work against persons with invisible disabilities after they are
admitted, and how this oppression is often compounded within the context of
intersectionality. The main research question which will guide our analysis is, “what
are the barriers that students with invisible disabilities face in higher education when
trying to access disability services?” Within this analysis, we will include data about the
number of students with invisible disabilities and their success in higher education,
qualitative data like specific student testimonials surrounding their lived experience,
an analysis on why accommodations are harder to access for those at the
intersections of gender, class, and race, and an analysis on the current disability
documentation/accommodation guidelines for post-secondary education institutions
in the United States.
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INTRODUCTION

Additionally, we will look at the specific ways in which structural barriers (disability
documentation process, lack of diagnosis, lack of funding for disability services) and
attitudinal barriers (interactions with professors, culture of disability services) come
together to impair educational success. Our analysis will be guided by several policy
frameworks, including the Americans with Disabilities Act (ADA), the Individuals with
Disabilities Education Act (IDEA) and the US Rehabilitation Act of 1973 (Section 504),
the United Nations Sustainable Development Goals (SDG), and the United Nations
Convention on the Rights of Persons with Disabilities (UNCRPD).

In this policy paper, we will also come to a number of important

recommendations about how to better the educational system, specifically within the
US college system, in order to make higher education disability services more
equitable for students with invisible disabilities. We will introduce our primary
conclusion, pertaining to the universal design for learning model, that the educational
system (classrooms, buildings, test resources, other accommodations) should provide
access to any student in need without the necessity for disability disclosure. Since we
realize that this is easier said than done, we will also discuss potential amendments that
could be made to the current disability accommodations model. These amendments
include adopting AHEAD guidelines, hiring more disability aware staff who can
appropriately/easily recognize students with disabilities, acquire greater funding for
students who require medical documentation, and overall loosen the current medical
documentation requirements for students pursuing disability resources.

“Whatare the barriers that students with

invisible disabilities face in higher
education when trying to access disability
services?”

INTRODUCTION
Methodology
The policy brief examines what
structural and attitudinal barriers
related to disability services hinder
access for students with invisible
disabilities on college campuses by
reviewing peer-reviewed articles and
literature relating to the subject, both
broadly for all colleges/universities in
the United States. We also narrow our
focus to a specific case study
comparison between the University of
Arizona and the University of
Washington, to serve as an example.
The main research question guiding
this literature review was “what are the
barriers that students with invisible
disabilities face in higher education
when trying to access disability
services?” As the policy brief explores
both structural and attitudinal barriers,
the brief emphasizes the importance
of anecdotal evidence as the inclusion
of the lived experiences of people with
invisible disabilities is vital to the
creation of impactful policy
recommendations.
Many of the sources selected
were found with the use of the UW
Libraries database, as well as Google
Scholar.
8
Examples of search terms that were
most relevant to the brief were
“invisible disabilities,” “university,”
“disability documentation,” and
“disability resources.”
In regard to its scope, the policy
brief prioritizes literature detailing the
experiences of students with invisible
disabilities specifically on American
college and university campuses,
except for one source that includes the
stories of attitudinal barriers faced by
students with invisible disabilities that
were universal in their meaning. The
policy brief excludes sources
regarding students with invisible
disabilities in K-12 education and limits
the scope to university campuses,
specifically the University of
Washington and the University of
Arizona.
Though the policy brief
emphasizes the analysis of race,
gender, class, and disability type as
identities that can further complicate
the process in accessing services,
there was not a significant number of
articles that explored the intersection
of these various identities – only the
examination of singular identities.
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INTRODUCTION

Policy Framework
For this policy brief we will be relying on multiple portions of the Americans with
Disabilities Act (ADA) and the 2008 amendments, the United Nations Sustainable
Development Goals (SDG), the United Nations Convention on the Rights of Persons
with Disabilities (UNCRPD), the Individuals with Disabilities Education Act (IDEA) and
the US Rehabilitation Act of 1973. While all five of these legal frameworks are important
for people with disabilities, there are particular sections that are most relevant to our
research.

United Nations Convention on the Rights of Persons

with Disabilities (UNCRPD)
• Recognizes disability from a social model perspective and
emphasizes the importance of Universal Design (preamble)
• Asserts the right of people with disabilities to full access to the
general education system and assures the right to reasonable
accommodation.
• "Persons with disabilities receive the support required, within the
general leducation system, to faciliate their effective education."
(Article 24)

United Nations Sustainable Development Goals

• "Ensure inclusive and equitable education and promote
lifelong learning opportunities for all." (SDG 4)
• "...build effective, accountable and inclusive institutions at all
levels." (SDG 16)
• Reaffirms the right of people with disabilities to access their
education, and places responsibility on the institutions to
remain inclusive.
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INTRODUCTION

Americans with Disabilities Act (ADA)

• Defines disability as being "person who has a physical or mental
impairment that substantially limits one or more major life activities, a
person who has a history or record of such an impairment, or a person
who is perceived by others as having such an impairment."
• ADA Amendments of 2008 broadened the defintion of disability to
ensure that institutions would not interpret the ADA definiton too
narrowly.
• "No qualified individual with a disability shall, by reason of such
disability, be excluded from participation in or be denied the benefits
of services, programs, or activities of a public entity, or be subjected to
discrimination by any entity." (Section 12132).
• This is what sets up the expectation for higher education institutions
to provide disability accommodations, so that they can fully
participate in the education process and receive it's benefits.
• Does not explicitly require institutions to collect disability
documentation, but also does not explicitly forbid it.

Section 504 of the 1973 Rehabilitation Act

• "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
discrimintation under any program or activity receiving Federal
financial assistance." (Section 504)
• Defines 'program or activity' as "a college, university, or other
postsecondary institution, or public system of higher education."
(Section 2A)
• In this case, 'discrimination' would mean a failure to provide
reasonable accommodations to students with disabilities in higher
education settings (for institutions that are federally funded).

Individuals with Disabilities Education Act (IDEA)

• States that K-12 educational institutions are responsible for
conducting an evaluation for disability when a school professional
believes that the student may have a disability (Part B).
• This means the burden of seeking documentation for a disability rests
on the educational institution, NOT the student or the student's family
themselves.
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ANALYSIS
OVERVIEW

Overview
Within the existing legal framework that post-secondary education institutions
must follow to ensure access for disabled students, there are several ways in which
students with invisible disabilities are left behind. Structural challenges (specifically,
policies that require medical documentation in order to receive accommodations) are
embedded into the institutions in ways that are often difficult to untangle. On top of
that, students with invisible disabilities face additional discrimination in the form of
attitudinal barriers when interacting with faculty, staff, and other students who do not
perceive their disability as valid. Students with invisible disabilities who also share other
intersecting identities like women or students of color may be left behind at even
higher rates. The following section will dig deeper into each of the listed barriers that
students with invisible disabilities face in higher education.

Structural Barriers
• Requiring disability documentation can pose a huge barrier,
disproportionately impacting students with invisible
disabilities

Attitudinal Barriers
•Professors often question the accommodations presented by
students with invisible disabilities, classifying them as invalid
or an 'unfair advantage'.
•Disability services offices are known to hold ableist attitudes
based off the Medical model of disability, resulting in
unpleasant experiences for students seeking services

Intersecting Identites
•Racial bias in medical settings have caused historic distrust between communities
of color and medical institutions, which potentially poses a barrier for students of
color with disabilities seeking documentation
•Women with invisible disabilities (specifically, ADHD and autism) are often
diagnosed later in life due to gender gaps in research, which potentially means
women are being disproprotionately impacted by documentation requirements.
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STRUCTURAL
BARRIERS

Disability Documentation
A major structural barrier for students with invisible disabilities in higher
education is accessing disability accommodations. According to the ADA, as
mentioned in ‘Policy Framework’, there is no legal mandate for higher education
institutions to require medical documentation of disability for students to get disability
accommodations (AHEAD, 2012). However, it is common practice for colleges and
universities to do so, as a way to determine who is part of the ‘protected class’ under
the ADA. According to the Office for Civil Rights under the US Department of
Education, “Schools may require you to provide documentation prepared by an
appropriate professional, such as a medical doctor, psychologist, or other qualified
diagnostician.” (Duncan 2020). In basic terms: colleges and universities are not
required to ask for medical documentation, but they are allowed to, as long as it serves
as “reasonable” and relevant to the requested accommodation.
Some institutions will grant accommodations based on a combination of
students’ self-report, observation of disability services staff, and external
documentation like an Individualized Education Plan (IEP) from their K-12 education.
Other institutions have strict, extensive requirements for medical documentation from a
licensed provider to ensure that the student does indeed have a disability. There is no
standardized law for all post-secondary education institutions to follow in terms of
collecting disability documentation.
For students with invisible disabilities, the strict requirement to obtain medical
documentation can create a huge barrier to accessing services. Students with visible,
physical disabilities often have a much easier time getting medical documentation, and
do not require as much extensive disability documentation. In practice, universities
tend to lean more on the student self-report and observation from disability services
staff in order to grant accommodations to students with visible physical disabilities, as
they are more obvious and ‘easier to evaluate’ (Rocco, 1998). On the other hand, the
burden of medical documentation tends to fall heavily on students with invisible
disabilities. These types of disabilities often require extensive psychometric testing,
and disability services offices will request that this testing be done at the expense of
the student (Whisler-Smith, 2013). This may result in those students being denied
services at disproportionate rates or create a burdensome process to the point where
students are discouraged from even attempting to get disability services. The over-
reliance on the medicalization of disability then becomes a huge barrier for students
with invisible disabilities in seeking accommodations at higher education institutions.
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STRUCTURAL
BARRIERS

Disability services offices around the United States tend to be underfunded and
understaffed (Harbour, 2008). The chances that they will have someone on staff who is
clinically trained and feels confident enough to determine by ‘observation’ if a student
has a psychological or learning disability are extremely low. Instead, students are often
encouraged to seek diagnosis elsewhere, with very limited support.
The cost for a medical evaluation outside of college or university support can be
incredibly high, making it near impossible for those without health insurance to pay for.
For example, testing for ADHD takes several months and ranges from a few hundred
dollars to thousands of dollars, if not covered by health insurance (“ADHD” 2010). If a
student is disconnected from their parents’ medical insurance or comes from a low-
income family that doesn’t have medical insurance, the cost of testing could pose a
huge barrier in accessing the accommodations they need. The length of time that
testing requires could also pose a barrier; every day that testing is happening means
another day that a student is struggling to be successful in their classes without the
accommodations they need. For students who do not have sufficient health care
coverage, this medical documentation requirement can mean the difference between
success in higher education and dropping out.

“The medicalization of accommodations

many times negatively hinders students’
ability to acquire the accommodations
that they need to be successful.”
-Mona Whisler Smith, “Exploring the Disabled Experience in
Higher Education: Voices of Students with Invisible Disabilities”
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STRUCTURAL
BARRIERS

Requiring specific, extensive medical documentation in order to get the

accommodations needed to be successful in one’s education can then be considered
a ‘burdensome process’, which goes against the ADA amendments provided from a
court case against Boston University in 1997. This states that “a university is prevented
from employing unnecessarily burdensome proof-of-disability criteria that preclude or
unnecessarily discourage individuals with disabilities from establishing that they are
entitled to reasonable accommodation” (“Guckenberger v. Boston University” 1997).
Even with this precedent in place, students around the U.S. are still struggling to get
their accommodations, as shown by an online publication from the U.S. Department of
Justice stating that “the Department continues to receive questions and complaints
relating to excessive and burdensome documentation demands” (“Testing
Accommodations”). There is a clear need for new policy implementation in order to
address this gap between what the ADA intended and what is currently practiced in
many university settings.

GUCKENBERGER et. al.

V BOSTON UNIVERSITY
August 15, 1997

Class action lawsuit brought by students with ADHD, ADD and

learning disabilities against Boston University under the ADA,
Section 504 of the Rehabilitation Act, and state law. The
students claimed that Boston University discriminated
against the those with learning disabilities by (1) establishing
unreasonable, overly burdensome eligibility criteria for
qualifying as a disabled student and (2) failing to provide
reasonable procedures for evaluation and review of a
student's request for accommodations.
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STRUCTURAL
BARRIERS

Case study:
University of Arizona and University of Washington
At the University of Arizona, for example, there
are very flexible and broad guidelines around
disability documentation. Their Disability Resource
Center website encourages students to explore
accommodations even if “you do not have
documentation, or your documentation is
outdated.” (Arizona Disability Resource Center,
n.d.). Their webpage states that “A conversation
about your experiences and expectations will help
determine if additional information is necessary to
support your accommodation requests,” showing
that documentation is not always necessary to
demonstrate need for accommodations.
The University of Washington (UW), on the other hand, tells a very different story.
UW’s Student Governance Policies state that medical documentation can be requested
by Disability Resources for Students (DRS) when “the reasonableness of a requested
accommodation is not readily apparent” (University of Washington, 2019). However,
the DRS website suggests that documentation is necessary in all cases, stating that
“Documentation that establishes the nature of a disability and/or health condition as
well as its impact for the student in the educational environment is needed to support
requested accommodations.” (“Getting Started”). Their ‘Documentation Guidelines’
website features a list of requirements, which includes things like a formal diagnosis
and the signature, contact information, and license number of a ‘qualified healthcare
provider’ (“Documentation Guidelines”). That website also includes subpages with
specific requirements for learning disabilities, traumatic brain injuries, ADHD, and
psychological disabilities, which appear to be far more extensive than other types of
physical disabilities. The only guidance provided for students who do not have this
type of documentation is that “Provisional accommodations may be established while
additional documentation is being obtained.” In practice, this often means
accommodations selected from a very limited available list and are not usually what the
student actually needs in order to achieve academic success. At UW, the student is
clearly still expected to obtain the additional documentation, which means the burden
still falls on the student in the end.
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STRUCTURAL
BARRIERS

An external report on UW’s One student writes in a Disability

Disability Studies, Services, and Programs
done by Dr. Sue Kroeger from the
University of Arizona in 2010 showed
many issues with the UW’s Disability
Services Office (DSO) and Disability
Resources for Students (DRS). After
interviewing 30 people within disability
organizations at the University of
Washington, Kroeger concluded that
“DRS and DSO spend a great deal of
time obtaining documentation and
verifying that individuals are eligible for
services and accommodations.” (Kroeger,
2010). This focus on eligibility prevents
DRS and DSO from focusing on the
broader, institutional-level changes that
need to be made to ensure accessibility
for disabled students, and instead
creates a narrow lens on the negative,
medical aspect of disability. Such a
narrow lens influences the culture of
disability services at UW’s campus in a
dramatic way, as shown by the students
themselves.
Connections Blog, “I had to prove I was
‘disabled enough’ in order to receive
accommodations and then have someone
else validate that I met some standard,”
referencing the struggle to access sufficient
paperwork when they were already aware
of what their disability was (“Challenging
One’s Identity”, 2020). During a community
forum for Autistic and Neurodivergent
students held in February 2021, multiple
UW students expressed frustration at the
‘disability tax’: the additional cost of time,
money, and energy that is required of
disabled students in order to access the
resources they need to be successful on
the same level as nondisabled students.
Kroeger’s report added that “several
students (graduate and undergraduate)
stated that they felt they ‘had to minor in
self-advocacy to obtain degrees,’ and
another added that service practices made
them feel like an ‘inconvenience.’”
(Kroeger, 2010).

DRS Mission Statement:

“Disability Resources for Students (DRS) recognizes disability as an

aspect of diversity that is integral to society and to our campus
community. DRS serves as a partner in fostering an inclusive and
equitable environment for all University of Washington students.”

If an equitable environment were really the priority, students would not

feel as though accessing their DRS services was a burdensome,
unreasonably difficult process.
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ATTITUDINAL
BARRIERS

Attitudes of Professors
Attitudinal barriers faced by students with invisible disabilities are harder to
quantify as many of them are classified by the lived experience of the students
themselves. As students experience the majority of their university-related
interpersonal interactions with their professors, these interactions are often where
students face ableist barriers. When the university fails to implement structural
components to protect students with invisible disabilities, professors wield significant
discretion over the accommodations that students receive. And in the case in which the
university does provide structural support (i.e., accommodations) to students with
disabilities, the professors are the ones who are charged with implementation, and
students still run into attitudinal barriers. One student described their experience as,

“A lot of professors are very accepting, but I do, I do feel like sometimes
they feel like you’re trying to get away with something. And I also think
that, that the act of asking them is a bit degrading where, you know,
because it should be your right.”
(Mullins & Preyde, 2013: 155)

This anecdote exemplifies the ways in which the professor is using a medicalized
model of assessing the need for support; students with invisible disabilities, who do
not have the necessary documentation to prove their need for accommodations, must
not only prove their need for support but also argue that they are not exaggerating
their circumstances.
These conversations with professors do not always happen in private. One
student expressed feeling alienated when their professor had asked the student to
identify themselves to receive accommodations in the 200-person lecture hall. (Bê,
2019: 184) Another student conveyed that when she mentioned her dyslexia to her
professors halfway through a course, her lecturers “were extremely exasperated” and
believed that “she had deceived them unnecessarily as they had spoken positively
about the dyslexic assistance at induction.” (Matthews, 2009: 232) In this instance, this
student’s professors did not recognize that stigma or the lack of systemic guidance
could hinder students from openly admitting their disability; instead, the professors
placed the onus and blame on the student for “deceiving” them. Once a student
identifies themselves as disabled to their professor, the lack of centralized, institutional
support and guidance allows for the professor to become either an ally or an adversary
to the student.
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ATTITUDINAL
BARRIERS

Another component that reinforces the attitudinal barriers experienced by

students with invisible disabilities is the over-reliance upon adjunct professors by the
university. This structural component influences the degree to which professors will be
receptive to students with invisible disabilities. In “Supporting College and University
Students with Invisible Disabilities,” Christy Oslund questions whether adjunct
professors receive the proper training and access to resources to assist students with
invisible disabilities. These areas include information of services offered, access to IT
education, and compensation for attending trainings. (Oslund, 2013: 138) Without
centralized support, adjunct professors could have limited experience and training to
accommodate students with invisible disabilities and perpetuate attitudinal barriers.

Culture of Disability Services Offices

The culture of on-campus disability resources is another area in which attitudinal
barriers present challenges to students with invisible disabilities. A general complaint
with higher education disability services offices is focused on the lack of personalized
support given to students with invisible disabilities (Bryant, 2014: 88). The root of this
issue is the lack of institutional and financial support given to disability services offices
from their colleges and universities, and its effect is that disability services staff are
overburdened with enormously large caseloads and have limited bandwidth to give
specialized support to students with invisible disabilities (Harbour, 2008).
There is additional concern from students with invisible disabilities that disability
services offices directly contribute to the medical-model-culture that places the onus to
access accommodations on the students. As disability services offices offer services to
students who can provide medical documentation to support their diagnosis, students
who may not have the financial resources to be evaluated by a medical professional
must become their own advocate. As there are limited disability resources specifically
designed for students with invisible disabilities, these students are unfairly expected to
value “self-determination” in their pursuit of support. These students must reason with
their professors or with their own disability services office on their campus to access
basic accommodations and be guaranteed equal opportunity in the classroom. When
the “cookie-cutter” approach to disability services does not work for students with
invisible disabilities, those students have reported feeling pressured to agree to
accommodation models that do not suit them. (Bryant, 2014: 88-89) In correcting
attitudes toward students with invisible disabilities, there must be focus given to
disability services itself.
 19
INTERSECTING
IDENTITIES

Race and Medical Diagnoses

Black and brown students with invisible disabilities face a set of unique barriers
when navigating disability resource settings. Regarding the requirement for medical
documentation to receive accommodations from the university’s DRS, the must be
acknowledgement of the extensive history of distrust felt by Black Americans toward
the medical system. Certain marginalized communities have a historically based
distrust of the medical system, causing them to avoid medical centers altogether,
which may discourage individuals from seeking a diagnosis to begin with. For example,
Black Americans have a long history of being misdiagnosed by medical professionals,
particularly with mental illnesses (Schwartz 2014). That, in combination with racial bias,
has resulted in a community-wide common distrust of the medical system more
broadly, may indicate that it’s less likely for Black Americans to feel comfortable
seeking medical diagnoses for disabilities they may have. This trend remains true for
many other marginalized groups as well, including LGBTQ+ folks, those who don’t
speak English, and other racial minorities like Native Americans or Latine populations.
Though not specific to university students, the American Psychiatric Association
published a report in 2015 that detailed the causes and implications of mental health
disparities for Black Americans. The report notes that “compared with whites with the
same symptoms, African Americans are more frequently diagnosed with schizophrenia
and less frequently diagnosed with mood disorders.” (American Psychiatric
Association, 2017) Although there is a need for further research on these trends
among college students, there is still a strong possibility that when university
institutions demand medical documentation in order for students to receive
accommodations, it forces Black and brown students to participate in a system that
does not serve them with dignity or humanity. An overreliance on a medicalized model
does further harm in corroding the trust between disability services and Black and
brown students with invisible disabilities.
 20
INTERSECTING
IDENTITIES

Gender and Diagnosis Disparities

In addition to race playing a factor in the accessibility of disability documentation,
there is significant evidence that gender may have a role as well. When it comes to
many invisible disabilities (more specifically, ADHD and autism), women tend to be
diagnosed at later stages of life rather than earlier (Fuller-Thomson, Lewis, & Agbeyaka,
2016; Bargiela et. al., 2016). There are a few potential reasons for this. One potential
cause of the diagnosis disparity is that the majority of published research on ADHD
and autism is based on samples that primarily (or exclusively) consist of boys (Mahone
& Wodka, 2008; Bargiela et. al., 2016). This trend is similar for many types of other
disability-related research. Women are less likely to be recruited into clinical trials, and
there is significantly less funding provided, on average, to women-specific research
studies (Holdcroft, 2007), leading to male-dominated perceptions of what certain
disabilities look and behave like.
In addition to this, women are often better at masking their disability-related
behaviors in an effort to “match elevated expectations of women in society”, especially
Autistic women (Milner et al., 2019). All in all, female-specific phenotypes of ADHD and
autism are significantly under-researched, and that heavily impacts the perception of
ADHD and autism for school professionals as they are looking at children’s behavior
and recommending which ones should be evaluated for those disabilities. In K-12
education, girls aren’t evaluated for ADHD and autism as often as boys, which means
when they proceed to post-secondary education, they are no longer supported by the
institutional responsibility for evaluations imposed by the IDEA and are now left to seek
out and pay for their own testing. There is a significant lack of research on women with
invisible disabilities in higher education when it comes to accessing disability services
and formal diagnoses. However, given that women are typically diagnosed more at
later ages, it would stand to reason that at college age, women would be more
impacted by the strict requirement for formal documentation in order to receive
accommodations. More thorough research is desperately needed in this area before
making any definite assertions.
 21
RECOMMENDATIONS

Universal Design
The current accommodations model utilized by post-secondary education
institutions is deeply flawed. In addition to the argument posed already regarding
difficulty of accessing disability accommodations when formal documentation is
required, there are other issues as well. Studies have shown that many
accommodations offered by disability services are “based on physician
recommendations and are often not evidence-based nor are they responsive to the
individual contexts of students with disabilities” (Weis, Dean & Osborne, 2016). Other
concerns arise from faculty themselves, who are often unaware of their federal
responsibility to implement accommodations, hold “ambivalent attitudes” about
supporting students with disabilities, and sometimes hold misconceptions about
accommodations as special treatment rather than equal access (Parker, Gould & Mullin,
2019).
One of the most effective ways in which we could address these structural and
attitudinal barriers towards people with invisible disabilities in higher education is
through the implementation of Universal Design in higher education institutions.
Universal Design can be defined as “the design and composition of an environment so
that it can be accessed, understood, and used to the greatest extent possible by all
people regardless of their age, size, ability, or disability” (“What is Universal Design”).
 22
RECOMMENDATIONS

Accommodations Model Adjustments and Supports

If higher education institutions are to stay with the current accommodations
model of addressing the needs of disabled students, then there are several ways
through which they could support students with invisible disabilities. Institutions could
adopt AHEAD guidelines on documentation requirements, which allow for more
prioritization of a students’ self-report and secondary observation from disability
service staff as opposed to only relying on medical documentation. Colleges and
Universities could hire more clinically trained staff who are more comfortable
evaluating the needs of students with psychiatric and learning disabilities. All disability
services staff could receive training on the social model of disability, to ensure they
aren’t evaluating students purely from a medical standpoint. Finally, institutions could
provide financial and logistical support to students who are asked to provide medical
documentation, so that the burden of obtaining it does not fall entirely on the students.

Providing
Hiring Clinically financial and
trained Disability logistical support
Services to pursue
Professionals disability
documentation
Social Model
training for
Disability
Services staff

Utilizing AHEAD
documentation
guidelines
 23
RECOMMENDATIONS

Utilizing AHEAD documentation guidelines

The AHEAD (Association on Higher Education and Disability) conceptual
framework “reflect a more mature understanding on disability that is essential for
fostering a positive campus perspective on disability”, which means moving away from
the medical model of disability and focusing on making the environment accessible
instead (“Supporting Accommodation Requests”). This conceptual framework outlines
the various types of documentation that a student should be able to use in order to get
accommodations. The primary type of documentation is a student’s self-report.
According to AHEAD, “It is often possible to evaluate whether a requested
accommodation is reasonable or not with minimal reliance on external documentation.”
The students themselves are the primary source of their experience, so listening and
validating their experience of disability is much less stressful than needing to rely on
medical documentation. If, for any reason, the student’s self-report isn’t clear or
convincing enough, you can also rely on observation and interaction with the student
(secondary source). Those who are granting accommodations should be experienced
disability professionals, so leaning on their own experiences of disability-related
interviews and using that to observe and evaluate the students’ claims about disability
should be a comfortable, easy process. Keep in mind that this should not be done
through a criticizing, medical lens, but rather one of validation, kindness, and sensitivity.
The advisors in disability services offices shouldn’t be the gatekeepers of
accommodations, but the guides to success.
If, for any reason, these two types of documentation are not enough, then AHEAD
recommends seeking out the third type of documentation: “information from external or
third parties”. This may include many different sources like educational or medical
records, reports from psychologists, teachers, or the educational system broadly.
Examples of these kinds of records include IEPs or Section 504 plans provided by K-12
educational systems. Even within this category, there are still many other alternatives to
medical documentation that should be sufficient to prove a need for accommodations,
according to AHEAD standards.
Adopting this alternative as legal policy would need to happen on a federal
level, so that the guidelines don’t vary dramatically from state to state. If it were
implemented, it would give students the legal grounding they would need to go after
the colleges that are demanding too much documentation.
 24
RECOMMENDATIONS

Hiring Clinically Trained Disability Services Professionals

Ensuring that each disability services office is staffed with clinically trained
professionals (with experience understanding psychiatric and learning disabilities)
would allow them to rely more on observation (secondary report) rather than medical
documentation. This becomes particularly important when it comes to students with
invisible disabilities. If you have clinically trained staff, they should know what questions
to ask in order to fully evaluate the barriers that the student is facing in relation to their
educational experience. The clinically trained staff would not need to provide a formal
diagnosis, as that is not legally mandated, but rather provide a clear and concise
evaluation of the student’s current needs through the lens of their clinical training.

Providing Social Model of Disability training to Disability Services Staff

Currently, disability services offices tend to operate on a very medical-model basis,
treating a students’ disability as if it is only valid once a licensed medical professional
deems it to be. If higher education institutions were to provide social model training to
all disability services staff, it would encourage them to look at their evaluations of
students in a more holistic way. It would help them to understand disability as
something that is created (and fluctuates) through interactions between the body/mind
and the environment, which results in a more thorough, individualized assessment
process for the student.

Providing Financial and Logistical Support to Pursue Medical

Documentation
If higher education institutions insist on collecting medical documentation, then
they must provide support to the student to ensure it is not a ‘burdensome process’.
This could take the form of financial support (subsidizing the cost of medical
evaluations) for students who are asked to pursue it and cannot afford it, or logistical
support. This could include things like providing temporary accommodations that are
actually effective, providing a list of medical professionals who could conduct testing,
and offering general counseling through the process overall. However, financial support
doesn’t necessarily address the complex needs of students of color who have
experienced trauma within the medical system, or students who do not feel comfortable
becoming formally diagnosed yet.
 25
RECOMMENDATIONS

As discussed, disability resource services offices are often financially constricted

and end up not offering specialized services to students with invisible disabilities. One
way in which additional funding can be appropriated to these support offices, as well
as health insurance expansion and coverage, is through the implementation of an opt-
out student health insurance plan. This is imperative to ensure coverage to all students,
regardless of class background, as well as the growth of evaluations and logistical
guidance offered by in-house medical professionals.

Disability Sensitivity Training

In order to address the attitudinal barriers that students face when interacting
with faculty, staff, and other students, disability sensitivity training could be
implemented at all levels within a higher education institution, including to adjunct
professors. Such training could include information about what qualifies as a disability
(paying special attention to invisible disabilities), preferred language, and dispelling
myths around students being ‘lazy’ or ‘not looking disabled’. Such training could take
place in student orientations, department faculty meetings, in introductory classes like
First Year Interest Groups or basic curriculum classes, etc. We would strongly
encourage these trainings to be mandatory for all faculty, staff, and onsite personnel,
seeing as most of the negative experiences come from professors who would be least
likely to opt-in to such a training.

Resources for Disability-Specific Communities

For some students with invisible disabilities, specialized resources may be helpful to
ensure their success in higher education. This could include increased mental health
support for students with psychological disabilities (could also identify as Mad/mentally
ill). Another example is resources dedicated for neurodivergent and/or Autistic
students like peer support groups, specialized community/peer advocates and opt-in
support with organization and scheduling.
Attention must also be given to hiring Black and brown medical providers in disability
resource settings. And there must be cultural competency training given to all mental
health practitioners in disability resource spaces to begin removing attitudinal barriers
that hinder the access to mental health support for Black and brown students.
 26
RECOMMENDATIONS

Increased Research on Intersecting Barriers

As mentioned in the ‘Intersecting Identities’ section, there is a lack of data on how
many students of color with invisible disabilities there are enrolled in higher education,
what their graduation rates are, and their experiences accessing disability services.
There is also a lack of data on women with invisible disabilities in higher education
regarding their ease in accessing disability documentation given that they are
diagnosed disproportionately at later ages. Both of these intersections need further
research in order to find specific, effective solutions to the barriers these communities
may be facing.

Summary of Recommendations

Universal Design

Accommodations Model Adjustments and Supports

• Utilizing AHEAD documentation guidelines
• Hiring more clinically trained disability services staff
• Social Model of Disability training for disability services staff
• Providing financial and logistical support in seeking disability documentation

Disability Sensitivity Training

Resources for Disability-Specific Communities

Increased Research on Intersecting Barriers

 27
CONCLUSION

Throughout this policy brief, we analyzed available data about the structural and
attitudinal barriers that students with invisible disabilities face in higher education when
acquiring and utilizing accommodations, in part, through an intersectional lens.
Although many of these barriers arise before a student's introduction into higher
education, we explore how these barriers can be heightened and enforced through the
current disability resource services format in higher education, which tends to have a
high reliance on accommodations model informed by the medical model of disability.
Overall, our policy brief is an initial effort to address the overwhelming lack of
accommodations and support for students with invisible disabilities, in both the
University of Washington and other higher education institutions. Our goal within this
policy brief is to begin breaking down the barriers that students with invisible disabilities
face while attempting to access disability resources, so that students with invisible
disabilities can complete college and thrive whilst doing so.

While we were able to acquire data about the approximate number of people with
invisible disabilities in higher education (approximately 19% of enrolled graduates have
a disability and roughly 69% of those disabilities are invisible (Lewis et. al., 1999)), there
is a significant lack of data about the completion/success rates of students who
specifically have invisible disabilities. There is, however, some available data about
completion rates for students with disabilities, in general, in higher education, as “only
34% of students with disabilities are able to complete a four-year degree within eight
years, compared to 51.2 percent of the general population” (Newman et. al., 2011). This
data remains extremely relevant to the main point of our research, in that, if universities,
college campuses, and disability services don’t make an active effort to address the
barriers that students with invisible disabilities (and disabilities in general) face, then the
disabled college student population will still struggle to complete their classwork and
their degree on the same level as their non-disabled peers.

Alternatively if disability services and college campuses begin to address this

divide through measures like universal design, adopting AHEAD guidelines, hiring
clinically trained disability services professionals, providing social model of disability
training to disability services staff, providing logistical and financial support for students
pursuing medical documentation, providing disability sensitivity training for all members
of faculty, and pursuing further research into the barriers students with intersecting
identities face, higher education institutions can promote educational success and
equity for all of their students, rather than catering to an able bodied majority.
 28
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