Accommodations by Disability and Medical Condition

Disability law does not work by diagnosis. There is no list that pairs a condition with the accommodations it entitles you to, and any school that behaves as though there is has already made a mistake. What the law asks is whether an impairment substantially limits a major life activity for you, and then what you need in order to have equal access.

180 daysGeneral deadline to file a disability discrimination complaint with the Department of Education’s Office for Civil Rights, unless OCR extends it. 34 C.F.R. § 100.7(b), applied by § 104.61.
45 daysThe longest a school can take to let you inspect your own education records after you ask. 34 C.F.R. § 99.10(b).
§ 104.44The Section 504 rule that requires academic adjustments, fair exam formats and auxiliary aids at colleges — and says what a college need not provide.
No list“Disability” is read in favor of broad coverage, and a condition that comes and goes counts if it would substantially limit you when active. 42 U.S.C. § 12102(4)(A), (D).

Find your condition

The Office for Civil Rights has published condition-specific guidance for a growing number of medical and mental health conditions, and that guidance is genuinely useful. It tells you which major life activity or bodily function OCR associates with the condition, and it gives concrete examples of modifications schools have provided. The pages below work through that guidance condition by condition.

Two framing points before you read any of them.

These lists are examples, not entitlements and not limits. OCR says elsewhere, in terms, that there is no list of all possible academic adjustments, because adjustments must be individualized and sometimes the right answer is a new solution rather than an off-the-shelf one.

Your condition may not have a fact sheet, and that means nothing. OCR has published on a particular set of conditions. The absence of a page for yours says nothing about whether you are covered.

Learning, attention and mental health

ADHD — the most detailed guidance OCR has issued on any condition, including a presumption that matters.
Learning disabilities and dyslexia — reading speed, processing and extended time, and why strong grades do not settle the question.
Autism — no OCR fact sheet, but on the Justice Department’s list of conditions that should, in virtually all cases, qualify.
Anxiety disorders — OCR’s 2024 fact sheet lists a single dorm room at the reduced double-room rate.
Depression — OCR says a school cannot hold a student on medical leave for depression to a fixed leave period it does not impose on students without disabilities.
Bipolar disorder — on the Justice Department’s list, and episodic — which the statute covers when the condition is active.
PTSD — on the Justice Department’s list; attendance flexibility, trigger-related adjustments and the Title IX overlap.
OCD — on the Justice Department’s list; OCD costs time, which is exactly what a timed exam measures.
Eating disorders — including excusal from a required meal plan.

Neurological, sensory and speech

Epilepsy and seizure disorders — epilepsy is on the Justice Department’s list; OCR’s fact sheet separates before, during and after a seizure.
Migraine — OCR names non-fluorescent classroom lights and permission to wear sunglasses or a hat in class.
Narcolepsy — short scheduled naps, and a class schedule built around the hours you are most alert.
Traumatic brain injury and concussion — traumatic brain injury is on the Justice Department’s list, and an impairment lasting less than six months can still qualify.
Deaf and hard of hearing — deafness is on the Justice Department’s list; interpreters, CART and clinical placements.
Blind and low vision — blindness is on the Justice Department’s list; accessible materials that arrive late are the usual failure.
Stuttering — OCR’s fact sheet frames the impact around classroom participation rather than grades.

Chronic and physical conditions

Diabetes — on the Justice Department’s list; OCR’s exam rule is to reschedule if blood sugar is high and pause the clock if it drops.
Cancer — on the Justice Department’s list; OCR’s fact sheet covers treatment as well as the disease.
Sickle cell disease — OCR ties it to the circulatory system and eight other major bodily functions.
Asthma — OCR’s shortest fact sheet, and what it does and does not support.
Long COVID — the subject of joint federal guidance in July 2021 confirming it can be a disability.
POTS and dysautonomia — posture-dependent and episodic, which collides with long standing rotations and three-hour exams.
Crohn’s and colitis (IBD) — restroom access during exams, with the clock paused.
GERD and acid reflux — among the most dismissed conditions, because heartburn is universal.
Food allergies — most of the work happens outside the classroom — in dining halls, at events and in residence.

Every condition, A to Z

ADHD · Anxiety disorders · Asthma · Autism · Bipolar disorder · Blind and low vision · Cancer · Crohn’s and colitis · Deaf and hard of hearing · Depression · Diabetes · Eating disorders · Epilepsy · Food allergies · GERD · Learning disabilities and dyslexia · Long COVID · Migraine · Narcolepsy · OCD · POTS · PTSD · Sickle cell disease · Stuttering · Traumatic brain injury

A note on OCR guidance

Every one of these fact sheets carries the same disclaimer, and it deserves repeating rather than burying: the guidance does not have the force and effect of law and is not binding beyond what statute and regulation already require, and all enforcement determinations OCR makes are based on the particular factual circumstances presented in each individual case. That is not a reason to discount it. It is a reason to understand what it is — the enforcement agency’s own account of how it reads the law, which is worth a great deal in a conversation with a disability services office, and rather less in a courtroom.

Every page in this section now cites the OCR document it draws on. The full set lives on the Department’s own index of condition-specific guidance, alongside The Civil Rights of Students With Hidden Disabilities and Section 504.

This is an individualized, fact-specific inquiry

Every determination described on this page is individualized. The Department of Education’s Office for Civil Rights says so directly: asked whether there is a list of all possible academic adjustments, OCR answers no — adjustments “must be individualized,” and “sometimes the most effective and practical academic adjustment for a given situation is a new solution rather than an off-the-shelf response.”

The lists on this page are examples. They are not comprehensive, they are not a menu, and they are not a ceiling. Two students with the same diagnosis can need entirely different adjustments, and OCR’s own guidance uses paired examples to make that point — one student whose treatment plan calls for supervision, another whose plan calls for privacy, same condition, opposite accommodation. A school that applies a fixed package to everyone with a particular condition has already made an error, whatever the package contains.

Nothing here predicts what any particular school will do, or what any particular student is entitled to. That depends on facts this page cannot know.

The law that governs a college accommodation request

Two statutes do the work. Section 504 of the Rehabilitation Act, 29 U.S.C. § 794, reaches every school that takes federal money — which is very nearly all of them. The ADA covers the rest: Title II for public colleges and universities, Title III for private ones as places of public accommodation. In the Eleventh Circuit, which governs Florida, claims under the two are analyzed under the same standards.

The regulation that actually decides most disputes is 34 C.F.R. § 104.44, and it is worth knowing what it says on both sides of the line.

What it requires. A college must modify academic requirements where necessary so they do not discriminate — and the regulation names examples: changes in the length of time permitted to complete a degree, substitution of specific courses, and adaptation of how a course is conducted. It requires modified examination formats so that results measure achievement rather than the disability, unless the disability is what the test is measuring. And it requires auxiliary aids — taped texts, interpreters, library readers, adapted classroom equipment.

What it expressly does not require. The same regulation says a college need not provide attendants, individually prescribed devices, readers for personal use or study, or other devices or services of a personal nature. A student who asks for a personal aide or a personal reader is asking for something § 104.44 does not oblige the school to supply, and it is better to know that at the outset. The regulation also provides that academic requirements the school can demonstrate are essential to the instruction, or to a directly related licensing requirement, are not discriminatory.

“Otherwise qualified” — and where Florida students lose

Protection runs only to a student who is “otherwise qualified.” Under Southeastern Community College v. Davis, 442 U.S. 397 (1979), that means able to meet the program’s requirements in spite of the disability, and the statute does not require substantial modifications to the program itself. The Eleventh Circuit put it plainly in Goldberg v. Florida International University, 838 F. App’x 487 (11th Cir. 2020): a qualified student is one who can meet the program’s academic standards with or without accommodations.

The recent Florida cases show where that bites. In Nehme v. Florida International University Board of Trustees, 121 F.4th 1379 (11th Cir. 2024), a medical student who failed at least eight courses — five of them after being placed on academic probation — was held not to be a qualified individual, and it counted against him that he conceded he had received proper accommodations for four of the failed exams. In J.A.M. v. Nova Southeastern University, 646 F. App’x 921 (11th Cir. 2016), repeated extended leaves of absence, exam rescheduling and excusal of misconduct were held to be accommodations that would fundamentally alter an osteopathic medicine program.

The practical lesson runs the other way, though, and it is the reason timing matters more than almost anything else: accommodations are forward-looking. A request made after a run of failures is fighting the record those failures created. The same request made before them is a different case entirely.

The school has to actually think about it — the strongest student-side rule

Deference to academic judgment is real. Courts will not override a genuinely academic decision unless it is “such a substantial departure from accepted academic norms as to demonstrate that the person or committee responsible did not actually exercise professional judgment” — Regents of University of Michigan v. Ewing, 474 U.S. 214, 225 (1985) — and courts in Florida give the same respect to a school’s judgment about the qualifications its program requires. But deference is earned, not assumed, and that is where cases are won.

Under Wynne v. Tufts University School of Medicine, 932 F.2d 19 (1st Cir. 1991) (en banc) — applied in Florida in Forbes v. St. Thomas University, 768 F. Supp. 2d 1222 (S.D. Fla. 2010), aff’d, 456 F. App’x 809 (11th Cir. 2012) — a school has “a real obligation” to “seek suitable means of reasonably accommodating” a student with a disability, and has to put in a factual record showing that its officials “considered alternative means, their feasibility, cost and effect on the academic program” before concluding that no reasonable accommodation was available. A conclusory assertion, with no evidence of deliberate consideration, is not enough. So the question to ask of any denial is not only “was this decision right?” but “is there any record that anyone actually weighed the alternatives?” Often there is not.

Two further points help. Whether an accommodation would impose an undue burden or fundamentally alter a program is generally a question of fact — Redding v. Nova Southeastern University, 165 F. Supp. 3d 1274 (S.D. Fla. 2016) — which means it is not something a school can simply assert its way past. And to establish fundamental alteration a school has to identify the essential requirement, show that modifying it goes to the core of the program, and show it considered whether any lesser alternative existed.

The interactive process, and a warning about how students lose it

Section 504 and the ADA do not use the phrase “interactive process” for college students the way employment law does, and the Eleventh Circuit has not held in a published decision that failing to engage in one is independently actionable — that remains unsettled. What Florida courts do recognize, from Forbes, is that the process is genuinely two-sided: the student carries the initial burden to identify the disability and make the case for specific accommodations, after which the school must consider the request and make a reasoned decision.

Here is the warning. In Amy v. Florida International University Board of Trustees, 2024 WL 5323717 (S.D. Fla. Nov. 20, 2024), the court found that the student broke down the interactive process by insisting on one particular accommodation and resisting any alternative. Where a school does not obstruct the process and makes reasonable efforts to communicate and to accommodate on the information it has, liability does not follow. Refusing every alternative on offer is a way to lose a case that could have been won — ask for what you need, but engage with what is proposed, and put the reasons in writing.

Technical standards

Published technical standards get real deference. Following Southeastern Community College v. Davis, the Eleventh Circuit treats a school’s academic standards as entitled to deference as the statement of the qualifications its program requires: Wood v. President & Trustees of Spring Hill College, 978 F.2d 1214, 1222–23 (11th Cir. 1992); see also Redding v. Nova Southeastern University, 165 F. Supp. 3d 1274, 1285 (S.D. Fla. 2016). They are not untouchable. The Section 504 regulation shields only the academic requirements a school can demonstrate are essential to the instruction or to a directly related licensing requirement, 34 C.F.R. § 104.44(a), so the showing is the school’s to make. And under Wynne, the school has to show that the people responsible actually considered the alternatives — their feasibility, cost and effect on the program — rather than simply pointing to the standard. Courts will not second-guess curriculum or clinical content on a thin record, but a standard that appears nowhere until the moment it is used to exclude a student is a different matter from one published and applied consistently for years.

Retaliation

Asking for accommodations is protected activity, and so is complaining about how a request was handled. A retaliation claim requires protected activity, the school’s knowledge of it, an adverse action, and a causal link — with but-for causation, and the familiar burden-shifting that follows. Retaliation claims sometimes survive where the underlying accommodation claim does not, because they turn on what the school did after the request rather than on whether the student was qualified.

Where to complain, and what it is worth

There are two routes and they are not alternatives you have to choose between carefully — a student may do both.

The Office for Civil Rights. A complaint to the U.S. Department of Education’s OCR generally must be filed within 180 days of the discrimination, unless OCR extends the time — 34 C.F.R. § 100.7(b), which applies to Section 504 through § 104.61. It costs nothing and needs no lawyer, though what you put in it matters.

Court. A postsecondary student does not have to exhaust administrative remedies before suing under Section 504 or the ADA. Filing with OCR is not a prerequisite.

On remedies, be realistic. Injunctive relief — reinstatement, the accommodation itself, correction of a record — and attorney’s fees do not require proof of intentional discrimination. Money damages do, generally shown through deliberate indifference: that the school knew of a substantial risk of discrimination and failed to act.

And one recent development that changes what these cases are worth. In Cummings v. Premier Rehab Keller, 596 U.S. 212 (2022), the Supreme Court held that emotional distress damages are not recoverable under Section 504, because it was enacted under the Spending Clause and funding recipients never consented to that exposure. The Eleventh Circuit extended that to ADA Title II in A.W. v. Coweta County School District, 110 F.4th 1309 (11th Cir. 2024), while letting the students’ claim go forward for other kinds of relief. Earlier Eleventh Circuit authority allowing emotional distress damages, Sheely v. MRI Radiology Network, 505 F.3d 1173 (11th Cir. 2007), no longer holds. For most students this means the value of a case lies in getting the accommodation, the place, or the record put right — not in a damages award for the distress of the fight.

This page describes how these rules work in general. It is not legal advice about your situation, and no outcome can be promised in any individual case.

College is not high school, and the difference catches almost everyone

If you had an IEP or a 504 plan at school, the rules you are now under are not the rules you grew up with. The Department of Education’s Office for Civil Rights sets out the shift plainly, and it comes down to four changes.

Nobody is looking for you. A college has no obligation to identify students with disabilities. In school, the district had a duty to find, evaluate and serve you. At college that duty does not exist. Section 504 actually goes further and prohibits a college from asking whether an applicant has a disability before admission — so the institution is not permitted to spot you on the way in, and it will not come looking afterwards.

The request is yours to make, and timing is part of it. OCR is explicit: at the postsecondary level it is the student’s responsibility to make the condition known and to request academic adjustments, and to do it in a timely manner. You may disclose to the 504 Coordinator, to a dean, to a faculty advisor, or to each professor individually. Nothing happens until you do.

Accommodations do not backdate. This follows from the point above and it is where most students lose. An accommodation granted in November does not repair a September exam. Where a student asks only after a run of poor grades, the school is answering a different question — not “what does this student need?” but “should we undo a record?” The same request made earlier is a far stronger case.

What the college owes you is different too. There is no IEP and no individualised education program. What Section 504 requires at this level is academic adjustments, modified examination formats and auxiliary aids — and the standard is that you meet the academic and technical standards requisite for admission to or participation in the program. The college does owe you one thing on its own initiative: it must inform students of the availability of auxiliary aids, services and academic adjustments, and name the person who coordinates its Section 504 compliance.

One protection is broader than people realize. Section 504 covers not only a current impairment but a record of one and being regarded as having one. A student with a history of mental or emotional illness, heart disease or cancer — or one who was misclassified — is protected even if the condition is not currently limiting.

What OCR itself gives as examples

These come from the Office for Civil Rights’ own guidance on hidden disabilities, and they are useful because they show the reasoning rather than a menu:

A student with cancer “may need a class schedule that allows for rest and recuperation following chemotherapy.”
A student whose learning disability affects the ability to demonstrate knowledge on a standardized test “may require modified test arrangements, such as oral testing or different testing formats.”
A student whose learning disability or impaired vision affects note-taking “may need a notetaker or tape recorder.”
A student with kidney or liver disease who has difficulty walking distances or climbing stairs may need “special parking space, sufficient time between classes, or other considerations, to conserve the student’s energy for academic pursuits.”
A student who is emotionally or mentally ill “may need an adjusted class schedule to allow time for regular counseling or therapy.”
A student with epilepsy whose seizures are stimulated by stress “may need accommodation for such stressful activities as lengthy academic testing”.

Notice what these have in common: each starts from a functional barrier and works to a fix. That is the structure a good request follows — not “I have X, so I get Y,” but “this is what X does to me in this setting, and this is what removes the barrier.”

Common questions

Does my condition have to be on a list to qualify?

No. The law requires “disability” to be read in favor of broad coverage, 42 U.S.C. § 12102(4)(A), and the question is whether your condition substantially limits a major life activity or bodily function compared with most people in the general population, 28 C.F.R. § 35.108(d)(1)(v). The Justice Department does list impairments that should, in virtually all cases, be found to qualify — including autism, cancer, diabetes, epilepsy, major depressive disorder, bipolar disorder, post-traumatic stress disorder, traumatic brain injury and obsessive compulsive disorder, 28 C.F.R. §§ 35.108(d)(2)(iii), 36.105(d)(2)(iii) — but a condition missing from that list is not excluded.

My condition comes and goes, or medication controls it. Does it still count?

It can. An impairment that is episodic or in remission is a disability if it would substantially limit a major life activity when active, 42 U.S.C. § 12102(4)(D). Whether a condition is substantially limiting is judged without regard to the help you get from medication and other mitigating measures — ordinary glasses and contact lenses are the exception, § 12102(4)(E). And an impairment lasting, or expected to last, less than six months can still qualify, 28 C.F.R. § 35.108(d)(1)(ix).

I get good grades. Can I still have a disability?

Yes. The Justice Department’s regulations put the focus on how a major life activity is limited, not on what you achieve: someone with a learning disability “may achieve a high level of academic success, but may nevertheless be substantially limited” in reading, writing, speaking or learning because of the extra time or effort it takes compared with most people, 28 C.F.R. § 35.108(d)(3)(iii).

Will accommodations change grades I have already received?

Usually not. Accommodations work forward from when you ask, which is why timing matters so much. Courts have refused to treat reversing an earlier academic dismissal as an accommodation — for example, Profita v. Regents of the University of Colorado, 709 F. App’x 917 (10th Cir. 2017). For a term that has already gone wrong, a grade appeal, a retroactive withdrawal or a readmission petition is usually the better tool.

Does a private or religious college have to accommodate me?

Usually, yes. Section 504 applies to every college that receives federal financial assistance — aid that reaches a college through its students counts, Grove City College v. Bell, 465 U.S. 555 (1984), a Title IX case — and it covers all of the college’s operations, 29 U.S.C. § 794(b)(2)(A). The ADA separately covers private colleges under Title III, 42 U.S.C. § 12181(7)(J), but Title III does not apply to religious organizations or entities they control, 42 U.S.C. § 12187, so at a religiously controlled college Section 504 is usually the route. Public colleges are also covered by Title II of the ADA.

Do my college accommodations carry over to the MCAT or the USMLE?

Not automatically — private testing organizations run their own process. But the ADA regulation that governs them requires documentation requests to be reasonable and limited to the need, requires considerable weight to be given to documentation of accommodations you received in similar testing situations, and requires a timely response, 28 C.F.R. § 36.309(b)(1)(iv)–(vi). See exam and testing accommodations.

When it is time to call a lawyer

Most accommodation requests should never involve counsel. Register, document, ask, receive. The moments that actually warrant a call are narrower and more specific:

The denial rests on a policy rather than on you. “We don’t do that” and “that isn’t one of our accommodations” are not individualized assessments, and OCR has said as much.
An essential requirement is invoked but cannot be found in writing. A technical standard or program requirement that appears for the first time in your denial letter is worth examining.
The school offers withdrawal, a leave, or a lighter program instead of a modification it never evaluated.
Something changed after you asked. Requesting a modification is itself protected activity, and a grade, a referral, a schedule, or a tone that shifts afterward raises a separate retaliation question that does not depend on whether the original request was correct.
A deadline is running. Internal appeal windows are short, an OCR complaint is generally due within 180 days, and a graduation or licensure date does not wait.
The stakes have escalated. Once probation, dismissal, a conduct referral, or a technical-standards determination is on the table, the matter is no longer an accommodation request.

These are fact-specific questions, and the answer usually turns on details — what was asked, in what words, to whom, and what the file says. If you are not sure whether your situation is one of these, that uncertainty is itself a reasonable reason to ask.

Where to go from here

Accommodations by type — extended time, stop-the-clock breaks, reduced-distraction testing, paper exams, memory aids, note-taking, recording, CART, food and medication, reduced course load, attendance flexibility, course substitutions, technical standards.
Accommodations by exam and by school — LSAT, MCAT, USMLE and COMLEX, NCLEX, GRE and GMAT, bar exam, CPA, SAT and ACT, and by program type.
The cases and guidance behind the rules — Davis, Ewing, Wynne, Guckenberger, Barnes v. Gorman, the ADA Amendments Act, and OCR guidance on ADHD, retaliation, and filing a complaint.
How I handle accommodation matters — what representation actually looks like when a request has been denied, delayed, or ignored.

This practice is student-side only

A Students’ Lawyer represents students and families. It does not advise, defend, or consult for colleges, universities, testing agencies, or licensing boards. Knowing how a school is supposed to run this analysis is what makes it possible to show when it has not — where the interactive process was skipped, where an essential-requirement finding was assumed rather than made, where a denial rests on a blanket policy rather than on this student’s documentation. The standard reads the same from either chair. The reason to know it cold is to hold the institution to it.

Get in touch to talk through a specific situation, whether you are a student or a family.

General information about disability law in education. It is not legal advice, it does not create an attorney-client relationship, and it cannot account for the facts of your situation or the law of your jurisdiction. Guidance documents from the Office for Civil Rights are cited throughout; OCR guidance does not itself have the force and effect of law, and OCR states that its enforcement determinations are based on the particular factual circumstances of each individual case.