In a preview of her Careers & Lifestyles column from the summer 2021 Pennsylvania CPA Journal, Elisabeth Felten, CPA, assistant professor of business at DeSales University in Center Valley, joins us to discuss testing accommodations available to those with disabilities seeking to pass the CPA Exam. Among the aspects covered are eligibility guidelines, frequently requested accommodations, and necessary documentation.
By: Bill Hayes, Pennsylvania CPA Journal Managing Editor
I think we can all agree that a CPA candidate should not have to choose between the prospects of passing the CPA exam and dealing with a possibly life-threatening situation. That is why the National Association of State Boards of Accountancy offers accommodations to people with disabilities who are set to take the CPA exam. In the summer 2021 Pennsylvania CPA Journal, our guest today, Elisabeth Felten, CPA, assistant professor of business for DeSales University in Center Valley, details eligibility requirements for accommodations, the types of accommodations available, and more. Today, she is here with us to offer an advanced preview of her piece.
Can you tell us a little bit about the professional licensing section of the Americans With Disabilities Act Amendments Act of 2008 and what that section sought to address?
[Felten] The Amendments Act came about because several court cases had narrowed the definition of disability so much that the intended protection of the ADA, the Americans with Disabilities Act, the original one, was not being fulfilled. Under the amendments, disability is being defined more broadly. More people – for example, people with ADHD – would qualify under this act.
Also, the amendments went on to acknowledge that individuals with disabilities were denied the opportunity for equal access to an education or to become licensed in their chosen profession because of their inability to receive needed testing accommodations.
The law specifically states that any private entity that offers examinations or courses related to licensing or certification for a professional trade or trade purposes have to offer examinations in a place and manner accessible to persons with disabilities.
What are the guidelines for eligibility for CPA exam testing accommodations?
[Felten] Overall, they have to have a disability as defined by the Amendments Act, but then after that, they have to demonstrate that they have a current need for testing accommodations. If they had a need previously, but currently there's no need, they would not qualify. Then further, that that accommodation can be reasonably provided. That definition is basically that it meets the candidate’s needs, it's feasible, and it does not create an undue hardship for the testing administrator.
Can you walk us through the general process of a candidate from looking to receive accommodations, and then up to actually sitting for the exam? What does that process usually entail and how much time does it take?
[Felten] It can take quite a bit of time. It's important that anyone who wants to request accommodations, or who needs accommodations, start the process as soon as possible, preferably as soon as they decide to sit for the exam.
They start the process by going through the NASBA – National Association of State Boards of Accountancy's – website, and that's nasba.org. They start by submitting a testing accommodations request form. Then that form, along with all their required supporting documentation, must be sent to NASBA CPA Examination Services at least 45 days prior to the candidate's intended test date. However, some accommodations can require up to 90-day notice, so that's why it's really important to get started quickly.
Then once those forms have been approved, they will receive a testing accommodations notice to schedule. From that point, they can then call Prometric, which is the testing agency, and they would contact their testing accommodations department so that they could set up a time.
I just really want to stress that if there's a candidate who believes that they need accommodations, and who is entitled to accommodations, but they don't follow that process, if they just show up at the testing location, they will not be offered special accommodations. They have to go through the process.
What sorts of accommodations are frequently made for people?
[Felten] There's a wide range of accommodations depending on the disability. NASBA actually has 80 accommodations that are already pre-approved. The most common are private testing rooms, additional testing times, screen readers for people who need to hear the material, and speech recognition support, so for people, for example, with difficulty writing, that they can use speech to answer. Then really, any other appropriate reasonable accommodation may be requested as long as the need is substantiated.
Who is actually responsible for seeing that the testing accommodations are arranged?
[Felten] While NASBA coordinates the process, it's really up to the candidate. They need to ensure that they have that testing accommodations notice of schedule and they have to give proper notice to the testing accommodations department of Prometric, and really understanding and adhering to those timelines is really important.
What sort of documentation or proof has to be provided if a candidate is looking to receive accommodations?
[Felten] The required documentation is actually very specific. Candidates must provide evidence of a substantial limitation to physical or mental functioning as evaluated by a licensed or otherwise qualified professional with credentials appropriate to diagnose and treat the disability. For example, a podiatrist can't write a letter diagnosing ADHD. It has to be the right credentials.
Then, that documentation also can't be more than three years old. If someone had this documentation maybe from college or previous testing accommodation, they would need to make sure that it's up to date.
It needs to be on official letterhead and there has to be a letter from a physician or a detailed report that describes the extent of the disability, the criteria for the diagnosis, the diagnosis itself, the type and length of treatment, and, specifically, the required or the recommended accommodation for that test taker.
There are some preapproved medical devices that can be brought into a testing center without pre-authorization. How does that work? It's without preauthorization, but do you have to notify someone that you have those items or are you completely free to have them without notification?
[Felten] Prometrics, the testing provider for the CPA exam, maintains on their website a list of pre-approved personal items, such as foam earplugs, EpiPens, inhalers, oxygen tanks, and insulin pumps. There's a long list there. Students can just arrive with any of those items on the list. There's no notification, or no prearrangement is necessary, but I really would recommend that they check out the list because there are some specific requirements. For example, pills can be brought, but they have to be unwrapped and not in a container. It's really important to check out the list before arriving.
What would you say, if any, are some of the misconceptions people have about testing accommodations as it relates to the CPA exam?
[Felten] I think primarily there's a misconception that the exam itself is being changed and that people who receive accommodations have some sort of advantage. This is absolutely untrue. We're trying to, by taking the CPA exam, assess a candidate's qualities and knowledge and expertise in being a CPA, and someone, for example, with reduced vision who needs a magnifying glass, they can be an amazing CPA and the fact that they can't read the test is what's blocking them.
Really, the accommodations change the environment of the exam. They don't change the exam itself. It's still the same CPA exam that everyone takes, and these accommodations, though, they play a really important role in just ensuring equal entrance to our profession.