National Healthcare Certification Organization (NHCO) ADA Accommodations, Non-Discrimination Policy, and Statement of Impartiality
The National Healthcare Certification Organization (NHCO) shall provide fair and reasonable accommodations pursuant to the Americans with Disabilities Act (ADA) to individuals with documented disabilities that qualify as medical conditions hindering a person’s ability to take the examination under standard testing conditions. The NHCO will consider requests for testing accommodations related to exams from candidates with a documented disability that substantially limits the candidate’s sensory, manual, speaking, or other functional skills, including a disability that significantly impairs the candidate’s ability to read or otherwise complete the examination. These accommodations can include additional time to take the exam or using approved auxiliary aids.
Candidates must complete the National Healthcare Certification Organization’s (NHCO) Exam Accommodations Request form in its entirety for consideration. Information about requesting accommodations is available in the candidate handbook and on the NHCO website.
Incomplete applications requesting special Americans with Disabilities Act (ADA) examination accommodations will not be accepted for consideration by the National Healthcare Certification Organization (NHCO). Applicants will be notified via email if their application and/or supporting documentation are insufficient for informed decision-making. They will be referred to the National Healthcare Certification Organization’s (NHCO) ADA Accommodation Request form for information on providing complete documentation.
Applicants who do not meet ADA-required standards will be notified via email with a general reason for the decision. Test accommodation decisions and the underlying rationale will only be communicated via email.
Consistent Decision-Making
There is frequently a disconnection between a clinical or medical diagnosis and the existence of an ADA disability warranting accommodations under the law. In other words, having a diagnosis or a labeled condition does not automatically qualify an applicant for protection, including test accommodations, under the ADA. Prior accommodations, in and of themselves, are not a basis for providing current or future accommodations. Conversely, if no prior accommodations have been provided, the qualified professional should include a detailed explanation as to why no accommodations were given in the past and why accommodations for the applicant are needed now. This is especially important for developmental conditions such as learning/reading disorders and attention deficit hyperactivity disorder (ADHD), as these conditions generally originate in childhood. One would expect substantial difficulties early in life that warrant therapy and/or accommodations. Impartial decision-making using consistent and professional standards protects testing and credentialing organizations from liability and maintains the credibility of the credentials awarded. In the interest of maintaining score integrity, test validity, and fairness for all test takers, and to protect the National Healthcare Certification Organization (NHCO) and its vendors from legal challenges, NHCO reviews all accommodation applications against the ADA standard of disability rather than simply the presence of a diagnostic label.
In their consideration of ADA accommodations requests, the National Healthcare Certification Organization (NHCO) should make a clear distinction between accommodations that are generally provided by educational institutions to assist students in improving their academic performance and the ADA’s more specific interpretation of “substantial limitation” in functioning compared to the “average person.”
Resolving accommodation disputes in lieu of an appeals process (which is not required by the ADA), the National Healthcare Certification Organization (NHCO) should provide applicants with an opportunity to provide supplementary data or to request reconsideration of a negative decision if there is a substantive basis for doing so. If a negative decision is made based on sufficient data, then the basis of an appeal is the applicant’s dissatisfaction with the decision, which is non-substantive and would, therefore, not merit reconsideration. Applicants should give a substantive basis for the appeal, such as supplemental information or identification of errors (e.g., incorrect reporting of test scores or other evaluator errors).
No information on ADA applicants will be provided to a third party, either verbally or in written format, without prior written release from the applicant. ADA applications and documentation will not be made available to, nor stored with, vendors. The National Healthcare Certification Organization (NHCO) reserves the right to negotiate a settlement to a decision-making dispute at its discretion. However, this should be done confidentially and on an individual, as-needed basis.
Non-Discrimination Policy
The National Healthcare Certification Organization (NHCO) accepts all properly completed examination applications from eligible applicants regardless of the applicant’s age, sex, race, religion, marital status, disability, sexual orientation, gender identity, or national origin, or any other characteristic protected under applicable state or federal laws.
Statement of Impartiality
The National Healthcare Certification Organization (NHCO) is fully committed to conducting all of its certification activities with the highest degree of impartiality, integrity, and fairness. NHCO recognizes that impartiality is essential to ensure public confidence in its certification programs, its governance processes, and the credibility of its credentials.
To protect this principle, NHCO has established and maintains a robust framework that actively identifies, monitors, and manages any risks to impartiality. This includes:
- Ensuring that all decisions related to certification, policy development, disciplinary actions, and appeals are made free from undue influence or bias.
- Requiring all Board members, committee members, volunteers, and staff to disclose actual, potential, or perceived conflicts of interest and recuse themselves from decisions where impartiality could be compromised. See the Recusal Process contained in Policy 34.0 - Mitigation of Conflict and Recusal Policy.
- Prohibiting commercial, financial, or other pressures that could improperly affect certification decisions or organizational policies.
- Promoting transparency in all policies, procedures, and decision-making processes.
- Maintaining clear boundaries between organizational functions to ensure fairness and impartiality.
- Requiring adherence to a formal Code of Conduct and Conflict of Interest Policy for all individuals involved in NHCO operations.
NHCO regularly reviews and improves its impartiality safeguards as part of its commitment to continuous quality improvement and stakeholder trust. All individuals involved in NHCO's certification processes share responsibility for upholding these standards.