Policy

    The RISE Act and What It Means for Disability Documentation in Higher Ed

    FMDr. Faridah Zawadi Mwangi, J.D., M.A.February 20266 min readUpdated 2026-02-09
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    Key Takeaway

    The RISE Act would require colleges to accept K-12 IEPs and 504 plans as sufficient disability documentation, eliminating expensive re-evaluation requirements. DRCs should start preparing by reviewing intake procedures and building workflows that can accommodate both traditional and K-12 documentation.

    What Is the RISE Act?

    The RISE Act (Response and Inclusion for Students' Equality) is proposed federal legislation that would fundamentally change how colleges handle disability documentation. The core requirement: postsecondary institutions must accept K-12 IEPs and 504 plans as sufficient documentation for disability accommodations.

    If you've been in disability services for more than a few years, you know how significant this is.

    Why Does This Matter?

    Right now, the transition from high school to college is where a lot of students fall through the cracks. In K-12, the school identifies students and creates plans. In college, students have to start over: get new evaluations (which cost $1,500-3,000 out of pocket), navigate an unfamiliar process, and self-advocate in ways they were never taught.

    The result? Only 37% of college students with disabilities disclose (NCES data). The other 63% either don't know they need to re-register, can't afford new evaluations, or give up on the process.

    What Would Change Under the RISE Act?

    What Colleges Would Be Required To Do

    • Accept IEPs and 504 plans as initial documentation
    • Provide interim accommodations while reviewing documentation
    • Maintain an interactive process to determine appropriate college-level supports

    What Would NOT Change

    • Institutions still determine which accommodations are appropriate for college
    • The interactive process between student and DRC remains
    • Institutions can request additional information if K-12 documentation is insufficient
    • Fundamental alteration and undue burden defenses still apply

    The Debate: Quality Concerns vs. Access

    Concerns I Hear from DRC Directors

    "K-12 documentation quality varies wildly." This is true. Some IEPs are thorough. Others list accommodations without functional limitation information. The RISE Act doesn't eliminate your professional judgment; it changes your starting point.

    "High school accommodations don't always translate to college." Also true. Extended time in a high school classroom is different from extended time on a three-hour college final. Your role shifts from gatekeeper to translator.

    "We'll be overwhelmed with requests." Possibly, but many of these students already have disabilities; they're just not disclosing. Serving them is literally the job.

    Why the Change Is Needed

    The current system disproportionately impacts:

    • Low-income students who can't afford $1,500-3,000 evaluations
    • First-generation students who don't know the system requires re-documentation
    • Students of color who face compounding barriers to accessing evaluations
    • Community college students where disability services are often understaffed

    How Should DRCs Prepare?

    Practical Steps You Can Take Now

    1. Train staff on reading K-12 documentation: IEPs and 504 plans have a specific structure. Make sure your team knows how to extract functional limitations and accommodation history from them.

    2. Build a crosswalk: Create a reference document mapping common K-12 accommodations to their college equivalents and noting where professional judgment is needed.

    3. Review your intake forms: Add fields for K-12 accommodation history, IEP/504 plan upload, and transition documentation.

    4. Develop interim accommodation procedures: If documentation review takes time, have a process for providing temporary supports.

    5. Update your software workflows: Your accommodation management system should be able to handle both traditional evaluations and K-12 documentation paths.

    What's the Timeline?

    The RISE Act has bipartisan support but hasn't passed yet. Regardless of when (or if) it passes, the trend toward accepting broader documentation is clear. Several states are already moving in this direction, and AHEAD has published guidelines encouraging more flexible documentation practices.

    Smart DRCs are preparing now rather than scrambling later.

    Frequently Asked Questions

    What is the RISE Act?

    The RISE Act (Response and Inclusion for Students' Equality) is proposed federal legislation that would require postsecondary institutions to accept K-12 IEPs (Individualized Education Programs) and 504 plans as sufficient documentation for disability accommodations in college.

    Would the RISE Act eliminate all documentation requirements?

    No. It would require accepting K-12 documentation as a starting point, but institutions could still conduct their own review to determine appropriate college-level accommodations. The goal is reducing barriers, not eliminating the interactive process.

    How should DRCs prepare for the RISE Act?

    Review your intake procedures, train staff on reading IEPs and 504 plans, build workflows that accommodate K-12 documentation alongside traditional evaluations, and consider offering interim accommodations while reviewing documentation.

    FM
    Dr. Faridah Zawadi Mwangi, J.D., M.A.

    Higher Ed Policy Analyst & ADA Compliance Consultant

    Faridah spent five years as an investigator at the Office for Civil Rights (OCR) in the U.S. Department of Education before moving to consulting. She's investigated over 200 disability discrimination complaints and now helps institutions get ahead of compliance issues instead of responding to them. She's the reason our audit logs are as thorough as they are.

    J.D., Georgetown University Law Center. M.A. in Disability Studies, Syracuse University. Former OCR investigator. 18 years in disability rights and higher education policy.

    ADA Compliance
    OCR Investigations
    Policy
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