Do Preadmission Screening and Resident Review (PASRR) Regulations Require a Test of Intellectual Functioning Be Completed as a Part of Level II Evaluations for Individuals with Intellectual...

Do Preadmission Screening and Resident Review (PASRR) Regulations Require a Test of Intellectual Functioning Be Completed as a Part of Level II Evaluations for Individuals with Intellectual Disabilities (ID) and Related Conditions (RC)?

There is a common misconception about this. The simple answer is "no" -- a test of intellectual functioning (IQ test) is not required by PASRR regulations.

The reasoning, broken down into its components, includes:

• 42 CFR 483.136(b) "Data" lists the data elements that must be collected to determine whether someone has an ID. Note that an IQ test is not among the required elements.

• 42 CFR 483.136(c) "Data Interpretation" indicates that "the State must ensure that a licensed psychologist identifies the intellectual functioning measurements of individuals with ID or a related condition."

There are a couple of very important things about this clause:

1. The fact that it is labeled interpretation means only that IQ tests, when they are administered, must be interpreted by a licensed psychologist. It does not say that such a test is required.

2. Licensed psychologist does not necessarily mean someone with a PhD. Instead, it means whoever the state chooses to license, according to its licensing policies and practices.

The Code of Federal Regulations (CFR) at 42 CFR 483.102(b)(3)(i) incorporates by reference the American Association on Intellectual Disability's Manual on Classification in Intellectual Disability (previously known as the American Association on Mental Deficiency: Classification in Mental Retardation) published in 1983. In its definition of "significantly subaverage”, the manual says the following: “Significantly subaverage is defined as IQ of 70 or below on standardized measures of intelligence. This upper limit is intended as a guideline; it could be extended upward through IQ 75 or more, depending on the reliability of the intelligence test used. This particularly applies in schools and similar settings if behavior is impaired and clinically determined to be due to deficits in reasoning and judgment.” In other words, the manual gives states a great deal of flexibility. An IQ of 70 is just an anchor, or a point of reference. It's not a firm cutoff and information about intellectual functioning can come from the education system and other settings.

This reasoning is also applicable to individuals with a related condition. PASRR regulations at 42 CFR 483.102(b)(3)(ii) reference 42 CFR 435.1010 for the definition of a related condition, which includes the following:

(2) Any other condition, other than mental illness, found to be closely related to intellectual disability because this condition results in impairment of general intellectual functioning or adaptive behavior similar to that of mentally retarded* persons, and requires treatment or services similar to those required for these persons.

The bottom line is IQ testing is not a requirement of PASRR. If testing has not been conducted, then a good psychosocial history is valid and useful for determining this element of the broader disability criteria, as more fully defined at 42 CFR 483.136(c)(2).  

If IQ testing was conducted and is available, it need not be current. Finally, if IQ testing was conducted and is available, then the person who administered and/or interpreted the testing must have met state qualifications for professionals permitted to complete that activity.