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April 27, 2018

Do PASRR Regulations Require a Test of Intellectual Functioning Be Completed as a Part of Level II Evaluations for Individuals with Intellectual Disabilities and Related Conditions?

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 intellectual disability (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 tests of intellectual functioning, 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) incorporates by reference the 1983 manual of what was then called the American Association on Mental Deficiency (AAMD). In its definition of "significantly sub average IQ," the manual says the following: “Significantly sub average IQ is defined as IQ of 70 or below on standardized measures of intelligence. This upper limit is intended as a guideline [emphasis mine]; 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.”

A copy of the relevant chapter can found here. 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 §483.102(3)(ii) reference §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

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 §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.

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