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Chapter 2: Documenting Disability Status and Accommodation Needs

This is one chapter of a broader Implementation Guide on providing accessible healthcare for people with disabilities. The chapter will guide you through how to implement documenting disability status and accommodation needs at your clinic or organization. The information in this chapter is a synthesis of existing research and learnings from health systems across the country. It is intended to provide guidelines adaptable to your local context.

Download this Chapter as a PDF↗

This chapter includes: 1) an introduction to the topic, 2) seven steps for implementation, and 3) a variety of appendices. Under each step, the Actions and Tasks section outlines best practices and questions to consider while creating and implementing documentation of disability status and accommodation needs at your organization. The Materials and Resources section lists the relevant appendices, which include worksheets, templates, examples, and other resources to assist you in completing the Actions and Tasks of each implementation step.

Appendices can also be used independently as resources for documenting disability status and accommodation needs. For example, you could use Appendix 2.5: Documentation LOINC Codes↗ if you are only interested in understanding what LOINC codes related to disability exist.

Why is it important to collect disability status?

  1. To identify and address potential disparities in care, patients’ disability status needs to be systematically and accurately documented.
  2. Healthcare organizations are required to provide patients with disability accommodations,1-3 including auxiliary aids and services.4 To effectively provide these resources, healthcare organizations first need to know patients’ disabilities and accommodation needs.

A growing body of literature finds that people with disabilities experience disparities in health and healthcare outcomes. For example, compared to people without disabilities, people with disabilities are more likely to have a greater number of chronic conditions and have higher rates of asthma, hypertension, emphysema, cardiovascular disease, diabetes, and arthritis.5 People with disabilities are also more likely to rate the quality of their health as fair or poor.6,7

What are the requirements for documenting disability status?

Section 4302 of the Patient Protection and Affordable Care Act requires the collection of disability status by organizations that receive federal funding.8

How does disability relate to other patient characteristics?

Disability is a patient-reported demographic characteristic like race, ethnicity, preferred language, gender identity, or sexual orientation. Processes for documenting other patient demographics should incorporate documentation of disability status.

Can a clinician assess a patient’s disability status?

Disability status and accommodation needs must be patient-reported. Disability status is different than a clinical assessment that is used to inform care provision. If a clinician suspects a patient has disability needs or that a patient would benefit from a disability-related accommodation, they should ask the patient the questions provided in this guide to facilitate that conversation.

Will we offend patients by asking about their disability status?

In multiple research studies, patients report little discomfort in disclosing a disability. Patients have the option to decline to answer.

How much work is it to ask patients about their disability status?

In a study in which registration staff asked one screener question followed by six disability status questions, call times increased by 18 seconds.9 Other methods for collection such as intake forms or the patient portal are potentially more time efficient for staff and providers.

Steps for Documenting Disability Status and Accommodation Needs

When implementing any new accessibility initiative at your organization, earning buy-in from leadership is essential. Support from leadership will ensure you have the resources necessary to successfully build and implement the documentation of disability status and accommodation needs.

Actions and Tasks

  1. Identify what types of leadership support and buy-in you will need.
  2. Identify potential champions across your organization.
  3. Identify how documentation of disability status and accommodation needs will fit within your organization’s existing priorities and initiatives (e.g., health equity, quality and safety, patient experience goals, etc.).
  4. Determine if your organization is involved in any regulatory initiatives that require documentation (e.g., Joint Commission Excellent Health Outcomes for All Certification, National Committee for Quality Assurance (NCQA) Healthcare Effectiveness Data and Information Set (HEDIS) reporting, U.S. Centers for Medicare and Medicaid Services (CMS) requirements, state-level requirements, etc.)

Materials and Resources

Appendices 0.3 and 0.10 can be accessed in the General Resources chapter↗.

The implementation team will be responsible for designing, leading, and monitoring the documentation of disability status and accommodation needs across your organization.

Actions and Tasks

  1. Identify the implementation team for documenting disability status and accommodation needs.
    • Consider including people across different departments and units within your organization.
    • Include leadership and others who have the authority to make changes.
    • Include staff who will be doing the work; they will know how the system works and will be helpful in implementing and piloting the project. This will also help with buy-in for the staff—who will more eagerly participate—and sustainability will be more attainable.
      • It could be helpful to start with a pilot team to work through challenges before expanding to the entire clinic or healthcare system.
  2. Determine the implementation team meeting structure.
    • How often will the team meet?
    • Is this a project that will be part of a quality improvement team or embedded within another team?
  3. Identify champion(s) for the project.
    • Who is this person(s) going to be?
    • Are they able to implement changes?
    • Will this be a clinical champion or a non-clinical team member champion? Are both clinical and non-clinical needed?
    • Is there someone at the system level with whom you can partner? For example, a Disability Coordinator?
  4. Establish common goals for team.
    • Ensure that it fits within organizational goals.
    • Use SMART Goals (Specific, Measurable, Attainable, Realistic, and Time-bound)

Materials and Resources

Appendix 0.5 can be accessed in the General Resources chapter↗.

Identify the current state of documenting disability status and accommodation needs at your organization using Appendix 2.2: Documentation Needs Assessment.

Actions and Tasks

  1. Identify if and where disability status and accommodation needs documentation is currently happening, including who is leading the work and the department or unit the work is happening within.
  2. Engage with other healthcare organizations to understand their documentation processes, including what is and isn’t working for them. Consider joining the Disability Equity Collaborative’s Documentation workgroup to create a peer network.

Materials and Resources

Part 1: Features

Determine what disability and accommodation questions will be in the Electronic Health Record (EHR) and the EHR features.

Actions and Tasks

  1. Establish the team responsible for determining what disability status and accommodation needs questions will be available in the EHR.
  2. Determine what EHR features will be included in your build.
  3. Define the disability questions that will be listed in the EHR.
  4. Define what potential accommodations will be listed in the EHR.
  5. Determine if there are already related forms/fields in the EHR and if that can be used or modified.

Materials and Resources

Appendix 0.8 can be accessed in the General Resources chapter↗.

Part 2: EHR Build

Develop the EHR build.

Actions and Tasks

  1. Identify who will be responsible for the EHR build.
    • Do you have a team that is identified specifically for EHR changes or builds?
    • Will you incur a cost to build and implement?
  2. Using questions that were identified in the previous step, complete EHR set up and build.
  3. Complete a trial run using test patients.

Materials and Resources

Decide when and who will collect disability status and accommodation needs. Aim to integrate the process into existing clinic and system-level workflows when possible.

Actions and Tasks

  1. Identify local barriers and facilitators to documenting disability status and accommodation needs (Appendix 2.6).
  2. Continue to utilize Appendix 2.2: Documentation Implementation Planning to specify site or clinic goals, strategies, timelines, milestones, and measures for successful routine collection of patients’ disability status and accommodation needs.
  3. Create a workflow map, a visual representation of the actions, decisions, and tasks to be performed for successful routine collection of patients’ disability status and accommodation needs. Appendix 0.6: Project Planning↗ includes example workflow maps.
  4. Determine what can and cannot be adapted in the process for documenting disability status. For example, can each clinic decide whether to collect at front desk or by Medical Assistant in exam room?
  5. Determine the resources needed to implement routine collection of patients’ disability status and accommodation needs. For example, you will likely need to dedicate time for staff to complete trainings.
  6. Following decisions made on workflows, processes, and roles, revisit the composition of the implementation team. Determine if additional individuals from the departments or units that will be involved in documentation should be included.

Materials and Resources

*Appendices 0.5 and 0.6 can be accessed in the General Resources chapter↗.

Ahead of implementation, consider the following actions to ensure staff, patients, and your organization’s systems are prepared to successfully document disability status and accommodation needs.

Actions and Tasks

  1. Determine who will provide consultation to assist with collecting patients’ disability status and accommodation needs.
    • This person will offer expert guidance, feedback, and problem-solving to a site longitudinally.
    • This can be a practice facilitator or similar role.
  2. Determine who will provide technical assistance and what this will include.
  3. Identify or develop tools and reminders that staff and providers will use to encourage collection (see Appendices 2.9 and 2.11).
  4. Implement training for staff and providers (see Appendix 2.12).
  5. Identify or develop patient-facing education materials to inform patients of the new processes for collecting disability status, its purpose, and what to expect.
  6. Determine how collected information will be integrated into other data structures in the organization (e.g., dashboards, quality reporting, scheduling templates and software, etc.)
  7. Determine how success will be defined for documenting disability status and accommodation needs, including appropriate metrics (e.g., acceptable rates of completion, patient complaints, staff and clinician satisfaction with the process, etc.).
    • Develop an evaluation plan to reflect your definition of success (see Appendix 2.13).

Materials and Resources

Roll out the implementation plan developed in previous steps to collect disability status and accommodation needs in the EHR.

Actions and Tasks

  1. Track and communicate rates of collection of disability status to responsible individuals (e.g., clinic or site leadership, individuals who are collecting data) and the implementation team.
  2. Review site-level data on documentation rates and determine if changes in workflow or strategies are needed.
  3. Make and document all needed adaptations.
  4. Conduct Audit and Feedback, an implementation strategy that includes providing site-level staff, provider, or team-level data on collection to those assigned to perform tasks.
    • For example, run EHR reports stratified by provider, or create a progress chart to display in a staff breakroom.
    • This Audit and Feedback article↗ details how to employ the strategy.
  5. Recognize high performing staff, clinicians, or specific clinics or sites to recognize and celebrate high completion rates.

Materials and Resources

Appendices

NAME DESCRIPTION
Appendix 2.1: Documentation Implementation Teams (PDF, 303 KB)↗ A list of all the individuals who could participate on the implementation team.
Appendix 2.2: Documentation Needs Assessment (PDF, 421 KB)↗ A worksheet to review the current landscape of the organization, identify mission, priorities, gaps, strengths, and specific goals for documentation.
Appendix 2.3: Documentation Implementation Planning (PDF, 591 KB)↗ A worksheet to identify the future direction and processes that will be followed for documenting disability status and accommodations.
Appendix 2.4: Documentation EHR Features (PDF, 411 KB)↗ A list of all the electronic health record (EHR) fields that might be available, places to look within the EHR for disability fields and accommodation needs, functions by role, auditing and report for Quality Improvement, and research support.
Appendix 2.5: Documentation LOINC Codes (PDF, 333 KB)↗ A list of Logical Observation Identifiers Names and Codes (LOINC) codes that are specific to documenting disability. Includes LOINC number, method or type, classification, question description, and status.
Appendix 2.6: Documentation Barriers and Strategies (PDF, 401 KB)↗ A list of potential barriers to documenting disability status and possible strategies for addressing the barriers. Barriers are organized categorically.
Appendix 2.7: Documentation Disability Questions (PDF, 499 KB)↗ Three recommended question sets that can be asked to patients to collect disability status and accommodation needs.
Appendix 2.8: Documentation Workflows (PDF, 1.2 MB)↗ A document with example workflow templates for how documenting disability status and accommodation needs can be operationalized in a health system. Provides guidance on when to ask, what fields in the EHR to use, how to collect, and who should ask.
Appendix 2.9: Documentation Frequently Asked Questions (PDF, 304 KB)↗ A Frequently Asked Questions (FAQ) document for staff about implementing disability status and accommodation needs collection into the clinic workflow.
Appendix 2.10: Documentation Who and When (PDF, 487 KB)↗ A comprehensive list of all the options for when to and who can collect disability status information. Includes considerations to discuss when deciding who will collect and when disability status needs to be collected.
Appendix 2.11: Documentation Sample Script and Question Prompts (PDF, 308 KB)↗ An example script for healthcare staff that includes the disability and accommodation needs questions and a prompt to deliver before asking the questions.
Appendix 2.12: Documentation Training Materials (PDF, 673 KB)↗ The training appendix includes six different parts:

  1. Introduction
  2. Training table that outlines who and how to train
  3. Table tent template for staff collecting disability status and accommodation needs
  4. Clinic signage examples
  5. Training slide deck an organization can use or modify to train their staff
  6. Videos accompanying training slide deck
Appendix 2.13: Documentation Monitoring Progress and Adaptations (PDF, 330 KB)↗ A worksheet to track progress and adaptions made to the implementation plan.

References

  1. Americans with Disabilities Act of 1990, Pub. L. No. 101-336, 42 U.S.C. §12101 et seq. (1990). https://www.congress.gov/bill/101st-congress/senate-bill/933
  2. Iezzoni LI, McKee MM, Meade MA, Morris MA, Pendo E. Have Almost Fifty Years Of Disability Civil Rights Laws Achieved Equitable Care? Health Affairs. 2022/10/01 2022;41(10):1371-1378. doi:10.1377/hlthaff.2022.00413
  3. Office for Civil Rights. Section 504 of the Rehabilitation Act of 1973. U.S. Department of Health and Human Services. Updated January 7, 2025. Accessed October 3, 2025, https://www.hhs.gov/civil-rights/for-individuals/disability/section-504-rehabilitation-act-of-1973/index.html
  4. Civil Rights Division. Auxiliary Aids and Services. U.S. Department of Justice. Updated February 28, 2020. https://www.ada.gov/resources/effective-communication/#auxiliary-aids-and-services
  5. Stransky M, Jensen K, Morris MA. Adults with Communication Disabilities Experience Poorer Health and Healthcare Outcomes Compared to People without Communication Disabilities. J Gen Intern Med. 2018;33(12):2147-2155. doi:doi: 10.1007/s11606-018-4625-1
  6. Havercamp SM, Scandlin D, Roth M. Health disparities among adults with developmental disabilities, adults with other disabilities, and adults not reporting disability in North Carolina. Public Health Report. Jul-Aug 2004;119(4):418-26.
  7. Altman B, Bernstein A. Disability and health in the United States, 2001-2005. 2008.
  8. U.S. Department of Health and Human Services Implementation Guidance on Data Collection Standards for Race, Ethnicity, Sex, Primary Language, and Disability Status (2011). Accessed April 7, 2026. https://aspe.hhs.gov/sites/default/files/private/pdf/76331/index.pdf.
  9. Morris MA, Hamer MK, Eberle K, Jensen KM, Wong AA. Implementation of Collection of Patients’ Disability Status by Centralized Scheduling. The Joint Commission Journal on Quality and Patient Safety. 2021/10/01/ 2021;47(10):627-636. doi:https://doi.org/10.1016/j.jcjq.2021.05.007

The development of Chapter 2: Documenting Disability Status and Accommodation Needs was supported by the National Institute on Deafness and Other Communication Disorders of the National Institutes of Health under award number R01DC020188. We thank the members of the implementation mapping advisory board for their contributions to inform this chapter.

We would also like to express our gratitude to Kori Eberle, Jennifer Halfacre, Dr. Tina Studts, and Ellie Mellor for their contributions and review of this chapter. Additionally, we would like to thank the members of DEC’s Leaders workgroup and Standards & Guidelines workgroup for their input and suggestions.

additional CHAPTERS

Introduction to Implementation Guide
Chapter 1: Building a Disability Accessibility Program
Chapter 3: Providing Accommodations
Chapter 4: Effective Communication
General Resources
Under a yellow dividing line, an image of a gear overlays DEC's logo with the text "Implementation Guide" to the left in light blue font.

Large print version available upon request.

Additional chapters are in development.

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