Please contact the DESP office at 408-741-2010 to obtain a large print, Braille or electronic version of this handbook.
The Disability and Educational Support Program was established in 1973 to provide support services, special instruction, counseling, assessments, and educational accommodations to enrolled students with disabilities. The Program currently serves over 700 students each year.
The information and policies set forth in this handbook are meant to clarify the roles and responsibilities of both the Disability and Educational Support Program and of the students who take advantage of the services offered.
The Disability and Educational Support Program (DESP) assists students with disabilities achieve their educational goals by providing academic adjustments, auxiliary aids, services and/or instruction designed to insure access to all campus programs, services, and facilities, and to facilitate maximum student independence and success.
How to Enroll in the Disability and Educational Support Program
If you are new to West Valley College (WVC) and/or the Disability and Educational Support Program (DESP):
- Begin by applying to DESP. You can apply in our office or online at DESP website.
- Upload your disability verification to your application or bring it to the office for assistance. The following documents are acceptable:
- A DESP Disability Verification form completed and signed by a medical professional. The DESP Disability Verification form is located at DESP Forms.
- If you have received services in high school, bring your most recent IEP and Psychoeducational Testing Report, or 504 supporting documentation.
- If written verification of your disability is not available, be prepared to discuss the history of your disability with a DESP certificated staff member.
- Schedule an appointment with a counselor or other DESP certificated staff member in the Disability and Educational Support Program at 408-741-2010.
To make the most of your appointment, it is important that you be on time. If you must cancel, please call as soon as possible. If you do cancel, be aware that it may take a while before you can reschedule.
Continuing students who will be using the same academic adjustments, auxiliary aids, and/or services as in their previous semester(s) must meet with a DESP counselor or other certificated staff at least once a semester to maintain eligibility for services. If you want to request a service that was not previously authorized, you must meet with a DESP counselor or a learning disabilities specialist for authorization.
Students, who have not been enrolled at West Valley College for a year or more, need to schedule an appointment with a DESP counselor or other certificated staff member to reactivate their file and reauthorize services. If you have been away for more than five years, your file has been destroyed and you must enroll as a new student by resubmitting documentation of disability. (See New Students above.)
- Students receiving services through DESP must be enrolled at WVC and must have a history of a permanent disabling condition, or a temporary disabling condition that has been verified by a DESP certificated staff member. The student’s disabling condition must limit one or more major life activities, and also impose an "educational limitation." An educational limitation is a disability related functional limitation in the educational setting that occurs when the limitation prevents a student from fully benefiting from classes, activities, or services offered by the college without specific additional support services or instruction. Examples of disabilities include physical, acquired brain injury, mental health, Attention Deficit Hyperactivity Disorder, Autism and learning disabilities.
- A DESP certificated staff member will review the disability documentation provided by the student and verify the disability by using one of the following means:
- Review of documentation provided by appropriate agencies or certified or licensed professionals outside of DESP
- Assessment by appropriate DESP certificated staff
- Observation by DESP certificated staff
- Students may also qualify for services based on history of disability and/or past use of accommodations.
- Once a student's disability has been verified, the DESP professional will work with the student utilizing an interactive process to identify the educational limitations, document them, along with the student’s educational goal(s), in the Academic Accommodation Plan. In some cases, temporary accommodations may be authorized while disability information is being evaluated.
- Services may be denied if it is determined that a student does not meet one or more of the above eligibility criteria.
- Students seeking to appeal the denial of services should seek remedy through the Coordinator of DESP. If, after consulting with the DESP Coordinator, students are still not satisfied, they may appeal to the Vice President of Student Services or the campus ADA 504 Compliance Officer.
- Students must possess the ability to respond appropriately to questions, follow directions, and demonstrate the potential to benefit from college programs and services.
- Students must demonstrate appropriate adaptive and/or self-help behavior. This includes providing their own personal attendant care. DESP does not provide this service.
- When enrolled in Educational Assistance Courses, students must demonstrate measurable progress towards the goals for the courses as established in the student’s Academic Accommodation Plan. Failure to do so may result in suspension of services.
- When enrolled in general college courses, students must meet the academic standards established by the college. Failure to do so may result in suspension of services.
Procedures for Requesting Academic Accommodations
Students are responsible for requesting their approved accommodations proactively each semester. To do so:
- Students go into their West Valley portal, and then their DESP portal accommodation portal.
- Select the courses they want accommodations for, and specify which accommodations for each course by clicking on the radial buttons.
- Click the “submit” button. This will then queue “Faculty Letters” (email notification) for each instructor, that lists the accommodations chosen for each class.
The Accommodations Specialist will then release the “Faculty Letters” to each instructor. This process may take up to 2 business days but we try to do within 24 hours.
If there is any difficulty in providing the necessary accommodations, the instructor and student should contact the DESP Accommodation Specialist, or a DESP Counselor, or Director, to review.
Community college DSPS programs provide services or instruction to eligible students that:
- Do not duplicate those otherwise available to students
- Are directly related to the functional limitations of the verified disability
- Are directly related to the student’s participation in the educational process
- Promote maximum independence and integration of students with disabilities
- Do not include any change to an approved course outline that is so significant that it alters the required objectives of the curriculum or course of study causing a fundamental alteration.
- Are consistent with the purposes of the community colleges.
Academic Adjustments, Auxiliary Aids and Services and Instruction
Decisions about the appropriate accommodations for any given student are made on an individual basis. DESP certificated staff utilize an interactive process “to work with the student to identify the functional limitations in the educational environment and to determine the needed auxiliary aids, services, academic adjustments and educational assistance classes” (Title 5 Section 56006), taking into consideration the documentation the student provides and/or assessment or observation by appropriate DESP certificated staff. Accommodations may include, but are not limited to, the following:
Adjustments Needed Due to Disability Related Absences
- Make-up quizzes/tests
- Extensions on assignments
Alternate Media and Assistive Technology
- Screen Enlargers
- Voice Activated Software (and training)
- Braille Keyboard
- Text Enlarger
- Text Readers (Jaws, Kurzweil)
- Alternate Media Training
- Braille Embossing
- Class selection Advisement
- Priority Registration
- Registration Assistance
- Adjustable tables
- FM Loop System (while supply lasts)
- Digital Recorder (while supply lasts)
- Smart Pen (while supply lasts)
- Real-time educational transcriber
- Sign language Interpreter
The Disability and Educational Support Program provides counseling services to assist students with physical disabilities that affect mobility. Counselors assist students with scheduling to accommodate the extra time that might be required to traverse the campus or to park a car closer to a classroom. In addition, classrooms may be moved to provide access.
- Note Takers
- NCR paper for note taking by classmate
- Smart Pen
- Digital Recorder
- Learning Ally
- Text Readers (Jaws, Kurzweil)
- Extended Time
- Print/Text Enlargement
- Periodic Breaks
- Distraction–Reduced Environment
- Computer Use for Tests
- White Board
- Text Reader
- Provided by Student
- Cared for/supervised by Student
- Academic Counseling
- Disability–Related Counseling
- Liaison/Referral to instructors, college and community resources
- Orientation to DESP and West Valley College
Learning Disability Services
- Assessment for learning disabilities
Educational Assistance Courses
- Basic Skills Courses in reading, writing and math
- Learning strategies course
- Support for writing and math
- No-fee Adapted Physical Education courses
See the current schedule of classes for a complete listing of DESP course offerings.
Educational Assistance Course Repeatability
Students are allowed to repeat educational assistance courses if one or more specific circumstances apply upon recommendation by the course instructor. Educational assistance courses require completion of the “Petition for Course Repetition” and approval by the course instructor or DESP Coordinator. Please contact the class instructor for information. Adapted Physical Education courses may be repeated without petitioning.
Students are first referred to the college’s tutoring services, including:
When the tutoring available through these centers does not meet the student’s needs, a DESP Staff Member will meet with the student to explore other tutoring resources.
Accommodations Services Policy
- Accommodations will not be provided until a student's application for services is complete and eligibility for such services has been verified.
- Once a DESP counselor, or other DESP certificated staff has verified a student's disability and the appropriate accommodations have been identified, the student will be referred to the DESP Accommodation Specialist or Alternate Media Specialist to arrange services. Step-by-step instructions for utilizing a particular service will be provided. A tutorial on how to request and implement accommodations is available on the DESP website at Academic Accommodations.
- Complete accommodation policies and rules for usage are provided to students when he/she utilizes a specific accommodation.
Subsequent Requests for Accommodation/Adjustment
- If, after the initial meeting has been held and the academic adjustments and/or auxiliary aids have been established, the student believes that additional and/or modified adjustments or auxiliary aids are called for, the student must meet with his/her DESP counselor or other certificated staff to discuss the reason for the requested adjustment. The counselor or certificated staff will then review relevant documentation, consult, if necessary, with the instructor to determine that the request does not fundamentally alter the course, and revise the list of approved academic adjustments and/or auxiliary aids as necessary. The Accommodation Specialist will then communicate the revised academic adjustments and/or auxiliary aids to the instructor(s).
- Instructors who receive direct requests for accommodation/auxiliary aid adjustment from students should refer all such requests to DESP for review pursuant to this policy. No decisions to implement or deny adjustments should be made unilaterally by the instructor.
Student Grievance Rights
Students are encouraged to follow the process listed in the student handbook, about grievance rights and appeals.
- If a student is denied an academic adjustment or use of an auxiliary aid by an instructor, or finds that the academic adjustment/auxiliary aid provided is ineffective, the student can appeal by following these steps:
- Students are encouraged to initially discuss the problem with the instructor. If the student has attempted to talk with his/her instructor, the student will be advised to follow the District Student Grievance policy, explained in the college catalog. The student is encouraged to invite their DESP counselor to participate in the discussion, if they desire. DESP (408) 741-2010, despFREEWEST_VALLEY
- If no resolution to the complaint is found with the instructor, the student should contact Amy Delevett, Director of DESP/ADA Compliance Coordinator at 408-741-2620 or amy.delevettFREEWEST_VALLEY – The complaint will be investigated, and an appropriate resolution will be explored.
- If the issue is not resolved, the appeal should be directed to the ADA/504 Compliance Officer, Associate Vice Chancellor of Human Resources, (408) 741-2060, who will make an interim decision pending a final resolution. The interim decision will be made within five working days. An investigation will be conducted leading to a final resolution within sixty days.
- If a student believes that they have been subject to discrimination related to a disability, they may file a written complaint pursuant to the District’s policy against unlawful harassment and discrimination with the college's ADA Compliance Officer, Amy Delevett. Alternatively, they can file a grievance directly with the State Chancellor’s Office or with the Office of Civil Rights.
- All records maintained by DESP personnel pertaining to students with disabilities are protected from disclosure and are subject to all other requirements for handling of student records.
- Participation by students with disabilities in DESP is entirely voluntary.
- Receiving academic adjustments, auxiliary aids, services and/or instruction from DESP does not prevent a student from participating in any other course, program, or activity offered by the college.
- Though the DESP process has been designed to be the most expedient in meeting student needs, students may choose to request academic adjustments, auxiliary aids, and/or services through the ADA/504 Compliance Officer. This officer will then verify the disability, engage in the interactive process to determine needed supports, and ensure their provision in a timely and effective manner. Students will be required to provide disability verification before services are provided.
Students receiving services and/or instruction through the DESP office shall:
- Provide DESP with the information, documentation and/or forms (medical, educational, etc.) deemed necessary by DESP to verify the disability (ies).
- Meet with a DESP counselor or other certificated staff to complete an Academic Accommodation Plan and agree to meet with the counselor or other certificated staff at least once a semester to continue eligibility for services.
- Be responsible in the use of DESP services and adhere to written service provision policies adopted by DESP (see Abuse of Services below).
- Comply with the Student Code of Conduct adopted by the college as written in the college catalog.
- When enrolled in Educational Assistance courses, make measurable progress toward the goals developed for the course as established in the student's Academic Accommodation Plan or meet the academic standards established by the college when enrolled in regular courses.
Failure to comply with the above standards may result in suspension of DESP services, as well as, consequences outlined in the College’s Student Disciplinary Policy of the Student Code of Conduct.
Disability and Educational Support Program staff members help students obtain the academic adjustments, auxiliary aids, services and/or instruction necessary to allow equal access to West Valley College's programs and services. It is the responsibility of DESP to utilize resources so that all students can receive equitable services. We establish policies and procedures that adhere to the WVC and DESP missions and that provide students access to reasonable accommodations
Suspension of Services
DESP also has the responsibility of establishing requirements for measurable progress and abuse of services. If a student does not adhere to established policies, s/he will be notified of the possibility of suspension of DESP services.
There are only two ways that services for eligible students may be suspended by DESP:
- Lack of measurable progress, or
- Abuse of services
A lack of measurable progress may be defined in any of the following ways and may result in a loss of DESP services:
- Failure to pass (by receiving grades of W, NP, or F) courses while utilizing appropriate accommodations.
- Failure to meet WVC's academic standards as defined by the Academic Probation and/or Dismissal policies.
- Failure to make measurable progress, for two consecutive semesters, toward goals developed for Educational Assistance courses as established in the Academic Accommodation Plan.
Abuse of Services
Abuse of services is defined as a failure to comply with the policies or procedures of the individual services that a student is using. Failure to comply with these policies or procedures may result in suspension of that service.
- Prior to the suspension of a service, the student will be notified in writing that, unless s/he meets with a DESP counselor, the service will be suspended.
- Once an "Intent to Suspend Services" letter has been sent, the student must agree to and sign a "Contract for Continuation of Services" before the date of suspension in order to avoid suspension of services.
- Suspended services may be reinstated during the current semester only with the authorization of a DESP counselor, other certificated staff or coordinator and only if there are extenuating circumstances which warrant reinstatement.
Students seeking to appeal the suspension of services should seek remedy through the Coordinator of DESP. If, after consulting with the DESP Coordinator, students are still not satisfied, they may appeal to the Vice President of Student Services.
If the DESP Coordinator or Vice President of Student Services approves a student's appeal, that student will be asked to agree to and sign a "Contract for Continuation of Services" to avoid service suspension.
All disability-related contacts with the DESP office and resulting information remain confidential unless a student signs a specific written release to share that information. In addition, DESP shares information with other appropriate West Valley administrators, faculty members or staff ONLY to the extent that it is necessary to facilitate the student’s educational process and at all times is sensitive to the student’s right to privacy and confidentiality. DESP will ask for student permission to obtain appropriate documentation to verify eligibility for services.
Liaison to Campus and Community
For reasons of confidentiality, DESP staff members will not discuss a student's disability with either faculty or staff without the student’s permission. As a result, students are encouraged to talk with their instructors about their specific accommodation needs. When requested by a student, DESP staff may intervene on the student's behalf to facilitate provision of academic adjustments or auxiliary aids, or to help students communicate their needs to others. Also, DESP staff may help students obtain services in the community by providing information and, in some cases, introductions to community resources.
The college has an ongoing process for evaluating architectural barriers and recommending changes.
If students encounter difficulties with access, please inform the DESP Coordinator and steps will be taken to evaluate and address the problem. Students may also contact the ADA/504 Compliance Officer to address his/her concerns.
Students who have a designated license plate or a temporary parking placard issued by the Department of Motor Vehicles do not need a West Valley College parking permit; they are eligible to park in any specially marked disabled parking space. If these spaces are full, parking is permitted in any other parking stall. Parking in driveways, on lawns or other illegal parking locations is not permitted.
Academic Substitution Policy
Students with disabilities are expected to meet the same academic requirements as all other students. The College’s policy on Academic Substitution/Waiver is available on the District website at District Procedures for Substitutions and Waivers or see Appendix B below.
Please meet with your counselor to request a substitution or waiver of an academic requirement. The policy in place at West Valley College applies only to this college. Academic policies vary at both California State University and University of California systems.
Section 504 of the Rehabilitation Act of 1973
Section 504 of the Rehabilitation Act of 1973 prohibits discrimination against individuals with disabilities in recruitment, admission and treatment after admission. It mandates all recipients of federal funding to make adjustments and accommodations in their programs and activities in order to provide qualified individuals with disabilities with opportunities equal to those enjoyed by individuals without disabilities.
Section 508 of the Rehabilitation Act
Section 508 amended the Rehabilitation Act to require federal agencies to make electronic and information technology accessible to individuals with disabilities. It provides students with disabilities access to electronic and information technology comparable to the access available to students without disabilities.
Americans with Disabilities Act
The Americans with Disabilities Act of 1990 (ADA) extends federal civil rights protection in several areas to people who are considered disabled. To be considered disabled under the ADA, a person must have a condition that impairs a major life activity, or a history of such a condition, or be regarded as having such a condition. A disabled person must be qualified for the job, program or activity to which s/he seeks access. That means the person must be able to perform the essential functions of the job or meet the essential eligibility requirements of the program or benefit. Reasonable accommodations provide students with adjustments that assure equal rights and privileges.
ADA Amendments Act of 2008
The ADA Amendments Act broadens the coverage of the Americans with Disabilities and Rehabilitation Acts in four key areas: the definition of “disability”, the list of “major life activities”, the use of mitigating measures and individuals regarded as disabled.
Full text of these laws can be found at: The US Department of Justice
California Community Colleges Title V Regulations
Sections 56000-56076 of Title 5 California Code of Regulations delineates the State regulations which apply to community colleges that offer support services or instruction to students with disabilities through Disabled Student Programs and Services (DSPS). Explanation of Title V Regulations can be found at Disabled Student Programs and Services.
Appendix A – Definitions of Title V Disability Categories
Acquired Brain Injury
Acquired Brain Injury is defined as a deficit in brain functioning which results in a total or partial loss of one or more of the following: cognitive, communication, motor, psychosocial and sensory perceptual abilities and limits the student’s ability to access the educational process.
Deaf and Hard of Hearing
Deaf and Hard of Hearing is defined as a total or partial loss of hearing function that limits the student’s ability to access the educational process.
Intellectual disability is defined as significant limitations both in intellectual functioning and in adaptive behavior that affect and limit the student’s ability to access the educational process. An individual may have an intellectual disability when:
- the person’s functioning level is below average intellectual functioning
- the person has significant limitations in adaptive skill areas as expressed in conceptual, social, academic and practical skills in independent living and employment; and (c) the disability originated before the age of 18.
Learning disability is defined as a persistent condition of presumed neurological dysfunction which may also exist with other disabling conditions. This dysfunction is not explained by lack of educational opportunity, lack of proficiency in the language of instruction, or other non-neurological factos, and this dysfunction limits the student’s ability to access the educational process. continues despite instruction in standard classroom situations. To be categorized as a student with a learning disability, a student must meet the following criteria through pscho-educational assessment verified by a qualified specialist certified to assess learning disabilities:
- Average to above average intellectual ability
- Statistically significant processing deficit(s); and/or
- Statistically significant aptitude-achievement discrepancies.
Physical Disability is defined as a limitation in locomotion or motor functions. These limitations are the result of specific impacts to the boy’s muscular-skeletal or nervous systems, and limit the student’s ability to access the educational process.
Blind and Low Vision
Blindness and low vision is defined as a level of vision that limits the student’s ability to access the educational process.
Mental Health Disabilities
Mental health disability is defined as a persistent psychological or psychiatric disability, or emotional or mental illness that limits the student’s ability to access the educational process.
Austism Spectrum disorders are defined as neurodevelopmental disorders described as persistent deficits which limit the student’s abiity to access the educational process. Symptoms must have been present in the early developmental period, and cause limitations in social, academic, occupational, or other important areas of current functioning.
Attention Deficit Disorder
Attention Deficit Hyperactivity Disorder is defined as a neurodevelopmental disorder that is persistent deficit in attention and/or hyperactive and impulsive behavior that limits the student’s ability to access the educational process.
Other Health Conditions and Disabilities
This category includes all students with disabilities, as defined in Section 56002, with other health conditions, and/or disabilities that affect a major life activity, which are otherwise not defined in Sections 56032-56042, but which limit the student’s ability to access the educational process.
Appendix B – West Valley – Mission Community College District Board Policy
BP 5140 – Disabled Students Programs and Services
References: Education Code Sections 67310 and 84850; Title 5 Sections 56000 et seq. and 56027
Students with disabilities shall be reasonably accommodated pursuant to federal and state requirements in all applicable programs in the District.
The Disabled Students Programs and Services (DSPS) Program (also known as the Disability Instructional Support Center and the Disability and Educational Support Program at the colleges) shall be the primary provider for support programs and services that facilitate equal educational opportunities as required by federal and state laws.
DSPS services shall be available to qualified students with verified disabilities. The services to be provided include, but are not limited to, reasonable accommodations, academic adjustments, technology accessibility, accessible facilities, equipment, instructional programs, special classes, and academic, personal, vocational, and rehabilitation counseling.
No student with disabilities is required to participate in the Disabled Students Programs and Services program.
The District shall respond in a timely manner to accommodation requests involving academic adjustments. The Chancellor shall establish procedures to implement this policy which, at a minimum, provides for an individualized review of each such request, and permits interim decisions on such requests pending final resolution by the appropriate administrator or designee.
The Chancellor shall assure that the DSPS program conforms to all requirements established by the relevant law and regulations. West Valley – Mission Community College District Administrative Procedures.
AP 5140 – Disabled Students Programs and Services
References: Title 5 Sections 56000 et seq.
Each College’s Disabled Students Programs and Services (also known as the Disability Instructional Support Center at Mission College and the Disability and Educational Support Program at West Valley College) are the primary providers of support programs and services that facilitate equal educational opportunities for students with verified disabilities who can profit from instruction as required by Federal and State laws. The services to be provided include, but are not limited to reasonable academic accommodations, accessible facilities and equipment, specialized instructional programs, and academic, personal and vocational counseling. Academic accommodations include, but are not limited to, test taking and note-taking accommodations, alternate media, sign language interpreters and real time captioning. Each College’s DSPS shall develop a Program Plan as described in Title 5 Regulations for DSPS, California Code of Regulations, which is submitted to the Chancellor’s office upon request. In addition, each College’s DSPS shall establish an advisory committee to meet at least once a year to give guidance and direction related to the needs of the local community.
A student with a disability is a person enrolled at a community college who has a verified disability which limits one or more major life activities and which imposes an educational limitation. Qualifying disabilities include, but are not limited to, learning disabilities, acquired brain impairment, psychological disability, and visual and hearing impairments. Verification of the disability is made by:
- Observation by DSPS professional staff, with review by the DSPS coordinator, through personal observation
- Assessment by an appropriate DSPS staff member
- Review by DSPS professional staff of documentation provided by an appropriate agency or certified professional by DSPS professional staff, with review by the DSPS coordinator.
DSPS counselors and instructors must meet minimum qualifications as set forth in Title 5 Regulations for DSPS, California Code of Regulations. In addition, each College shall designate a DSPS coordinator who meets the minimum qualifications of a DSPS counselor or instructor and an additional minimum qualification as set forth Title 5 Regulations for DSPS, California Code of Regulations.
Participation in each College’s Disabled Students Programs and Services by students with disabilities is completely voluntary and does not preclude participation in any other course, program or activity. All records maintained by DSPS personnel pertaining to students with disabilities are protected from disclosure and subject to all other relevant statutes and regulations for handling of student records. Students receiving support services or instruction from DSPS must comply with the student code of conduct adopted by each College and be responsible in their use of DSPS services as described in each College’s DSPS Student Handbook. In addition, students shall make measureable progress toward the goals established in the student’s Student Educational Contract as set forth in Title 5 Regulations for DSPS, California Code of Regulations.
Also see AP 6365 titled Accessibility of Information Technology.
The District is committed to providing equal access to all members of the District community and to supporting the open access policy of the California Community College system by providing barrier-free access to all students, including access to electronic and information technology in accordance with State and Federal mandates (Sections 504 and 508 of the Rehabilitation Act of 1973, as amended in 1998, the Americans with Disabilities Act of 1990, as amended in 2008 and California Senate Bill 105). The District is committed to expanding the boundaries of access beyond the physical setting for students with disabilities recognizing that students are entitled to equal access to electronic information and technology.
A disability may preclude a student from demonstrating required proficiencies or from completing course requirements necessary for an AA or AS degree in the same manner as non-disabled students. There may be the need to accommodate students with documented disabilities to the greatest extent possible without compromising the student's course of study, the student's confidentiality and dignity, and the integrity of the student's degree.
All graduates shall master the competencies required by The California Code of Regulations, Title 5 and to complete the courses required for graduation. Most disabilities that preclude a student from completing a course can be overcome by altering the method of course delivery and providing a combination of appropriate accommodations. Therefore, for most students with documented disabilities, the first level of accommodation will involve extra help: disability-related tutorial assistance, auxiliary aids, test accommodations, and/or special courses are examples of the kinds of assistance the District may extend to students. For some students with a disability, such accommodations and alterations of course delivery will not be enough to enable completion of the course. For these students, a course substitution will be individually considered under the conditions described in local procedures. Only in the most extreme cases will a course waiver be considered. All policies and procedures that apply to approval of course substitutions or waives also apply to proficiency requirements.