CMAS Accommodations for IEP and 504 Plans in Colorado

The spring CMAS testing window is approaching and you're at an IEP meeting. Someone mentions your child might need paper-based testing, or text-to-speech on the ELA portion. The team looks uncertain. "We need to check if that's allowed."

Colorado's CMAS accommodation rules are genuinely complex — and more rigid than most parents or even some district staff realize. An accommodation that's perfectly standard in daily instruction can be invalid or even invalidating on a state assessment if it wasn't properly documented, if the IEP language wasn't precise enough, or if a required approval form wasn't submitted by December. Here's what you need to know before that conversation happens.

The Foundation: Accommodations Must Be in the IEP or 504 Plan First

The most important rule in Colorado's CMAS accommodation framework is that testing accommodations must already be documented in the student's IEP or 504 plan to be valid during state assessment. An accommodation that's used informally in the classroom, or that teachers apply on a case-by-case basis, does not transfer to the CMAS unless it is explicitly listed in the governing document.

This sounds obvious, but it means every annual IEP or 504 review meeting before the testing window is an opportunity to ensure accommodation language is current and precise. Vague entries like "extended time as needed" or "preferential seating" don't tell the test administrator exactly what to provide. CMAS administration requires specificity.

For IEP students, the accommodations section must align directly with the student's disability-related needs as documented in the PLAAFP. The accommodation should reflect how the disability creates a barrier to demonstrating knowledge on a computer-based test — not just how it affects daily classroom work.

Standard vs. Designated Supports vs. Accommodations

Colorado's CMAS framework distinguishes between three types of support:

Universal tools are available to all students without documentation — things like scratch paper, highlighters (on computer-based tests), and zoom features.

Designated supports are available to students whose IEP, 504 plan, or EL plan identifies a specific need. These include features like color contrast settings, answer masking, and text-to-speech for Math (but see below for ELA).

Accommodations are supports that change the standard testing conditions and require IEP or 504 documentation. Extended time, small group testing, and the use of a scribe for written responses fall into this category.

Understanding which category applies to the support your child needs affects what documentation is required and whether additional approval is needed.

The Text-to-Speech Restriction on ELA

This is the single most consequential restriction in Colorado's CMAS accommodation framework, and it catches many parents and districts off guard.

Colorado's 2020 Academic Standards require students to decode and comprehend written text independently. For the CMAS English Language Arts (ELA) assessment, this means that text-to-speech cannot be used as a standard accommodation for ELA. Using a human reader or text-to-speech on the ELA portions of the CMAS fundamentally alters what the test is designed to measure — a student's independent reading and comprehension ability — so using it without approval compromises the validity of the test results.

For Math, Science, and Social Studies CMAS assessments, text-to-speech is an allowable accommodation for students with documented IEP or 504 needs. But for ELA, a different process applies.

Unique Accommodation Requests (UARs)

If a student requires an accommodation that falls outside the standard list — including text-to-speech for ELA, a human read-aloud for ELA, or other accommodations that alter what the test measures — the school must submit a Unique Accommodation Request (UAR) to the CDE's Assessment Unit.

This is not a routine form. It requires documentation of:

• The specific nature of the student's disability
• Why the disability prevents access to the standard computer-based format or ELA construct
• What evidence supports the accommodation's use in daily instruction
• The specific accommodation being requested

The UAR submission deadline is typically December 15 of the testing year — well before the spring window. If a UAR isn't submitted and approved by that deadline, administering the accommodation renders the test invalid. "Invalid" means the scores don't count for accountability purposes, which has consequences for both the student's academic record and the school's reporting.

This December deadline is frequently missed, especially in districts where IEP case managers and testing coordinators don't communicate proactively. If your child's IEP includes an accommodation that might require a UAR for CMAS, ask at the fall IEP meeting — not in February.

Paper-Based Testing Accommodations

Some students with specific disabilities cannot effectively use a computer-based test format. Fine motor difficulties, certain visual impairments, or severe attentional challenges that are exacerbated by screen-based tasks may make paper-based testing the only appropriate format.

To access paper-based CMAS materials, the IEP or 504 plan must specifically document that the student's disability directly prevents access to digital assessment. A general note that the student receives print materials in class is not sufficient. The documentation must establish the connection between the specific disability and the barrier to computer-based testing.

This means if a student currently doesn't have paper-based testing documented in their IEP and they need it for CMAS, the IEP must be amended before the testing window — and that amendment may require a full team meeting or at minimum a written agreement to amend under ECEA Rule 4.03(2)(d).

Practical Steps Before the Testing Window

At the fall IEP or 504 meeting:

• Review the current accommodation list and ensure every accommodation your child uses daily is explicitly documented
• Ask specifically: "Are any of these accommodations classified as Designated Supports or Accommodations under CMAS guidelines? Do any require a UAR?"
• If your child uses text-to-speech for reading in any academic context, ask how that applies to the ELA CMAS and whether a UAR is needed

By December 15:

• Confirm with the district testing coordinator that any required UARs have been submitted to CDE
• Get written confirmation — an email is sufficient — that the submission was made

Before the testing window opens:

• Request a copy of the CMAS Accessibility and Accommodations checklist the district uses for your child's specific assessment
• Verify that test administrators are aware of the documented accommodations

If accommodations weren't provided during testing:

• Document what occurred in writing immediately after
• Contact the special education coordinator in writing to request a Prior Written Notice explaining why the accommodation wasn't implemented
• If the accommodation was omitted due to district error, this may support a compensatory education claim or a state complaint

The CMAS accommodation process is one of the most technical — and most consequential — parts of Colorado special education compliance. A student who doesn't receive their documented accommodations during state testing hasn't been provided FAPE.

The Colorado IEP & 504 Blueprint includes a CMAS accommodation checklist with the exact IEP language CDE requires to document standard accommodations, paper-based testing, and text-to-speech — and the steps to take when accommodations are missed.

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