Michigan Cognitive Impairment Eligibility: The Three-Part Test Under MARSE

Michigan's Cognitive Impairment eligibility category carries some of the most specific quantitative thresholds in the entire MARSE framework. Unlike categories where eligibility hinges on professional judgment and clinical interpretation, CI eligibility has explicit numerical benchmarks — which means it's easier to identify when a determination is wrong, but it also means students can be improperly excluded if only one or two parts of the three-part test are considered.

What Michigan's CI Category Requires

Under MARSE R 340.1705, a student qualifies for special education under Cognitive Impairment if the evaluation documents all three of the following:

1. Cognitive development approximately 2 or more standard deviations below the mean.

This means the student's score on an individually administered standardized cognitive assessment falls at roughly the 2nd percentile or below. Most cognitive assessments — including the WISC-V, WJ-IV Cognitive, KABC-II, and others — use a scale where the mean is 100 and one standard deviation is 15 points. Two standard deviations below the mean corresponds to a score of approximately 70 or below.

The "approximately" language matters. MARSE doesn't set a hard cutoff of 70. A student who scores 71 or 72, particularly when confidence intervals around the score are considered, should not be automatically excluded. Cognitive tests have measurement error (typically ±5 points), and a student who scores 72 with a 95% confidence interval of 67-77 is reasonably interpreted as functioning at the threshold. The MET should address this in the evaluation report rather than relying on a single point score.

2. Academic achievement in the lowest 6th percentile in both reading and arithmetic.

This is the academic component of the three-part test. It requires documentation that the student's performance on individually administered achievement measures falls below the 6th percentile in reading and in arithmetic. Both areas must be below the 6th percentile — not just one.

This two-subject requirement creates an important nuance: a student who is extremely low in reading but closer to average in math may not qualify for CI under MARSE, even with a low cognitive score. The achievement criterion is designed to ensure that the cognitive impairment is actually affecting academic learning across core academic domains, not just in a single area.

3. Impairment of adaptive behavior.

Adaptive behavior refers to the collection of conceptual, social, and practical skills that individuals develop to function in daily life. Adaptive behavior assessments — such as the Vineland Adaptive Behavior Scales or ABAS-3 — measure skills like communication, community use, self-direction, health and safety, academics, leisure, self-care, and social functioning.

For CI eligibility, the adaptive behavior impairment should be consistent with the cognitive profile. A student whose cognitive and achievement scores are in the CI range but who has average adaptive functioning — who manages daily life, communicates effectively, and navigates social situations independently — may not meet the full CI standard. Conversely, a student whose daily living skills are severely impaired alongside low cognitive and academic performance clearly meets the criterion.

All Three Criteria Must Be Met

This three-part structure is important to understand because Michigan's CI eligibility is explicitly not based on cognitive score alone. A student with a low IQ score but average or above-average achievement scores does not qualify for CI — the academic achievement criterion isn't met. A student with low academic scores and apparent cognitive delays but intact adaptive functioning may not qualify if the adaptive behavior piece falls short of the threshold.

This is genuinely stricter than how some families (and even some school staff) think about intellectual disability. It's also why parents and outside evaluators sometimes disagree with a CI determination: if one component of the three-part test is borderline or was improperly assessed, the entire determination is at risk of being incorrect.

What the CI Evaluation Must Include

Given the three-part structure, a complete CI evaluation must assess all three domains. The MET must include a school psychologist for any CI evaluation — this is a MARSE requirement, not just best practice. The school psychologist typically administers the cognitive assessment and interprets results across all three domains.

The evaluation should include:

• An individually administered standardized cognitive assessment (not a group screening tool)
• Individually administered standardized academic achievement testing in reading and mathematics
• A standardized adaptive behavior assessment, typically completed with input from both a parent informant (who knows the student at home) and a teacher or school informant (who knows the student in the educational setting)
• Review of existing data including grades, work samples, classroom observations, and prior evaluations

If the evaluation you received is missing any of these components, the evaluation is incomplete. An assessment that relies on a school psychologist's observation without a standardized adaptive behavior scale, or that uses group achievement tests instead of individually administered measures, does not meet the MARSE standard for a CI evaluation.

CI Severity and Placement

While MARSE doesn't formally subdivide CI into tiers, IEP practice differentiates between mild, moderate, severe, and profound levels based on cognitive and adaptive functioning. A student with mild CI (cognitive scores roughly in the 55-70 range) may be appropriate for a resource room model with substantial general education access. Students with moderate to severe CI typically require more specialized programming — often through an ISD-operated center-based setting.

MI-Access and the CI Connection

Students identified as CI are frequently recommended for Michigan's alternate assessment system, MI-Access, which has three tiers — Functional Independence, Supported Independence, and Participation. The MI-Access decision must be made by the IEP team, not unilaterally by the district.

This is a consequential decision. A student assessed on alternate achievement standards cannot earn a standard high school diploma based solely on MI-Access performance — they may receive a certificate of completion, which does not carry the same post-secondary value. If the school is recommending MI-Access, ask the team to document why M-STEP with accommodations is insufficient and what the diploma implications are before agreeing. Federal law caps alternate assessment participation at 1% of total enrollment, which creates a systemic incentive for schools to limit MI-Access — the question must be answered based on the individual student's needs, not enrollment math.

When a CI Determination Is Wrong

CI denials and improper CI identifications both occur. On the denial side, a student who appears to be functioning at a CI level may be denied because achievement scores are slightly above the 6th percentile threshold, or because the adaptive behavior assessment was completed only with teacher input (and the teacher doesn't see the student outside the structured classroom environment). A parent informant on the adaptive behavior scale often captures a more comprehensive picture of real-world functioning.

On the over-identification side, a student with significant reading difficulties (SLD) may score low on an achievement measure in ways that artificially depress the academic criterion, and a school that hasn't conducted sufficient RTI documentation may default to CI. This is particularly a concern for students from low-income backgrounds or students who have had significant disruptions to their schooling — the achievement criterion for CI could be affected by factors other than cognitive impairment.

If you believe the CI determination was incorrect in either direction, request an IEE. An independent school psychologist can administer a different cognitive battery, use a different adaptive behavior scale with both parent and teacher informants, and provide the IEP team with an independent analysis.

The Michigan IEP & 504 Advocacy Playbook includes a CI eligibility review checklist covering each of the three criteria, the required evaluation components, and the language for challenging a determination you believe was based on incomplete or inaccurate data.

The LRE Obligation Doesn't Disappear

CI identification often results in placement discussions that default to ISD center programs without adequately exploring less restrictive options first. Michigan's LRE requirement applies to students with CI just as it does for every other disability category — the district must document why supplementary aids and services in a general education setting are insufficient before moving a student to a segregated program.

Severity of need influences the analysis, but it doesn't eliminate the obligation. A student with mild CI may be appropriately served in a resource room model with general education access for much of the day. Even students with more significant needs are entitled to a thorough LRE review. If the school is proposing an ISD center placement without that documented analysis, that's an advocacy gap worth addressing before you sign the IEP.

See more United States guides →