Is ADHD Considered a Learning Disability According to IDEA? The Answer is Not that Simple

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What Is a Learning Disability?

Understanding what is and is not a learning disability isn’t as straightforward as it might seem. In the realm of special education, the term “learning disability” has a specific definition which excludes some learning impairments which, at first glance, might seem like learning disabilities. Attention Deficit Hyperactivity Disorder (ADHD) is one of those conditions which directly impacts learning, yet fails to meet the criteria to be classified as a learning disability under federal guidelines.

Generally speaking a learning disability is a condition that causes learning problems, or causes difficulty in effectively employing specific learning skills. Learning disabilities vary widely from person to person but commonly impacted skills include:

  • Reading
  • Spelling
  • Writing
  • Listening
  • Speaking
  • Reasoning
  • Math

Special education programs usually define a “learning disability” in accordance with the definition from the Individuals with Disabilities Education Act (IDEA). IDEA is the federal law governing the provision of special education and related services to children with learning disabilities. IDEA defines a learning disability as:

…a disorder in one or more of the basic psychological processes involved in understanding or in using language, spoken or written, that may manifest inteslf in an imperfect ability to listen, think, speak, read, write, spell, or do mathematical calculations, including conditions such as perceptual disabilities, brain injury, minimal brain dysfunction, dyslexia, and developmental aphasia. Title 34: Code of Federal Regulations, Section 300.7 (c)(10), December 2005


ADHD is a condition characterized by problems with inattention, hyperactivity, and impulsivity. Those affected by this disorder have a hard time controlling their behavior and paying attention. An estimated 2 million U.S. school children are afflicted with ADHD. Because the problems associated with ADHD tend to have an adverse impact on learning, it is often incorrectly labeled a learning disability. Confusion is further compounded by the fact that 20-30% of children with ADHD actually do have co-existing learning disabilities.

The Difference Between ADHD and Learning Disabilities

The individual with a learning disability has a measurable deficit in one or more areas of learning, while performing at or above average norms in others. School systems usually diagnose students with a learning disability when there is a significant gap between their IQ and their performance on a battery of educational tests. The tests given to diagnose a learning disability are different from standard academic achievement tests and are usually administered by a psychologist.

ADHD does not meet the federal definition of learning disability because it impacts all areas of learning and all cognitive functions rather than any isolated one. Additionally, ADHD is a medical condition and must therefore be diagnosed by medical professionals rather than school system personnel.

Federal Guidlines That Apply to ADHD

A child diagnosed with ADHD but with no co-existing learning disabilities is classified under IDEA as “other health impaired”.

(9) Other health impairment means having limited strength, vitality, or alertness, including a heightened alertness to environmental stimuli, that results in limited alertness with respect to the educational environment, that—

(i) Is due to chronic or acute health problems such as asthma, attention deficit disorder or attention deficit hyperactivity disorder, diabetes, epilepsy, a heart condition, hemophilia, lead poisoning, leukemia, nephritis, rheumatic fever, sickle cell anemia, and Tourette syndrome; and

(ii) Adversely affects a child’s educational performance.

However, just because a child with ADHD is classified as “other health impaired” does not mean the are ineligible for services under IDEA. It all depends on the severity of the child’s condition and whether or not other learning disabilities are also present.

According to, a child classified under OHI is eligible for services under IDEA under the following conditions:

a) the student must be diagnosed with AD/HD by the school district, or the school must accept the diagnosis rendered by another qualified professional; b) the AD/HD must result in limited alertness to academic tasks, due to heightened alertness to environmental stimuli; c) the effects of the AD/HD must be chronic (long-lasting) or acute (have a substantial impact); d) this must result in an adverse effect on educational performance; e) the student must require special education services in order to address the AD/HD and its impact.

If the child’s ADHD is not considered severe enough to qualify for services under IDEA, they still may be entitled to protections under Section 504 of the Rehabilitation Act which prohibits discrimination based upon a disability. Although ADHD alone is not always considered a learning disability, it is considered a disability. It is therefore possible for a child with ADHD who is not covered by IDEA to be eligible for services and accommodations under Section 504. The special education staff at a school can assist parents in assessing which provisions apply to their situation and facilitate implementation of the appropriate educational assistance.