Quick Answer
In Virginia, students with low working memory or slow processing speed are often penalized on tests not for lacking knowledge — but for lacking the cognitive bandwidth to hold information in memory under timed conditions. Formula sheets, reference cards, graphic organizers, and extended time are legal, appropriate IEP accommodations. Giving a student access to a formula sheet is not cheating — it is access. The goal of the assessment is math, not memorization.
What Working Memory Actually Is
Working memory is the brain's mental whiteboard — the cognitive space where you hold information while you actively use it. When you solve a multi-step math problem, working memory holds the intermediate result while you work on the next step. When you follow a three-part direction, working memory holds step one while you process steps two and three. When you write a sentence, working memory holds the beginning of the sentence while you construct its end.
For students with low working memory, that whiteboard is small and erases quickly. This does not mean the student is less intelligent. It means their cognitive architecture makes certain tasks harder — specifically tasks that require holding and manipulating information simultaneously. This affects academic performance significantly because most academic tasks are designed without accounting for working memory limitations.
Processing speed is a related but distinct profile. It refers to how quickly the brain accurately processes and responds to information. Students with low processing speed know the material — they just need more time to retrieve it, apply it, and produce a response. Timed tests systematically measure processing speed as much as they measure content knowledge, penalizing students who know the content but cannot demonstrate it at the rate the test assumes.
Both profiles are commonly identified through psychoeducational evaluations. If your child's evaluation includes a cognitive battery (WISC, WPPSI, Woodcock-Johnson, or similar), look for the Working Memory Index and Processing Speed Index scores. If these scores are significantly lower than other cognitive scores — or lower than expected for the student's academic potential — they should be addressed in the IEP's present levels and in the accommodations.
The Cheating Question — Answered
When parents ask for formula sheets, notes, or reference cards as IEP testing accommodations, the most common pushback from schools is: "That would be cheating."
This response misunderstands what tests are for.
A math test is designed to assess whether a student can apply mathematical reasoning. It is not designed to assess whether a student can memorize the formula for the area of a triangle. If a student with low working memory knows exactly how to apply the formula but cannot hold the formula in memory while simultaneously performing the calculation, the test is measuring their working memory deficit, not their mathematical reasoning.
Giving that student a formula sheet removes the working memory obstacle and measures what the test is actually supposed to measure: the reasoning. That is not cheating. That is access.
The same logic applies to notes on an essay test. If a student with low working memory has studied the content thoroughly but cannot simultaneously retrieve multiple facts, organize them, and compose written language — all working memory tasks — the test is measuring working memory load, not content knowledge. Notes reduce the retrieval demand and allow the content knowledge to be demonstrated.
The underlying principle is that accommodations should not change what is being assessed — they should change the conditions under which the student accesses the assessment. A formula sheet on a math reasoning test does not change what is being measured (reasoning). It removes an obstacle that would otherwise prevent the student from demonstrating the skill.
Memory Aid Accommodations
These accommodations reduce working memory load by providing external support for information retrieval.
Formula sheet / reference sheet
A teacher-prepared or student-prepared sheet containing formulas, rules, or procedures for use during specific assessments. Should be consistent, used across all similar assessments (not just tests), and specified in the IEP.
IEP language: "Student will be provided a teacher-approved reference sheet containing formulas and mathematical procedures for use during all math assessments, quizzes, and classwork."
Personalized notes
Student-created notes, outlines, or vocabulary lists used during assessments. Most appropriate for content-knowledge assessments (social studies, science, reading) where the goal is application, not memorization.
IEP language: "Student may use a one-page (front and back) self-prepared notes page during assessments in [subject areas]."
Graphic organizers
Pre-structured visual frameworks that reduce the organizational working memory demand of writing tasks. Student fills in content; the structure is provided.
IEP language: "Student will be provided a graphic organizer for all written composition tasks of three paragraphs or more."
Multiplication / math fact charts
For students whose working memory makes fact retrieval inconsistent. The goal in upper grades is typically application of procedures, not computation from memory.
IEP language: "Student may use a multiplication table and math facts reference during math class and assessments."
Vocabulary word wall or personal word bank
For students who know word meanings but cannot reliably retrieve them under timed writing conditions. The list should contain content vocabulary, not be a cheat sheet with answers.
Environment and Pacing Accommodations
These accommodations reduce the performance-degrading effects of time pressure and environmental distractors on students with processing speed deficits.
Extended time
The most commonly requested processing speed accommodation. Typically "time and a half" (1.5x the standard time) or "double time" (2x). The goal is not to give extra time for extra effort — it is to remove the artificial penalty of a time limit that the assessment's construct does not require.
IEP language: "Student will receive extended time (time and a half / double time) on all timed assessments, quizzes, and standardized tests."
Separate testing environment
Testing in a low-distraction setting removes the additional working memory burden of managing environmental input. This does not mean solitary confinement — a small group room with low noise is often sufficient.
IEP language: "Student will take all assessments and standardized tests in a small group or separate low-distraction setting."
Chunked or segmented assessments
Large assessments divided into smaller segments administered across multiple sessions, with breaks between. Reduces fatigue-related degradation of working memory capacity.
IEP language: "Student may take assessments in multiple shorter sessions, with breaks between sections as needed."
Directions read aloud or repeated
Reduces working memory demand for comprehending written directions while simultaneously managing test anxiety and test-taking demands. Especially useful for multi-step tasks.
IEP language: "Test directions will be read aloud to student; student may request that any direction be repeated."
Reduced length assignments (not reduced expectations)
For classwork and homework — not assessments — reducing the number of problems while maintaining depth. Ten math problems demonstrating mastery is equivalent to twenty if the skill is consistent. IEP language should be clear that the reduction is quantitative, not qualitative.
Writing It Into the IEP
Vague accommodation language is unenforceable accommodation language. "Accommodations as appropriate" or "extended time as needed" are meaningless because they give the teacher total discretion to provide or withhold the accommodation at will.
Every accommodation should specify:
- What the accommodation is (specifically — not "extra time" but "double time")
- When it applies (all assessments, all math assessments, assessments over 20 minutes, etc.)
- Who provides it (classroom teacher, testing proctor, SLP)
- How it is documented (teacher confirms provision in student's file, accommodation is noted on test paper)
The accommodation section should be directly tied to the present levels. If the psychoeducational evaluation shows a Working Memory Index of 72 and a Processing Speed Index of 78, the present levels should document those scores and explain how they affect academic performance. The accommodations should then respond to those specific documented needs — not be a generic list.
When the team resists including specific accommodations, ask: "What in the present levels data supports not providing this accommodation?" If the data shows low working memory and the accommodation reduces working memory load, the burden is on the team to explain the mismatch — not on the parent to justify the accommodation.
State Tests and Standardized Testing
IEP testing accommodations can and should apply to state standardized assessments, not just classroom tests. Most states allow the accommodations most commonly needed by students with working memory and processing speed deficits, including extended time, separate testing setting, and reference materials (where consistent with what the test measures).
Important principles for state testing accommodations:
- The accommodation must be listed in the IEP. Verbal agreements are not sufficient for state testing — the IEP must document the accommodation explicitly.
- The accommodation must be routinely used in instruction. Most states require that accommodations approved for state testing be the same accommodations regularly used in the classroom. An accommodation the student has never used before the state test will likely be denied.
- Some accommodations are restricted for specific assessments. Each state's accessibility manual lists what is permitted and prohibited for each test. Review it before the IEP meeting to know what to request.
- Request the accommodation early. State testing accommodations need to be documented in the IEP before the testing window. If the IEP meeting is coming up, advocate for the full accommodations list now.
If the school denies state testing accommodations that are listed in the IEP and allowed under state policy, request a written explanation and contact your state education agency's assessment office.
When Anxiety Compounds Processing Speed
Test anxiety and processing speed deficits do not just add together — they compound each other. Research consistently shows that anxiety consumes working memory resources. Under timed, high-stakes conditions, a student with generalized anxiety or test anxiety is experiencing reduced working memory capacity on top of any baseline working memory weakness. The result is performance that significantly underestimates the student's actual knowledge.
If your child has both low processing speed (or low working memory) and anxiety, the IEP accommodations list should address both:
- Extended time addresses processing speed and reduces time-pressure anxiety
- Separate testing environment removes social anxiety triggers (being watched, comparing pace with classmates)
- Clear advance notice of test format reduces unpredictability anxiety
- Breaks during testing allow for anxiety regulation mid-assessment
- Access to a sensory or fidget tool during testing can support regulation without distracting others
The accommodations for anxiety and processing speed often overlap, and a well-written IEP may address both without needing to separate them into distinct lists. See also: Anxiety and the IEP for the full framework on anxiety-related supports.
Your Next Steps
1. Find the cognitive scores in the evaluation.
Look for the Working Memory Index and Processing Speed Index in the psychoeducational evaluation. If these scores are significantly lower than the Verbal Comprehension or other ability scores, there is a documented cognitive load discrepancy that should be driving accommodation decisions. If you don't have a recent evaluation, you can request one.
2. Check the present levels section of the IEP.
Does the present levels section mention working memory or processing speed? Does it describe how these affect academic performance? If not, that is the first gap to address — the accommodations have to flow from documented needs.
3. Request the specific accommodations by name.
Before the meeting, prepare a written list of accommodations you are requesting, with the IEP language you want. "I'm requesting that the accommodations section include: double time on all timed assessments; teacher-prepared formula reference sheet for all math assessments; separate testing environment; and directions read aloud." Specific requests move meetings forward.
4. Ask about state testing explicitly.
Ask the team: "Will these accommodations be available on the state assessment?" If any accommodation on the list is not approved for state testing, ask why and what documentation would support approval.
5. Verify the accommodations are actually being used.
An IEP accommodation that exists on paper but is not provided is a compliance failure. After the meeting, ask the teacher to confirm how the accommodations are being implemented for each class and each test. Follow up in writing if you observe accommodations not being provided.
Virginia — State-Specific Guidance
Virginia
Virginia's Standards of Learning (SOL) assessments provide accommodations to IEP students as documented under Virginia's Participation and Accommodations Guidelines. Common accommodations include extended time, separate testing setting, use of reference materials where permitted, and directions read aloud. Accommodations must be routinely used in classroom instruction and documented in the IEP.
Verified Apr 2026