A little history and bits and pieces.
IBCCES:
I heard about it quite along time ago, maybe 20 years. There was not a lot of information about them and how they started, but at least in the beginning, they were associated with Autism Speaks and ABA. They did education, mostly autism related and also offered certification.
They also offer
Autism Certification for Amusement & Theme Parks, as well as other places like museums. The majority are in the US, with a handful in other places, like Dubai, Saudi Arabia, Hong Kong. As far as I know, they developed the Autism Certification business and are the only ones offering it (part of certification involves doing training and certification with IBCCES).
Sesame Place was the first park Autism Certified park in 2018.
IBCCES Accessibility Card:
As far as I can tell, this was probably started in connection with their certification program. Because the organization’s focus is Autism and Developmental Disabilities, their Accessibility Access Card seems to also be more focused on that. I don’t know when they started applying their process to other disabilities or what the organization’s understanding of other disabilities. Their website says:
“The IAC is for anyone who is requesting accommodations – including but not limited to individuals who are autistic,
use a wheelchair, are blind/low vision, deaf/hard of hearing, have mobility support needs, are accompanied by a service animal, have sensory sensitivities, cognitive disabilities, or have other needs and concerns.”
The bolded items are specifically ones that should not require proof for accommodation per the ADA; for example, people with Service Dogs can be asked 3 questions about their dog and the services it provides.
The IBCCES Card (as far as I understand) would not be subject to the ADA, since they don’t provide accommodation; they are basically just a clearinghouse that says, “yes, this person submitted the information we asked for”.
I have read comments on different places where people wrote they submitted things like IEPs (even old ones), proof of being on SSI, handicapped parking permits and letters from their doctor that said only “this person has a disability”. The things I’ve read, it doesn’t seem like a very robust system to prevent abuse - many of those things tell very little about a person’s needs in a theme park.
HIPAA
Since the IBCCES is collecting some protected health information, they would be required to safeguard it (even though HIPAA is generally about Healthcare Workers/Facilities and Insurance). It’s actually not that difficult to safeguard that information once they have it, as long as it’s all in a digital form. Access is monitored.
Hospitals and clinics have medical record profiles assigned to each job type that only gives them access to the information needed to do their job. For example, admitting would have access to very few parts of the chart, unit secretaries would need more, Nursing would have access to much of the record, but time limited after the patient leaves. Infection Preventionist (my role) would have access to almost all of the record, except parts protected by specific laws (Mental Health, Drug Abuse & Addiction). Getting Access to other parts involve “breaking the glass”, which means an additional sign in with password and reason access is needed, along with knowledge that someone would be reviewing it. (Needing the “break the glass” always freaked me out, even though I needed to access it).
Access Passes at parks
The IBCCES process is only part of the process. The individual parks still do their own screening process, which still seems to be a variation of the same questions Universal and Disney ask - I.e. “what are your concerns with waiting in the regular lines”.
I
think the park could get away with any ADA concerns about requiring proof by offering a minimal level of access without proof. They would be hearing from me regarding an ADA complaint if they said my daughter’s wheelchair could not be used in lines without proof.