I think your daughter might really benefit from accommodations that are tailored to the specific needs mentioned above. She is always going to do better than administrators and SPED folks think would qualify for help, because of her giftedness, but her performance (regular meaning of the word!) and intelligence should match up, and accommodations would seem to be needed to make that happen.
I do think meeting with an advocate or lawyer would be helpful in charting a course, not in an adversarial spirit but more researching.
That said, I did all that and one of my kids refuses accommodations in college! Another one of my kids thrived ONLY because of accommodations and her life has literally been changed by their availability.
Would your daughter’s life be changed? It is not clear. You and your daughter can judge that best perhaps. In some cases, accommodations are absolutely and clearly needed, others, not so much. Good luck!
I sense this thread is ending so just slipping one more in! Good luck with Irlen- that would be wonderful if it really does help…