The IEP- Individual Education Plan Should Tell A Story. Does Yours?

By Allan Roth, M.S.ED. of Alliance Resources and Associates, Inc.

While the order of items is not exact and the names of the items might have a slight variation, all of these components need to be in the IEP, with the information complete and accurate.

Here is a common sequence of an IEP with an explanation listed below for each of the items:

  • Cover Page –  The BEGINNING of the story… This is where our IEP story begins. Here, we will learn the name of the student, their age/birthdate, the grade that they are in, whether they have had an IEP or section 504 plan before, whether they are going to their neighborhood school, who the parent or parents is/are, contact information, ethnicity, primary language, handicapping condition/s, etc.
  • ITP,  Individual Transition Plan – This 2 to 3 page document is in addition to the IEP and comes in play by the time the student is 16 years old; but can be as early as 14 years old. The purpose of the ITP is to set up a plan based on a student’s hopes, dreams, and desires, for post high school. Therefore, the ITP includes questions such as: What does the student want to do for a vocation— will the student go to a trade school, a community college, a four-year school, or straight to work? Where will the student live–at home with parents, on their own in an apartment or house, or with friends? And, what kind of independent living skills does the student have? The ITP should be the guiding document that leads the focus of the IEP, as the student moves through grades 10th-12th.
  • PLOP, Present Levels of Performance – This section often goes by similar names: present levels of academic achievement, present levels of academic performance, present levels of educational performance, etc. The name does not really matter. This is the first place where student specific data should show up. It is very important that this section has accurate information that is measurable and observable. Words like improved, doing well, struggles with, is challenged by, etc., are not helpful, unless they are supported by concrete data. This section will normally start out with a couple of sentences about the strengths and interests of the student. Then it will move onto specific information for reading, writing, math, communication, fine motor, gross motor, prevocational/vocational, social/emotional, and activities of daily living. Having looked at any challenges in the PLOP area, the last piece will be to list any and all areas of need. These are the areas that will have goals written for them, in order to bring the student to expected levels. But, where did the information come from? It comes from any and all available information— standardized tests, informal tests and observations, report cards, discipline and health records, teacher input, parent input, and, when appropriate, student input.
  • State Testing – These tests help the school compare itself to other schools in the district, the state, and the nation. The scores are not of much use to parents. While the state has made it inappropriate to tell parents they can opt out, because the state needs as many students taking it for statistical reasons as possible, there are times when taking the test is not a good use of a student’s time. Yes, there are benefits to practicing test taking skills (these are untimed and online). And yes, there is something to be said for having a child do what typical peers are doing and a chance to learn from peer models on how to take a test. All that said, if you feel there are better uses for a child’s time than four 2-3 hr days of state testing, a parent can write/email a note stating their intent to opt out of state testing for the current school year (2017-2018, for example); be sure they sign, print their name, list their child’s name and list the child’s DOB. The parent should keep a copy.
  • Goals – Goals must have 7 parts directly written into them, or implied, to be legally compliant. The goals are the cornerstone of an IEP as they are developed from the PLOP and lead directly to services. Remember, goals are not written until all accommodations or adaptations to the gen ed setting have been tried (SST process). Services, then lead to placement; but we are getting ahead of ourselves.  Goal writing is an art, in and of itself. Therefore, the details for goal writing have been left to a different White Paper called, “How to write a baseline/objective/goal”. Note these key aspects, though: goals should be a best professional estimate of what can be accomplished in a year’s time (never more, per ed code). Goals are measuring what the student will be able to do and thus should be free of any type of guidance or prompt; which are staff dependent and cannot be standardized. Goals should never have a range (2-3 paragraphs, 6-8 hits, etc.) as getting to the lower end of the range for increasing skills/behaviors meets the goal and getting to the upper end of the range for decreasing skills/behaviors meets the goal. If the intent is to avoid limiting success, that is better accomplished via terms like 3 or more and 8 or less; using the example ranges from above. Last, when a level of a skill is important, such as a reading level, it needs to be a specific grade level versus the student’s independent/instructional reading level, as the student is already at their independent/instructional level, always is and always will be, so no growth can occur and the goal can have been and is already met. Be sure to read the White Paper on How to write a baseline/objective/goal for details on how to write them. Goal Progress reports should be written in the same format as the goal and should have specific data, in the same format as the goal. Supporting raw data should be available to affirm how the goal progress was determined. Simply stating, making progress, sufficient progress, and other vague terms are not acceptable. Goal progress should be reported every nine weeks or more frequently.
  • Special Factors – This special section of the IEP delineates unusual/atypical/uncommon needs of students and thus has its own space. Things included in this area of the IEP are: does the student need Assistive Technology, does the student have a Low Incidence Disability (deaf, hard of hearing, blind, deaf/blind, etc.), does the student need training in English as a Second Language, and does behavior impede the learning of the student or others? When this form is needed, the first (Assistive Technology) and the last (Behavior impact) are the two most likely parts to be used/needed. Assistive Technology can be very detailed and/or broad, as it includes items off the shelf (whether modified or not) and both hardware and software. The key is whether the student needs the high or low tech hardware/software due to their disability or not. It is NOT a question of whether the class/school already has the item, strictly whether the student needs it due to their disability. If yes, and the school has it, great. If yes, but the school does not have it, then the school needs to get it. In some districts, the Special Factors page is multiple pages as it may include details of how services are provided. It is important to note that direct services and consultation services need their own set of service hours or it is possible your child will never see the service provider. Thus, if you see a number of hours, and it says via a combination of direct, collaboration and consult, be sure to insist that consult be pulled and kept separate, so that you know exactly how much actual service you can expect for your child. (See the services discussion for additional important information on how to write the services.)
  • Accommodations / Modifications – This is probably one of the least understood and more complex areas of the IEP. Few teachers and administrators actually understand this area and the differences between them. This area can be a 45 minute training to begin to understand the nuances; a cursory explanation will have to suffice in this space. Accommodations come from the federal laws under Section 504 and the ADA- Americans with Disabilities Act. The two laws are very similar and not important to this review. In short, accommodations level the playing field while not significantly changing the standard the student is working towards. Note: these are ​not ​ the teacher’s personal standards, which are irrelevant here; but rather, national or state standards that have been tested, research based and mandated. Modifications are the opposite in that they DO significantly change the standard that all other students of the same age/grade are working on. Last, it is important to understand that there is no simple list of accommodations versus modifications, as a single adaptation can fall into either category, depending on how, when, and what it is being used for. A simple example is extended time on tests. In most circumstances, extended time on a teacher made test is an accommodation and the amount of extension is determined by an IEP Team. But, that same extended time on a standardized test will have thrown off the research and formal scoring tables, thus jumping it to a modification status. Note: an accommodation in a core class can keep a student working towards a four year college diploma while a modification in a core class can cause the student to lose that option/status. The new IEPs are now expecting accommodations, modifications, and supplemental aids and services to be listed separately, to try to help clarify what type of adaptation is being proposed. Think about any adaptation you can come up with and see if you can give an example of how that adaptation might be an accommodation. Then, see if you can use the same adaptation and state how it might be a modification. When you can do that fluidly, you will have grasped this elusive concept.
  • Services – Once the goals have been properly listed and the accommodations and modifications have been determined, it becomes possible to determine how much service a student needs for each aspect of the IEP. Some key elements for the professionals to consider when proposing service levels/amounts are: how many goals, who else is supporting the goals, how quickly does the student catch on to new skills, how well does the student generalize learned skills from the therapy session to non-therapy use (generalization), how many students will be seen at one time, will this student need individual, group, or both types of sessions, etc.? Using these and other variable, the professional is responsible for making a service level recommendation which should be included in their report, along with any proposed accommodations or modifications. The ed code notes that the student must be taught by properly credentialed staff or an instructional aide that is supervised by properly credentialed staff. Based on this, a related service provider (OT, Speech, APE, PT, etc.) could find that a student needs a goal and services but not be the one who provides the services– an aide or special education teacher may be the actual provider and overseen by the related services specialist. Only when there are too many kids for others to provide the service or the service needed is too specialized, will the ed code mandate the related service provider be the one administering the services. Services should be written either in the service area, in the comments area, or in the Team Notes; specifying the frequency and duration of services. There are 36-38 weeks in a school year. Most related services do not operate the first two and last two weeks of the school year– as the site wants to allow teachers to set up rules and procedures with the students at the beginning of the school year and to wrap things up, at the end of the school year. Thus, a service needing one hour per week should be listed as 32 or more sessions of 60 minutes, per year; or as 60 min per week. Some team members want services listed as yearly and make it seem like the flexibility in providing the services yearly is needed. While there are some rare instances when this is true, more times than not, the team member is trying to write yearly services to avoid being caught out of compliance when they are short staffed/sessions. The IEP is for the student and should be written on behalf of the student, not the service provider nor the district. Thus, it is recommended to never have an IEP that does not at least state the service expectation to be monthly or more frequently; and rarely, if ever, yearly. Consult services are slightly different and often need to be front-loaded as consult is staff to staff training. Consult services don’t technically need to be written into an IEP, as staff are free to consult on or about any student, with or without an IEP. So, don’t worry as much about consult services and whether they are written as yearly. Always double check the services to make sure they are clear and definite. Check the start and end dates, whether the service is group or individual (they get separate lines or clear info in the comments area) and whether the services will be provided in the general education setting or in the special education/service provider location setting. Some IEPs list generic information such as SAI- Specialized Academic Instruction. This is a catch all term and provides no information as to who is providing the service, their credential, nor the program they represent. Using SAI as the service is never acceptable. Make sure the specific service type/level is clearly noted either on the service line or in the comment box for that service. For example, SAI by a Resource or Learning Center teacher is totally different than SAI by a Special Day Class teacher. Be clear about what is being offered. ESY- Extended School Year (a.k.a. Special Education Summer School) is determined by one or more of three criteria, based on appropriate data. The three criteria are: regression, recoupment, or in the midst of learning a critical concept. The essence of the first two criteria is— does it take longer, following a break, for the student to catch up to where they were prior to the break, than it does for a gen ed student. The accepted formula is— 1 day of catch up for every 3 days off. Thus, after a one week break and two days of review, if the data shows the student behind where they were prior to the break, then ESY should be offered; regardless of whether the student intends to use it or not.
  • Placement – There is a full continuum of placement options that must be made available, per Federal Law. The continuum starts by Pushing In services into the general education classroom. The next level is Pull Out services to a Resource Specialist or Learning Center. In most cases, once a student needs services in Pull Out for half or more of their day, the student is usually shifted to a Special Day Class (SDC) or Self-Contained Class. If a student is not successful on a comprehensive campus in a SDC class, then a separate site in the district or Non-Public School will typically be considered. The last and most restrictive placement is a type of 24/7 private school with specially trained staff, called a RTC- Residential Treatment Center. At any point on the continuum, if a student has an acute or chronic health issue that prevent school attendance for more than 10 consecutive school days, a doctor or school psychologist can authorize Home/Hospital Instruction. This service is usually offered at 5 hrs/wk to deliver work, administer tests, and provide supplemental instruction, so the student does not fall too far behind in key areas. Not all classes can be taught at home— foreign language, labs, and many electives fall into this category, and will therefore need to be adjusted or possibly dropped. A Full Inclusion school/district, is a form of Push In service, but cannot exclude Pull Out service options; even if the student needs to be bussed elsewhere to get what is needed. Placement decisions must always be based on the concept of LRE- Least Restrictive Environment. LRE is a concept, not a place. LRE means that a student must be placed with the least amount of service that will provide educational benefit, not the best program or most desired program; rather, the program closest to, or similar to, the general education class, as possible (sometimes this is an RTC placement).
  • FAPE- wrapping up This section summarizes what percent the student will be Pulled Out for all special education services. It will determine if transportation is needed. And, it will include things like outside agency participation and the frequency with which the goal progress will be reported (at least as often as general education reports progress). [See Goals, above, for further info.]
  • Team Notes – While I have yet to meet anyone who does not see the benefit of Team Notes, this item is not a required component of the IEP and has no consistent content from one administrative designee to the next, across sites, districts or states. In fact, some districts have eliminated Team Notes, to the chagrin of the special education staff. Some Team Notes, due to the lack of guidelines, have little more than a list of attendees or an agenda. Other Team Notes are close to a transcript of the meeting. Both seem out of place. A tape recorder can and should capture every word said. The Team Notes should capture key discussion elements not included in the IEP, or provide guidance/explanation for IEP items needing more information than allowed in the IEP document. These are Team Notes, so everyone should have input. If the author of them refuses to read them and make on the spot adjustments, be sure to cross off the word “Team” and insert the author’s name, as they then have become personal notes versus Team Notes. If need be, handwrite on the Signature Page that the author refused to discuss the content of the Notes.Signature Page There are three broad choices here: fully agree to the IEP, partially agree to the IEP, fully disagree to the IEP. If everyone has participated cooperatively, hopefully the last choice will never happen. However, there are many times when there is a disagreement over the goals,services, or placement. In those times, be sure to note what areas ARE agreed upon, so they can possibly be implemented. It is usually wise, at the end of the IEP meeting, to write approval in the Team Notes, or via initials, to implement agreed upon goals and services. At the same time, it is equally wise to NOT sign the IEP immediately. Take a copy home and put it aside for 2 days. Let your mind clear. Go back and read it over 2-3 days later. If all sounds correct, then sign it. If there is a problem, get it fixed before signing. Never feel that the IEP must be signed immediately. Always take a copy home, even if it is just rough notes, needing to still be put into the computer; take photos if need be. The BEGINNING​ …. time to take all the hard work and start implementing the IEP, collecting data along the way (at least quarterly) and getting ready to do the process all over again … next year!

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