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Practice FAQ

ARDs and the IEP

      Scroll down for the following FAQ subjects (in order):

  •  Can I draft IEPs for the following school year?  
  • Online resources on the benefits of collaborative IEPs.
  • Difficult ARDs:  
    •  Should the recommendation for services be sent home prior to the ARD meeting?  
    • Parent wants to know the recommendation for services before IEPs are discussed.
    • Is it required to send therapy notes home every 9 weeks if parent requests? 
  • Can OTAs or PTAs go to ARD meetings? What is appropriate supervision of assistants?
  • Should school frequency of services be written in the smallest increment?
  • NEW! Can an IEP committee change services against a therapist's recommendation?
  • NEW! When writing the schedule of services, are we required to include specific weeks?

 

I work in a district that is implementing a new concept of writing IEPs from the beginning of an academic year to the end of the academic year (as opposed to a 12 month period). While this makes sense if the district's academic IEPs/ goals that are TEKS based, I am having difficulty in understanding this for functional goal areas addressed in Occupational Therapy. If a student has an annual ARD in the middle of the year and has mastered some of his/her IEP objectives, OT would of course draft and propose new OT objectives. The difficulty is that the district wants OT to submit a draft IEP for the following school year. Due to the fact that IEPs should be drafted by the students Present Level of Performance I feel as if one cannot draft an accurate IEP for the following school year. It's as if the district is wants OT to simply "guess" as to what that student's level of performance at the end of the school year to draft an IEP for the following year.

In the situation above, the school district has made a decision regarding procedures, and will expect all instruction personnel and related services providers to comply. I agree that there will be guesswork involved, but in practice that is always the case – there is no way to know in advance the actual degree of progress that can be achieved by a student, or the rate at which a student will progress. Should a student return in the fall with different needs (due to growth/maturity, transfer to a different school, etc.), the OT can collect data to document what has changed. An ARD can then be called to update the PLAAFP and make any needed changes in the IEP. 2012

 

I was wondering if you were privy to any online resources or documents in regard to collaborative IEPs.  In other words, articles that discuss the benefits of IEPs not being separate (i.e. OT IEPs) across disciplines.

Developing and implementing collaborative goals/objectives for students promotes team collaboration and team integration of strategies. Too often, separate goals/objectives lead to a focus on impairment without context, fragmentation in service delivery, and no follow through with strategies. This can lead to requests for more therapy time, increasing costs.

AOTA resources are your best bet. Check out the current AOTA statement on OT practice in schools. Please refer to page 6 (3/4 of the way down the page), to see how this is characterized in this statement. Two additional AOTA publications address this issue:

Hanft, B. & Shepherd, J. (2008). Collaborating for Student Success: A Guide for School-Based Occupational Therapy. Bethesda, MD: AOTA Press. pp. 155-156.

Clark, G. F., & Chandler, B. E. (eds.) (2013). Best Practices for Occupational Therapy in Schools. Bethesda, MD: AOTA Press. pp. 57 – 61.

There are also sources in education literature that identify student goals (not discipline-specific goals) as best practice. Do a little research on your own and you will find them. 2013

 

We have been experiencing some difficult ARDs currently with advocates present.   Concerns that we have include:

1) a parent requesting OT Recommendation with services page to be sent home ahead.  We were told not to send this home, but to only send the OT Eval/Report.  The service page is presented at end of ARD with our recommendations.

Your district is one of only two I know of that do not include service recommendations in the body of the evaluation report (the standard of care across disciplines). If I were the parent, I would be interested in knowing what you are thinking prior to ARD. However, the final recommendations result from the ARD process -- the flow of information that begins with the review of the PLAAFP, continues through decisions about goals and placement, and ends with the services and supports needed for the student to make progress (including related services).

2) going out of order of the ARD and asked what our recommendation/plan of care is prior to the IEPs being discussed.

Stick to your guns. You are a related service, related to the goals and objectives the developed by the collaborative team. Placement is also a consideration. Even if you shared preliminary recommendations, you should not be finalizing them until you have all the information from the process.

3) told to send home OT notes every 9 weeks to family.  Is this required if parent asks? How can we avoid this?

If you have discipline-specific goals (and I’m not sure why you would), then you have to send home a report of progress whenever other students in the district get progress reports (report cards). On the other hand, if goals are developed for the student with those supporting the goals identified (so-called “collaborative goals” that include the teacher and perhaps other service providers), then a report still must go home, but there does not need to be one from each provider. Note: The goals/objectives should reflect what the student will accomplish in 12-months time. Various disciplines may be needed to support the goal (and the teacher should be central), but each discipline does not need its own goal.
Your district administration needs to make decisions on these issues  regarding when to say no and when to say yes.

Should OTAs and PTAs be allowed to go to the ARD meetings? Does it make a difference whether the goals I am supporting are collaborative or discipline-specific? I am a COTA and my OTR does provide the required supervision monthly; however, it is most often the case that the OTR has not laid eyes on a student until the re-evaluation comes due. 

In answer to your question, there is no prohibition against occupational therapy assistants attending ARDs. The OT and the OTA should agree that the OTA has the skills to report and knowledgeably discuss data gathered on student performance and participation from the perspective of occupational therapy. However, an OTA cannot evaluate and cannot recommend, write or alter IEP goals and objectives – only the OT can evaluate and contribute/participate with the ARD Committee (IEP team) in developing goals and objectives. This is true whether goals and objectives are discipline-specific or collaborative. 
 
The working arrangement you describe gives me pause. If the OT knows all of the students from working with them in previous years and you have ample opportunity for routinely discussing all students’ response to interventions provided, I can see how it might work. If that is not the case, and it sounds from your remarks that it may not be, it is cause for concern. If you are not receiving OT supervision that is meaningful in directing you in OT services for each of the students with OT IEPs and/or you are being asked to play a role that is outside the boundaries of allowable OTA activities per TBOTE Rules, you have an obligation to inform your district administration that your supervision is inadequate and seek an immediate solution to the problem. Your first responsibility is to the students. Your services must be consistent with licensure requirements for Supervision of an Occupational Therapy Assistant (TBOTE Chapter 373.3) and the Code of Ethics (TBOTE 374.4).
 
 
As a PT, I have always written frequency for service in the smallest increment. My question is does the same apply to OT? Should school frequency be written in the smallest increment? Is there a written place to find this information such as Texas Education Agency (TEA)?  
TEA has two official documents on related services, including 1)  Related Services Q and Aand 2) Documenting the Frequency, Location and Duration of Related Services. Both of these documents are available on the TEA website (if you are searching on the TEA site, try searching for “related services guidance”). Requirements for documenting time, frequency and duration of services in the IEP is addressed, but the language you are seeking is not present in either document. 
However, since 2009, TEA officials have verbally requested of special education administrators that the documentation of time and frequency for all services documented in the IEP, including OT and PT, be in the smallest possible increment.
The rationale for this approach has been the many complaints that have occurred in our state from parents who did not understand how the implementation of services would play-out after the IEP meeting. Calls to TEA occurred when time and frequency were expressed in large blocks of time (e.g., 120 minutes per semester), with parents expecting the time to be meted out into visits every few weeks from the beginning to the end of the semester. They were angered to learn after the fact that, in some cases, all services had been provided in one or two visits late in the semester (typically due to staffing shortages), so that interventions did not play a role in programming in an on-going fashion. When they looked into it, TEA found too many such occurrences. Other factors such as findings in due process hearings as well as the need to estimate the number of sessions for each student for purposes of Medicaid projections likely influenced this “smallest increment” preference. 
In conclusion, using the smallest possible increment of time and frequency in the IEP to describe how services will be provided to a student is not unique to physical therapy, but is a practice that should be followed by OT as well.
  
NEW!  Our district has asked that OTs and PTs not attend ARD meetings. At a recent ARD meeting, the committee decided not to accept the OTs discharge report and has instead decided the student needs sensory goals. Are they allowed to do this?
Let’s focus your question a bit: Can an ARD/IEP committee make a decision to continue services, including a change in the focus of the services, when the professional has recommended discontinuation?
The answer is yes. In federal and state policy, the ARD/IEP team is given the legal authority to develop a program of special education and related services for the student with disabilities. From a legal perspective, ARD/IEP team decisions must be based on current data, and certainly should seriously consider the recommendation of the service professional. However, if in canvassing all of the current data available to the committee, they decide to continue services and seek a particular focus (even though the professional may not agree), they can do so.
The IEP must then be implemented as agreed upon by the committee. While the professional might not like being overridden by the ARD/IEP team, that has no bearing on the district’s responsibility for implementing the IEP. The only legitimate objection that could be made by the professional is in the very rare instance when the services would result in harm to the student. This would be very unlikely for most OT interventions, and therefore an argument very difficult to make.

NEW!  When writing the schedule of services, are we required to include specific weeks we will be seeing a student? For example, 30 minutes three times per grading period on weeks 1, 3, & 5.
 
The Texas Education Agency (TEA) provides guidance on this issue, stating that each IEP must include the frequency, duration, and location of the services to be provided. If a service is to be provided less than daily, the frequency must use a weekly reference, such as 30 minutes every two weeks or two 20 minute sessions per three weeks. There is nothing in TEA’s guidance that requires IEP committees to specify during which of those weeks the services will occur. If a grading period reference is to be used, the IEP must clearly document what that duration is (e.g. grading period = 6 weeks). TEA’s guidance does state that, “The LEA’s commitment of resources should be clear to parents and other IEP team members and clearly stated in the IEP in a manner that is understood by all involved in the development and implementation of the IEP.”
 

 

 

 
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