Practice FAQ 

Evaluation  - Data Collection and Report Writing 

       Scroll down to see the following FAQ subjects (in order)


While prohibited by their Texas Practice Acts from diagnosing, occupational therapists and physical therapists can and do evaluate students as part of the collaborative team conducting the FIE. In this case, their evaluation contributes to the comprehensive data-gathering from which the ARD/IEP team makes decisions about the student’s eligibility for special education.
Occupational therapists or physical therapists may also be asked to evaluate a student who has already been identified under IDEA as a student eligible for special education. In this case, the evaluation is to assist the ARD/IEP team with determining whether there is an educational need for occupational therapy or physical therapy services to be added to their IEP in support of the student’s goals and objectives.
Occupational therapy or physical therapy evaluations under IDEA can serve either purpose separately or both at once. 

You will certainly be gathering data for your reevaluation any time you are with the student, but as you get close to the due date for the reevaluation, I don’t know of any reason you can’t use the intervention sessions to do some formal testing if it is needed. Be sure to continue interacting with the campus personnel so that you also know if there are issues you need to address (in other words, don’t be so singularly focused on data-gathering that you aren’t aware of and responsive to instructional personnel). The Texas Education Agency has also provided guidance that students are not to be “overserved”, so be careful not to spend all of the student’s intervention time evaluating and then have no time left to meet the student’s current needs.

The Texas Board of Occupational Therapy Examiners (TBOTE) Rule 362.1 (33) defining the Occupational Therapy Plan of Care specifies that “A written statement of the planned course of Occupational Therapy intervention . . . must include goals, objectives and/or strategies, recommended frequency and duration . . .” TBOTE Rules do not say that the required elements must be on the evaluation report itself, but it is clear that they need to be written.

The Texas Board of Physical Therapy Examiners (TBPTE) Rule 322.1 (c) describing the Physical Therapy plan of care development and implementation states that “(1) The PT must develop a written plan of care, based on his evaluation, for each patient” and “(3) The plan of care must be reviewed and updated as necessary following a reevaluation of the patient’s condition.” 
TBPTE Rule 346.,1 regarding practice in Education Settings, gives the following guidance: “(a) In the educational setting, the physical therapist conducts appropriate screenings, evaluations, and assessments to determine needed services to fulfill educational goals. When a student is determined by the physical therapist to be eligible for physical therapy as a related service defined by Special Education Law, the physical therapist provides written recommendations to the Admissions Review and Dismissal Committee as to the amount of specific services needed by the student (i.e., consultation or direct services and the frequency and duration of services).”
Thus, the rules state that the plan of care must be written based on the evaluation, but do not specify that the plan of care must be included in the evaluation report itself; the guidelines for the educational setting simply state that written recommendations will be provided to the ARD committee.

Is it appropriate to include the plan for services in the evaluation report?

Although including the items that constitute the Plan of Care are usually in the evaluation report, one ISD in the Houston area has chosen to write their OT and/or PT recommendations on a separate document that is brought to the IEP meeting along with the written report. The document is called “OT and/or PT Plan of Care” and includes all the required elements. In some cases, the PT or OT may modify his/her recommendations as a result of the information shared during the IEP process. That change would then be documented on the form by the therapist at the meeting. If the IEP team determines some other frequency and duration is needed to support the IEP other than what the therapist recommends, that can be documented in the minutes/written deliberations. However, the therapist’s written recommendations should be submitted into the student’s official record along with the final determination made by the committee, whether it is on the report or a separate form. That documentation will be important to the district over time if the IEP team has to consider setting limits on continuing demands from parent/guardian for therapy when 1) data shows that therapy is not making a difference or is no longer needed, or 2) the IEP team tries to meet parent/guardian concerns by providing therapy at a greater frequency/duration than the professional recommended but data indicates no additional benefit from the increase.  When the IEP team finally decides to say, “no,” there will be a record that the district made a good faith effort to meet the parent’s concerns.

I am currently dealing with a parent who is requesting that her child be tested and diagnosed for dysgraphia. It appears that her “outside” OT and/or physician said that the school district OT could test and diagnose this. Can OT’s test and diagnose for dysgraphia? If not, who is responsible for this diagnosis?

No, OTs do not diagnose in schools (or anywhere else for that matter). If a parent wants services from their local school district for dysgraphia, they can bring documentation of a medical diagnosis, and then go through the evaluation process so that the IEP team (ARD Committee) can determine if the child has a need for special education and related services (just like any other diagnosis). The personnel involved in the testing might include the OT, but not necessarily.  Handwriting is an instructional issue, so it is not automatic that an OT would be involved. Even if a disability that results in dysgraphia is identified, OT may not be required. Best results for writing, as indicated by evidence across research studies over many years, is from explicit instruction and practice, neither of which require an OT. (See:  Graham, S. & Harris, K. R. 2005. Improving the Writing Performance of young Struggling Writers: Theoretical and Programmatic Research From the Center on Accelerating Student Learning. The Journal of Special Education. 39. 1. 19 – 33).   
Dysgraphia is a brain- and language-based disorder that is identified using multiple measures of assessment. There is no single measure or assessment tool that will identify or rule out dysgraphia. Dysgraphia can be present either with or without a Specific Learning disability in Written Expression, but there must be an orthographic processing deficit, according to the Texas Education Association’s (TEA) The Dyslexia Handbook 2021. Occupational Therapists can certainly play a role in the identification process using their skill in task analysis to determine the student’s ability to perform the mechanics of handwriting, as well as memory for letter forms, visual-motor coordination, motor planning, sensory-motor contributions and sequencing. Skilled observations of the student in a variety of authentic writing tasks is critical, as is coordination with the diagnostician or LSSP.​
Ethically [TBOTE Rule 374.4 (c) (3) and APTA Code of Ethics, Principle #3], and legally (IDEA law/regs and Texas laws/regs) you must recommend what the student needs in order to benefit from his special education, based on his evaluation, not allowing caseload/workload capacity factors to influence your recommendation. That is the first consideration. Once the ARD/IEP committee makes the final determination for service time/frequency/duration, the district must then figure out how it is going to provide the services. Assuming your schedule is efficient, your job is to let the district know your workload capacity, and when you no longer have capacity to add students. They have to then figure out how to serve what you and any OT colleagues in the district cannot. That does not mean you have abandoned the student per TBOTE Rule and are personally responsible for problem-solving how the student will be served.  The district has that responsibility. 
There is no requirement that a new evaluation be conducted when a student moves into your district unless your district does not receive a current evaluation and IEP. In fact, it is important that there be no interruption in services if at all possible.
However, if a current evaluation does not accompany the student, you will need to comply with notice and consent procedures and conduct a new evaluation. OT and PT Rules in our state require that services in the Plan of Care, (in school settings this is the IEP) be based on an evaluation. IDEA and Texas Special Education Rules and Regulations require the evaluation to be current.
If a student moves into your district accompanied by an evaluation, you will want to review the evaluation that accompanies the student to make sure 1) the data reflected appears current in its description of the student including his strengths and educational needs, and 2) that the IEP (Plan of Care) goals/objectives address the needs and can be implemented in the new district as written. Some things are obvious, such as a goal written by the previous district based on activities done in a pool or at a therapeutic riding facility. If your district doesn’t have these features you will need to revise the IEP (Plan of Care) so that activities in support of the targeted outcomes can be accomplished in your environment. It could also be that the student was not included during much of the school day and in your district it is customary that students with disabilities spend much more time in regular education instructional settings with their peers. In that case you will need to consider, in concert with the IEP team, whether goals/objectives need to be changed and the intensity of the services needed to support the student’s progress on the new goal (e.g., time, frequency and duration) – essentially a revision to your Plan of Care. 
Your question is a good one, as there is often confusion around this issue. 
Federal and state policy specify that ARD/IEP committees must make all decisions about services and suppports for students based on current data. Entry into special education and the resulting decisions about instruction and the need for related services are made based on a Full and Individual Evaluation (FIE).
After services are initiated, up-to-date data must be presented at each annual ARD/IEP meeting so that decision-making for the next 12 months is also based on current data. Data should include work samples, charts, graphs, or other quantifiable evidence from progress monitoring toward goals/objectives.
Reevaluation is required at least every 3 years, unless the ARD/IEP team determines that there has been no change from the previous evaluation. If that is determined, the committee can bring the date of the evaluations done most recently up to the current date, and the new date becomes the legal date of record. The commitee may also decide that while there is need for reevalation in one area or for one service, reevalutaion is not needed in all areas or for all services.
In our experience, no change is very rare. For most kiddos, there are continuous changes in their growth and development, periodic changes in placement, and/or changes in teachers (which can mean increased or decreased need for therapy support).
It is important for you to know how your district administration sees this issue and what procedures they want you to follow. Districts differ in their philosophy and approach, and you will want to ensure your practice is aligned with their preferences.
Yes. Be sure that your documentation reflects what you did to evaluate the equipment for the student and your rationale for the recommendation you made not to use it. If the district has decided to proceed despite your recommendation, you must let go of the situation as it is no longer in your hands.
Under federal law (the Individuals with Disabilities Education Act [IDEA]), evaluations for occupational and physical therapy at school should answer the question of whether that service is required in order for the student to benefit from his or her special education program. To do that, data collection needs to include a variety of sources, including student records, observations of the student in various contexts where he or she may be struggling, and interviews with parents and teaching staff regarding their perspectives of the student’s strengths and areas of concern. When additional information is required in order to make decisions about whether occupational or physical therapy is needed, additional standardized and non-standardized assessments may be useful. The use of such assessments is not required in the law or in licensure. In the school setting, functional activities and participation at school are the focus of evaluation. Assessment of impairments, such as range of motion, tone, strength, etc. would not be the focus, but might be taken into consideration if they impact the student’s ability to perform needed tasks and to participate in the educational program. For more information, please see the links below. The first is an article on the TxSpot website; the second is from the American Physical Therapy Association Section on Pediatrics. Even if you’re an occupational therapist, the information is well-presented and applicable to occupational therapy as well.



​“This disclaimer governs your use of our website; by using our website (www.hcde-texas.org) and (www.txspot.org), you accept this disclaimer in full. Selecting links will take you away from the HCDE/TxSpot sites. We are not responsible for the contents of any other websites. We reserve the right to modify these terms at any time.” ​