Step 7: Planning for Other Considerations and Special Factors
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IEPs are dense and contain a ton of information! To make sure that nothing gets left out accidentally, most IEP templates include a specific structure for “other considerations.”
The federal law requires five special factors to be considered in the IEP:
- Behavior that impedes learning
- Limited English proficiency
- If the student is blind or visually impaired
- The communication needs of the student, especially if the student has hearing loss
- Assistive Technology
However, states and districts vary on additional factors that are required.
The template your district uses may list these factors under “other considerations” or as individual sections.
If the consideration is listed in the IEP template, you must address it, even if it doesn’t apply to your student. But, it can be very short and sweet. If any given circumstance doesn’t apply to the student a simple statement saying it doesn’t apply is generally enough.
You may also feel that some of the considerations are overlapping and that you’re repeating yourself. For example, students may use assistive technology to communicate. If you thoroughly cover both considerations within one area, it’s usually enough to say so in the second area. For example, when filling out the Communication Needs section, you may say “Communication needs are addressed in the Assistive Technology section of the IEP.” However, some IEP teams prefer to be more specific with each consideration.
Click the special consideration areas to learn more:
Behavior that Impedes Learning
This section of the IEP is rather straightforward. It should detail any behavior that interferes with the student’s learning or the learning of their classmates.
It should also include information about the preventative strategies that work best to keep the behavior at bay as well as any response strategies that teachers can use when they see the behavior. Federal law specifically lists the use of positive behavioral interventions and supports to address the behavior.
If the student has a Functional Behavioral Assessment (FBA) and Behavior Intervention Plan (BIP) it should be indicated here. You usually don’t need to replicate all of the information in the plan within the IEP, but giving a few details is helpful. List the specific challenging behavior as well as the function and the main interventions used. Then, ensure that the FBA and BIP are included in the student’s digital and physical files so they can be easily accessed in the future.
If the student does not display unexpected behavior, simply state something like, “The student does not display any behavior that impedes their learning or the learning of others at this time.”
Limited English Proficiency
With English Language Learners being a growing population in US schools, IEPs must explicitly state if English is not a student’s first language.
If English is not the primary language, IEP teams must obtain and review assessment data about the student’s ability to speak, read, write, and understand English.
IEP teams should consider if any limited abilities in English will impact the student’s ability to benefit from their IEP instruction. If so, they should discuss if the student should receive their specialized instruction in their native language or in English. Or if tutoring in English should be provided as an IEP service in addition to any other English as a Second Language instruction.
They may also need testing accommodations such as the use of an English translation dictionary in their native language.
If English is the student’s native language, a simple statement such as “The student’s primary language is English and there are no concerns around limited English proficiency at this time.”
Students who are Blind or Visually Impaired
Obviously, being blind or visually impaired and the impact it has on the student should be discussed in many other sections of the IEP. The federal law specifically focuses this section on the need for the IEP team to determine instruction in Braille is appropriate for the student.
The law states that the IEP should provide instruction in Braille unless an appropriate evaluation of the child’s reading and writing skills has been assessed, including an evaluation of their future need for Braille, and the team determines that Braille is not appropriate for the student.
If Braille is required for the student, work with the vision specialist or Teacher of the Visually Impaired in your district to ensure instruction is appropriate.
If this is not an area of concern, simply state that “the student is not blind or visually impaired and does not require instruction in Braille.”
Communication Needs
Communication is a critical aspect of education for students with disabilities. This section of the IEP explicitly outlines anything the student needs in order to understand others and express themselves at school.
If your student uses any kind of support for communication, clearly state that here. For example, they may use a picture exchange system or communication device to express themselves. Or, they may need picture support and extended time to process directions from staff.
In addition, teams must consider the student’s opportunities for direct communication with peers and staff in their communication mode. They should have meaningful opportunities to talk to their peers in ways that work for them.
The team must also consider if direct instruction in their mode of instruction is required.
If communication is not a concern, simply state “The team determined there are no communication needs at this time.”
Students who are Deaf or Hard of Hearing
For students who are Deaf or hard of hearing, additional consideration should be given to their communication needs. The federal law specifically requires IEP teams to discuss the student’s opportunities for direct communication with peers and professionals in their mode of communication.
For students who communicate with sign language, consider the need for a sign language interpreter.
Work with the experts in your division, like the teachers of the deaf and hard of hearing to ensure the student receives the most appropriate support and instruction.
Assistive Technology
Assistive Technology (AT) can be a critical part of a student’s ability to participate in their education.
AT can include a wide variety of supports, from low-tech options like pencil grips or slanted writing surfaces to high-tech speech recognition software and communication devices.
Any AT required by the student should be explicitly listed in this section of the IEP, along with details about how the student uses the technology.
Make sure to clearly describe the technology and avoid jargon. For example, use the full term like “speech output device” instead of “talker.”
This section should also provide information about how the current AT being used is performing for the student and any details about upkeep or training needed for staff.
If the student doesn’t require any AT, a simple statement will do. For example, “Assistive technology is not required at this time for the student.” Or, “The IEP team determined there are no concerns related to assistive technology at this time.”
Participation in State and District Testing
Every state has some kind of standardized testing to measure student progress. And, the vast majority of students with disabilities participate in these tests. In fact, many states limit the number of students schools can opt out of state testing.
In this section, note if the student will be participating in any state testing within the duration of the IEP.
This section may sound like:
- “The student will participate in the state test for 6th Grade Math and World Geography with state-approved accommodations.”
- “Because there are no state testing requirements for kindergarten, the student will not be participating in state testing in the next year.”
- “The student is on a modified curriculum and will be participating in alternative assessments for 11th Grade Reading and Math.”
Testing Accommodations
If the student is participating in standardized tests, the IEP will need any Testing Accommodations to be listed in a separate section from Classroom Accommodations.
While Classroom Accommodations are used all year and can vary widely depending on student needs, Testing Accommodations are typically limited. This allows the test to still be reliable without denying the student reasonable accommodations to take the assessment.
Check with your local (state or district) representative to find out what accommodations are permitted on each specific test. Many districts will require testing accommodations to be pre-approved in advance of the test or be selected from a pre-approved list.
Transportation Needs
Students may need specialized transportation for a variety of reasons. Many students with physical disabilities need specialized equipment that requires an accessible bus. Other students may demonstrate behavior that makes riding on a regular school bus dangerous.
Whatever the cause, if any specialized transportation services are needed, make sure to describe them in this section of the IEP.
Examples include having a bus aide to assist the student with behavior or mobility, accessible seating, a safety harness, or a modified, shorter route to school.
If there are no concerns related to transportation needs, a statement such as “the student currently rides the regular school bus to and from school each day with no accommodations, services, or concerns.” Or, “The student is currently driven to and from school each day by their parents and there is no need for specialized transportation at this time.”
Extended School Year Services (ESY)
Students with disabilities often struggle with the long break in the summer. Extended school year services, usually called ESY, are one way to mitigate learning loss.
However, it isn’t for every student. There are strict requirements to determine if students are eligible for ESY. Most students with disabilities will not qualify for ESY.
ESY is not summer school or an enrichment program. And students can’t be excluded from other school-provided programs based on their participation in ESY. It’s also not childcare and it isn’t required to be in the student’s home school or be provided all day.
ESY Services do not need to cover all IEP goals and do not have to be provided for a full day. Students may only need services for a single or a few goals, which could be as little as 30 minutes of instruction a week.
Requirements
Below are the typical considerations for determining if ESY is right for a student. It must be discussed by the IEP team, and the student must require ESY services in order to benefit from their special education services during the regular school year in order to qualify. However, these may vary by school district, so check with your local representatives.
- Regression and Recoupment
If there is data to show that the student consistently loses progress they’ve made over extended breaks and doesn’t recoup the skills at a reasonable pace, the IEP team may determine that ESY is needed. - Emergent or Breakthrough SkillsIf the student is demonstrating initial growth on a skill or is at a critical stage of developing a skill that is necessary for their education, ESY Services may be needed to prevent losing this progress.
For example, a student who is just starting to learn to sound out words. If they do not master the skill, the break-in instruction may set them back significantly. This is often important when students have shown little to no progress earlier in the school year but finally start making progress towards the end.
- Ability of Parents to Provide Educational Structure at Home
As stated above, ESY is not childcare. However, there have been cases where ESY was required because the child’s guardians were unable or unwilling to provide basic structures that would prevent the loss of skills. ESY may not be needed if the student is able to participate in summer programs or get some basic reading or math practice at home- such as with worksheets or computer programs provided by the school. - Severity of the Disability
Students with more significant disabilities are more likely to require ESY services due to being more likely to lose skills over breaks and be slower to recoup skills upon returning to school.
However, disability category alone must never be used to make IEP decisions in any case, including ESY decisions.
- Interfering Behavior
Some students who demonstrate challenging classroom behaviors require ESY services. However, it should be considered that ESY is often housed in a single school for a division and the student will likely have a different teacher. This means new rules, routines, people, and peers. These can be particularly challenging for students who struggle with following routines. Especially when ESY services are only provided for a few hours a week. IEP teams should consider this when discussing if ESY will benefit the student and if other options may be more helpful. - Special Circumstances
Of course, every IEP team should consider any special circumstances that may necessitate ESY services.
Ultimately, this decision is a team decision and should answer the question “Does the student require an extended school year to benefit from their educational program during the regular school year.”
If the IEP team determines the student does require ESY services, a statement such as “Due to data displaying the student shows a significant amount of regression after breaks from school and takes several weeks to recoup lost skills, the team determined ESY services are necessary to work on these goals/skills: (List goals or skills).”
The section should then also list the amount of time the student will attend each week. This can range from as little as 30 minutes a week to four full days of instruction and anything in between.
If the IEP team determines the student does NOT require ESY services, a statement such as “The IEP team reviewed the student’s data and determined they do not require ESY services at this time.” You can go on to elaborate on any other considerations that were discussed as well, such as the parent’s plans to enroll the student in a summer program or any special circumstances discussed.
Medical Needs
For students to be successful at school, their basic health needs must be met. For some students with disabilities and complex medical needs, this is much more complex.
Often, this is where medications taken either at home or at school are discussed. Be sure to include any medical diagnoses, such as ADHD, asthma, or allergies that may or may not impact their education.
For students with more threatening disorders, such as severe asthma, epilepsy, or food allergies, and students with complex needs, like a feeding tube or trach, much more detailed information is needed.
IEP teams should write a specific Health Care Plan to be attached to the IEP. This plan is written with medical professionals, such as the school nurse and the student’s doctor, along with the IEP team. It should clearly detail what medically necessary supports the student needs on a daily or weekly schedule as well as what to do in the case of emergencies.
It’s very important that this plan includes all of the necessary details, including:
- What will happen routinely to support the student
- What the signs of an emergency are
- What to do in case of an emergency
- Where needed equipment is kept
- Who is responsible for carrying out each aspect of the plan
- What training is needed for staff
- Who will provide that training
If there are no medical needs, a short statement such as “The student has no medical needs or concerns at this time” is sufficient.
With all of the specific supports and interventions students need, it’s no surprise that staff might also need training.
This section of the IEP should list any specific training that school staff need to support the student and who is responsible for providing it.
Some examples include:
- The special education teacher or a behavior specialist training staff in how to follow the behavior plan
- The nurse providing training on how to administer emergency medication or change simple medical equipment
- The parents providing training in how to change the batteries in a hearing aid
- The special education teacher attending training in a specific reading or math program
If no training is needed, state that clearly. For example, “The team discussed training and determined there were no training needs for school personnel at this time.”
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