ARDs and the IEP
- NEW: Can OT and PT be listed as “Supplementary Aids and Services" in the IEP?
- What is my role in the development of the Present Levels of Academic Achievement and Functional Performance (PLAAFP)?
- What should I consider when planning therapy services for a homebound student?
- Can I write collaborative goals with another provider?
- How much OT or PT time should I recommend for my student?
- Can the ARD/IEP committee override my recommendations?
- How can I advocate for my district to move toward collaborative and integrative services?
- Can I draft IEPs for the following school year?
- Where can I find resources supporting collaborative goals?
- I have several questions about things that advocates have demanded (see below):
- Should OTAs and PTAs attend ARD meetings?
- Must frequency of services be documented in the smallest increment?
- On the schedule of services, are we required to include specific weeks we will see a student (e.g. 30 min three times per grading period on weeks 1, 3, & 5)?
NEW: Can OT and PT be listed as “Supplementary Aids and Services" in the IEP?
While it is technically possible for occupational therapy or physical therapy to be listed under Supplementary Aids and Services in an IEP, it’s not clear what the benefit would be if you are, or plan to be, providing student-specific, individualized support.
Both IDEA and Texas law define occupational therapy and physical therapy as related services. OT and PT services, whether delivered through a direct or indirect/consultative model, and whether documented as a related service or as supplementary aids and services, must be provided in compliance with OT and PT licensure rules. It’s important to distinguish between student-specific and non-student-specific services.
Student-specific OT and PT services in the school-based setting are services that are designed to address the individualized needs of a particular student and are provided because of that student’s unique educational needs.
Student-specific services include, but are not limited to:
- Direct intervention, in which the therapist works directly with an individual student or a small group for the purpose of addressing that student’s IEP-related goals or needs.
- Indirect or consultative intervention when the consultation is focused on a specific student, such as collaborating with teachers, staff, or parents to develop, modify, or monitor strategies, supports, or accommodations for that individual student.
- Collaboration regarding a specific student, including problem-solving, data review, modeling strategies, or providing recommendations related to an individual student.
In contrast, non–student-specific services are activities that are not tied to an individual student and are intended to support multiple students, classrooms, or the school environment as a whole. Examples include school-wide initiatives, general staff training, environmental supports applied broadly, or sharing universal strategies that are not individualized or tracked for a particular student.
Key distinction:
If the OT or PT service is designed, adjusted, or delivered based on the needs of an individual student, it should be considered student-specific, regardless of whether the service is provided directly to the student or indirectly through consultation with others.
When providing student-specific OT or PT services, therapists must complete an evaluation, obtain physician referrals (as required by discipline specific licensure rules), and develop a Plan of Care that includes goals, as well as the frequency and duration of services needed to support the student.
OTs and PTs can, however, provide non–student-specific services to districts in other capacities, for example, as Specialized Instructional Support Personnel (SISP) under the Every Student Succeeds Act (ESSA). These types of activities often include school-wide initiatives such as the Comfortable Cafeteria or other environmental supports, which are not listed in an individual student’s IEP. OTs may also provide general classroom support without a formal OT evaluation, such as providing teachers with a handout of general strategies to support attention in the classroom. Similarly, PTs may support school-wide initiatives such as developing and promoting a campus-wide movement or physical activity program, consulting on safe and developmentally appropriate movement opportunities during recess or classroom breaks or assisting with school-wide physical fitness and injury prevention activities. These supports are intended to benefit the broader student population rather than address the needs of an individual student.
Regardless of where your district documents OT or PT services within an IEP, therapists must complete appropriate evaluations, obtain physician referrals (when required), and develop a Plan of Care, in accordance with applicable licensure rules, for each student receiving student-specific, individualized services.
- Supplementary Aids and Services (Component of the IEP) - Center for Parent Information and Resources (parentcenterhub.org)
- https://tea.texas.gov/academics/special-student-populations/special-education/related-services-for-students-with-disabilities-qustions-answers.pdf
- https://www.tota.org/assets/FINAL_OT%20ESSA%20Admin_4-25-22.pdf
- Supplementary Aids & Services - Texas Project First
What is my role in the development of the Present Levels of Academic Achievement and Functional Performance (PLAAFP)?
Under IDEA §300.320(a), every IEP must include a statement of the student’s present levels of academic achievement and functional performance (PLAAFP). This statement must:
- Describe the student’s current performance in measurable, objective terms to establish a baseline.
- Explain how the student’s disability affects their involvement and progress in the general education curriculum (or, for preschool, participation in appropriate activities).
- Identify strengths, needs, interests, and learning style, using current and relevant data from a variety of sources.
In addition, the PLAAFP serves as the foundation for a student’s IEP goals and guides decision-making regarding services, supports, and accommodations. Each area of need identified in the PLAAFP must have a corresponding IEP goal.
1. Share Functional Performance Data
OTs and PTs provide objective, measurable information about how a student functions in the school environment, including:
- Postioning/Transfers (getting in/out of classroom furniture; on/off floor/commode/cafeteria bench/seat; assuming and sustaining a posture/position for learning; and, classroom and personal equipment used/needed)
- Mobility (navigating classroom, school grounds, hallways, cafeteria, restroom, playground, community/jobsite; managing curbs, ramps, and stairs; participating in PE/APE/recess; and, school or personal equipment used/needed)
- Self-Help (manipulating fasteners on clothing; managing clothing; toileting; dressing; completing personal hygiene tasks; eating and drinking; and, equipment needed to complete those tasks)
- Completing Classroom Tasks (picking up and utilizing classroom materials; cutting; marking, writing; drawing; accessing cubby/locker/backpack; written expression and literacy skills; and, equipment needed to complete those tasks)
- Functional and Social Behaviors (ability to work independently; attention to task; following directions; organizational skills; social skills; managing feelings and behavior; making needs known/self-advocacy; transitioning between tasks or people; safety awareness; plans for post-secondary role; participation in leisure/recreational activities; and, accommodations/modifications needed for success in these areas)
Data sources can include:
- Standardized assessments and progress monitoring data.
- Observations in natural environments (classroom, cafeteria, playground).
- Teacher, staff, student, and parent input.
- Work samples, grades, attendance, discipline records, and information on accommodations or assistive technology effectiveness.
2. Describe the Impact on Educational Access
Clearly link findings to educational outcomes in terms of what the student is able to do.
For example:
Instead of “has poor core strength,” write: “Demonstrates ability to maintain an upright seated position for up to 10 minutes. During longer periods, he benefits from supported positioning to sustain attention during desk work.”
Explain how the student's disability creates barriers to participation in routines, affects use of materials, limits mobility or independence, or influences stamina and attention.
3. Identify Strengths and Needs
Highlight what the student does well and areas needing support:
Strengths (e.g., highly motivated; self-identifies when needs to use accommodations; anticipates next steps in routine tasks; successfully engages in social interactions during structured activities.)
Needs (e.g., has difficulty with hand-written class assignments and needs support to compose sentences legibly; requires specialized positioning and mobility equipment to navigate through the school environment and participate in school activities.)
Remember that every area of need identified in the PLAAFP should be linked to a measurable IEP goal.
4. Collaborate with the IEP Team
Provide your input during ARD/IEP discussions to ensure an accurate and complete picture of the student’s present levels of academic achievement and functional performance.
Coordinate with teachers, parents, and other specialists to align findings with educational needs and priorities.
Use language that is accessible to all team members, avoiding jargon and focusing on educational relevance.
5. Contribute to Goal Development
The OT and PT’s input to the PLAAFP helps guide the ARD/IEP team in developing measurable annual goals that are collaborative, interdisciplinary, and related to the student’s unique needs.
Bottom line:
The role of the school-based OT and PT is to contribute current and objective information about functional performance that helps the team understand how the student’s disability affects their educational participation and progress. This information forms the foundation for meaningful, achievable IEP goals and ensures the district meets its obligation to provide a free appropriate public education (FAPE).
What should I consider when planning therapy services for a homebound student?
Homebound is an instructional setting determined by a student’s Admission, Review, and Dismissal (ARD) Committee. For students aged six and older, specific eligibility criteria must be met for a student to receive instruction in this setting. Students aged three through five may be placed in the homebound instructional setting if deemed appropriate by their ARD Committee. The student’s Individualized Education Program (IEP) will document homebound as the instructional setting and outline other necessary components identified by the ARD Committee to ensure the student receives a Free and Appropriate Public Education (FAPE).
When determining a student’s need for occupational therapy (OT) or physical therapy (PT) in a homebound setting, it is essential to apply the same individualized considerations as in any other instructional setting. A one-size-fits-all approach should be avoided. Individual student needs vary, and it is inappropriate to assume that homebound services will always or never be provided, or that students will consistently receive a predetermined number of visits, or a specific fraction of their service time compared to their school-based placement. Therapy services in the homebound setting must address functional and academic needs that directly impact the student’s ability to access and benefit from their educational program as outlined in the IEP.
Best Practices for Determining OT and PT Needs in Homebound Settings
An integrated service model that employs an interdisciplinary team approach is recommended. Several factors should be considered when evaluating the need for OT or PT in a homebound setting:
- Curriculum Demands
- What goals and objectives will be addressed by the homebound teacher and other providers?
- Learning Environment
- What aspects of the environment where learning will occur might support or hinder participation?
- For example, what seating and positioning options are available to optimize engagement? Are adapted instructional materials needed to assist the student with participating in learning activities? Are additional mobility supports needed to ensure the student can safely navigate their home environment for learning activities?
- Staff Knowledge and Support
- Do school staff require guidance to meet the student’s physical needs and promote participation in learning activities?
- For instance, do they understand how to position the student optimally for learning?
- Existing Supports and Services
- What supports are currently in place, and what additional strategies may facilitate or hinder the student’s participation?
- What other accommodations, modifications, assistive technology, or instructional and related services are being provided to address the student’s needs?
Therapists should assess whether there are unmet needs that necessitate OT or PT services. Recommendations must be based on the student’s current needs within the homebound setting. Comprehensive information gathering and collaboration with the student’s team are critical to identify specific needs and the supports already in place. The ARD Committee must determine whether OT or PT services are required to support the student’s progress toward mastering IEP goals and how such services might assist.
Collaboration and Coordination
Since homebound services typically occur in the family’s home, coordinating with homebound teachers or other providers when scheduling therapy visits is essential. This ensures that OT or PT services remain educationally relevant and collaborative.
Conclusion
- Students placed in a homebound setting remain eligible for special education services and are entitled to receive all the supports and services necessary to benefit from their educational program.
- The process and factors considered when determining a student’s need for occupational therapy (OT) or physical therapy (PT) in a homebound setting are the same as in any other instructional setting.
- Service delivery in a homebound setting may require adjustments in frequency, duration, and methods of progress monitoring.
- Therapists should remain flexible and collaborate with the ARD Committee to adapt services to the unique demands of the home environment while maintaining alignment with the IEP.
Can I write collaborative goals with another provider?
Collaborative goals are Individualized Education Program (IEP) goals developed by an interdisciplinary team. Collaboration is a core component of the Individuals with Disabilities Education Act (IDEA). Collaboratively developed goals can result in improved outcomes, shared ownership, and increased teamwork in selecting and implementing strategies to support students’ mastery of their IEP goals. Further, there is no wording in the IDEA or Texas law that requires service providers to write their own discipline-specific goals. According to the “Joint Statement on Interprofessional Collaborative Goals in School-Based Practice, “IEP goals are individualized to the student and do not belong to any specific discipline.” (AOTA, APTA, ASHA, 2002, p. 3).
OTs and PTs often collaborate and co-implement IEP goals with classroom teachers, helping to support both academic and functional goals. However, they can collaborate with any instructional or related services providers the student may need, including homebound teachers, teachers of students with visual impairments, speech-language pathologists, music therapists, orientation and mobility specialists, adaptive PE teachers, and more.
In the IEP development process, providers must determine how, when, and by whom data collection will occur and who will be responsible for reporting progress to parents via the progress report. Generally, multiple providers will collect their own data and share it with the provider responsible for progress reporting.
Here are a few resources for more information:
Fact Sheet: Developing Collaborative IEP Goals (from APTA)
Fact Sheet: Occupational Therapy's Role with School Settings
How much OT or PT time should I recommend for my student?
Related services such as occupational therapy (OT) and physical therapy (PT) are supportive services provided to students with disabilities to assist them in benefiting from special education. But how does one determine what is appropriate in terms of the time, frequency, and duration of services needed to provide support to a student?
TxSpot often receives questions as to whether tools or guidelines exist that can help determine the amount of therapy a student will need at school. While several tools have been developed, including the “Determination of Relevant Therapy Tool,” the “Considerations for Educationally Relevant Therapy,” and the “Occupational Therapy and Physical Therapy Service Needs Checklist, A Guide to Service Delivery for Ages 3-21,” more research is needed to determine whether these tools have validity. There are so many variables to consider that it is difficult for a tool to address them all. But what these tools do have in common is a focus on determining what services are educationally relevant, in other words, what is needed for students to make adequate progress toward their goals and objectives and benefit from their special education program.
Research does support an integrated model of service delivery. This means services provided to the child and on behalf of the child (direct and indirect) that are embedded in natural environments during daily routines. This approach emphasizes the importance of 1) working in collaboration with the educational team, and 2) applying interventions at the time and place the participation or performance concern occurs. An integrated approach doesn’t assume the barrier to success is in the child with the disability but rather acknowledges that the issue is often the fit between the student and his environment.
With all of this in mind, what should therapists consider when formulating recommendations about the time, frequency, and duration of services? The therapist must gather data regarding not only student factors such as physical abilities, sensory processing, and self-help skills, but also contextual factors that impact a student’s performance or participation. These can include the supports that are currently in place, how adequately these supports are helping the student to succeed and the skillset of the teacher. It is likely that a first-year teacher who does not have experience working with students with autism will likely need more support from OT than a veteran teacher. The inexperienced teacher may need support to learn how to implement common sensory strategies in the classroom, set up a structured environment, utilize visual schedules, etc. The school environment must also be considered and includes the physical, time-based, and sensory aspects of all areas of the campus, such as the classroom, hallways, bathrooms, cafeteria, playground, gym, and more.
Factors such as the amount of structure in the classroom or noise level in the cafeteria to the spacing and layout of classroom desks and tables can all impact how successful a student may be. All these factors must be considered when determining how much support may be needed from your service in order for the student to make adequate progress and benefit from his education. Consideration should be given to time that may be needed to adapt a student’s environment, activities and tasks, support accommodations including assistive technology, and more.
The student’s evaluation is one source of data and is a critical tool to help therapists in developing educationally relevant recommendations. A school-based evaluation must address concerns that prompted the request for the evaluation, but should also address the student's participation and performance across all domains within the scope of OT or PT. The evaluator must consider the student’s Individualized Education Program (IEP), including Present Levels of Academic Achievement and Functional Performance (PLAAFP), goals and objectives, and other supports and services currently in place to address the student’s needs. If a student was evaluated in a previous school year, the therapist will want to consider additional data when formulating recommendations. Sources include information from the student’s IEP such as progress on goals and objectives and the student’s present levels of academic achievement and functional performance, as well as progress notes and reports and data collected by both the therapist and teacher.
In consideration of the above information, therapists must think about not only any time needed to work directly with a student but also time to collaborate and communicate with and provide training/education to others on the student’s educational team. Thought must also be given to the time needed to order, create, or adapt equipment or other assistive technology. Finally, time must be allotted to collecting and analyzing data on student progress and the effectiveness of interventions.
Keep in mind that decisions about the time, frequency and duration of OT and PT services are ultimately made by a student’s ARD Committee. The responsibility of the therapist is to be knowledgeable about each student’s unique and individual needs and to recommend an appropriate time, frequency, and duration to the ARD Committee for consideration that is based on data.
Links to Resources:
Related Services for Students with Disabilities - Questions and Answers (texas.gov)
Joint Statement on Interprofessional Collaborative Goals in School-Based Practice - AOTA, APTA, ASHA
Can the ARD/IEP committee override my recommendations?
The answer is yes. In federal and state policy, the IEP team (ARD committee in Texas) is given the legal authority to develop a program of special education and related services for the student with disabilities. This is known as the Individualized Education Program (IEP). From a legal perspective, ARD committee decisions must be based on current data, and certainly should consider the recommendation of the service provider.
The service provider’s responsibility is to bring a sound recommendation to the ARD committee that is supported by evaluation and other current data. In addition, the service provider needs to actively listen to information provided by others present in the meeting as well as questions or concerns posed to him/her. At times, the provider may hear information that is new and warrants discussion and possibly a change in service recommendations. If this occurs, it is good practice to ensure that the ARD deliberations clearly articulate the change in the therapist’s recommendations and the reasons for the change.
If there are differing opinions regarding therapy services for the student and the service provider does not feel that the available information warrants a change in recommendation, he/she should make sure that the deliberations document the original recommendations. If after that, the committee decides not to follow the recommendation of the service provider, they can do so. This applies to situations where a different frequency or intensity of services is decided upon, or when the committee changes the focus of the service and the goals the provider is supporting, or even when the service provider is recommending discontinuing services and the committee decides to continue the services.
Even if the service provider does not agree with the decision, the IEP must be implemented as specified. While the professional might not be happy about being overridden by the ARD committee, 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 instance when the services specified by the ARD committee are contraindicated or would result in harm to the student.
How can I advocate for my district to move toward collaborative and integrative services?
I am sorry to hear that you are having trouble getting others to embrace a more collaborative approach; I can certainly appreciate your challenge. Change is a stressful process for most, and it takes time.
Many OTs and PTs are not educated on how to provide services in the school setting and upon entering school practice, employ their knowledge of clinical practices aimed at remediation of impairment or closing a developmental gap. In order to meet the standard of supporting a student's educational needs, evaluations, interventions and supports need to be provided in natural environments during daily routines.
You may want to approach your administration about providing training—to other therapists, diagnosticians, other service providers, teachers, school leaders, and parents—using professional literature and the evidence. We have a mandate from the Individuals with Disabilities Education Act (IDEA) and the Every Student Succeeds Act (ESSA) for practices based on scientific research. Evidence tells us of the importance of context – both in terms of understanding the facilitators and barriers to learning and participation, and in the provision of strategies to overcome the barriers.
Below are two resources to support your position. Both are applicable to school-based occupational therapy as well as school-based physical therapy.
Joint Statement on Interprofessional Collaborative Goals in School-Based Practice - 2022 (asha.org)
Also, familiarize yourself with the International Classification of Function and the World Health Organization model for persons with disabilities; it emphasizes that disability is the result of the interaction between persons and their environment. Take the time to understand the ICF's model of disability in the “Towards a Common Language for Functioning, Disability and Health" (2002) (currently found on page 9).
Another resource can be found within IDEA and IDEA guidance resources. Individuals with Disabilities Education Act (IDEA) Topic Areas. One of the main principles of IDEA is Least Restrictive Environment (LRE).
Good luck with your endeavors towards best practice.
Can I draft IEPs for the following school year?
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.
Where can I find resources supporting collaborative goals?
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. Below are a few resources you may find helpful.
Occupational Therapy Association (2016). Fact Sheet: Occupational Therapy in School Settings. Bethesda, MD: AOTA Press.
Dole, R.L., Arvidson, K., Byrne, E., Robbins, J. Schasberger, B. Consensus among experts in pediatric occupational and physical therapy on elements of individualized education programs. Pediatr Phys Ther. 2003 Fall; 15(3): 159-66.
Hanft, B. & Shepherd, J. (2008). Collaborating for Student Success: A Guide for School-Based Occupational Therapy. Bethesda, MD: AOTA Press. pp. 155-156.
Wynarczuk, K.D., Chiarello, L.A., Fisher, K., Effgen, S.K., Robert J. Palisano, R.J., & Gracely, E.J. (2019): Development of student goals in school-based practice: physical therapists’ experiences and perceptions, Disability and Rehabilitation, DOI: 10.1080/09638288.2019.1602673
Clark, G. F., & Chandler, B. E. (eds.) (2013). Best Practices for Occupational Therapy in Schools. Bethesda, MD: AOTA Press. pp. 57 – 61.
McEwen, I.R. (ed.) (2009). Providing Physical Therapy Services under Parts B & C of the Individuals With Disabilities Education Act (IDEA), 2nd Ed. Alexandria, VA: Section on Pediatrics, American Physical Therapy Association.
I have several questions about things that advocates have demanded (see below):
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.
2) going out of order of the ARD and asked what our recommendation/plan of care is prior to the IEPs being discussed.
3) told to send home OT notes every 9 weeks to family. Is this required if parent asks? How can we avoid this?
Should OTAs and PTAs attend ARD meetings?
Must frequency of services be documented in the smallest increment?
On the schedule of services, are we required to include specific weeks we will see a student (e.g. 30 min 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, “What is required is that the IEP includes information about the amount of services that will be provided, so that the level of the agency's commitment of resources will be clear to parents and other IEP Team members. ...The amount of time to be committed...must be ...clearly stated in the IEP in a manner that is understood by all involved in the development and implementation of the IEP.” (Documenting the Frequency, Location, and Duration of Services.)
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