Placement & the Least Restrictive Environment

We’ve mentioned placement and Least Restrictive Environment (“LRE”), in previous postings. Today’s posting focuses specifically on these aspects of special education.

 

As discussed previously, placement is the last decision made by an Individualized Education Plan (“IEP”) team and is that setting in which a student’s measurable annual goals can be met using the services determined necessary by the IEP team and which is the least restrictive when compared to all other possible educational settings in which the goals could be met using the services determined necessary. In other words, once you’ve figured out goals and services, the IEP team has to examine all of the possible settings in which the services could be provided and the goals met, then pick the one that is the least restrictive.

 
“Least restrictive” is a relative term specific to the individual child. What may be least restrictive for one child may not be least restrictive for another. The language found at 34 CFR ? 300.114 states that:  “To the maximum extent appropriate, children with disabilities … are educated with children who are nondisabled;”  and “Special classes, separate schooling, or other removal of children with disabilities from the regular educational environment occurs only if the nature or severity of the disability is such that education in regular classes with the use of supplementary aids and services cannot be achieved satisfactorily.”

What this means in plain English to parents is that if your child’s needs can be met in the regular education setting with push-in supports, the regular education setting is the LRE. The public schools cannot segregate special education students from the regular education setting purely on the basis that these students have disabilities. The needs created by their respective disabilities have to be so severe in nature or so unique to serve, that the necessary services cannot feasibly be pushed into the regular education setting and met with success.

So, how do you know when it’s time to consider pull-out options or alternative placements to the regular education setting? It all depends on the child.

Let’s say, for instance, that you have a teenage daughter with significant social anxiety. She’s become a recluse and refuses to go to school at all and refuses to go places with the family except at night with a hoodie pulled over her head. Her IEP includes a behavioral goal targeting attendance, since this is an area of measurable need that requires specific attention in her IEP.

Clearly, regardless of how academically capable she might be, you’re not going to successfully place her on a comprehensive high school campus in a whole bunch of different classes throughout the day and passing in the halls between classes, much less lunch and PE.  A very small class with pushed-in mental health services on a continuation school campus may be more appropriate.

 

 

As another example, let’s say you have an 11-year-old son with delayed cognition, impaired attention, and mild autistic like behaviors, most of which involves perseverative thought, ritualistic behaviors, and inappropriate dialoging skills. While it would be possible to push an appropriate curricular program into the regular education setting, the reality is that the inattention could easily make the regular education setting highly distractible to this young man and his behaviors could require constant adult redirection. It could quickly become an exercise in frustration for everyone involved and derail not only this young man’s receipt of an education, but also that of his classmates. But, if you don’t know for sure that this is what will happen, you should at least try it. Then, at least, if things don’t work out, you know you that your decision to move the child to a more restrictive setting is informed and everyone knows that a less restrictive setting proved unsuccessful.  You should never presume the worst automatically when considering placement options.

 

A young man like this might actually benefit from spending at least part of his day in either a Resource Specialist Program (“RSP”) or a Special Day Class (“SDC”) setting. Perhaps, his day would end up being divided among the regular education, RSP, and SDC settings. That’s the thing about placement: you can mix and match components to come up with the most appropriate combination for each individual child. But, this requires flexibility on the part of the public education system and special education placements designed with this mix-and-match type of planning in mind.

 

It has been my unfortunate experience in many situations that placements have been offered by public education agencies based on what they already have in place rather than that necessarily serves as the LRE for a particular student. In fact, almost one year ago, we launched web site devoted to this very issue regarding the schools located in San Luis Obispo County, CA, http://www.slocoesdc.info.

 

This web site was inspired by the cases of children coming from tiny rural K-8 districts in SLO County that only offered placement up to RSP. Students of these tiny districts who needed more intensive placements than RSP usually had only one other choice: a Severely Handicapped SDC operated by the San Luis Obispo County Office of Education (“SLOCOE”). Of course, this wasn’t appropriate if the students weren’t severely handicapped.

 

There were no in-between placements being offered or created to meet the needs of students who needed more than RSP but not so restrictive a level of intervention as a Severely Handicapped SDC. While neighboring districts offered Learning Handicapped SDCs, SLOCOE did not and neither did these children’s home K-8 districts. Some of these children would have been most appropriately placed in a Learning Handicapped SDC but were not placed in these classrooms due to inter-agency politics, even when these Learning Handicapped SDCs were operated on the same campuses as the Severely Handicapped SDCs to which they were being bused every day.

 

When http://www.slocoesdc.info failed to facilitate productive discussions between local schools and parents to address this serious placement issue, KPS4Parents filed a compliance complaint with the California Department of Education (“CDE”) against San Luis Obispo County Special Education Local Plan Area (“SLOSELPA”) alleging that the full continuum of placements was not being made to all the children served by public education agencies within SLOSELPA’s jurisdiction, as is required by State law. The matter remains pending at this time and, according to our last conversations with CDE, its Focused?Monitoring and Technical Assistance?(“FMTA”)?Unit is working with SLOSELPA to address this concern.

 

The point, here, is that placement and the LRE requirements are complex issues that involve constantly changing needs that public education agencies have to address from one school year to the next. Creating cookie-cutter solutions isn’t the answer. There are people working in public education who actually think that placement is (or should be) driven by the IQ score of the student. There remains entrenched in some public education agencies the mentality that actually educating children with special needs is an unachievable goal and an utter waste of time and resources and, as such, warehousing such children and minimizing their expense to the public agency is the most prudent form of administrative stewardship that can be exercised.

 

There are sometimes teachers and other school site staff who just don’t want to have to work as hard as the situation actually requires. So long as they go through the motions and enough kids leave their classrooms knowing at least something more than they knew when they first arrived, these “educators” believe they have earned their paychecks and no one can expect any more of them than that. 

 

I once had a student we represented enrolled in a mainstream computer class where she was receiving a “C” as her grade. She was, however, bombing out all of her other mainstream classes. Thinking that maybe the computer teacher had found some way to get through to her somewhat, we invited him to this young lady’s IEP meeting so he could share his insights with the rest of us. Unfortunately, once he got to the meeting, he admitted that he gave “Cs” to all of the special education students who enrolled in his class because they at least showed up and he didn’t know what else to do with them. The young lady’s special education case carrier, who was also her RSP teacher, was horrified. 

 

There wasn’t much need for me to stick around after that. The school site special education team jumped all over the situation, reassessed this young lady to figure out what was going on, and developed a much more appropriate IEP after that.

 

Reassessment is often a perfectly appropriate way to respond to a failed placement. If a special education program fails, it’s because there was a variable that either wasn’t known or was ignored as was, therefore, left unaddressed. In many instances, the variable simply was not identified, making reassessment or additional assessment necessary.

 

Everything in special education is dependent upon thorough, accurate assessment data. It’s the foundation upon which present levels are identified, goals are written, services are selected, and placement is chosen.? Assessment conducted in an effort to ascertain why a child is not responding to intervention should include observations and analyses of the settings in which the child is succeeding and not succeeding. That way, when the IEP team sits down to revise the IEP, it has data about all kinds of things that will help in determining what placement is the LRE.

Writing Measurable Annual Goals – Part 2

In our posting, Writing Measurable Annual Goals?- Part 1, we talked about what goals are, the purpose they serve, and how they relate to present levels of performance. In today’s posting, we’re going to talk about the federal requirement that goals be measurable and how measurable goals can be written.

I cannot emphasize enough how critically important it is that goals are clearly and succinctly written in objective, quantifiable terms. In order for anything to be measurable, it must deal in absolutes and the language must mean the same thing to anyone who reads it.

First I’m going to give examples of unmeasurable goals and then I’m going to give you examples of measurable goals. I want you to contrast and compare them against each other.

Examples of Unmeasurable Goals:

[Student] will demonstrate understanding of language concepts by naming items within a given category with 80% accuracy.

Now pretend you have to implement this goal. First you’ll notice that this sentence contains two verbs: “demonstrate”  and “naming”. This is confusing. The piece that reads “will demonstrate understanding of language concepts” is superfluous and misleading. Including this language implies that something greater is going on here than that for which the language of the goal really provides.

There is another place on the goal page where the type of goal can be indicated without cluttering up the language of the goal itself. The language of the goal should describe what exact task the student is supposed to perform and nothing more.

If you eliminate this unnecessary bit to render the goal down to only what outcome the student needs to demonstrate, you’re left with “[Student] will name items within a given category with 80% accuracy.”  This is incredibly vague.

Does the student only have to do this once during the entire year that the IEP is in effect in order to have met the goal? If so, has he really mastered any new skill ? If not, how many trials must he perform at 80% accuracy in order to determine that the targeted skill has been mastered? How is the 80% calculated? How is any of this supposed to be measured? How many items must the student name within a given category? From how many categories will he have to name items? I’d also prefer to see the words “at least” immediately precede “80%” so that the student is expected to achieve “at least 80% accuracy,” which is different that saying flat-out the target is 80% and no more.

[Student] will write 15/26 letter sounds when dictated orally.

Again, this is vague. While we have some numbers in here, the goal overall is not measurable. How many trials must the student perform in order for it to be said that he mastered the targeted skill? And which 15 of the 26 letter sounds must he write? The way the goal is written, he’d only have to perform as described once during the entire year the IEP is in effect and the goal could be said to have been met. That doesn’t mean that knowledge was gained or a skill was acquired. It could be a totally random fluke.

I’d also like to see “at least” precede “15/26” for the same reasons indicated above under the previous example, along with clarification of which 15 letter sounds he’s supposed to learn. It shouldn’t include the ones he already knew when the baseline data was taken for the present levels statement.

In the classroom setting, [Student] will follow an individually designed visual schedule of his daily activities with minimal verbal prompts as measured by observation record achieving 80% accuracy.

Here, this sounds pretty okay except for the measurability. At least you have a decent idea of the spirit of the goal, but how many is “minimal”? Is the 80% accuracy meant to be averaged over the course of the year or just within the final stage of the goal? If it’s just the final stage, how long of a period of time is that? How is the 80% calculated? Is it a flat-out 80% or at least 80%?

In my many years as a special education advocate, I’ve come to realize that “achieving 80% accuracy” has become the arbitrary language that gets plugged in by default because it sounds measurable to parents, most of whom really don’t understand the measurability requirement or how it can actually be satisfied. It implies that some kind of calculation must be taking place or you wouldn’t be able to arrive at a percentage and 80% sounds like a high enough number that most parents will think the goal is reasonably ambitious.

But, when you start picking apart the language of the goal to turn it into a math word problem, you realize that there are too many unidentified variables to do any kind of calculation that can result in any kind of a percentage. Far too often, the percentage isn’t really the result of measurement; it’s a “guesstimation.”? Teaching staff will say, “Oh, I’d say he was about 75% accurate.”? There is no measurement in a situation like this at all.

To arrive at 80%, you need 4 out of 5, 8 out of 10, or 16 out of 20, etc. things done a certain way for the math to work out. This is where the number of trials and the number of presentations per trial becomes important.

When you get into reading and writing goals, this becomes even more complex. You need to specify the grade level of the passages to be read or written or use other terminology that describes the complexity of the language that the student is expected to read or write. You cannot use vague language like “at his instructional level” without identifying what the student’s instructional level is in the present levels of performance statement.

Really, that kind of language should be avoided altogether because the purpose of a goal is to move the student forward. If the goal is expecting the student to be performing at the same instructional level at the end of the goal as he was performing at the beginning, this generally means that he?isn’t actually expected?to progress.

The only real way to use this kind of language is to make sure there is also a goal in the IEP targeting the increase of the student’s instructional reading level and collecting data on progress towards that goal throughout the same annual IEP time frame so that the instructional reading level is known while any other goals that require presentation of text at the student’s instructional level can be appropriately adjusted as the year progresses.

Sometimes goals are poorly written because the school members of the IEP team really don’t know how to write them. Other times, they are deliberately keeping the language vague so that there is little that parents can actually hold them to. If the student fails to progress, it’s hard to point to the goal and say he didn’t meet it if it was vaguely written. Some school team members deliberately write weak goals so that they aren’t accountable to much.

Examples of Measurable Goals:

When presented with a worksheet containing 20 numbers, [Student] will correctly identify the place value of each number independently (tens, hundreds, thousands, ten thousands) in at least 4 of 5 trials over 2 consecutive weeks as measured by work samples.

This is nicely written. There is no way that two different people could pick this up and walk away with different understandings of what needs to be done.

Given a picture of interest, [Student] will be able to independently write 2 sentences (no dictation or adult prompting) using correct punctuation and capitalization in at least 3 out of 4 trials in a two week period as measured by work samples.

Again, this is really succinct clear language that describes an outcome that can be easily measured. It’s evident what the student has to do to demonstrate mastery of the targeted skill.

When given a reading passage at the end of first grade level about a topic of interest, [Student] will orally answer factual questions correctly by giving a sentence of at least 3 words in at least 3 out of 5 opportunities per trial for 4 trials within a 2 week period as measured by teacher made test.

This is a little convoluted, but you still arrive at the same place no matter how you look at it. Goal-writing isn’t meant to be Shakespeare. You could rearrange the words so they flow more smoothly, but the targeted outcome is still explained even as it is.

When you compare these last three examples against the first three, you can see the stark differences. The first three are vague and don’t really tell you what you’re supposed to do. The last three describe specific outcomes that can be measured.

The first two examples of the unmeasurable goals don’t even explain how they will be measured. The third unmeasurable goal example uses “observation record” as its method of measurement, but you have to be really careful with this.

Just like an arbitrary percentage without any indication of how it is actually supposed to be calculated is really just an estimate rather than a measurement, the term “observation” is often used as an arbitrary indication of how progress will be measured. In and of itself, “observation” isn’t any kind of measurement at all. “Observation” is simply looking at something.

An “observation record” is only as good as the kind of data it’s meant to collect and if that data isn’t described in the goal, whatever is recorded is likely to be unmeasurable.? I prefer that, instead of observation records or logs, there are data sheets and the method of measurement is indicated as “specific data collection,” but I’ll go along with “observation record” if the language of the goal is clear on what will be recorded or a copy of the observation record to be used is attached to the IEP as one of its pages, so there’s nothing left to anyone’s imagination as to what is supposed to happen.

If the goal is written in measurable terms, then the data sheets can be fairly simple check-off lists or tally sheets. Comments and anecdotal observations should supplement the data to provide context, but they shouldn’t replace the data.

We hope this makes goal writing make more sense. Please post your questions and comments. We realize this can be complicated and want to make sure you understand. As an added resource, you can visit http://www.calstat.org/iep/.


Was this article helpful? Please donate to help cover the costs of our blog.
.

.
KPS4Parents is a 501(c)(3) non-profit organization, tax ID 65-1195513.
All donations are tax-deductible.