Barbara
Moore-Brown, Ed.D.
Director, Special & Alternative Education
El Rancho Unified School District
Pico Rivera, CA
Beth Nishida, M.A.
Coordinator, Special Education
Hacienda LaPuente Unified School District
La Puente, CA
In 1975, Congress passed Public Law 94-142, the Education for All
Handicapped Children Act (EAHCA), which mandated educational services
for children with disabilities in this country. Since that
time, special education has continually evolved. Some of these
changes may have seemed subtle, yet were extremely important, like
changing the name of the law to the Individuals with Disabilities
Education Act (IDEA). Others have seemed dramatic and have
raised high levels of controversy, like the inclusion of students
with significant disabilities into general education program, or
including students with disabilities in statewide testing. Each
change has been rooted in the fight to provide a free appropriate
public education (FAPE) to students with disabilities. Additionally,
the climate of special education has made us increasingly aware of
our legal obligations and critical of our practices under the law. Presently,
we are on the cusp of another reauthorization that may bring sweeping
change to how special educators operate in schools, creating the
need to examine what we do and why we do it. In some cases,
these practices are held near and dear by some individuals who provide
service to students with disabilities.
Child Find
In 1975, school districts in many parts of our country were denying
educational services to children with disabilities. These
circumstances led to a federal mandate for special education in the
United States. To ensure that such denial would not occur,
procedural safeguards, or rights and protections, were guaranteed
to parents and children. Among these procedural safeguards
were requirements regarding evaluation and identification of children
as having a disability. Key to these rights and protections
is parent consent for assessment. In order to ensure that all
children with disabilities that might not be in school were located
and provided with an education, requirements for “search and
serve” or “child find” were put into the law.
The U.S. Department of Education (2000) has reported to the Congress
that the original intent of special education, to locate and provide
access to children with disabilities, has been met. In 1997,
the focus of IDEA shifted from access to services, to a focus on
educational results (IDEA, 1997, SS 601[c]). As noted, many
things have changed between 1975 and 1997, but one of the most noteworthy
is in how we “search” for, or locate and find students
with disabilities. In 1975, one of the easiest ways to find
children who might have disabilities was to conduct massive classroom
screenings of all children in certain groups, such as those entering
kindergarten, or those at certain grade levels. This usually
involved conducting a short battery of sample test items with students
to check their articulation, vocabulary, language development and
pre-academic skills. In 1975, some children who did not appear “school
ready” would be sent home to mature for another year, while
others would be tested to determine if they needed special education
services.
In 2002, many children have some sort of pre-school experience prior
to entering kindergarten. While there is still a great disparity
of skills between children entering school for a variety of reasons,
there is no “screening” for academic readiness. It
is also rare to find speech-language pathologists (SLPs) who feel
compelled to screen kindergarten classes for children who might need
services. There are several reasons for this. One is
because mass screening is extremely time-consuming, with seemingly
little actual benefit in terms of identification. Since many
children have attended pre-school, most children with speech and/or
language difficulties would have been referred at that level. As
educators, we also understand that even children with no prior school
experience, need opportunities to enter school, learn the routine
and have time to learn, adjust and mature in the educational environment. Children
need to be given time to adjust to the learning environment of school,
so conducting a screening of their skills early on in their school
experience would be meaningless. At all grade levels, teachers
and other support staff have a greater understanding of accommodations,
modifications and techniques for adjusting the academic curriculum
so that children can be successful. The current focus on literacy
has resulted in a greater focus on individualized needs that can
be addressed in the general education classroom. One final
reason that SLPs no longer conduct mass screenings is that most of
them do not need to go in search of students for their caseloads.
Child find continues to be a mandate under the IDEA, but school systems
have different ways to conduct child find than existed in 1975. When
individual children are having difficulties in school, they are referred
to the school’s Child Study Team (CST) or Student Study Team
(SST). This process is a general education function, and is
designed to assist teachers, students and families by identifying
methods of assisting the student. If interventions are not
successful, and a student continues to struggle, then the student
may be referred for special education assessment to determine if
s/he is a child with a disability requiring special education. Key
to this process is considering all areas which might be impacting
the student.
Evaluation
Procedures
The
IDEA is very specific in the procedures that must be followed
for evaluation. The Code of Federal Regulations
(CFR, 1999) requires that:
• No
single procedure is used as the sole criterion for determining
whether a child is a child with a disability and for determining
an appropriate educational program for the child.
(34CFR§ 300.532 (2)(f)).
• The child is assessed in all areas of suspected disability, including,
if appropriate, health, vision, hearing, social and emotional status,
general intelligence, academic performance, communicative status, and motor abilities.
(34 CFR§ 300.532(2)(g)).
• In evaluating each child with a disability. The evaluation is sufficiently
comprehensive to identify all of the child’s special education and related
services needs, whether or not commonly linked to the disability category in
which the child has been classified. (34 CFR§ 300.532(2)(h)).
• Upon completing the administration of tests and other evaluation materials
-- A group of qualified professionals and the parent of the child must
determine whether the child is a child with a disability. (34 CFR§ 300.534(a)(1).
Concerns
About Screening As a Pre-Referral Activity
Even
though SLPs in schools have, for the most part, abandoned the
practice of mass screenings of groups of children, a common practice
is pre-referral screening of individual children. SLPs may conduct a screening as
a result of a request by an individual teacher for them to "check" a
child or as a result of a SST recommendation. Many SLPs
believe screening is a very efficient practice. They view
it as a way to prevent having to conduct a full assessment on
an individual child, especially if the referral is inappropriate. They
feel they can quickly determine if the child appears to require
the services of an SLP or if the concern that the teacher has
brought to their attention is developmental. The problem
with this rationale, and practice, is that it is contrary to
the requirements described above for evaluation to determine
eligibility.
Screening has been an accepted practice for many years in our field, and
is even outlined in the 1989 Program Guidelines for Speech-Language
Hearing Specialists in California (California Department of Education, 1989),
the ASHA Preferred Practice Patterns (ASHA, 1997) and the Guidelines
for the Roles and Responsibilities of School-Based Speech-Language Pathologists
(ASHA, 1999). Screening is
also an approved activity for speech-language pathology assistants (SLPAs). Typically,
a screening is used to check if the child might potentially qualify for services,
and if further evaluation is warranted. The problem is that once that has
been done, the team has begun conducting an evaluation, most often without parental
consent. This practice is contrary to requirements for evaluation.
The practice of screening for the purpose of determining whether or not the
child should have additional evaluation is problematic for several
reasons. By
conducting a screening in this way, a single assessor has pre-determined eligibility,
violating the requirements for parental consent, assessing in all areas of suspected
disability and the for a multi-disciplinary team assessment. If the student
is recommended for further evaluation as a result of the screening, no other
issues may be considered, possibly missing areas of need. If
the student is not recommended for further evaluation, then the
SLP alone has made the determination of eligibility, absent parental
and multi-disciplinary team participation. One other problem is
that when assessments are conducted, a meeting is required to review
the evaluation and this has also not occurred when a screening
is done.
SLPs may believe that nothing is wrong with going into a classroom and listening
to a child, at the teacher’s request. The belief holds because
they are not administering any formal tests, they are listening to the child
at the teacher’s request, and they are protecting themselves from time-consuming,
inappropriate referrals. The CFR require that qualified personnel be
the conductors of evaluation and providers of service (SS 300.23). When
an SLP goes into a classroom and singles out a given child, and uses his/her
trained ear and knowledge skill set to listen to the child, s/he has just
conducted an assessment [e.g. data collection and the gathering of evidence
(ASHA, 1999; p. 19)] and evaluation [e.g. bringing meaning to that data through
interpretation, analysis and reflection]. Even though this assessment
may not be a formal one and no formal tests were administered, it can be
considered an evaluation because of the knowledge base and expertise of the
SLP. However,
this assessment has been done without parental consent or following the other
requirements identified above. Violating these requirements can be
considered a violation of the child’s due process rights,
and could lead to legal problems for the school district.
Legal
Concerns
As
early as 1986, a case regarding screening held that a school
district was conducting an assessment when they used procedures
for one student that they did not use for everyone in that child’s
class. (Forest Park (MI) School District, 352 IDELR 182; OCR
1986; cited in Gilyard, 2002) In this case,
the procedures were used without consent from the parent. That case
has implications for speech-language pathologists, as well as for other
special education assessors. The outcome of this case suggests
that general consultation about student difficulties is acceptable,
but when the specialist interacted with the student in an attempt
to determine whether more assessment was warranted, the evaluation
had already begun.
A more recent 9th Circuit Court of Appeals case, in 1996, reinforced the
importance of parental consent, and not having dual tracks for determining
eligibility. (Pasatiempo v. Aizawa, 103 F.3d 796 (9th Cir.1966).) In this case, the
state of Hawaii defended their use of a dual-track system of evaluation, depending
on the suspicion of the school’s screening committee as to whether or not
the child had a disability. The 9th Circuit Court found that it is not
in the purview of the school to make this determination prior to evaluation,
and that parents cannot be denied their procedural rights to consent. In
essence this case emphasized: 1) there need to procedures in place; 2)
the procedures need to be systematic; 3) parents need to give consent prior to
assessment; and 4) this consent needs to be informed consent. This case
can be interpreted to apply to this discussion about screening, in that if screening
is used as part of the procedures to determine whether or not a child has a disability,
then such procedures need to be identified. It is noteworthy
that since this case is a 9th Circuit decision, it has applicability
to California.
Using Effective Procedures
Changing legal requirements, as well as increased due process cases,
have forced school personnel to re-examine current practices. The
good news is that by analyzing our practices, it may be possible
to solve more than one problem at once. Consider for a moment,
a long-time complaint of many SLPs in schools, that “they (teachers,
administrators, parents, etc.) don’t know what
I do!” Current thinking on service delivery has
suggested that the best way to solve this problem is by not separating
ourselves from the functions of the classroom or school. (Moore-Brown & Montgomery,
2001). In
other words, the more we are involved with the issues and concerns
of teachers and principals, related to student need, then the greater
the opportunity they have to learn about the skill set and knowledge
base of the SLP. By extending
this line of thinking to utilization of the SST process for consideration
of all students with learning problems and suspected disabilities,
it is possible to see how on-going discussion and participation by
the SLP can help the team understand how speech and language issues
impact the child’s academic achievement. For
example, the SLP can help the team understand how concerns about
phonemic awareness and reading concerns in children may be related
to their suspected phonological impairment. Through utilizing
the school’s problem solving process
to address student need, the goal to avoid inappropriate referrals
can be achieved. We
may also be able to increase team members’ general awareness
of the role of the SLP, and how speech and language issues impact
academics.
Local
Decisions
Whether
or not to utilize screening as a part of the protocol for pre-referral
is a local decision that should be addressed with the special
education administration at the school district and Special Education
Local Plan Area (SELPA). If
it is decided to utilize screening as a pre-referral practice,
then parental consent should be obtained. This is critical
as a single child is being identified as being suspected as having
a disability. Failure to obtain
parental consent could be construed as denial of due process procedures. Should
further speech and language evaluation not be conducted as a result
of the screening results, and the parent had not been informed
or consent received, the district could be responsible for the
cost of that evaluation and services if the parent sought private
evaluation and services.
ASHA Director of School Services, Sue Karr, indicated to the authors of this
article that ASHA does advise members to follow procedures consistent
with the parental consent requirements of IDEA and to check state and
local education agency requirements. Unfortunately, the state of California
Department of Education (CDE) does not yet have updated program guidelines for
speech-language-hearing programs. However, justifying the use
of screening procedures using the program guidelines from 1989, when
no less than two major reauthorization of the law have been made
since then, would not be considered advisable.
SLPs may be reluctant to use the SST as a method for determining whether
a student should receive a comprehensive speech and language evaluation,
due to dysfunction of the SST at their school site. However, the SLP may find that helping
the school solve those problems may be more productive for students and staff
in the long run. The benefits of an effective SST process
may eventually outweigh the work required to revamp the system so
that it is responsive to many needs.
In the long run, the answer on whether to screen or not to screen lies at
the local level. Screening is a permissive activity. Mass screenings,
as they are completed with large groups of children, do not require parental
consent. However, any time an individual child is singled out,
parental consent should be obtained.
In looking at updated procedures for child find, SLPs (and RSP teachers)
should utilize the SST process of the school, which is designed to be
a problem-solving vehicle for teachers, students and parents. Through this system, team members
can learn about developmental milestones for speech and language, how to provide
accommodations and modifications, implications for literacy concerns with children
suspected of having a speech or language disorder, and how to look at the whole
child, and not just one presenting issue. By training SST members
in these skills, the SLP will also be training the team on how speech
and language issues impact school performance, and what types of
concerns would warrant an appropriate referral.
Before deciding whether to screen or not to screen, SLPs should examine what
the purpose of the screening is. If it is to save time and to prevent inappropriate
referrals, the problems may outweigh the perceived benefit. SLPs need to
understand that legally there is no such thing as an individual screening or
just popping into a teacher’s classroom to listen to a child. The
expertise utilized to perform that task just constituted that act
as an assessment.
With mandates to consider how the child’s disability affects their
ability to progress in the general education curriculum, utilizing the procedures
set forth for assisting students seems to be natural. But most importantly,
the increasing world of litigation in special education makes
examination of our practices critical. Whatever practice your local
agency decides to follow, make sure that you have addressed the required
components of multidisciplinary assessment, receiving informed
parental consent and assessing in all areas of suspected disability.
References
- American
Speech-Language-Hearing Association (1999). Guidelines
for the roles and responsibilities of the school-based speech-language pathologist. Rockville,
MD: Author.
- American Speech-Language-Hearing Association (1999). Preferred practice
patterns for the profession of speech-language pathology. Rockville, MD: Author.
- California Department of Education. (1989). Program guidelines for language,
speech, and hearing specialists. Sacramento, CA. Author.
- Code of Federal Regulations (1999). Assistance to states for the education
of children with disabilities and the early intervention program for infants
and toddlers with disabilities; Final regulations, C.F.R., Title 34, § 300,
301, and 303. (1999).
- Gilyard, K. (2002, January). Preparing special education assessors for
I.E.P. team meetings and due process hearings. [Handout]. Presentation
at the Association of California School Administrators
Conference, Monterey, CA.
- Individuals with Disabilities Education Act (IDEA) Amendments, 20 U.S.C. SS
1400 ed seq. (1997).
- Moore-Brown, B. & Montgomery, J. (2001). Making a difference for America’s
children: speech-language pathologists in public schools. Eau Claire,
WI: Thinking Publications.
- Pasatiempo v. Aizawa, 103 f.3D 796 (9TH Cir. 1996). Available [online]. http://caselaw.lp.findlaw.com/scripts/getcase.pl?navby=search&case=data2…9417092.htm.
- U.S. Department of Education (2000). Twenty-second annual report to Congress
on the implementation f the Individuals with Disabilities Education Act. Washington
D.C.: Author.
- American Speech-Language-Hearing Association (2001). Scope
of practice in speech-language pathology. Rockville, MD: Author.
Special
Thanks to Sue Karr of ASHA and Drin Barber, Esq. of WACSEP
for their assistance with this article. |