It is late September and school personnel are busy congratulating themselves for having survived a month of school. Routines are fairly well established, most everyone can find the right bus and classroom and, hopefully, most of the Individualized Education Programs (IEPs) are written and being implemented.
Even though nothing requires IEPs to be renewed at the start of each school year (annual review is required), many schools still try to write or review and amend all IEPs in August or September, leading to IEP meeting exhaustion-and, perhaps, a tendency to not construct well-thought-out IEPs.
One of the inappropriate aspects of the IEPs developed in many local education agencies (LEAs) is the continuation of separate OT goals. To reiterate, there are no OT goals on an IEP. There are student goals which the OT may support or address as a related service.
OT services are "related" to special education as defined by the annual goals on the IEP. In the federal legislation and the implementing regulations, "the term 'related services' means transportation, and such developmental, corrective, and other supportive services... as may be required to assist a child with a disability to benefit from special education, and includes the early identification and assessment of disabling conditions in children." (Individuals with Disabilities Education Improvement Act of 2004, 20 USC 1400).
The regulations use almost identical language. Code of Federal Regulation 34, Sec. 300.34(a) states, "Related services means transportation and such developmental, corrective, and other supportive services as are required to assist a child with a disability to benefit from special education?" These services are "related" to the specific educational program as identified on the IEP.
Neither the law nor the regulations state that there are no OT goals. Both do state the process of development and content of an Individualized Education Program. The IEP is developed by a team, whose specific and potential members are stated in the law, and reflects the student's specially designed instruction for up to a year.
The IEP includes:
"(I) a statement of the child's present level of academic performance and functional performance,
(II) a statement of measurable annual goals, including academic and functional goals,
(III) a description of how the child's progress toward meeting the annual goals will be measured and when periodic reports on the progress the child is making toward meeting the annual goals? will be provided,
(IV) a statement of the special education and related services to be provided to the child, or on behalf of the child, and
(IV) the projected date for the beginning of the services and modifications and the anticipated frequency, location and duration of those services and modifications." (IDEA, 20 U.S.C. 1414 (d)(1)(A)(i))
Currently, OT does not stand alone as a service on an IEP. It is a related service to the education program. It is related to the annual goal(s), which address academic and/or functional performance. Therefore, OT is listed as one of the professional services which will address a specific or multiple goals. Do not confuse this with a 504 plan, on which OT may be the only professional service provided to identify, design and implement modifications and accommodations for a student with a disability who is not eligible for special education services.
What many OTs are encouraged by their local education agencies to put on the IEP as "OT goals" are appropriately part of the OT intervention plan, which may or may not be considered part of the student's official education record, depending on state education record statutes. Annual goals are developed from evaluation data, including present level of performance, and in consideration of the educational requirements (expected level of performance). It is essential to know what a student is expected to do and why a student is not achieving. This guides the OT to ways to address the whys so the student can do the whats.
Intervention in the schools may take many forms, including identification of and training in use of assistive technology, environmental modification, task modification, identification and facilitation of alternative instructional strategies or ways to demonstrate competence, use of various kinds of cuing or prompts and development of skills. Some interventions are more quickly and easily implemented than others.
The annual IEP goals always describe what the student will do. How you support the student in making progress toward and achieving those academic and functional goals to which OT is related requires your professional clinical reasoning, therapeutic use of self, creativity, flexibility, advocacy and diplomacy skills.
It does not require separate OT goals.
Barbara Chandler, MOT, OTR, FAOTA, has more than 30 years' experience as a practitioner, manager, advocate and educator. She is currently the occupational therapist with Home Care Services, Haywood Regional Medical Center, Clyde, NC, and chair of the School System Special Interest Section. Contact her at firstname.lastname@example.org.