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Transcript for Lesson 3 Presentation: Developing the Heart of the IEP |
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In the last lesson we left the IEP team members seated comfortably at a round table with herbal tea and soothing music. The meeting is about to begin. In this lesson we deal with the process of developing the heart of the IEP. In Lesson 1, we presented the IDEA requirements for all the elements that must be contained in an IEP. In this lesson we concentrate on the three most important components of an IEP: (a) the statement of the child's present levels of performance, (b) a statement of the special education and related service which are necessary in order to adequately address the child's unique educational needs, and (c) a statement of measurable annual goals, including benchmarks or short-term objectives which indicate the progress a child is expected to be able to make when the district provides appropriate special education and related services. Additional content requirements for the IEP will be addressed in Lesson 4: Completing the IEP. |
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A very simple concept underlies the IEP. It is so simple it is sometimes overlooked or forgotten. The concept is this: the most basic, fundamental purposes of the IEP are (1) to identify and describe the child's unique educational needs (described as present levels of performance), (2) to determine what services are necessary to address those needs, and (3) to establish reasonable goals the student will be able to accomplish if the services are appropriate. This sequence is so critical it should be memorized--What are the student's needs? How will we address those needs? How will we know if our services are appropriate?
As we move into actual IEP development, it is good to remind ourselves that the IEP to be developed must be educationally useful and it must be developed according to the procedural rules of IDEA. If an IEP is not legally correct, a district could be liable for not providing a free appropriate public education (FAPE) to a student with a disability. Such liability could cost the district in time spent in litigation or mediation and in dollars for legal representation and reimbursement to parents. If an IEP is not educationally useful, then all parties to the IEP have wasted their time in developing the IEP, and the student for whom the IEP was developed will not benefit from an appropriate program. |
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The first thing the IDEA regulations tell us must be in the IEP is a "statement of the child's present levels of performance including how the disability affects the child's involvement and progress in the general curriculum." This is a logical starting place for IEP development. Twenty years ago Appendix C (1981) to the IDEA regulations provided guidance to us about the present levels of performance (PLOPs): (1) the PLOPs should deal with all areas of education that are affected by the disability--academic, daily life activities, mobility, etc.; (2) the PLOPs should be written in objective, measurable terms--self-explanatory test scores may be used if they reflect the impact of the disability; and (3) there should be a direct relationship among the PLOPs, the services to be provided to address the PLOPs, and the goals and objectives (Question 36). |
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Selecting PLOPs
How should the IEP team decide which of the child's hundreds of performance levels should be on the IEP? First, only areas of performance affected by the disability (or otherwise contributing a unique educational need) need be included. It is not appropriate to have a predetermined list of "topics" to be described as PLOPs for every child. If a district chooses (for reasons other than IDEA requirements) to add a descriptive narrative about the child on the IEP, the law does not prevent that. However, it is not required. It can be helpful to ask, "What is it about this child that requires us to individualize for her?" In other words, what (of educational significance) is not predictable about this girl, given her age, grade, gender, etc.? If a 7th grade student has been diagnosed as learning disabled and attention deficit disordered, odds are high he will be described as disorganized, impulsive, lacking in good sense of time (often late), reading below grade level, and failing to turn in some homework. These, then, are proper topics for the PLOPs, services, and goals. The needs may be combined, or perhaps prioritized, so that on any given IEP there may be only three or four PLOPs and goals. Others may be added later. |
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A related way to approach the selection of PLOPs is to ask, "What are this child's unique needs?" She needs better handwriting, she needs to manage her anger better, to get to school every day and on time, and to read better. Again, these "needs" can then be expressed as PLOPs. Each PLOP will then be addressed by a service and a goal (with objectives).
Let us look at a common example of a student diagnosed with dyslexia who is identified under IDEA as learning disabled (LD). By definition, his reading performance is affected by his disability, so reading level should appear as a PLOP. Further, we will need to include the services to be provided to improve his reading performance and the goal we believe he will reach as a result of the services. This linking of PLOPs to services to goals and objectives is analogous to a person standing on Highway 101 at milepost 39 (PLOP) waiting for a bus (special education service) to take her to milepost 58 (goal). En route, she'll pass mileposts 40, 45, and 50 (objectives or benchmarks). Milepost numbers are a consistent unit of measurement used from PLOP through objectives to annual goal. |
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Measurable PLOPs
Let us take a moment to discuss the concept of "measurable." More will be said about it when we deal with writing measurable goals and objectives later in this lesson, but it is just as important that the PLOPs be expressed objectively as it is for the goals and objectives. The PLOP tells us where we are starting. Without knowing that, we cannot meaningfully assess progress. For example, Joe was at milepost 50 on December 20. How far had he come since he started on September 1? We have no idea unless we know where Joe started on September 1. This is the function of the PLOP--it tells us where we are starting. Not only must it be measurable, it must be measured! It is not enough to say, "Maria has a real problem with getting to class on time, with the right books, assignments, and a pencil that writes." We need to be able to say that "At least twice a week Maria fails to arrive on time with all the necessary materials." But, more about this later. |
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Units of Measurement
To return to reading performance, what single unit can we use to describe the PLOP, the objectives, and the annual goal? We might consider using a standardized reading test score such as a grade level equivalent (2.1 GE), a standard score (SS = 86), or a percentile (35 %tile). However, we would have to reject all of these because even if they were appropriate measures of progress (they are not), to use any of them would require that in addition to having given the test initially to obtain the PLOP, we would have to re-administer it a minimum of four times within the year. Progress, assessing whether the child has reached the pertinent objective, must be reported to parents at least as frequently as for non-disabled children. Typically that would be every 6 or 9 weeks. To administer a traditional standardized reading test a minimum of 5 times in a school year would be highly inappropriate and a waste of valuable time. We need an objective measure of reading level that can be repeated and that will be sensitive to the progress the student makes. We strongly recommend this type of PLOP, objectives, and goal: |
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For additional examples of PLOPs, objectives, and the goal, refer to Handout 2 Section 1. Here is an actual "Present Levels of Educational Performance" page taken from an IEP prepared in 2001 for a 7 year old IDEA student: |
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Present Levels of Educational Performance
Strengths
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Needs
A very different approach to PLOPs is seen in the following narrative style. "Jane" (not her real name) is 6 years old. |
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Academic--Jane is able to match colors and shapes. She can string beads. She has been heard to rote count to 10, but generally not on request. Also can recite ABC to G, but not on request. She can work a simple puzzle, build towers with blocks, cut with assistance (using squeeze scissors) and scribble (to color). She enjoys painting. She has shown "pointing to" skill only with computer. |
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The IDEA PLOP regulation also requires that the statement of PLOPs include how the disability affects involvement and progress in the general curriculum. Little, if any, guidance is available as to how to satisfy this requirement. If a 9th grader reads at a second grade level, it is apparent he can only function in the general curriculum if the content of the curriculum is made available to him in a way he can access. Furthermore, his written expression is, in all probability, at no higher level than his reading. Therefore, he cannot be expected to use writing to express his understanding of the curriculum, and he must have alternative opportunities. A mild speech impairment might have no significant impact on participation in the general curriculum, but a severe language problem could preclude much meaningful participation. While the PLOP requirement related to the curriculum is not yet well understood, it is obvious that the process of considering the issue can be helpful to the rest of the IEP development and perhaps to the later placement decision. |
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To sum up, legally correct and educationally useful PLOPs (1) deal with performances affected by the disability; (2) are objectively measured; and (3) are directly related to services and goals. |
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An IEP team might proceed something like this in arriving at the most important PLOPs for Jamie Smith, a 6th grader with a severe written expression disorder.
We will now look at the next required component of the IEP following the PLOPs--the statement of needed services. |
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The IDEA requires a statement of the special education and related services and supplementary aids and services to be provided to the child, or on behalf of the child, and a state of the program modifications or supports for school personnel that will be provided for the child--
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Statements, Not Checkmarks With that background, if we return to the regulation itself (34 CFR 300.347), the first thing that we see is the word "statement." The huge majority of IEPs contain no statement of services whatever. Many use, for example, a checkmark by the word special education, perhaps followed by an amount of time (e.g., 4 hours a week). That one checkmark is intended to represent, apparently, all the services needed to address all the PLOPs, objectives, and goals. Another approach, almost never seen but far more desirable, is to describe the service (whether it is special education, related service, modification, or anything else) being provided to address each of the child's unique needs (expressed as a PLOP). Suppose, for example, one of Toni's PLOPs is that "She has 2-5 angry, inappropriate verbal or physical outbursts a day." The service could be a checkmark in front of the preprinted words "special education," or it could be a real statement such as "anger management, small group counseling (not to exceed 5 students) every day for 30 minutes before school in the library, to be conducted by J. Jones or other qualified counselor." Suppose that Jason is in 9th grade, has above average intelligence, and his reading PLOP is "Jason reads 3rd grade material (a 200-word passage) at 40-60 wpm with 5-10 errors." The services, again, could be a checkmark by the words "special education" or better, it could be a statement, as IDEA requires, such as "1:1 direct instruction reading tutoring, twice daily for 35 minutes each session, taught by a person trained in direct instruction, in a quiet, private area." Common sense suggests that, at a minimum, the statement of special education and other services should comply with the law and should allow the parents, the student, or an outsider to determine whether the service is being delivered as promised. |
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Specifics of Needed Services One of the many potential benefits of the IEP team thinking seriously about the specifics of necessary services is that doing so opens the door for genuine brainstorming and problem solving. Compare two IEP team approaches to this PLOP: "Malcolm never initiates social contact with his peers." Our first, traditional team says, "Let's put a checkmark by 'counseling once a week'." The second team says, "What could we do about Malcolm's inadequate social skills?" Several suggestions are offered, including "nothing." The team decides on the following idea: "Let's pair him up with Jose who is very popular and beautifully skilled at making and keeping friends. For the first 5 minutes of recess and for going through the lunch line, Jose would be happy to cooperate." The team confers about how to say that as a service and decides on this statement of service: "Structured peer support and modeling for 5 minutes daily plus during the cafeteria lunch line." Which solution is the less expensive? Which would you bet will be more effective? Faster? More fun? More in compliance with the letter and spirit of IDEA? The range of services that may need to be included on an IEP is broad. Among common services are assistive technology devices and services, 1:1 aides, counseling, extracurricular activities, interpreter services, medical services (for diagnosis/evaluation and those medical services which do not require an M.D. to perform), occupational therapy, anger management, nursing services, physical therapy, psychotherapy, recreational services, school health services, speech therapy, behavior management plans, language therapy, testing accommodations, transportation, vision therapy, tutoring, extended school year, computer training, social skills training, and many more. Remember--IDEA, for good reason, requires a statement, not a checkmark, to describe these and all other services the IEP team has decided to try. Distinctions are sometimes made among related services, supplementary aids and services, and accommodations and modifications. IDEA does not require such distinctions. It only requires that all such services that are needed be stated on the IEP, regardless of what they are called. If a state or district requires that distinctions be made, they should be made according to state or district guidelines. If there is no such requirement, it needn't be made, as long as we recall that only special education services require goals. |
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IEP teams should focus on individualizing the needed service to the student while relying heavily, if not exclusively, on research-proven, effective practices. To illustrate, let's return to Jamie Smith and his PLOP of "writes 12 letters per minute with 3-4 illegible." After some discussion, the team agrees on a dual approach--to immediately begin keyboarding instruction and also to work on increasing Jamie's rate and legibility, recognizing that Jamie won't always have access to a computer. The keyboarding instruction posed a temporary problem because it wasn't offered at Jamie's middle school, but then the case manager recalled that a teacher who had just retired (and had volunteered to tutor occasionally) previously taught typing at the high school. She was contacted and agreed to provide two hours tutoring weekly in keyboarding at the middle school, provided Jamie had the opportunity to practice 20 minutes a day. So the required statement of service for that PLOP included "2 hours weekly keyboarding tutoring and 20 minutes of supervised practice daily."
The discussion then turned to increasing Jamie's rate and legibility of writing. Ms. Lopez was very knowledgeable about the use of brief, timed daily probes or practice sessions (1 or 2 minutes each) with charting and reinforcement. The team quickly agreed that it was worth a try. Ms. Lopez decided to create a group with the other three boys who were also very slow in writing. The team described the service on Jamie's IEP as "daily, timed copying and writing practice sessions, total 2 minutes, to be charted and reinforced." Other teams might word the same service descriptions somewhat differently. As long as the service is described with sufficient detail that an outsider could monitor whether or not the services was being delivered as promised, that is sufficient. |
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Guidelines for IEP teams as they decide and record needed services include these:
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A major focus and intention of the changes Congress made in IDEA 1997 was to improve educational results for students who have disabilities. Appendix A to the IDEA regulations offers these helpful observations: Measurable annual goals, including benchmarks or short-term objectives are critical to the strategic planning process used to develop and implement the IEP for each child with a disability. Once the IEP team has developed measurable goals for a child, the teamMany people use the terms "objectives" and "benchmarks" interchangeably or nearly so. For purposes of IEPs, most objectives/benchmarks should contain a date. Since progress must be reported to the parents of students with disabilities at least as often as parents of non-disabled children receive progress reports, efficiency supports having an objective/benchmark for the end of each reporting period. The only difference between an objective/benchmark and a goal is that the goal is the final objective for the year. Thus it is an annual goal whereas the first objective is the goal for the first progress reporting period. Let's take a simple example of a young student who is learning sight vocabulary.
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Many IEPs contain goals and objectives that are Not Real, that is, they are so totally not measurable that it is apparent no one ever intended to determine whether the student had reached them. Here are some examples of not measurable and, therefore, indefensible goals/objectives. Sadly, all are taken from real IEPs.
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If only one misconception about measurability could be cleared up, it should be the false belief that inserting a percentage into a goal makes it measurable or makes it appropriate. This proposition is so preposterous as to provoke laughter if it weren't such a serious matter. Consider:
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Now, just for fun, suppose you have been hired to measure (d) above--to determine whether June has improved her behavior 90%. How would you do that? One cannot make a goal or objective measurable just by putting a percentage in it, but what does make a goal measurable? A measurable goal or objective, standing alone with no further information, allows a yes or no determination as to whether the child has accomplished it. "Will improve high jumping performance" does not allow a yes or no without further information. "Will high jump 3 feet by June 5" does allow a yes or no. Furthermore, a measurable goal allows multiple observers who have never seen the child before to agree whether the goal has been reached. In the words of Mager (1997), whose work on writing instructional goals is classic, "An objective is considered measurable when it describes a tangible outcome. For example, objectives that describe intended outcomes that you can see or hear are measurable ... 'Be able to tie a knot' is measurable because we can see knot-tying behavior ..." In addition to an observable performance, a measurable goal or objective must also include a criterion statement that will indicate the standard to be met. For example, tie a square knot in 5 seconds. Sometimes it is also necessary to specify conditions under which the performance will occur, e.g., given access to the internet, the student will write a 1,000 word paper on a specified topic with no factual inaccuracies, spelling errors, or incorrect grammar. In short, a measurable goal, objective or benchmark must specify (1) an observable student performance, (2) a standard or criterion, and (3) if necessary, the conditions under which the performance will occur. Too many IEPs contain "goals" such as "John will improve his reading skills." That performance is too vague, and there is no standard or criterion whatsoever. If John learned one new sight word, would that be satisfactory? What if he read faster but less accurately? Would that satisfy the goal? For Jinx, Junior, John, and June above, here are their goals and objectives rewritten so they are measurable:
Almost unlimited refinements can be made in any measurable goal. Common sense is a good guide to use. Would most teachers agree on one of these three levels of refinement as being appropriate for school use?
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Examples of poor goals/objectives/benchmarks Here is one example of very poor goals/objectives/benchmarks taken from real IEPs, followed by an improved version. A goal need not be perfect, but it must be measurable by someone other than the person who wrote it. Poorly Written Version 1. J.B. will use at least 2 strategies to take responsibility for his anger management with 90% accuracy. Improved Version Given 10 hypothetical anger-producing situations, J.B. will describe appropriate responses to each. or J.B. will have zero inappropriate responses per month to situations which last year resulted in inappropriate displays of anger. For additional examples, refer to Handout 2 Section 3. Practice makes better and better. If writing behavioral goals and objectives still seems foreign or difficult, here are two non-technical tips. Suppose that you tend to think first in non-behavioral terms (e.g., he needs to learn to respect adults, or she should appreciate reading more). Ask yourself, "How would I know he was being more respectful?" Perhaps several things come to mind--he would say "sir" or "ma'am" when addressing an adult, he would not interrupt adults when they are talking, he would avoid all vulgar language in adults' presence. Any or all of these provide a good beginning for a goal/objective. "How would I know she appreciates reading?" Maybe you might know by the number of books she reads, or the amount of time spent reading, or by her choice of reading as a "reward" activity. The measurability element comes in answers to questions like "how often," "how many," "how fast," and "how many times." A disturbing trend has developed in some states whereby teachers can be found laboriously selecting standards or benchmarks from the state assessment guides or curricula (for general education students) and diligently copying them onto IEPs. This sad, wasteful activity is so widespread that we repeat from Appendix A the legal guidance on this topic: ... a public agency is not required to include in an IEP annual goals that relate to areas of the general curriculum in which the child's disability does not affect the child's ability to be involved in and progress in the general curriculum. If a child with a disability needs only modifications or accommodations in order to progress in an area of the general curriculum, the IEP does not need to include a goal for that area; however, the IEP would need to specify those modifications or accommodations. (Question 4) |
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To sum up, the heart of the IEP consists of what the child needs (expressed as PLOPs), what services will be provided to address those needs (in a statement, not a checkmark), and what the child can be expected to accomplish if the services are effective (goals and objectives or benchmarks). The remainder of the required IEP content is presented in the next lesson. |