TxSpot has received many
questions about direct services versus consultation services.
First, it may be helpful to understand that neither the state of Texas nor the
Individuals with Disabilities Act (IDEA) use the term, “consultation.”
IDEA regulations state that
a student’s IEP must contain a statement of “special education and related
services and supplementary aids and services…to be provided to the child, on
behalf of the child, and…(through) program modifications and supports”
(IDEA Regulations, Part B, Section 300.230, italics added). The Texas Education Agency
(TEA) uses the terms, “direct” and “indirect” to describe services. The TEA
describes these two terms as follows:
Direct services
usually refer to hands-on, face-to-face interactions between the related
services professional and the student. These interactions can take place in a
variety of settings, such as the classroom, gym, health office, resource room,
counseling office, or playground. Typically, the related service professional
analyzes student responses and uses specific techniques to develop or improve
particular skills.
Indirect services
may involve teaching, consulting with, and/or directly supervising other
personnel (including paraprofessionals and parents) so that they can carry out
therapeutically-appropriate activities. …. (For example), a physical therapist
may serve as a consultant to a teacher and provide expertise to solve problems
regarding a student's access to instruction.
Although the TEA defined
direct and indirect services in their 2009 FAQ, the terms were not meant to be
mutually exclusive since they describe methodologies that may both be needed to
best meet the student’s ongoing needs. Defining and limiting the methodologic
approach can result in unnecessary inflexibility that is unresponsive to student
needs.
Instead of defining the
treatment approach as either direct or indirect, the evidence supports a blended
approach, sometimes called an integrated service model. This model stresses the
importance of working in context: interventions are applied in the environment
and to the task or activity where the student’s needs occur. Integrated services
include both direct and indirect services embedded into the natural environment
where the participation or performance issue occurs.
Unfortunately,
some IEP management software is designed using a drop-down menu that requires a
forced choice of direct OR indirect. If so, there is sometimes a “work around”
that will allow designation of a blended approach.
Further complicating the
matter is Medicaid reimbursement for services. Medicaid only reimburses for
direct service, that is, for service when the student is directly involved. For
example, time spent consulting or training staff or developing or modifying the
adaptive equipment is billable ONLY when the student actively takes part in the
activity.
There are times when the
therapist may be pressured to provide only direct services. However, IDEA
indicates that the treatment approach is to be determined by the IEP committee
based on individual student needs. It should not be influenced by software
limitations, the student location (e.g. - school vs. homebound) or reimbursement
rules (Medicaid). It must be recognized that both direct and indirect services
are important in contributing to successful student outcomes and should be
included as part of integrated IEP service time.
Some school districts
support the concept of “classroom support” in which generalized support or
consultation is offered to the teacher and other classroom personnel to provide
non-individualized strategies that apply to any student in the class. An example
would be an occupational therapist who describes the strategy of using a short
pencil or broken crayon to help students develop a tripod grasp for handwriting.
This is a general strategy that would be applicable to any or all students in
the class. This type of generalized support does not need to be
included as part of IEP service time.
So, to the question, “Direct
versus indirect services: Which should I do?” the answer is…Both!