Practice FAQ Evaluation - Data Collection and Report
Writing Scroll down to see the following FAQ subjects (in
order)
While
prohibited by their Texas Practice Acts from diagnosing, occupational therapists
and physical therapists can and do evaluate students as part of the
collaborative team conducting the FIE. In this case, their evaluation
contributes to the comprehensive data-gathering from which the ARD/IEP team
makes decisions about the student’s eligibility for special
education.
Occupational
therapists or
physical therapists
may
also be asked to evaluate a student who has already been identified under IDEA
as a student eligible for special education. In this case, the evaluation is to
assist the ARD/IEP team with determining whether there is an educational need
for occupational therapy or physical therapy services to be added to their IEP
in support of the student’s goals and objectives.
Occupational
therapy or physical therapy evaluations under IDEA can serve either purpose
separately or both at once.
You will
certainly be gathering data for your reevaluation any time you are with the
student, but as you get close to the due date for the reevaluation, I don’t know
of any reason you can’t use the intervention sessions to do some formal testing
if it is needed. Be sure to continue interacting with the campus personnel so
that you also know if there are issues you need to address (in other words,
don’t be so singularly focused on data-gathering that you aren’t aware of and
responsive to instructional personnel). The Texas Education Agency has also
provided guidance that students are not to be “overserved”, so be careful not to
spend all of the student’s intervention time evaluating and then have no time
left to meet the student’s current needs.
The Texas Board of Occupational Therapy Examiners (TBOTE) Rule 362.1
(33) defining the Occupational Therapy Plan of Care specifies that “A written
statement of the planned course of Occupational Therapy intervention . . . must
include goals, objectives and/or strategies, recommended frequency and duration
. . .” TBOTE Rules do not say that the required elements must be on the
evaluation report itself, but it is clear that they need to be written.
The Texas Board of Physical Therapy Examiners (TBPTE) Rule 322.1 (c)
describing the Physical Therapy plan of care development and implementation
states that “(1) The PT must develop a written plan of care, based on his
evaluation, for each patient” and “(3) The plan of care must be reviewed and
updated as necessary following a reevaluation of the patient’s condition.”
TBPTE Rule 346.,1
regarding practice in Education Settings, gives the following guidance: “(a) In
the educational setting, the physical therapist conducts appropriate screenings,
evaluations, and assessments to determine needed services to fulfill educational
goals. When a student is determined by the physical therapist to be eligible for
physical therapy as a related service defined by Special Education Law, the
physical therapist provides written recommendations to the Admissions Review and
Dismissal Committee as to the amount of specific services needed by the student
(i.e., consultation or direct services and the frequency and duration of
services).”
Thus, the rules state that the plan of care must be written
based on the evaluation, but do not specify that the plan of care must be
included in the evaluation report itself; the guidelines for the educational
setting simply state that written recommendations will be provided to the ARD
committee. Although
including the items that constitute the Plan of Care are usually in the
evaluation report, one ISD in the Houston area has chosen to write their OT
and/or PT recommendations on a separate document that is brought to the IEP
meeting along with the written report. The document is called “OT and/or PT Plan
of Care” and includes all the required elements. In some cases, the PT or OT may
modify his/her recommendations as a result of the information shared during the
IEP process. That change would then be documented on the form by the therapist
at the meeting. If the IEP team determines some other frequency and duration is
needed to support the IEP other than what the therapist recommends, that can be
documented in the minutes/written deliberations. However, the therapist’s
written recommendations should be submitted into the student’s official record
along with the final determination made by the committee, whether it is on the
report or a separate form. That documentation will be important to the district
over time if the IEP team has to consider setting limits on continuing demands
from parent/guardian for therapy when 1) data shows that therapy is not making a
difference or is no longer needed, or 2) the IEP team tries to meet
parent/guardian concerns by providing therapy at a greater frequency/duration
than the professional recommended but data indicates no additional benefit from
the increase. When the IEP team finally decides to say, “no,” there will be a
record that the district made a good faith effort to meet the parent’s concerns.
No,
OTs do not diagnose in schools (or anywhere else for that matter). If a parent
wants services from their local school district for dysgraphia, they can bring
documentation of a medical diagnosis, and then go through the evaluation process
so that the IEP team (ARD Committee) can determine if the child has a need for
special education and related services (just like any other diagnosis). The
personnel involved in the testing might include the OT, but not necessarily.
Handwriting is an instructional issue, so it is not automatic that an OT would
be involved. Even if a disability that results in dysgraphia is identified, OT
may not be required. Best results for writing, as indicated by evidence across
research studies over many years, is from explicit instruction and practice,
neither of which require an OT. (See: Graham, S. & Harris, K. R. 2005.
Improving the Writing Performance of young Struggling Writers: Theoretical and
Programmatic Research From the Center on Accelerating Student Learning. The
Journal of Special Education. 39. 1. 19 –
33). Dysgraphia is a brain- and language-based
disorder that is identified using multiple measures of assessment. There is no
single measure or assessment tool that will identify or rule out dysgraphia.
Dysgraphia can be present either with or without a Specific Learning disability
in Written Expression, but there must be an orthographic processing deficit,
according to the Texas Education Association’s (TEA) The Dyslexia Handbook 2021. Occupational Therapists can
certainly play a role in the identification process using their skill in task
analysis to determine the student’s ability to perform the mechanics of
handwriting, as well as memory for letter forms, visual-motor coordination,
motor planning, sensory-motor contributions and sequencing. Skilled observations
of the student in a variety of authentic writing tasks is critical, as is
coordination with the diagnostician or
LSSP.
Ethically [TBOTE Rule 374.4 (c) (3)
and APTA Code of Ethics, Principle #3], and legally (IDEA law/regs and Texas
laws/regs) you must recommend what the student needs in order to benefit from
his special education, based on his evaluation, not allowing caseload/workload
capacity factors to influence your recommendation. That is the first
consideration. Once the ARD/IEP committee makes the final determination for
service time/frequency/duration, the district must then figure out how it is
going to provide the services. Assuming your schedule is efficient, your job is
to let the district know your workload capacity, and when you no longer have
capacity to add students. They have to then figure out how to serve what you and
any OT colleagues in the district cannot. That does not mean you have abandoned
the student per TBOTE Rule and are personally responsible for problem-solving
how the student will be served. The district has that
responsibility.
There is no requirement
that a new evaluation be conducted when a student moves into your district
unless your district does not receive a current evaluation and IEP. In fact, it
is important that there be no interruption in services if at all possible.
However, if a current evaluation does not
accompany the student, you will need to comply with notice and consent
procedures and conduct a new evaluation. OT and PT Rules in our state require
that services in the Plan of Care, (in school settings this is the IEP) be based
on an evaluation. IDEA and Texas Special Education Rules and Regulations require
the evaluation to be current.
If a student moves into your district
accompanied by an evaluation, you will want to review the evaluation that
accompanies the student to make sure 1) the data reflected appears current in
its description of the student including his strengths and educational needs,
and 2) that the IEP (Plan of Care) goals/objectives address the needs and can be
implemented in the new district as written. Some things are obvious, such as a
goal written by the previous district based on activities done in a pool or at a
therapeutic riding facility. If your district doesn’t have these features you
will need to revise the IEP (Plan of Care) so that activities in support of the
targeted outcomes can be accomplished in your environment. It could also be that
the student was not included during much of the school day and in your district
it is customary that students with disabilities spend much more time in regular
education instructional settings with their peers. In that case you will need to
consider, in concert with the IEP team, whether goals/objectives need to be
changed and the intensity of the services needed to support the student’s
progress on the new goal (e.g., time, frequency and duration) –
essentially a revision to your Plan of Care.
Your question is a good one, as
there is often confusion around this issue.
Federal and state policy specify that ARD/IEP committees must make all
decisions about services and suppports for students based on current data. Entry
into special education and the resulting decisions about instruction and the
need for related services are made based on a Full and
Individual Evaluation
(FIE).
After services are initiated, up-to-date data must be presented at each
annual ARD/IEP meeting so that
decision-making for the next 12 months is also based on
current data. Data should include work
samples, charts, graphs, or other quantifiable evidence from progress
monitoring toward goals/objectives.
Reevaluation is required at least every 3
years, unless the ARD/IEP team determines that there has been no
change from the previous evaluation. If that is determined, the
committee can bring the date of the evaluations done most recently up to the
current date, and the new date becomes the legal date of record. The commitee
may also decide that while there is need for reevalation in one area or for one
service, reevalutaion is not needed in all areas or for all services.
In our experience, no change is very rare.
For most kiddos, there are continuous changes in their growth and development,
periodic changes in placement, and/or changes in teachers (which can mean
increased or decreased need for therapy support).
It is important for you to know how your district administration sees
this issue and what procedures they want you to follow. Districts differ in
their philosophy and approach, and you will want to ensure your practice is
aligned with their preferences.
Yes. Be sure that your documentation reflects what you did to
evaluate the equipment for the student and your rationale for the recommendation
you made not to use it. If the district has decided to proceed despite your
recommendation, you must let go of the situation as it is no longer in your
hands.
Under federal law (the Individuals with
Disabilities Education Act [IDEA]), evaluations for occupational and physical
therapy at school should answer the question of whether that service is required
in order for the student to benefit from his or her special education program.
To do that, data collection needs to include a variety of sources, including
student records, observations of the student in various contexts where he or she
may be struggling, and interviews with parents and teaching staff regarding
their perspectives of the student’s strengths and areas of concern. When
additional information is required in order to make decisions about whether
occupational or physical therapy is needed, additional standardized and
non-standardized assessments may be useful. The use of such assessments is not
required in the law or in licensure. In the school setting, functional
activities and participation at school are the focus of evaluation. Assessment
of impairments, such as range of motion, tone, strength, etc. would not be the
focus, but might be taken into consideration if they impact the student’s
ability to perform needed tasks and to participate in the educational program.
For more information, please see the links below. The first is an article on the
TxSpot website; the second is from the American Physical Therapy Association
Section on Pediatrics. Even if you’re an occupational therapist, the information
is well-presented and applicable to occupational therapy as well.
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