*LDA sent the following letter to all State Directors of Special Education regarding delays in evaluations and reevaluations.
September 1, 2020
As the start of the school year draws near, more and more school districts are determining that the safest option for the students and the professionals that serve them is to remain closed to in-person instruction. With the spread of the virus clearly not under control this is certainly understandable. What is less understandable is the continued delay of evaluations and reevaluations.
When schools closed abruptly as a result of the pandemic, a backlog of eligibility evaluations and reevaluations was created. With public educators scrambling to find ways to deliver instruction remotely, and tele-assessment not readily accessible due to limited training and tools, the decision to delay assessments was necessary. Public school leaders and their advocacy organizations indicated that waivers to the IDEA mandated evaluation timelines were needed. Thankfully, Congress has sided with advocacy and civil rights organizations and has not granted the requested waivers in recognition that sufficient flexibility is embedded within the IDEA. Educators and parents can decide together, in full compliance with IDEA, that it is in the best interest of a child to extend a timeline or delay certain assessments until they can be administered in person. Many families working collaboratively with their school teams made decisions to delay assessment. Other families found that their school districts made similar decisions without parent input.
The vast majority of parents have waited patiently for school psychologists, speech and language pathologists, occupational therapists, special educators and others to determine the best way to move forward. With in-person education being postponed in many school districts across the country, it is time for those with the responsibility for conducting evaluations and the organizations that support them to bring forth solutions. The students whose initial evaluations were suspended were referred for a reason; they were struggling and unable to fully access the regular education curriculum. More than likely those struggles have been exacerbated by the educational situation in which we find ourselves.
While a number of the professional organizations representing school psychologists nationally and at the individual state level have enumerated threats to the validity of remote and physically-distanced assessments and special education evaluations in general, children have languished without support. Few school psychology organizations at the national or state level have acknowledged that between 20 and 30 studies of performance-based cognitive, achievement, neuropsychological, and language tests (see Appendix A) have provided evidence that scores obtained in face-to-face and tele-assessment modes are equivalent. This evidence should inform current practices and be considered during interpretation of test performance.
An enormous amount of funding is allocated to employ trained, qualified, certified, and competent school psychologists and place them in schools to provide these services for children. School psychologists are well suited due to their training, expertise, and credentialing to evaluate the literature on equivalence of tele-assessment and face-to-face performance-based assessment and to make multiple critical decisions about the data they collect from tests in a tele-assessment mode. Furthermore, they are qualified to make judgments about the validity of assessments in a socially distanced context. They are uniquely well suited to adjust and adapt their assessment approach for the current situation and interpret accordingly. Yes, test data that are likely to be affected by tele-assessment procedures may involve some extra “noise”. (Wright, Mihura, Pade, & McCord, 2020) and therefore may be slightly less precise. For example, scores on a test of mathematical ability will still be heavily influenced by the mathematical ability of the student being assessed, but some of the construct irrelevant variables introduced by an altered assessment mode may add a layer of imprecision to the process. Just because the measure is slightly less precise than usual does not mean that the data it elicits about math ability does not represent the student’s actual functioning. Because of the slightly less precise measure of abilities and functioning, a well-trained school psychologist knows to be even more deliberate than usual to confirm and triangulate tele-assessment test data with the reports provided by teachers, related service providers and parents, and even with another measure if necessary. This process is no different than what should always be expected of a school psychologist who is conducting a thorough evaluation.
Rather than enumerating the barriers now being faced in carrying out IDEA mandates, professional organizations, higher education and State Education Agencies must assist school psychologists, speech and language pathologists, and other professionals involved in eligibility evaluations to broaden their skill sets to prepare them to provide professional services using remote and/or physically-distanced assessments. Child Find responsibilities have not been waived and children will continue to need evaluations and reevaluations. We concur with the Massachusetts Psychological Association and the Massachusetts Neuropsychological Society that “…access to remote and physically-distanced assessment is in the interest of the public health…as well as in the interest of the civil rights and clinical well-being of thousands of children”. We commend organizations such as the American Psychological Association (APA), the American Speech-Language-Hearing Association (ASHA), the California Association of School Psychologist (CASP), and others for providing realistic and important guidance to school practitioners. We know that many school psychologists, speech and language pathologists and others involved in the evaluation process are ready and able to develop realistic solutions.
Some professionals are advocating that Response to Intervention (RTI) should become the method of choice for initial evaluations because of the interruption to instruction caused by the COVID pandemic, and because schools will need to provide intense intervention to many students. We agree that evidence-based core instruction and interventions targeted to a student’s specific academic needs are essential for all students, but most especially for students with disabilities. We maintain, however, that for schools that have not already done so, this is not the time to implement new instructional and intervention frameworks such as RTI. Evidence strongly suggests that fidelity of implementation has been a consistent problem and RTI’s validity as a Specific Learning Disability (SLD) identification method is questionable. Advocacy organizations are hearing from parents that their children who already struggled academically pre-pandemic are being denied evaluations or quickly found not eligible as a result of “a lack of instruction” that was created by school closure. Often these students disengage from the remote instruction being provided by districts precisely because of their yet to be identified disabilities and unmet academic, social and emotional needs. It is essential that implementation of RTI not become yet another barrier to students receiving necessary special education support.
Our current situation can serve as an opportunity for school psychologists, speech and language pathologists and other school-based professionals involved in making eligibility decisions to broaden not only their skill set, but also to reexamine the mandates of IDEA. For example, one component of an evaluation for suspected learning disabilities is observation of the child in the classroom. It is true that a classroom observation is not possible for many students at this time. However, the vast majority of students who must be evaluated were in classrooms prior to pandemic related school closures. Most schools have copious data available to them for every child who may be eligible for special education. As early as 2006, the United States Department of Education (USDOE) provided guidance that school teams had the option when evaluating a student, to “use information from an observation in routine classroom instruction and monitoring of the child’s performance that was done before the child was referred for an evaluation…”.
Evaluations conducted in this time of remote learning can serve to bring the process into greater alignment with the vision of Congress by elevating the role of parents and giving greater deference to the information provided by teachers and related service providers. IDEA (section 300.304) directs evaluators to utilize “…strategies that provide relevant information that directly assists persons in determining the educational needs of the child…” When children are being educated remotely, that relevant information cannot be obtained without fully collaborating with the parents and caregivers who are charged with ensuring their children engage in the instruction provided. Relevant information may well include observation of the student in the remote environment by dropping into a Zoom class or other online platform. All of this information, as well as the direct assessment data collected by school psychologists, speech and language pathologists, and others must be analyzed and understood within the context of the performance and observational data collected from those who had the opportunity to work with the student in the classroom and/or the remote environment.
A critical function of school psychologists, speech and language pathologists, and other school-based professionals is to evaluate students in a manner appropriate to the educational context we find ourselves in for the purpose of ensuring the student’s access to the learning, behavioral and emotional supports necessary for educational and life success. Our most vulnerable students are depending on the expertise, ingenuity, and leadership of the professionals involved in eligibility evaluations to uncover the path that will allow them to thrive as learners. As the special education leaders in your state we thank you for what you have done to date to ensure the compliance of districts in your state with IDEA’s Child Find Mandates. We ask that you support local education agencies (LEA’s) in providing school psychologists, speech and language pathologists and other school-based professionals involved in making eligibility decisions, with the resources and support they need to apply their expertise in the service of educational equity for students with disabilities.
Cindy Cipoletti, Esq., Executive Director Monica McHale-Small, Ph.D, President
Organizations in Support of this Statement
Learning Disabilities of Association of Connecticut
Learning Disabilities Association of Illinois
Learning Disabilities Association of Iowa
Learning Disabilities Association of Maine
Learning Disabilities Association of North Carolina
Learning Disabilities Association of Pennsylvania
Learning Disabilities Association of Texas
Learning Disabilities Association of Wisconsin
Decoding Dyslexia Alaska
Decoding Dyslexia Connecticut
Decoding Dyslexia Georgia
Decoding Dyslexia Indiana
Decoding Dyslexia Iowa
Decoding Dyslexia Maryland
Decoding Dyslexia Massachusetts
Decoding Dyslexia Military
Decoding Dyslexia Oklahoma
Decoding Dyslexia Pennsylvania
Decoding Dyslexia Virginia
Decoding Dyslexia Washington
Decoding Dyslexia Wisconsin
American Psychological Association. https://www.apa.org/topics/covid-19
American Speech, Language, Hearing Association www.asha.org
Association of School Psychologists of Pennsylvania. www.aspponline.org
California Association of School Psychologists. http://casponline.org> pdfs
Idaho State Department of Education
National Association of School Psychologists www.nasponline.org/COVID-19
Massachusetts Psychological Association/Massachusetts Neuropsychological Society
MPA/MNS Statement on Remote and Physically – Distanced Assessment within the Context of Independent Evaluations June 8, 2020
Washington Office of Superintendent of Public Education
Novel Coronavirus (COVID-19) Guidance & Resources | Novel Coronavirus (COVID-19) Guidance & Resources | OSPI
For School Districts. Special Education Covid -19
Considerations and Selected Studies Supporting Equivalence of Performance-Based Cognitive, Achievement, Neuropsychological, and Language Tests
When a test mode change is considered, to inform interpretation practitioners need to evaluate the extent to which the resulting scores have been established as equivalent, or interchangeable, with those that result from the original mode. In the case of studies that compare face-to-face with tele-assessment modes, if equivalence is achieved, the scores obtained in either mode are interchangeable, and the normative information collected in the face-to-face mode can be applied to the tele-assessment mode.
The existing equivalence evidence should be considered during interpretation. Several investigations have been conducted with school-age children, and many others were conducted with individuals with far less technology experience and access than children in public schools, such as older adults with dementia.
While this body of research has limitations, there is far more evidence supporting the efficacy of tele-assessment than for some other methodologies (e.g. RTI), As with all empirical questions, methodologically-sound research should guide decision-making research on tele-assessment is evolving continuously. Thus, all practitioners evaluating students must monitor this research base and make decisions as advocates for children, especially those with disabilities or suspected of having a disability.
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