3 do’s and 2 don’ts for documentation during extended school closures

Keeping detailed and focused documentation about special education services will show that your district made good-faith efforts to continue individual specialized services during the coronavirus outbreak—plus help in preparing for when in-person schooling resumes.

If you made a modification to a homework packet for a student with disabilities, you need to document it. If a special education teacher has tried to contact a parent of a student with disabilities, but has been unsuccessful, those attempts must be documented. If a parent refuses any special education services at this time because she is overwhelmed, that also needs to be documented.

It is critical during this time of extended school closures and distance learning that any activity to support a child’s IEP is documented. The documentation will help show that your district made good-faith efforts to continue individual specialized services during the coronavirus outbreak. It will also help your district meet reporting requirements and be better prepared for when in-person schooling resumes.

Consider these do’s and don’ts for documentation:

DO have a system for tracking. Whether you have a common virtual space or universal forms, it’s important to tracking efforts and services methodically. The tracking system should be accessible and easy to use for service providers and teachers. It also should be understandable to educators who did not work directly with the student.

Glenna Gallo, assistant superintendent of special education for the Washington Office of Superintendent of Public Instruction, says the state developed an optional form for tracking changes to a student’s IEP during extended school closures that has been well received by educators.

The process of documentation should be driven by the central administration office to maintain consistency and perhaps uniformity with other education departments. Remind staff to maintain confidentiality with student information.

DO be specific about what should be documented. The Louisiana Department of Education says that school systems should document modifications, delays, inability to deliver service and other changes to special education and related services provided to students with disabilities during extended school closures.

At a minimum, the Louisiana education office said such documentation should include:

  • The dates services were provided
  • Education and related service minutes (both offered and delivered)
  • Services provided to the student (both current and modified)
  • Staff who provided the services
  • Accommodations and modifications provided based on the updated IEP
  • Student’s response to services and accommodations
  • Any notes from educators that may be relevant to the student’s situation

DO continue to follow the IDEA’s notification requirements. The IDEA’s parent notification requirements still apply during extended school closures. The unique circumstances of the coronavirus outbreak may mean that communication between school systems and parents will be done through phone calls and video chats. While communication can be done this way, school systems should take steps to document their activities. It’s best to consult with your district attorney or state education office for specific guidance.

DON’T rely on your memory. You may know that an IEP meeting was postponed because one of the team members was sick, but will you be able to remember that detail in a few months? Make sure to take note of particular facts in a situation that could have an influence on service delivery, procedural rights, and compliance.

DON’T give up. You should document situations where parents refuse to have their child participate in distance learning, including educator outreach efforts and parent responses. Educators should regularly check back with the family to see if some educational components can be added, even if it’s a little at a time. Document those efforts too.

Gallo says the task of continuing to teach during the pandemic is challenging, but not impossible. “This is a different way we’ve had to operate. We’re building the entire system from scratch.”

The focus first needs to be on the safety and health of students and families and then on the continuation of services, she says. “I tell [administrators] keep taking action, keep improving, and keep moving and don’t stop because of concerns with compliance.”

Kara Arundel covers special education for Special Ed Connection, a DA sister publication.

Read more DA coverage on special education.

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