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A RESOURCE MANUAL FOR THE
DEVELOPMENT AND EVALUATION
OF SPECIAL PROGRAMS
FOR EXCEPTIONAL STUDENTS
VOLUME III-J
Interagency Service Plans For The
Profoundly Mentally Handicapped
Bureau of Education for Exceptional Students
State of Florida
Department of Education
Tallahassee, Florida
Ralph D. Turlington, Commissioner
Affirmative action/equal opportunity employer
June 1983 CBG 60 620
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This Resource Manual was developed by Leon County Public Schools through
the Special Project, Interagency Development, funded by the State of Florida,
Department of Education, Bureau of Education for Exceptional Students, under
Federal Assistance for the Education of the Handicapped (P.L. 91-230, EHA
Part B, as amended by P.L. 93-380 and P.L. 94-142).
Copyright
State of Florida
Department of State
1983
PREFACE
This resource manual was developed and written by the Interagency Development
Project, a Title VI-B project awarded to the Leon County School Board by the
Florida Department of Education, Bureau of Education for Exceptional students.
The funding period for the grant began July 1, 1981 and ended June 30, 1983.
The project had three major goals for the two-year grant period: first, to
study interagency coordination of service plans for school-aged profoundly
mentally handicapped (PMH) students in Florida; second,*to identify practices
for agency coordination; and third, to develop a resource manual and comple-
mentary training materials for Florida educators interested in improving
interagency coordination of service plans for PMH students. To meet these
goals, project activities for the two-year grant period included:
1. A state-wide survey of services to school-aged PMH students.
2. On-site and telephone interviews with personnel from
public schools, the Florida Department of Health and
Rehabilitative Services (HRS), and Intermediate Care
Facilities for the Mentally Retarded (ICF/MRs).
3. A study of public school and HRS coordination of services
at Tallahassee Sunland Center.
4. The development and production of a resource manual and
training materials to help school districts, HRS, and
ICF/MRs coordinate service plan reviews for school-aged
PMH students.
Public school personnel interested in improving the coordination of services
to PMH students will find this resource manual and the companion training
program A Resource Manual for the Development of Interagency Service Plans
for the Profoundly Mentally Handicapped: Partners in Planning: A Training
Program useful references. Using different formats, both publications provide
information on the agencies that serve PMH students, the legal bases for
service plans, service plan documents, and methods for coordinating planning.
The two manuals may be used independently or in conjunction for group training.
Users of this manual may not be familiar with all of the legal and agency terms
that relate to the provision of services for PMH students. Appendix B presents
a glossary of terms that provides definitions of some of the cornonly-used
terms. This glossary should be used as a reference when unfamiliar terms
appear in the text.
-iii-
ACKNOWLEDGEMENTS
This resource manual is one in a series of publications developed to help
Florida school districts provide special programs for exceptional students.
It was developed by the Interagency Development Project, Leon County Public
Schools under the guidance of:
Charles H. Couch
Superintendent of Schools
Robert M. Connors
Director, Exceptional Student Education
Lynda Roser
Coordinator, Exceptional Student Education
Linda F. Laugen, Project Director
Interagency Development Project
During the field survey conducted in the first year of the Interagency Develop-
ment Project, 52 school district and HRS personnel responded to written ques-
tionnaires, 23 exceptional student education administrators answered questions
through telephone surveys, and 83 individuals were interviewed. The Inter-
agency Development Project recognizes the contributions of these professionals,
without which this resource manual could not have been developed. Members of
the DOE/HRS Interagency Task Force also had the opportunity to review rough
draft materials of the resource manual and training materials. Appreciation
is expressed to these individuals for their willingness to provide construc-
tive content suggestions.
A 14-member advisory committee was also established to oversee project activi-
ties and materials production. A list of advisory committee members appears
in appendix A.
TABLE OF CONTENTS
PREFACE . . . . . . . iii
ACKNOWLEDGEMENTS .............. .. ......... v
LIST OF FIGURES ........................... ix
INTRODUCTION ............................ 1
CHAPTER 1: PARTICIPANTS IN SERVICE PLANNING . . . 5
Florida's Local School Districts . . . 5
The Bureau of Education For Exceptional Students (BEES) 7
The Department of Health and Rehabilitative Services
(HRS) ..................... ... ... 8
Developmental Services' Continuum of Care . ... .13
The Emerging Role of ICF/MRs in Serving PMH Students 17
CHAPTER 2: STATUTES, RULES, AND REGULATIONS AFFECTING
SERVICE PLANS FOR PMH STUDENTS . . .. 18
Legal Bases for IEPs .................. 20
Legal Bases for Hab Plans . . . 21
Legal Bases for ICF/MR Service Plans . .. 24
Similarities among Statutory Requirements . .. .27
Legal Bases for Service Plan Reviews . . 31
Legal Bases for Student and Client Reevaluation .. 34
Participants in Service Plan Reviews . ... 39
CHAPTER 3: DOCUMENTS USED IN SERVICE PLANNING . . .. 45
School District IEPs .................. 45
School District Implementation Plans . . .. 50
HRS Habilitation Plans . . . ... .50
Active Treatment Plans ................. 60
Similarities in School District and HRS Service
Plans . . . . . . 63
CHAPTER 4: METHODS FOR COOPERATIVE PLANNING . . . 66
Method 1: One Meeting/One Service Plan . ... .67
Method 2: One Meeting/Two Service Plans . ... .73
Method 3: Separate Meetings with Cross-representation/
Two Service Plans ....... ...... 76
Method 4: Two Meetings with Shared Written Information/
Two Service Plans . . .... .81
Other Cooperation Strategies . . ... .95
APPENDIXES ....... ...................... 105
A. List of Advisory Ccmnittee Members . . .. 107
B. Glossary of Terms .................. 108
-vii-
LIST OF FIGURES
CHAPTER 1
1: Continuum of Services to PMH Clients of HRS .
2: PMH Students Requiring Interagency Coordination
3: HRS District Boundaries . . .
4: Developmental Services Continuum of Care .
2
Statutory Requirements for Service Plans . .
Legal Bases for Individual Service Plans . .
Relationship of the IEP to the Hab Plan . .
Legal Requirements for Service Plan Reviews .
Requirements for Student and Client Reevaluation
Required Participants in Annual Service Plan Reviews
Statutory Requirements for Service Plans and Service
Reviews . . . . . .
3
Florida Individual Educational Plan . .
Group Implementation Plan . . . .
Developmental Services Program Habilitation Plan .
Active Treatment Plan . . . .
16: Similarities in School District and HRS Service Plans
. 20
. 28
. 30
. 34
. 38
42
Plan
. 43
S 48
S 51
. 52
. 62
. 63
CHAPTER 4
17: Major Provisions of School District-HRS District
Cooperative Agreements for Sunland Centers, 1982-83 .
18: Agency Requirements for Student/Client Data . .
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CHAPTER
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CHAPTER
12:
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96
103
INTRODUCTION
Two major systems in Florida share the responsibilities for the physical, so-
cial, and educational development of profoundly mentally handicapped (PMH)
individuals. The public schools of Florida ensure the provision of educa-
tional services to all PMH students between the ages of 5 and 18 (subsequent-
ly referred to as school-aged in this manual). Local school districts meet
the needs of PMH students living in their own, group, or foster homes or in
HRS residential facilities. Florida law (Section 232.01, F.S.) permits local
districts to serve only those students classified as school-aged or to extend
their programs to include students below age 5 and above age 18. Thus, some
school districts provide educational programs for students beyond the man-
dated ages and serve PMH children from birth through age 21. The exact ages
served vary from school district to school district. For each student en-
rolled in exceptional education, school districts must develop an Individual
Educational Program (IEP) that describes the educational and related services
the student will receive.
The second major system, the Florida Department of Health and Rehabilitative
Services (HRS), is responsible for providing appropriate services to eligi-
ble PMH children, adolescents, and adults. The Developmental Services Pro-
gram of HRS provides specific community services (see Chapter 2) and resi-
dential placement and care for individuals whose needs dictate such place-
ment. The Developmental Services Program also provides educational programs
for children and young adults not served by local school districts. HRS
programs for PMH clients over age 21 often include adult basic education,
which is provided by local school systems. Public Law (P.L.) 95-602 re-
quires that each client of the Developmental Services Program have a written
habilitation (hab) plan that describes all the services the individual is to
receive.
Through these two state systems, PMH individuals receive a continuum of care
and training like the one represented in Figure 1.
FIGURE 1
CONTINUUM OF SERVICES TO PMH CLIENTS OF HRS
BIRTH AGE 5 AGE 18 AGE 21
(VARIABLE) (VARIABLE)
SCHOOL-AGED*
HRS PROVIDES APPRO- THE LOCAL SCHOOL DISTRICT HRS PROVIDES APPRO- HRS PROVIDES TRAIN-
PRIATE SERVICES, PROVIDES THE EDUCATIONAL PRIVATE SERVICES, ING AND OTHER DEV-
INCLUDING EDUCATION, PROGRAM. HRS PROVIDES INCLUDING EDUCATION, ELOPMENTAL SERVICES.
WITHIN EXISTING OTHER APPROPRIATE SERVICES WITHIN EXISTING SOME LOCAL SCHOOL
RESOURCES. EACH THAT CAN INCLUDE RESIDEN- RESOURCES. EACH DISTRICTS PROVIDE
CLIENT HAS A HAB TIAL PLACEMENT. EACH CLIENT HAS A HAB ADULT BASIC EDUCA-
PLAN AND AN IEP, STUDENT HAS A SCHOOL SYSTEM PLAN AND AN IEP, TION.
BOTH DEVELOPED BY IEP AND AN HRS HAB PLAN. BOTH DEVELOPED BY
HRS. HRS.
*Exact ages in the school-aged category vary from school district to school district.
Although this continuum generally represents the provision of educational ser-
vices throughout the state, it does not depict the situation in every school
and HRS district. The exact range of the "school-aged" category varies from
school district to school district. Some school districts provide exceptional
student education programs for students from birth through 21 years old;
others from 3 to 19; and still others from 3 to 21. Some districts serve PMH
students beyond age 18 on an individual basis and provide adult basic educa-
tion for HRS clients over 18. HRS may provide educational services to those
PMH clients not being served by local school systems.
In serving PMH children under age 5 and adults between 18 and 21, HRS must
meet the same legal requirements for the education of the handicapped that
apply to local school districts. State Board of Education Rule 6A-15 man-
dates IEPs for all Developmental Services clients, aged 21 or below, who are
receiving educational services from HRS (SBER 6A-15.14). Thus, PMH clients
who are receiving HRS educational services also have IEPs developed by HRS
personnel. When these individuals enroll in public school programs, IEP de-
velopment becomes the responsibility of local schools. Distinguishing be-
tween HRS and school system IEPs is important because HRS requirements for
the development and use of IEPs vary slightly from those of local school dis-
tricts and the Florida Department of Education (DOE). Because this manual
addresses only the "school-aged" category of PMH students, all references to
IEPs are to those developed by local school districts, not by HRS.
Figure 2 illustrates the importance of coordination for school-aged PMH stu-
dents.
FIGURE 2
PMH STUDENTS REQUIRING INTERAGENCY COORDINATION*
TRANSFER OF STUDENTS FROM HRS TRANSFER OF STUDENTS FROM
TO LOCAL SCHOOL DISTRICT. I LOCAL SCHOOL DISTRICT TO
COORDINATION NEEDED HRS. ORDINATION NEEDED
AGE 5 AGE18
(VARIABLE) (VARIABLE)
SSCHOOL-AED* 1
TWO SYSTEMS PROVIDING SERVICES.
COORDINATION NEEDED FOR:
* SERVICE PLANS (IEPs AND HAB
PLANS)
* SERVICE PLAN REVIEWS
* EVALUATION AND DATA COLLECTION
1----- -- -- -- -- -
IF HRS IS THE ONLY AGENCY
SERVING, COORDINATION IS
NEEDED ONLY WHEN PMH
STUDENTS BEGIN TO RECEIVE
EDUCATIONAL SERVICES FROM
THE IOCAL SCHOOL SYSTEM.
IF
SE
NE
ST
FR
DI;
AGE 21
HRS IS THE ONLY AGENCY
RVING, COORDINATION IS
EDED ONLY WHEN PMH
UDIOTS ARE TRANSFERRED
3M THE LOCAL SCHOOL
STRICT TO HRS.
PMH STUDENTS HAVE: PMH STUDENTS HAVE: PMH STUDENTS HAVE:
HRS HAB PLAN SCHOOL SYSTEM IEP HRS HAB PLAN
HRS IEP HRS AB PLAN HRS IEP
*AS NOTED IN FIGURE 1, THE EXACT AGE RANGE OF PMH STUDENTS ATTENDING PUBLIC SCHOOL VARIES FROM
SCHOOL DISTRICT TO SCHOOL DISTRICT.
BIRTH
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Local school districts and HRS serve school-aged PMH students from three
different home environments: (1) students who live with their natural par-
ents or guardians: (2) students who live in group or foster homes; and (3)
students who live in HRS-operated or private residential facilities. Because
of the differing needs and environments of these three categories of PMH stu-
dents, types of service delivery and interagency coordination of services
vary. Along with individual needs and environments, agency resources also
help determine exactly what types of services students receive. Service de-
livery to these students ranges from simple to complex, but federal and
state regulations are the same for the education of all three types of stu-
dents.
Because of a mutual concern for the individuals in their charge, staffs with-
in local school systems, HRS districts, the DOE, and the central HRS head-
quarters are seeking to identify and implement positive practices for inter-
agency coordination of services. A logical starting point for such coopera-
tion is the coordination of habilitation plans and IEPs. The coordination
of these documents is affected by numerous factors, however, some of which
stem from federal, state, and agency requirements and their interrelation-
ships. Other factors are specific to only one or a few localities and thus
require that local agencies devise specific procedures to address them.
Purpose of This Manual
This resource manual has been developed to better acquaint public school and
HRS personnel with the statutes, rules, and regulations on which service
plans are based. It also describes the service plans used by local school
districts and HRS and suggests ways in which local agencies may coordinate
the development and implementation of these documents.
The information in the following chapters is intended for the use of public
school superintendents, exceptional student education administrators and
supervisors, school principals, teachers, and other public school personnel
involved in coordinating educational services with HRS and other agencies.
Both individually and collectively, these people play important roles in
creating and nurturing interagency communication. The manual can also
help HRS personnel understand the procedures local school districts use to
provide educational services. The statutory bases for service planning and
the alternatives for coordination should suggest ways in which both agencies
might adjust local policies and procedures to encourage and enhance coopera-
tive efforts.
Chapter 1 introduces the principal agencies involved--Florida's local school
districts, the Florida Department of Education, and the HRS Developmental
Services Program--and describes their structure and the services they pro-
vide to school-aged PMH students. Chapter 2 details the statutory bases
for service plans and service plan reviews. It compares the statutory re-
quirements for service provision and documentation and points out resulting
compatibilities and constraints to interagency coordination.
Chapter 3 describes the IEP Florida's public schools use to provide educa-
tional services to exceptional students and compares it with the hab plan
used for Developmental Services clients. This section explains the require-
ments of both plans and includes sample formats and definitions.
Chapter 4 presents four alternatives for agency coordination through inter-
agency planning and service provision. Because local needs and circumstances
vary (for example, the coordination needs of school districts with Sunland
Centers are specific to those districts), the chapter offers a continuum of
coordination practices for consideration.
As school and HRS personnel review these alternatives, they may also want to
consider developing written agreements between the two agencies where these
are not mandated by law. Thus, chapter 4 also discusses written cooperative
agreements and other written forms of service coordination. An overview of
data collection and sharing is also included. The communication of data on
students and programs is indirectly related to service plans and service
plan reviews. At the same time, it is an important element of coordination
and school districts interested in improving the education and care of PMH
students will want to consider it as well.
Although the manual offers suggestions for increasing interagency coordina-
tion, it does not attempt to address or resolve the numerous and often situa-
tional problems related to individual and group cooperation. Nor does it
attempt to instruct local school districts on the "best" or "correct" way to
provide services to PMH students. Local school boards and school district
personnel will want to consider all viable alternatives for service delivery
and select or adapt those that they believe meet student needs and local
circumstances.
CHAPTER 1
PARTICIPANTS IN SERVICE PLANNING
As pointed out in the introduction to this manual, Florida's local school
districts and HRS have both been charged with meeting the needs of profound-
ly mentally handicapped (PMH) individuals. The Bureau of Education for
Exceptional Students (BEES) within the DOE provides local school districts
with direction and support in the development of exceptional student educa-
tion programs. HRS has delegated the role of program planning for the de-
velopmentally disabled to its Developmental Services Program Office. This
chapter discusses these agencies' roles and responsibilities and highlights
the procedures and operations by which they fulfill statutory requirements.
Florida's Local School Districts
Local school districts are bound by Section 230.23, F.S., and State Board of
Education Rule 6A-6.331, which require the development of IEPs. State laws
and State Board of Education rules require school districts to meet general
requirements for IEP development, but they allow considerable latitude in
the development of specific content. As a result, local school districts
that serve PMH students vary substantially in the combination of strategies,
procedures, and activities they use to meet statutory requirements and stu-
dent needs. Generally, however, local school districts use one of three
management structures to develop IEPs for PMH students:
1. The school-based model assumes that most of
the responsibility for identifying exceptional
students and for finding appropriate programs
to meet their needs belongs to school-level
personnel (i.e., principals, guidance counselors,
and teachers). These personnel are responsible
for decision making and for carrying our district
procedures and policies.
2. In the central-office-based model, the central or
district office assumes the decision-making role.
School personnel identify students who may need
exceptional student education programs. Staff in
the central office are assigned specific respon-
sibilities for assessing the needs of students and
for deciding which program is appropriate for each
student.
3. In the shared-decision-based model, the needs of
exceptional students are identified, assessed, and
met through the interaction of school personnel
who are acquainted with individual students and
district staff who are knowledgeable about program
designs, related services, and the coordination of
services. This model requires greater cacuni-
cation and coordination between the school and
the district.
Whatever their form of management, school districts also differ in the organ-
ization of staffing and other meetings. Some school districts use a one-
step process that combines decisions on student eligibility with the develop-
ment of the IEP. Participants meet and discuss a student's assessment re-
sults and profiles. Next, they compare these with eligibility criteria for
exceptional student programs. If a student is considered eligible for a
particular program, the committee members develop an IEP.
Other school districts employ a two-step process. First, an eligibility
staffing is held to review assessment results and to determine whether a
student qualifies for an exceptional student program. The school psycholo-
gist, the guidance counselor, the staffing specialist, the student's teacher,
and the parent often attend this staffing. If a student is considered eli-
gible, a second meeting, to write the IEP, is scheduled and held within 30
days. The staffing specialist or guidance counselor, the teacher, and the
parents) usually participate in the IEP meetings.
Although federal and state statutes require that certain individuals attend
these meetings, the laws are flexible enough to permit diverse representa-
tion by school system personnel. For example, the local school district
representative may be a central-office employee or a school-based staff
member. Personnel assuming this responsibility include exceptional student
education directors, program consultants, staffing specialists, principals,
and teachers. Other persons interested in the student's program may also be
invited to attend, and some districts encourage participation by all person-
nel working directly with the student. This approach usually results in the
attendance of at least one teacher and various therapists. Other districts
organize their meetings around the presence of a local school district re-
presentative, the parentss, and a teacher or therapist.
Because local practices vary so widely, no typical procedures for developing
IEPs can be cited. Factors such as schedules for annual reviews, document
formats, details required for IEP components, and specific personnel to
participate in meetings all vary. A school district's schedule for annual
reviews is a particularly important variable. Many school districts schedule
annual reviews of all IEPs for the end of the school year. The months of
April and May are set aside for meetings of parents, teachers, and local
school district representatives to review students' progress during the school
year and to develop IEPs for the next school year. Other school districts
schedule a certain number of IEP review meetings each month during the school
year. The students' IEPs are then reviewed during the same month one
calendar year later. This concept works best when students are enrolled in
programs with curricula and instructional materials that cover entire skill
areas and sequences rather than in textbook-oriented classes, which may differ
greatly from one year to the next. In the latter situation, projecting goals
for the next year is usually more difficult.
The Bureau of Education for Exceptional Students (BEES)
BEES assists in the development of state and federally funded educational
programs for students who are hearing-impaired, mentally handicapped, physi-
cally handicapped, speech-impaired, emotionally handicapped, gifted, visu-
ally-impaired, and learning-disabled. It provides technical assistance in
program development and evaluation to school districts, other state agencies,
and universities; conducts program audits; and prepares resource materials
and manuals. BEES also helps school districts interpret applicable statutes
and rules and promotes standards for educational practices.
In assuming these responsibilities, the Bureau has two major purposes: to
provide direction and support for exceptional student education to local
school districts and to ensure the provision of adequate exceptional student
education programs. To achieve these purposes, staff members of the four
sections of the Bureau perform a variety of activities. Consultants in the
Program Development Section serve as content experts in different categories
of exceptionality. These consultants provide technical assistance to excep-
tional student education personnel through bulletins, training, on-site visits,
and other activities. The Program Review and Evaluation Section participates
in audits of local school districts to examine districts' practices and
compliance with required standards. The resulting reports are forwarded to
the school districts for corrective action.
BEES provides additional support to school districts through the Florida
Diagnostic and Learning Resources System (FDLRS), a system of associate
centers throughout the state that offer materials and inservice training to
persons working with exceptional students. The Program Services Section of
BEES manages the FDLRS system. The Clearinghouse/Information Center handles
special projects, parent services, and personnel preparation.
The fourth section of BEES, Resource Development, administers federal pro-
jects dealing with various aspects of exceptional student education at both
state and district levels.
To ensure that local school districts are providing adequate programs for
exceptional students, BEES requires each district to submit, annually, a
set of district procedures for serving exceptional students [SBER 6A-6.34].
These procedures are to address:
1. the organization and operation of the school
district's exceptional student education program
2. the provision of special programs that include:
criteria for eligibility
procedures for screening, referral, student
evaluation, determining eligibility and
educational placement, providing an IEP, and
dismissal or reassignment of students
descriptions of program organization, instruc-
tional programs, supportive services, and
housing for special programs
plans for evaluating programs
3. the provision of programs through multi-
district cooperatives
4. contractual arrangements with non-public
schools, when applicable
5. due process hearings
6. student discipline
The school districts' procedures must be in compliance with all State Board
of Education rules relating to special programs for exceptional students and
must be submitted to BEES for review and approval prior to the first funding
count in October. Once BEES approves a school district's procedures, they
become a binding document for that district.
The Department of Health and Rehabilitative Services (HRS)
HRS is the state agency responsible for providing integrated delivery of all
health, social, and rehabilitative services to eligible Florida residents.
For service delivery purposes, the state is divided into 11 HRS districts,
each serving from 1 to 16 counties. iFigure 3 illustrates HRS district bound-
aries.
FIGURE 3
HRS DISTRICT BOUNDARIES
.O *
Each district is authorized to provide the following programs to HRS clients:
Aging and Adult Services (AA)
Children's Medical Services (CMS)
Children, Youth, and Families (CYF)
Child Support Enforcement (CSE)
Developmental Services (DS)
Health (HE)
Alcohol, Drug Abuse, and Mental Health (MH)
Vocational Rehabilitation (VR)
Economic Services (ES)
Medicaid Services (DM)
For PMH clients, the most relevant of these programs is Developmental Ser-
vices, which serves developmentally disabled individuals. Under Florida
law, children and adults may be classified as developmentally disabled if
they exhibit disorders or syndromes caused by retardation, cerebral nalsy,
autism, or epilepsy and the symptoms constitute substantial handicaps that
are likely to continue indefinitely.
Florida law [Ch. 393, F.S.] also permits Developmental Services to accept
clients who qualify for services under P.L. 95-602, [ 102(7)] which defines
"developmental disability" as a severe, chronic disability that:
is attributable to a mental or physical
impairment or combination of mental and
physical impairments;
is manifested before the person attains
the age of 22;
is likely to continue indefinitely;
results in substantial functional limita-
tions in three or more of the following
areas of major life activity: self-care,
receptive and expressive language, learn-
ing, mobility, self-direction, capacity
for independent living, and economic
sufficiency; and
reflects the person's need for a combina-
tion and sequence of special, interdisci-
plinary, or generic care, treatment, or
-9-
other services that are of lifelong or ex-
tended duration and are individually plan-
ned and coordinated.
PMH children, adolescents, and adults meet both state and federal criteria
for developmental disabilities and are thus eligible to receive services
through the Developmental Services Program. Developmental Services staff in
each HRS district:
1. identify individuals who are eligible for
and want specialized assistance;
2. identify specific, individual needs;
3. help the client or the client's family
identify resources and obtain services to
meet these needs;
4. coordinate service delivery; and
5. reassess the individual's needs and services
provided.
Services for each client are coordinated by means of a written habilitation
(hab) plan developed by an interdisciplinary team. Case managers, or social
workers assigned to each client assume the responsibility for obtaining the
services indicated on the hab plan. Intended to provide services that help
reduce or eliminate client dependency, the system involves three basic pro-
cesses: (1) habilitation planning; (2) implementation of the hab plan; and
(3) reassessment of client needs.
Habilitation Planning. Once the district Diagnosis and Evaluation (D&E) Team
has determined that a person is eligible for Developmental Services, an
interdisciplinary team called the Habilitation Planning Conmittee (HPC)
develops a hab plan that identifies goals and service needs for the recipient.
The HPC is made up of at least one member of the D&E team or a Qualified
Mental Retardation Professional (QMRP),1 the case manager (usually a social
worker), the client, the client's guardian, and others familiar with the client.
HRS is not required to provide all the services listed in the plan but will
Chapter 10D-38, FAC [10D-38.02(26)] defines a QMRP as any one of the
following: (a) psychologist with at least a master's degree from a accredited
program, with specialized training and 1 year of specialized experience in
treating the retarded; (b) a physician duly licensed to practice medicine or
osteopathy, with specialized training and 1 year of specialized experience in
treating the retarded; (c) an educator with a degree in education from an
accredited program and with specialized training and 2 years of experience
in working with the retarded; (d) a social worker with a bachelor's degree
in social work from an accredited program and with specialized training and
-10-
either coordinate the provision of services from outside sources or document
efforts to obtain services that cannot be provided.
Implementation of the Hab Plan. A Developmental Services case manager de-
velops a strategy for implementing the goals of the hab plan. This person
negotiates with service providers and provides supportive case work to
clients and their families. The case manager is responsible for monitoring
clients in their homes or in residential facilities.
Reassessment of Client Needs. Both federal and state statutes require that
Developmental Services revise each client's habilitation plan annually.
This reassessment may be conducted by the case manager in consultation with
the client or by the HPC. At least every three years, reassessment must be
conducted by the HPC. Service providers are required to attend or send
progress reports to the HPC.
Other Services Provided. In addition to referral, diagnosis and evaluation,
and case-work services, Developmental Services clients and their families may
receive any of the following services appropriate to their needs.
Education, Training, and Therapy--These services
include specialized training in the categories
of self-care, pre-vocational, social, academic,
daily living, communication, and motor skills.
Occupational, speech, and recreation therapies
may also be provided.
Recreation--Planned and supervised activities are
designed to: (1) help meet specific individual
therapeutic needs in self-expression, social
interaction, and entertainment; (2) develop skills
2 years of experience in working with the retarded, or a bachelor's degree
in a field other than social work and at least three years social work
experience under the supervision of a qualified social worker and with
specialized training and 2 years of experience in working with the retarded;
(e) a physical or occupational therapist as defined in 20 CFR 405.1101(m) or
(q) who has specialized training and 1 year of experience in treating the
retarded; (f) a speech pathologist or audiologist as defined in 20 CFR 405.
1101(t) who has specialized training and 1 year of experience in treating
the retarded; (g) a registered nurse who has specialized training and 2 years
of experience in treating the retarded; (h) a therapeutic recreation special-
ist who is a graduate of an accredited program and who has specialized train-
ing and 1 year of experience in working with the retarded; (i) a rehabilitation
counselor certified by the committee on Rehabilitation Counselor Certification
who has specialized training and 1 year of experience in treating the retarded.
-11-
and interests leading to enjoyable and constructive
use of leisure time; and, (3) improve the client's
well-being.
* Parent Training--Training, counseling, and support
services include parent training classes, regular
individual home instruction, assessment of the
needs and abilities of clients, individual plans,
and continuing assistance.
* Respite Care Placement--Temporary 24-hour residen-
tial care for clients relieves the family or foster
parent of stress caused by continuous management
and supervision or by a sudden family crisis.
Respite care must not exceed 30 consecutive days
during any calendar year and may be provided
either in the community or at a Sunland Center.
* Family Placement--Relatives or caretakers receive
supplemental payments that allow clients to remain
in, or return to, their homes.
Medical and Dental Services--Medical, dental, and
related services identified in a client's habilita-
tion plan are provided.
Transportation--Clients may receive transportation
to and from service providers and community facili-
ties or sources.
Social Group Services--Group work and social, cul-
tural, and leisure-time experiences help clients
cope with personal problems, relieve various
pressures, and develop more adequate functioning.
Counseling--Clients and their families receive
assistance in resolving social, health, or emotional
problems.
Escort Services--Clients are assisted in going to
and from service providers.
Health Support Services--Therapies and other care
and assistance are used in training the client to
develop self-sufficiency.
Developmental Training--Infant stimulation, pre-
school programming, pre-vocational training, and
related services are designed to develop skills a
client needs to function independently.
-12-
Residential Care--Residential placements, which
vary in restrictiveness, include foster homes,
group homes, habilitation centers, Intermediate
Care Facilities for the Mentally Retarded, and
Sunland Centers.
Continuum of Care. For all Developmental Services clients, the type of re-
sidence is a major factor. Because clients vary in their needs for training
and care, Developmental Services uses the concept of a "continuum of care"
to determine the appropriate residential setting for each client, a continuum
that ranges from the least restrictive to the most restrictive.
The appropriate setting for an individual is determined by the client's needs
for training and care and by the quality of services the client can receive
there. Developmental Services defines "most restrictive" as "a setting with
less freedom, more control over the client's activities" and "least restric-
tive" as "a setting with a great deal of independence with minimum control
over the client's activities." Figure 4 describes the settings in the con-
tinuum of care in order, from the least to most restrictive.
FIGURE 4
DEVELOPMENTAL SERVICES CONTINUUM OF CARE
LOCATION
OWN HOME
A family or guardian arrangement.
A client in this setting may live
independently and receive few
supportive services from Develop-
mental Services. This setting is
usually considered the least re-
strictive environment, although
specific environments vary widely.
SUPPORT SERVICES AVAILABLE
4
* Case management (by Developmental
Services social worker)
* Educational or training services
* Respite care for the family
* Therapies
* Medical and dental care
" Public education for school-aged
clients provided by the local
school district
-13-
FIGURE 4, CONTINUED
DEVELOPMENTAL SERVICES CONTINUUM OF CARE
LOCATION SUPPORT SERVICES AVAILABLE
FOSTER HOME
A family setting that provides
support and care to the client. The
facility and family (staff) are re-
quired to meet licensure standards.
Foster home placement is recommended
when the emotional development and
physical care of the client requires)
the security of parent surrogates.
A foster home can serve no more than
3 clients. It is considered the
least-restrictive and most appro-
priate residential setting for all
children under twelve who cannot
remain in their own homes.
GROUP HOME
A family-operated home serving from
4 to 8 children or adults, located in
a setting where clients are integrat-
ed into the normal activities of the
neighborhood or a facility with
staff who provide a simulated family
setting for 9 to 16 clients. The
larger facility may be located in a
typical residential setting or in a
setting where multipurpose housing
is found. Group homes meet clients'
emotional and physical needs in a
supportive family atmosphere that
encourages peer identification,
semi-independent living, and social-
ization.
RESIDENTIAL HABILITATION CENTER
A community residential facility
operated primarily for the diagnosis,
treatment, or rehabilitation of
clients. This facility provides a
structured residential setting with
continuing individualized evaluation,
* Medical and dental care
* Educational and training opportuni-
ties
Therapies
Recreational opportunities appro-
priate to the level of the client
Public education for school-aged
clients provided by the local
school system
Religious nurture as indicated by
the client or guardian
* Job-related training for adult
clients
* Medical and dental care
* Educational and training opportuni-
ties
* Therapies
* Job-related training for adult
clients
* Recreational opportunities appro-
priate to the level of the client
* Public education provided by the
local school system for school-aged
clients
* Religious nurture as indicated by
the client or guardian
Medical and
Educational
ties
Therapies
Job-related
clients
dental care
and training opportuni-
training for adult
-14-
FIGURE 4, CONTINUED
DEVELOPMENTAL SERVICES CONTINUUM OF CARE
LOCATION
planning, 24-hour supervision, and
coordination and integration of
health and rehabilitation services.
Such a facility may not serve fewer
than 17 clients.
COMMUNITY ICF/MR
A residential facility with a maximum
of 60 beds. The ICF/MR may be li-
censed to serve persons with varying
degrees of physical and mental dis-
abilities. A community ICF/MR is a
private nonprofit or for-profit
organization that must meet all state
and federal regulations for ICF/MR
facilities and for the developmentally
disabled. The HRS Office of Licen-
sure and Certification certifies and
monitors all ICF/MR facilities in
Florida. ICF/MR programs were
developed to meet the residential
and training needs of severely and
profoundly retarded individuals.
To be accepted by an ICF/MR, a client
must meet financial and programmatic
eligibility requirements; be eligible
for Medicaid; have a specified degree
of retardation or additional handicap;
and need the level of care provided by
the facility.
CLUSTER ICF/MR
Three one-story homes grouped in one
location, each with the capacity for
serving 8 clients. Each residence is
equipped and furnished to meet clients
needs in a home-like atmosphere.
Florida's cluster facilities have been
specifically designed to provide
SUPPORT SERVICES AVAILABLE
* Recreational opportunities appro-
priate to the level of the client
* Public education for school-aged
clients provided by the local
school system
* Religious nurture as indicated by
the client or guardian
* Support services for clients in
this program must be provided by
the ICF/MR facility. No ICF/MR
facility may accept clients for
whom they cannot meet the needs
identified on individual habilita-
tion plans.
*Public education for school-aged
clients provided by the local
school system
*Support services for clients in
this program must be provided by
the ICF/MR facility. No ICF/MR
facility may accept clients for
whom it cannot meet the needs
identified on individual hab plans.
*Public education for school-aged
-15-
i-
FIGURE 4, CONTINUED
DEVELOPMENTAL SERVICES CONTINUUM OF CARE
LOCATION SUPPORT SERVICES AVAILABLE
alternative residential placement for
mentally handicapped clients now living
in the Orlando and Tallahassee Sunland
centers. Individuals currently being
transferred to cluster ICF/MRs are
severely or profoundly handicapped and
have multiple handicapping conditions.
Cluster ICF/MRs must meet all federal
and state regulations applicable to
other ICF/MR facilities.
SUNLAND CENTER
Large residential facilities that
serve severely and profoundly mentally
handicapped clients who are unable to
live in less-restricted environments.
The Sunlands in Miami, Marianna,
Gainesville, and Ft. Myers are single-
floor facilities that serve primarily
ambulatory clients who do not generally
require 24-hour medical supervision.
These centers are currently being
renamed under legislation passed in
1982.
clients provided by the local
school system
*Psychological services
SMedical and dental care
*Training opportunities
*Adult basic education (provided
by HRS)
* Therapies
* Recreational opportunities
appropriate to the level of the
client
*On-site case management
*Religious nurture as indicated by
client or guardian
SEducation for school-aged clients
provided by public school system
-16-
T mWlit Moe of ICF/MRs in Serving PMH Students
The ICF/MR program was created in 1972 with the passage of P.L. 92-223. A
component of the medicaid program, it is designed to provide residential and
habilitation services to retarded persons whose mental and physical handicaps
require an intensive level of care and services. To receive ICF/MR placement,
an individual must be eligible for medicaid, diagnosed as mentally retarded,
and in need of the comprehensive habilitation services provided by ICF/MRs.
In its "Five Year Plan For Services" (1981), Developmental Services identified
as a major priority the deinstitutionalization of PMH clients residing in the
Tallahassee and Orlando Sunland centers. To meet this objective, HRS is de-
veloping ICF/MR facilities throughout Florida. These facilities must meet
stringent federal and state requirements for certification and operation; they
are monitored annually by the HRS Office of Licensure and Certification.
ICF/MRs vary in size and the types of clients served. A facility licensed as
a residential ICF/MR may have 60 or fewer beds in 15-bed living units. A
larger facility licensed as an institutional ICF/MR may serve as many as 64
clients in 16-bed living units. Cluster ICF/MRs consist of 3 homes, each
designed to serve 8 clients, grouped under a 24-bed license.
Cluster facilities now being developed will be the primary recipients of
school-aged clients from Tallahassee and Orlando Sunland centers. The con-
tinuing transfer of school-aged clients to cluster facilities will have a
significant effect on the school districts involved.1 As cluster facilities
are completed, local schools must prepare to serve additional PMH students
with multiple handicapping conditions. To ensure a smooth transition for
these students from institutional to community placement, local school
systems must respond to their special needs. Federal and state ICF/MR regu-
lations have created additional standards for client data collection, pro-
gress reporting, and service plan reviews. Because local schools will
provide educational services to cluster clients, cluster facility staff may
request school system cooperation in meeting ICF/MR standards for the care
and training of these children.
School systems are free to determine the extent of such cooperation, and
certain forms of coordination may not be feasible. For cluster clients to
receive the maximum benefit from community placement, however, their educa-
tional and training programs must be mutually planned, coordinated, and
complementary. Verbal and written agreements may both be needed. Thus, to
the extent that local conditions permit, school district staff will want to
cooperate with cluster staff just as they would with HRS residential facili-
ties and private, nonprofit organizations that also serve PMH children in
the school district.
1Cluster facilities are currently operating in Orange, Duval, Pinellas,
Palm Beach, and Leon school districts. Additional facilities are either
under construction or planned for Escambia, Bay, Leon, Duval, Alachua,
Pinellas, Martin, Hillsborough, Polk, Marion, Volusia, Lee, Broward, Columbia
and Dade school districts.
-17-
CHAPTER 2
STATUTES, RULES, AND REGULATIONS AFFECTING
SERVICE PLANS FOR PMH STUDENTS
School district and HRS personnel who participate in cooperative planning for
the care and education of PMH students must take into account federal, state,
and agency regulations that deal with the development and implementation of
both IEPs and hab plans. Even though agency staffs may implement their ser-
vice plans independently, they cannot approach cooperative service planning
without first understanding the legal and regulatory bases for each plan.
If service goals and objectives are to be integrated and compatible, both
parties must be willing to learn about and adapt to the others regulations
and constraints.
To achieve such coordination, HRS districts, HRS residential facilities, and
local school districts may need to reconsider--and revise--what may previously
have been viewed as "iron-clad" and "unalterable" policies. An important
first step is to determine whether such policies accurately reflect federal
and state statutes. Sometimes, disagreements between agencies stem from
individual and group interpretations of statutory requirements, rather than
from the statutes themselves.
Local constraints, the problem of confidentiality, and the identification of
surrogate parents have affected--and will continue to affect--some aspects of
agency coordination. At the same time, however, the pertinent federal statutes
and regulations and state statutes are compatible in a number of significant
ways. Local school districts and HRS districts thus have the flexibility, the
opportunity, and the responsibility to jointly plan coordinated programs that
include common or complementary goals and mutually agreed on short-term objec-
tives. Equally as important, few statutes and agency regulations prohibit
local school systems and HRS districts from cooperating in planning and inte-
grating services. For example, school and HRS personnel are free to:
1. share service plan documents with parental permission;
2. coordinate goals and objectives on service plans;
3. coordinate the ways in which goals and objectives
are written;
4. coordinate time-lines ifor the accomplishment of
goals and objectives;
5. coordinate annual review dates of service plans;
6. participate in each other's service plan reviews;
7. share evaluation results with parental permission;
8. share data gathered on PMH students with parental
permission; and
9. coordinate the periodic reevaluation of PMH students.
-18-
The legal compatibilities outlined in this chapter should suggest a number of
possibilities for interagency coordination that will not be hampered by legal
constraints. In addition, chapter 4 outlines 4 alternative methods for joint
planning that are not prohibited by either statutory mandates or agency regu-
lations. Clearly, the essential ingredients of interagency coordination are
a spirit of compromise and the shared goal of improving the services to PMH
students. These ingredients are readily available to individuals within both
agencies who want to see all PMH students reach their maximum potential.
In coordinating service plans and annual meetings to review and update these
plans, staff members of school and HRS districts will need to understand fed-
eral and state statutes and rules of the Florida Administrative Code (FAC)
dealing with:
1. service plan documents;
2. required meetings to develop and review service
plan documents;
3. reevaluation of students or clients; and
4. required participants in service plan reviews.
Legal Bases for Service Plans
Both the federal government and the state of Florida require that each state
agency providing services to exceptional students and to developmentally dis-
abled individuals develop written plans for service implementation. In
Florida, these service plans are the school system's Individual Educational
Plan (IEP) required by SBER 6A-6.331 and P.L. 94-1421 and HRS' habilitation
(hab) plan, required by Chapter 393, F.S. and P.L. 95-602. Federal regula-
tions for ICF/MRs also require a "written plan of care" [Federal Interpretive
Guidelines for 45 CFR 249.13]. In addressing service plans for ICF/MRs in
Florida, Chapter 10D-38, FAC indicates that all ICF/MR clients must have both
a hab plan and an Active Treatment Plan (ATP). PMH students who receive only
public school services have one legally required service plan--the IEP. PMH
students who are also HRS Developmental Services clients have two--a school
system IEP and an HRS hab plan; and PMH students living in ICF/MRs have three--
a school system IEP, and HRS hab plan, and an ICF/MR ATP. Figure 5 illustrates
federal and state requirements for service plans and how those requirements
translate into public school, HRS, and ICF/MR documents.
1As noted in Chapter 1, HRS also develops IEPs for PMH clients ages 0-5
and 19-21 who are not served by local school districts, as required by Chapter
6A-15, FAC.
-19-
FIGURE 5
STATUTORY REQUIREMENTS FOR SERVICE PLANS
PUBLIC SCHOOL SYSTEM
STATUTORY MANDATE TO
PLAN AND PROVIDE ED-
UCATIONAL AND RELATED
SERVICES USING A
WRITTEN DOCUMENT.
[SBER 6A-6.331; P.L.
94-142, Sec. 4(4) (19)]
HRS DEVELOPMENTAL
SERVICES
STATUTORY MANDATE TO
PLAN AND PROVIDE SER-
VICES USING A WRITTEN
DOCUMENT. [Section
393.065(2), F.S.; P.L
95-602, Sec. 112.(a)]
HABILITATION (HAB)
PLAN
HPS-ICF/MRs
STATUTORY MANDATE TO
PLAN AND PROVIDE SER-
VICES USING A WRITTEN
DOCUMENT [Section
393.065, F.S.; 42 CFR
442]
Legal Bases for IEPs. Most educators of PMH students are aware that P.L. 94-
142 provides the statutory basis fori the development of IEPs. The law defines
an Individualized Education Program thus [.4(4) (19)]:
The term "individualized education program" means a
written statement for each handicapped child devel-
oped in any meeting by a representative of the local
educational agency or an intermediate educational
unit who shall be qualified to provide, or supervise
the provision of, specially designed instruction to
meet the unique needs of handicapped children, the
teacher, the parents or guardian of such child, and,
whenever appropriate, such child, which statement
shall include (A) a statement of the present levels
of educational performance of such child, (B) a
statement of annual goals, including short-term
instructional objectives, (C) a statement of the
specific educational services to be provided to such
child, and the extent to which such child will be
able to participate in regular education programs,
(D) the projected date for initiation and anticipated
duration of such services, and appropriate objective
criteria and evaluation procedures and schedules for
determining, on at least an annual basis, whether
instructional objectives are being achieved.
The federal mandate is reflected in Florida State Board of Education Admini-
strative Rule 6A-6, which requires each school district to develop IEPs for
-20-
INDIVIDUAL EDUCATIONAL
PROGRAM (IEP)
INDIVIDUAL PLAN OF
CARE:
* HRS HABILITATION
PLAN
* ACTIVE TREATMENT
PLAN (ATP)
exceptional students that meet the criteria in P.L. 94-142 [SBER 6A-6.331(3)].
Each district shall develop an individual educational
plan for each exceptional student. (a) An individual
educational plan consists of written statements in-
cluding:
(1) A statement of the student's present levels of
educational performance;
(2) A statement of annual goals, including short-
term instructional objectives;
(3) A statement of the specific special education
and related services to be provided to the
student and the extent to which the student
will be able to participate in regular educa-
tional programs;
(4) The projected dates for initiation of services
and the anticipated duration of services; and
(5) Appropriate objective criteria and evaluation
procedures and schedules for determining, on
at least an annual basis, whether the short-
term objectives are being achieved.
These legal mandates have led the Bureau of Education for Exceptional Students,
Florida Department of Education to develop written guidelines for school dist-
ricts to use in developing IEPs2 and audit districts' compliance with the
statutes and State Board of Education Rules. Provided that district school
boards include the key elements identified in these regulations, they may
determine the exact IEP format they will use.
Legal Bases for Hab Plans. The comparable legal basis for HRS Developmental
Services hab plans is P.L. 95-602, which requires each state receiving federal
funds to provide developmentally disabled persons (a category that includes
the profoundly mentally handicapped) with written hab plans that state the
long-term habilitation goals, the intermediate habilitation objectives, and
the specific services to be provided for each client. The specifications in
P.L. 95-602 appear as follows:
SEC.112. (a) The Secretary shall require as a condi-
tion to a State's receiving an allotment under part
C that the State provide the Secretary satisfactory
assurances that each program (including programs for
any agency, facility, or project) which receives
funds from the State's allotment under such part (1)
has in effect for each developmentally disabled per-
son who receives services from or under the program
a habilitation plan meeting the requirements of
subsection (b), and (2) provides for an annual review,
2See A Resource Manual For the Development and Evaluation of Special
Programs for Exceptional Students: Vol. III-A Individual Educational Pro-
grams, Florida Department of Education.
-21-
in accordance with subsection (c), of each such plan.
(b) A habilitation plan for a person with de-
velopmental disabilities shall meet the follow-
ing requirements:
(1) The plan shall be in writing.
(2) The plan shall be developed jointly by
(A) a representative or representatives of the
program primarily responsible for delivering or
coordinating the delivery of services to the
person for whom the plan is established, (B)
such person, and (C) where appropriate, such
person's parents or guardian or other represen-
tative.
(3) The plan shall contain a statement of the
long-term habilitation goals for the person and
the intermediate habilitation objectives relating
to the attainments of such goals. Such objectives
shall be stated specifically and in sequence and
shall be expressed in behavioral or other terms
that provide measurable indices of progress. The
plan shall (A) describe how the objectives will
be achieved and the barriers that might interfere
with the achievement of them, (B) state objective
criteria and an evaluation procedure and schedule
for determining whether such objectives and goals
are being achieved, and (C) provide for a program
coordinator who will be responsible for the im-
plementation of the plan.
(4) The plan shall contain a statement (in
readily understandable form) of specific habili-
tation services to be provided, shall identify
each agency which will deliver such services, shall
describe the personnel (and their qualifications)
necessary for the provision of such services, and
shall specify the date of the initation of each
service to be provided and the anticipated duration
of each such service.
(5) The plan shall specify the role and objec-
tives of all parties to the implementation of the
plan.
Florida statutes for hab plans preceded the federal statutes by several years,
and amendments to Chapter 393 brought the state regulations already in force
into compliance with P.L. 95-602. Chapter 393, F.S. assigns the following
responsibilities to HRS [S. 393.065(2)].
The department [HRS] shall prescribe and provide an
appropriate individual habilitation plan for each
client. The parent or guardian of the client or, if
competent, the client shall be consulted in the devel-
opment of the plan and shall receive a copy of the
plan. Each plan shall include the most cost-beneficial,
least restrictive environment for accomplishment of the
-22-
objectives for client progress and a specification
of all services authorized. The plan shall include
provisions for the most appropriate level of care
for the client. Within the specification of needs
and services for each client, when residential care
is necessary, the department shall move toward
placement of clients in residential facilities based
within the client's community. The ultimate goal of
each plan, whenever possible, shall be to enable the
client to live a dignified life in the least restric-
tive setting, be that in the home or in the community.
(a) The department shall develop and prescribe by
rule a standard habilitation plan form. This form
shall be used by each district.
The final mandate in this section of Chapter 393, to "prescribe by rule a
standard habilitation plan form" is father detailed by Chapter 10F-3 of the
Florida Administrative Code, which prescribes the content and format of the
hab plan to be used by all HRS districts. Chapter 10F-3 lists the skill areas
or measurement categories needed for each client and divides them into three
sections [10F-3.12(7) (e)]:
SECTION A SECTION B
Psychological Basic Academic Skills
Psychosocial Self-Care Skills
Medical Daily Living Skills
Dental Human Growth and Development
Nursing Cornunication Skills
Physical Therapy Social Skills
Occupational Therapy Motor Skills
Recreation Skills Job-related Skills
Therapeutic Visits Recreation Skills
Long Range Optimal Plan
SECTION C
Ability to Give Express and Informed Consent
Least Restrictive Environments in Wiich Above Services may be
Rendered
Justification of Residential Setting
Section (7)(e) 7 also states:
In cases where a particular category or groups of
categories are determined by discussion to be re-
levant to the client's habilitation plan, but it
is decided that the Retardation Program3 is not
responsible for providing services of the partic-
ular category or group of categories to the
3ow the Developmental Services Program.
-23-
particular client, the relevant categories shall be
entered on the plan accompanied by a statement that
explains why it is not appropriate for the Retarda-
tion Program to provide goals or authorize services
in that category or categories.
Finally, these requirements are further expanded in HRS manual 160-2, Client
Services, developed by HRS to record policies and standards for implementing
services to Developmental Services clients. The manual, which is reviewed
and approved by HRS Legal Services before it is distributed for use, includes
an interpretation of legal requirements. It defines a.hab plan as follows
in paragraph 4-5:
A habilitation plan is an individualized prescrip-
tive plan written by the Developmental Services
Program. The purpose of the habilitation plan is
to identify client needs and authorize the expen-
diture of state funds for the provision of services.
The habilitation plan tells what is to be done. In
developing a habilitation plan, the client's present
level of functioning or development in each appli-
cable program or service area is described. In each
program area, goals written in measurable terms
identify the performance level to be obtained or
maintained by the client over the duration of the
habilitation plan.
To ensure that record keeping is consistent and in compliance with federal
and state regulations, HRS also requires the use of a standardized hab plan
format, HRS-DS form 3033. The manual thus states in paragraph 4-5 that "only
HRS-DS Form 3033 or identical format when word processors are used, may be
used for habilitation plans in the Developmental Services Program." Following
paragraph 4-5 is detailed information to be included in each of the hab plan's
four sections.
Legal bases for ICF/MR service plans. For ICF/MRs, federal regulations also
mandate written service plans that are similar in concept to hab plans. The
Code of Federal Regulations regarding Medicaid [42 CFR 442.418(b)(1)] states:
The [interdisciplinary] team must--
(1) Conduct a comprehensive evaluation of the individual
covering physical, emotional, social, and cognitive
factors; and
(2) Before the individual's admission-
(i) Define his need for service without regard to the
availability of services; and
(ii) Review all available and applicable programs of
care, treatment, and training and record its findings.
Under the heading "Training and Habilitation Services" [42 CFR 442.463], the
regulations state:
(a) The ICF/MR must:provide training and habilitation
services to all residents, regardless of age,
-24-
degree of retardation, or accompanying disabilities
or handicaps.
(b) Individual evaluations of residents must--
(1) Be based upon the use of empirically reliable
and valid instruments, whenever these instru-
ments are available; and
(2) Provide the basis for prescribing an appro-
priate program of training experiences for
the resident.
(c) The ICF/MR must have written training and habili-
tation objectives for each resident that are--
(1) Based upon complete and relevant diagnostic
and prognostic data; and
(2) Stated in specific behavioral terms that per-
mit the progress of each resident to be assessed.
(d) The ICF/MR must provide evidence of services de-
signed to meet the training and habilitation
objectives for each resident.
(e) The training and habilitation staff must--
(1) maintain a functional training and habilitation
record for each resident; and
(2) provide training and habilitation services to
residents with hearing, vision, perceptual, or
motor impairments.
The Interpretive Guidelines for 45 CFR 249.13 interpret these and other stan-
dards and include survey procedures for federal monitors of ICF/MRs. The
introduction to these guidelines states:
The ICF/MR standards take into account the widely
varying needs of the mentally retarded and persons
with related conditions which have been defined to
include those with cerebral palsy and epilepsy.
The goal of the special standards is to assure
that the IMR [Institution for the Mentally Retarded
and Persons with Related Conditions] provides a
range of services adequate to develop maximum inde-
pendent living capabilities of its residents in
order to return them to the community at the earliest
possible time. To further assure that the mentally
retarded receive the services they need, Congress
stipulated that each resident must receive active
treatment to be eligible for Medicaid support.
-25-
Standard 249.10(d) (1)(v) defines active treatment and describes the "plan of
care" needed for each client:
Active treatment means:
(A) An individual "plan of care" which is a written
plan setting forth measurable goals or behaviorally
stated objectives and prescribing an integrated
program of individually designed activities, ex-
periences or therapies necessary to achieve such
goals or objectives. The overall objective of the
plan is to attain or maintain the optimal physical,
intellectual, social, or vocational functioning of
which the individual is presently or potentially
capable.
The corresponding guideline states:
A "plan of care" must be written for each resident
and include both short and long range goals which
can be measured in terms of the individual's habil-
itation and progression from dependent to independ-
ent functioning. The goals should reflect both
specific results to be accomplished and the general
level of functioning to be reached by the resident.
Estimates should be made of the length of time needed
to accomplish the various goals.
In Florida, these and other federal regulations have served as the basis for
the development of rules for licensure and certification of ICF/MRs. Appear-
ing as Chapter 10D-38 of the Florida Administrative Code, these rules took
effect on December 1, 1978 and were revised in 1982. In the Florida regula-
tions, the federally used term "individual 'plan of care"' becomes two sepa-
rate documents: the HRS hab plan and the Active Treatment Plan.
Chapter 10D-38 defines the plans thus:
Habilitation Plan--A plan for providing programs
and services to a client based on a joint inter-
disciplinary, professional diagnosis and evalua-
tion consisting of, at least, a complete medical,
social, and psychological assessment as well as
any additional assessment as appropriate. The
habilitation plan sets forth the behavioral goals
which are to be achieved by the client over a 12
month period and provides the basis for the devel-
opment of the short-term objectives which will
constitute the client's Active Treatment Plan.
[10D-38.02 (22)]
Active Treatment Plan--A single document, indi-
vidually written plan of care developed by an
interdisciplinary team. The Active Treatment Plan
should be a prioritization of needs identified on
-26-
the client's Habilitation Plan, which sets forth
measurable and behaviorally stated short-term
objectives to be reviewed monthly and revised,
accordingly, by each service provider. It is not
necessary for all areas of the Habilitation Plan
to be addressed simultaneously. However, each
goal must be addressed within the twelve-month
time frame of the Habilitation Plan. Revisions
should be based on the collection of data and
progress reports. The Active Treatment Plan
prescribes an integrated program of individually
designed activities, experiences, or therapies
necessary to achieve the stated short-term
objectives. [10D-38.02(1)]
Later, Chapter 10D-38 addresses the training and habilitation services each
client is to receive and defines these services as "deliberate attempts to
facilitate the intellectual, sensorimotor, and effective [sic] development
of the individual" [10D-38.16(1)]. Continuing, it states [10D-38.16(3)]:
Training and habilitation services available to
the facility should include:
(a) Establishment and implementation of active
treatment programs providing:
(1) Continuous evaluation and assessment
of the individual;
(2) Programming for the individual;
(3) Instruction of individuals and groups;
(4) Evaluation and improvement of instruc-
tional programs and procedures.
Similarities Among Statutory Requirements
A comparison of these federal and state laws and regulations shows a number
of similarities between the requirements for public school and HRS service
plans. Each agency, for example, must develop a written service plan with
similar elements. Local school districts, HRS districts, HRS residential
facilities, and ICF/MRs use their respective plans as management tools to
specify the student or client services they are responsible for. Differences
in the documents reflect the differences in services that each agency is
legally required to provide. HRS hab plans must address all services that a
client needs. For school-aged clients enrolled in public school programs,
hab plans also include those educational services. Similarly, state and
federal laws require that Florida's local school districts address the total
educational and related services a student is to receive. The IEP acts to
provide written documentation of this planning and service provision.
Figure 6 lists the legal bases for service plans and describes the compo-
nents required for each plan.
-27-
FIGURE 6
LEGAL BASES FOR INDIVIDUAL SERVICE PLANS
PUBLIC SCHOOL SYSTEM
STATUTORY MANDATE TO PLAN AND PROVIDE
EDUCATIONAL AND RELATED SERVICES
USING A WRITTEN DOCUME [SBER 6A-
6.331; P.L. 94-142]
HRS DEVELOPMENTAL SERVICES
STATUTORY MANDATE TO PLAN AND PROVIDE
SERVICES USING A WITTEN DOCUMENT
[S.393.065, F.S.; P.L. 95-602]
HABILITATION PLAN
ADDRESSES TOTAL CLIENT SERVICES.
SECTION 393.065, F.S. REQUIRES THE
USE OF A-STANDARD HABILITATION PLAN
FORMAT. THE DOCUMENT MUST INCLUDE
STATEMENTS OF:
* Long-term habilitation goals* and
intermediate habilitation objectives
stated in behavioral or other terms
that provide measurable indices of
progress [P.L. 95-602]
* Specific habilitative services to
be provided [P.L. 95-602; S.393.065,
F.S.]
* The most cost beneficial, least re-
strictive environment for accomplish-
ment of the objectives for client
progress [S.393.065,F.S.]
* Specification of all services autho-
rized [S.393.065, F.S.]
*Chapter 10F-3, FAC states that a goal
should indicate the level of function-
ing to be attained by a client within
one year.
HRS ICF/MRS
STATUTORY MANDATE TO PLAN AND PROVIDE
SERVICES USING A WRITTEN DOCUMENT
[42 CFR 442.400, SUBPART G; INTERPRE-
TIVE GUIDELINES FOR 45 CFR 249.13]
INDIVIDUAL PLAN OF CARE*
f ADDRESSES TOTAL CLIENT SERVICES.
THE DOCUMENT(S) MUST INCLUDE:
* Measurable goals of behaviorally
stated objectives
A prescription of an integrated
program of individually design-
ed activities, experiences, or
therapies
*ICF/MRs in Florida use the HRS
Developmental Services habilita-
tion plan and the ICF/MR Active
Treatment Plan to fulfill federal
requirements.
ADDRESSES EDUCATIONAL AND RELATED
SERVICES. DOCUMENT MUST INCLUDE:
* Statement of the student's
present levels of educational
performance
* statement of annual goals and
short-term instructional objectives
* Statement of specific educational
and related services to be provid-
ed
* Projected date for initiation and
anticipated duration of such
services
* Objective criteria and evaluation
procedures and schedules
IEP formats vary from school district
to school district.
Some of the required components of these service plans are the same. For ex-
ample, each must include:
1. long-term goals (Both HRS and the DOE define "long-term"
as "annual.");
2. short-term objectives (included on the ATP, IEP, or IPP
when developed by HRS);
3. specific services to be provided; and
4. a time-line for the accomplishment of goals and objectives.
Statutory compatibility alone does not, however, bring about integrated planning
and services. Neither federal nor state laws require that service plans for PMH
students receiving services from several agencies be developed jointly. The
Florida Administrative Code does, however, mandate joint participation in
specific instances of placement and transfer. For example, in addressing HRS
educational programs for the handicapped, SBER 6A-15 states:
When the placement decision involves the considera-
tion of least restrictive educational environments
which the school system can provide, the school
district exceptional student education administrator
or designee shall be requested to attend the staff-
ing committee meeting. [6A-15.14(2) (c)]
When the admissions committees of Mental Health or
Retardation residential care facilities consider the
placement of exceptional students in Mental Health
hospitals or Sunland Centers, the school district
exceptional student education administrator in the
county where the residential facility is located
shall be invited to attend the residential placement
meeting and shall be invited to participate in the
decision regarding the residential placement of the
exceptional student. [6A-15.15(1)
When Mental Health, Retardation or Social and Eco-
nomic Services residential placement committees meet
to discuss and recommend placement of an exceptional
student in a private residential facility, the school
district exceptional student education administrator
or designee in the student's home county shall attend
the meeting and participate in the decision regarding
the residential placement of the student [6A-15.15(2)]
The reasons for a recommendation for placement in the
residential facilities described in (1) and (2) above
shall be documented jointly be Department [IRS] and
the school district representative. [6A-15.15(3)]
-29-
Typically, school and HRS districts independently develop and use their re-
spective plans. Both use the documents to ensure that an organized program
of services is provided and to authorize the disbursement of funds or other
resources. HRS generally uses the school system's IEPs to represent Section
C of the hab plan for school-aged clients, except for those residing in
ICF/MRs. Figure 7 illustrates this use.
FIGURE 7
RELATIONSHIP OF THE IEP TO THE HAB PLAN
IEP
LEA MANAGEMENT TOOL REFLECTING ALL
EDUCATIONAL AND RELATED SERVICES
PROVIDED; MUST INCLUDE:
* Student's present level of per-
formance
* Annual goals and short-term
instructional objectives
* Specific special education and
related services to be provided
* Projected dates for initiation
of services
* Anticipated duration of services
* Appropriate objective criteria
and evaluation procedures and
schedules
HAB PLAN
HRS MANAGEMENT TOOL REFLECTING ALL
SERVICES NEEDED; MUST INCLUDE:
Section A (see p. 23)
Section B (see p. 23)
SECTION C
(Section B in Ch. 10F-3, FAC)
* Basic academic skills
* Self-care skills
* Daily living skills
* Human growth and development
* Comrunication skills
* Social skills
* Motor skills
* Job-related skills
* Recreation skills
Section D (part of Section C in Ch.
10F-3, FAC)
As figure 7 shows, elements of the two plans are related. This relationship
implies coordinated planning and compatible long-range goals and short-term
objectives. To ensure that PMH students receive integrated and compatible
services, school district and HRS staffs must develop service plans that
include complementary and reinforcing goals and objectives. Alternative meth-
ods for achieving this coordination are outlined in Chapter 4 of this manual.
-30-
Legal Bases For Service Plan Reviews
Federal and state laws also require annual reviews of service plans. For IEPs,
P.L. 94-142 [. 6.14(a)(5)] states:
". .. that the local educational agency or intermediate
educational unit will establish, or revise, whichever is
appropriate, an individualized education program for each
handicapped child at the beginning of each school year
and will then review and, if appropriate revise, its pro-
visions periodically, but not less than annually."
SBER 6A-6.331(3) reiterates this requirement:
(b) An individual educational plan which has been review-
ed and revised, if appropriate, within the past year,
must be in effect at the beginning of each school
year for each exceptional student continuing in a
special program. For new exceptional students assign-
ed to a special program, an individual educational
plan must be developed in conjunction with the assign-
ment to a special program.
(c) Meetings shall be held to develop, review, and revise
an exceptional student's individual educational plan,
(1) A meeting shall be held at least once a year to
review each exceptional student's individual educa-
tional plan and, as appropriate, revise its provisions.
Finally, the DOE supplements these requirements by establishing standards for
IEP annual review and revision. A Resource Manual For the Development and
Evaluation of Special Programs for Exceptional Students: Vol III-A Individual
Educational Programs, states (p.42):
At least once each calendar year, the IEP must be reviewed.
The annual review meetings may be held at any time through-
out the year, including (a) at the end of each school year,
(b) during the summer before the new school year begins, or
(c) on the anniversary date of the student's last IEP meet-
ing.
Public law 95-602 establishes a similar requirement for annual review of HRS'
habilitation plans [. 112.(c)]:
Each habilitation plan shall be reviewed at least annually
by the agency primarily responsible for the delivery of
services to the person for whom the plan was established
or responsible for the coordination of the delivery of
services to such person. In the course of the review, such
person and the person's parents or guardian or other re-
presentative shall be given an opportunity to review such
plan and to participate in its revision.
Chapter 393, F.S. goes a step further by requiring HRS to review clients' pro-
-31-
gress every six months. The statute states [S. 393.065(2)(e)]:
The department [HRS] shall review progress in achiev-
ing the objectives specified in each client's habilita-
tion plan, at least semiannually, and shall revise the
plan annually, following consultation with the client,
if competent, or with the parent or guardian of the
client. The department shall annually report in writing
to the client, if competent, or the parent or guardian
of the client with respect to the client's habilitative
and medical progress.
Under the heading "Client Status and Annual Reassessment," Chapter 10F-3, FAC
[S. 3.14(1)] continues:
At least annually the habilitation plan committee shall
reassess and update the habilitation plan.
HRS manual 160-2, Client Services, devotes a chapter to reassessment and, in
section 5-3, states:
Each year, in the month of the habilitation plan date,
the plan must be reviewed in consultation between the
social worker and the client/guardian, if the project-
ed reassessment date is in a subsequent year. The
purpose of this review is to determine if the current
habilitation plan requires revisions (addenda).
(a) In preparation for this review the social worker
must gather annual reports from all service providers.
Reports from Developmental Training Programs must con-
tain the results of annual assessments. A summary of
assessments and goals which correspond to needs identi-
fied through the assessments should also be submitted on
the HRS-DS Form 3033, Page(s) C.
For ICF/MRs, the Code of Federal Regulations [42 CFR 442.400, Subpart G] re-
quires annual review of service plans and annual updating based on new evalua-
tions. In the section entitled "Annual review of resident's status," the
following statement appears [S. 442.422(a)]:
All relevant personnel of the ICF/MR, including person-
nel in the living unit, must jointly review the status
of each resident at least once a year and produce pro-
gram recommendations.
The same federal regulations also state that each client's evaluation and pro-
gram plans shall be "reviewed by a member or members of an interdisciplinary
professional team at least monthly with documentation of the review entered in
the resident's record" [42 CFR 442.434(b)].
In addressing planning and evaluation, the federal regulations also state [S.
442.456]:
-32-
Interdisciplinary teams consisting of individuals
representative of the professions or service areas
included in this subpart that are relevant in each
particular case, must--
(a) Evaluate each resident's needs;
(b) Plan an individualized habilitation program to
meet each resident's identified needs; and
(c) Periodically review each resident's responses
to his program and revise the program accord-
ingly.
Chapter 10D-38, FAC, which governs the licensing and certification of ICF/MRs
in Florida, reiterates this requirement [10D-38.15(3)]:
Programs and services and the pattern of staff
organization and function within the facility
shall be focused upon serving the individual needs
of clients and shall provide for:
(a) Comprehensive diagnosis and evaluation of each
client as a basis for planning programming and
management
(b) Design and implementation of an individualized
habilitation program to effectively meet the
needs of each client.
(c) monthly review, evaluation and revision by a
member or members of an interdisciplinary team.
1. All client programs including monthly progress
reports and necessary revisions, as submitted
by each service provider, must be reviewed
each month by the QMRP.
2. All client programs must be jointly reviewed
at least quarterly by the QMRP and a core team
consisting of, but not limited to, Social
Services, Behavioral staff, medical (as repre-
sented by the Registered Nurse), and direct
care personnel responsible for the care and
development of the client. This will serve
as the quarterly review as required by 42 CFR
456.380(c).
3. The QMRP is responsible for the monthly and
quarterly Active Treatment Plan review process
and may require the involvement of other per-
sonnel as he/she deems necessary.
The statutes, rules, and regulations that require annual service plan reviews
are essentially the same for local school systems, HRS districts, and ICF/MRs.
Differences appear in the requirements for semi-annual review of HRS habilita-
tion plans and for quarterly and monthly reviews of ICF/MR written plans. The
similarities and differences in requirements are represented in Figure 8.
-33-
FIGURE 8
LEGAL REQUIREMENTS FOR SERVICE PLAN REVIEWS
REQUIREMENT SCHOOL SYSTEM HRS HRS-ICF/MR
Annual Review (or X X X
more frequently,, (Any time during (Before or at an- (Before or at anni-
as appropriate) the calendar year niversary date of versary date of
or at anniversary client's admit- client's admission)
date of IEP.:i IEPs tance.
must be in effect
at the beginning
of each school
year.)
Semi-annual Review X
(By HRS social
worker)
SX
Quarterly Review (By an interdisci-
plinary team)
Monthly Review X
(By a member or
members of an in-
terdisciplinary
team)
As Figure 8 shows, school systems and HRS are legally required to review
their service plans at least annually. HRS personnel must also conduct more
frequent reviews, but these typically do not include school system represen-
tatives. The common requirement for annual reviews, however, enables locall
school systems, HRS facilities or districts, and ICF/MRs to coordinate thee
meetings if they choose. For example, IEPs must be in effect at the begin-
ning of each school year, but statutes and regulations do not specify that!
these be done at a particular time, such as May and June of the preceding /
school year. Both IEP and hab plan annual reviews may precede the anniversary
dates of these documents. Thus, the laws allow a local school district and an
HRS residential facility to coordinate dates of reviews to allow attendance by
both staffs and joint development of services.
Legal Bases for Student and Client Reevaluation
Local school systems, HRS, and ICF/MRs are also required to periodically "re-
evaluate" or "reassess" all PMH students or clients. SBER 6A-6.331(c) states
that school districts should conduct these reevaluations at least every three
-34-
years, or more frequently if conditions warrant.
In providing guidelines to local school systems, the DOE's Bureau of Educa-
tion for Exceptional Students reiterates the statutory requirements [A
Resource Manual for the Development and Evaluation of Special Programs for
Exceptional Students, Vol. III-A: Individual Education Programs, p. 42]:
Each three years the student must be re-evaluated.
As a result of the re-evaluation, the IEP may need
to be completely revised. Revisions may include
changes in exceptional student program assignment
and related services.
For HRS Developmental Services clients, Chapter 10F-3, FAC, does not
specify to what extent the client is to be reassessed. Under the
Section "Client Status and Annual Reassessment" [10F-3.14] the following
statement appears:
(2) When indicated, the habilitation plan committee
shall request updated diagnostic and evaluative (D&E)
information and suspend the formulation of the hab-
ilitation plan until such information is obtained.
This statement seems to imply that clients are to be reevaluated on an
individual basis, if the committee determines it necessary. HRS manual
160-2 defines "reassessment" as "a process which periodically develops,
through semi-annual review and annual revision of a client's habilitation
plan, a knowledgeable statement of current needs and past development for
each client" [HRSM 160-2 5-l.a]. Again, this definition does not directly
address client reassessment. Further in the same chapter, however, the
manual states that in preparation for annual reassessments, social workers
must obtain annual reports from all service providers and that "reports
from Developmental Training Programs must contain the results of annual
assessments [5-3.a]." HRS program standards require that service providers
conduct their own annual assessments and report the results of these as-
sessments to the social workers responsible for annual hab plan reviews.
For three-year reassessments of hab plans, social workers must also
obtain reports from all service providers and update clients' psychosocial
assessments [4-4.a(l) (2)].
Chapter 6A-15, FAC requires HRS to conduct a comprehensive reevaluation of
each exceptional student at least every three years. The rule states
[6A-15.14(1) (c) (2) (d)]:
The Department shall provide a comprehensive
reevaluation of each exceptional student at
least every three (3) years, or more frequently
if parent requires, if conditions warrant, or
if Department agency rules specify a more
stringent frequency; provided however, a medical
examination shall be performed annually, as
prescribed in Rules 6A-15.02 and 6A-15.06, FAC.
-35-
Federal regulations for ICF/MRs [42 CFR 442] specify that each resident be
reevaluated annually. In defining "active treatment," standard 42 CFR 435.
1009 indicates:
Re-evaluation medically, socially, and psy-
chologically at least annually by the staff
involved in carrying out the resident's
individual plan of care, including review of
the individual's progress toward meeting the
plan objectives, the appropriateness of the
individual plan of care, assessment of con-
tinuing need for institutional care, and
consideration of alternate methods of care...
The interpretive guideline for this standard reads:
The ICF-MR staff and outside professional
team members who work with each resident
must reassess the resident's program pro-
gress, and need for continued institutional-
ization. This must be done annually or at
more frequent intervals if the resident's
progress (or failure to progress) indicates
a need for reevaluation.
Chapter 10D-38 of the Florida Administrative Code expands these requirements
[10D-38.16(5)]:
Individual evaluations of clients shall:
(a) Commence within 90 days prior to the
client's admission to the ICF/MR;
(b) Be conducted at least annually;
(c) Be based upon the use of reliable,
written and valid instruments whenever
such tools are available. If not avail-
able, the facility has the responsibility
to develop reasonable assessments.
(d) Provide the basis for prescribing an
appropriate program of learning experiences
for the client.
For school systems and HRS districts, these statutory and agency require-
ments suggest the possibility of cooperative planning and sharing of
evaluations. Because these reevaluations are used to develop new service
plans, both agency personnel and PMH students should benefit from a
coordination of evaluation instruments and activities and the sharing
of evaluation results. The statutes and rules do not clearly define
what constitutes reevaluation and reassessment, and school systems and
-36-
HRS variously interpret these terms. These differences in interpretations
have resulted in different approaches to reevaluation and sometimes, in mis-
understandings. Both the statutes and agency requirements allow school
districts and HRS to reevaluate PMH students cooperatively, however. For
example, although chapter 10F-3, FAC lists intellectual assessment instru-
ments to be used in initial HRS evaluations of potential clients, it does not
require that these same instruments be used for subsequent assessments. HRS
manual 160-2 states [3-2.c.(1)(b)]:
For purposes other than eligibility determina-
tion, any test may be used that professional
judgment dictates, including intellectual as-
sessment instruments not in the above list.4
HRS regulations thus allow HRS personnel to choose from other assessment
instruments for their annual hab plan reviews. In discussing the Evaluation/
Goal pages of the habilitation plan form, the same manual states [4-5.b(l)]:
In the left hand column, the assessment tool
used and the applicant/client's present level
of functioning are stated in readily under-
stood terms. "Assessment tool" in this context
means a written procedure, a test, a behavioral
inventory, a developmental checklist, an inter-
view questionnaire, etc. The main criterion of
an assessment tool in this context is that the
method used to determine the client's present
level of functioning should be able to be re-
peated to demonstrate progress or lack of it.
Only for ICF/MRs, whose regulations require new batteries of evaluations every
year, does the coordination of assessments present a problem. Staff members
of these facilities, however, recognize the differences between their require-
ments and those of local school districts and are prepared to meet federal and
state requirements for evaluation that exceed those required of local school
districts and other HRS facilities. School districts that do administer new
batteries of tests annually may want to take advantage of the opportunity to
coordinate evaluation activities with ICF/MRs located in those districts.
Figure 9 summarizes the similarities and differences among the requirements
for reevaluation of students/clients.
With the exception of one assessment instrument, the Perkins-Binet Test
of Intelligence for the Blind and Visually Impaired, 1978, the list appearing
in Client Services is the same as that in Chapter 10F-3, FAC: Stanford Binet
Form LM; Wechsler Adult Intelligence Scale; Wechsler Intelligence Scale for
Children--revised; Wechsler Preschool and Primary Scale of Intelligence;
Bayley Scales of Infant Development; Cattell Infant Intelligence Scale;
Columbia Mental Maturity Scale; McCarthy Scales of Children's Abilities;
Leiter International Performance Scale; Haptic Intelligence Scale for the
Adult Blind; Hiskey-Nebraska Test of Learning Aptitude (for the deaf).
-37-
FIGURE 9
REQUIREMENTS FOR STUDENT AND CLIENT REEVALUATION
PUBLIC SCHOOLS
HRS DEVELOPMENTAL SERVICES
RESVLUAION F EG{ ECEPIO
REEVALUATION OF EACH EXCEPTIONAL
STUDENT AT LEAST EVERY THREE YEARS
SBER 6A-6.331(c)
The district shall provide a reevalua-
tion of each exceptional student at
least every three (3) years, or more
frequently if conditions warrant; pro-
vided, however, a medical examination
shall be performed annually, as pre-
scribed in Rule 6A-6.3015(3)(d), FAC.
P.L. 94-142
A 121 a. 534 Reevaluation.
Each State and local educational agency
shall insure:
(a) That each handicapped child's
individualized education program is
reviewed in accordance with 121 a.
340-121 a. 349 of Subpart C, and
(b) That an evaluation on the child,
based on procedures which meet the
requirements under 121 a. 532, is
conducted every three years or more
frequently if conditions warrant or if
the child's parent or teacher requests
an evaluation.
Neither state nor federal statutes
define reevaluation.
ANNUAL REASSESSMENT OF HABILITATION PLANS
Rule 10F-3.14, FAC
(1) At least annually the habilitation plan
canmittee shall reassess and update the
habilitation plan.*
(2) len indicated, the habilitation plan
committee shall request updated diagnostic
and evaluative (D&E) information and
suspend the formulation of the habilitation
plan until such information is obtained.
*Chapter 10F-3 does not indicate whether
reassessment of a habilitation plan also
means reassessment of the client.
REASSESSMENT OF HABILITATION PLANS EVERY
THREE YEARS
HRS Manual 160-2(5-4): Reassessment by the
Habilitation Planning ccrmittee.
The Habilitation plan must be reassessed by
the HPC at least every three years. (Refer
to paragraph 4-3)
a. In preparation for the meeting, the so-
cial worker must:
(1) Gather reports from all service provid-
ers (Refer to paragraph 5-3a).
(2) Update the previous psychosocial
b. Invitation of HPC members may be the re-
sponsibility of social worker or the D&E
chairperson at District option.
ANNUAL REEVALUATION OF IHE CLIENT
Interpretive guidelines for 45 CFR 249.13
Standard 435.1009
Re-evaluation medically, socially, and
psychologically at least annually by the
staff involved in carrying out the resi-
dent's individual plan of care, including
review of the individual's progress toward
meeting the plan objectives, the appro-
priateness of the individual plan of care,
assessment of continuing need for insti-
tutional care, and consideration of
alternate methods of care.
Interpretive Guideline for Standard
435.1009
The ICF/MR staff and outside professional
team members who work with each resident
must reassess the resident's program pro-
gress and need for continued institu-
tionalization. This must be done annually
or at more frequent intervals if the
resident's progress (or failure to pro-
gress) indicates a need for reevaluation.
Rule 10D-38.16(5) FAC
Individual evaluations of clients shall:
(a) Ccmmence within 90 days prior to the
client's admission to the ICF/MR;
(b) Be conducted at least annually;
(c) Be based upon the use of reliable,
written, and valid instruments whenever
such tools are available. If not
available, the facility has the respon-
sibility to develop reasonable asses-
sments;
(d) Provide the basis for prescribing an
appropriate program of learning experi-
ences for the client.
HRS ICF/MRs
In order to coordinate the mandated three-year reevaluations of other HRS
clients, public school and HRS staffs will need to: (1) reach agreement on
assessment dates (perhaps in conjunction with coordinated dates of annual
reviews of service plans); (2) obtain parental permission to release evalua-
tions; and (3) establish procedures for sharing the assessments. School
districts interested in helping HRS integrate educational service goals into
hab plans and encouraging program continuity will want to cooperate with HRS
personnel who request evaluation results on PMH students.
Participants in Service Plan Reviews
Federal and state laws delegate the responsibilities for the development of
service plans to the agencies responsible for the delivery of services. In
Florida, local school districts are responsible for planning and providing
educational programs for school-aged PMH students. HRS is responsible for
other aspects of care and training for these individuals.
Although the statutes specify--and separate--these responsibilities, HRS and
ICF/MR regulations imply or suggest that school system personnel participate
in hab plan reviews for both community and residential clients. For example,
Chapter 10F-3, FAC requires the following [10F-3.12(2) (b)]:
The habilitation plan committee shall be composed
of representatives of the following disciplines:
psychological, social, medical, and educational.
The individual responsible for the implementation
of the habilitation plan shall also be a member of
the committee. In addition, others working with
the client and the client's parents or guardian,
or the client if competent shall be invited to
join the committee. The composition of the hab-
ilitation plan committee will be subject to the
restrictions provided for in section 393.13(4)(m),
Florida Statutes, regarding confidentiality.
HRS manual 160-2 also states [4-12(b)(5); 4-9(e)]:
The specialists, including but not limited to
appropriate residential facility representatives
and public school instructional personnel, who
have been implementing the client's program must
be invited to be members of the Habilitation
Planning Committee.
For ICF/MR residents who attend public school it
is necessary to include the public school in-
structional personnel in the Habilitation Plan-
ning committee so that the school's IEP and the
facility ATP are coordinated. The ICF/MR and
-39-
public school will share responsibility for
implementation of goals in Section C1 and
portions of Section A.
Federal standards for annual reevaluation of ICF/MR clients also require the
participation of all those involved in carrying out a client's program [42
CFR 435.1009; Interpretive Guideline 4 for 45 CFR 249.10(d)(1)(v) (d)]:
Reevaluation medically, socially, and psycho-
logically at least annually by the staff in-
volved in carrying out the resident's individ-
ual plan of care, including review of the
individual's progress toward meeting the plan
objectives, the appropriateness of the individ-
ual plan of care, assessment of continuing need
for institutional care, and consideration of
alternate methods of care .
The ICF/MR staff and outside professional team
members who work with each resident must reas-
sess the resident's program, progress, and need
for continued institutionalization. This must
be done annually or at more frequent intervals
if the resident's progress (or failure to pro-
gress) indicates a need for reevaluation.
In defining the habilitation plan committee, the Florida rule for ICF/MR
licensure states [10D-38.02(23)(b)(1), FAC]:
A complete reassessment is required from each
professional discipline who has been serving
the client throughout the year, except for the
psychologist (refer to Chapter 10D-38.18(7), FAC,)
All service providers shall attend the annual
HPC meeting.
Although the 1982 revisions to Chapter 10D-38 eliminated the requirement
that educational staff attend quarterly reviews, both federal and state re-
gulations still require that external service providers submit periodic re-
ports to the ICF/MR staff. Interpretive Guideline 5 for Standard 249.13(c)
(ii) reads:
The parent facility has a written agreement with
an outside source which ensures that said outside
source will provide written, documented, periodical
1For categories within Sections A and C, refer to page 23.
-40-
reports on the adjustment of the resident.
The reports should include but are not
limited to the following:
(1) progress reports
(2) treatment plans
(3) short-term goals for treatment
(4) long-range goals for treatment
(5) discharge planning
(6) demonstrated need of the patient
for continued services
In Florida, the HRS Office of Licensure and Certification has interpreted the
federal requirement for periodic reports as "monthly." Chapter 10D-38, FAC
specifies [10D-38.15(3) (c) (1)]:
All client programs including monthly pro-
gress reports and necessary revisions, as
submitted by each service provider, must be
reviewed each month by the QMRP.
These regulations require that outside service providers (1) attend annual
service plan reviews for students residing in ICF/MRs; and (2) submit monthly
reports on students' progress to the ICF/MR administrator.
Although ICF/MRs sometimes view public school personnel as service providers,
federal and state laws establishing the educational responsibilities of local
school systems do not require school system personnel to attend meetings of
other agencies. Educators who are interested in developing complementary
programs and methodologies will want to cooperate with HRS and ICF/MR staffs,
whether or not the laws require them to do so. Shared planning implies
benefits for all involved. Public school teachers can became acquainted with
a student's home environment and total program of care; HRS and ICF/MR staff
can more easily coordinate their training activities with those of local
schools; and PMH students are more likely to receive integrated training and
educational programs. Thus, to the extent that local teacher union contracts
and other constraints permit, local school districts may want to recommend
that teachers or teacher representatives attend annual service plan reviews
and provide ICF/MRs with documentation needed to meet state and federal
certification requirements for these facilities.
Figure 10 lists those individuals who are required to participate in service
plan reviews. Figure 11 summarizes the statutory requirements for service
plans and service plan reviews and illustrates the large number of similar-
ities in requirements for local school districts and HRS. The "Comments"
column points out areas in which statutes, rules, and regulations differ.
-41-
FIGURE 10
REQUIRED PARTICIPANTS IN ANNUAL SERVICE PLAN REVIEWS
ANNUAL REVIEW OF IEPS
BY THE
LOCAL SCHOOL DISTRICT
ANNUAL REVIEW OF HAB
PLANS BY HRS DEVELOP-
MENTAL SERVICES
ANNUAL REVIEW OF HAB
PLANS BY ICF/MRS
________________________________ .1
Participants:
v Representative of the local school district
e Teachers)
t Parents)
* Student, when appropriate
o Other individuals at the discretion of the
parent or district school system
o A member of evaluation team or someone
knowledgeable of the evaluation procedure
and results if the student has been
evaluated for the first time [P.L. 94-142
Regulations, 121a.344; SBER 6A-6.331]
Participants:
o The agency primarily responsible for the
delivery of services
o The client's parents or guardian
o The client
[P.L. 95-602, 112.(b)]
* The department (HRS) following consultation
with the client, if competent, or with the
parent or guardian of the client
[S. 393.065(2)(e), F.S.]
* The habilitation plan committee [Rule
10F-3.14(1), FAC] This committee shall
be composed of representatives of psycholo-
gical, social and educational disciplines,
plus the individual responsible for the
implementation of the habilitation plan
[10F-3.12 (2) (b)]
Participants:
* Staff involved in carrying out the resi-
dent's individual plan of care [42 CFR
435.1009(d)]
* ICF/MR staff and outside professional team
members who work with each resident
[Reference 45 CFR 249.10(d)(1)(v)(D)]
* All service providers [Rule 10D-38.02(23)
(b) (1), FAC]
* Public school instructional personnel
[HRS manual 160-2, 4-9(e)]
-42-
I
FIGURE 11
STATUTORY REQUIREMENTS FOR SERVICE PLANS AND SERVICE PLAN REVIEWS
STATUTORY REQUIREMENT SCHOOL DISTRICT HRS HRS ICF/MR COMMENTS
A written service plan for each X X X
student or client
Standard form for service plan X X
Service plan to include:
Long-term (annual) goals X X X
Short-term objectives written X X X
in measurable terms
Short-term objectives written X X If short-term objectives on IEPs
in behavioral terms (or other are not written in behavioral
terms that terms, ICF/MR staff must rewrite
can be them to comply with federal
measured) regulations.
A list of services to be X X X
provided
A time-line for accomplishing X X X
goals and objectives
Periodic Review of Service Plans
Annual X X X
Semi-annual X
Quarterly X
e Monthly X ICF/MRs must obtain monthly
reports on student progress
from all service providers;
school districts are not re-
quired to provide documentation.
________________________ __ _____ L________ ___________
FIGURE 11, CONTINUED
STATUTORY REQUIREMENT SCHOOL DISTRICT HRS HRS ICF/MR COMMENTS
Agency staff to be responsible X X X
for service plan review
Periodic Reevaluation or Reassess- ICF/MR regulations need not con-
ment of each student or client flict with public school require-
* Annually X* X ments, since federal statutes
mandate that ICF/MRs be respon-
sible for meeting this require-
ment.
* At least every three years X
Participation by outside service The Federal Code of Regulations
providers: [42 CFR 442.400, Subpart G] re-
* Required attendance at service X X quires all service providers to
plan reviews attend annual service plan re-
views. Chapter 10F-3, FAC
requires that educational person-
nel serve as representatives on
habilitation plan committees.
* Invited attendance at service X X X
plan reviews
* Written accounts of student or X HRS requirements for reports from
client progress service providers reflect acency
regulations rather than legal
mandates. [HRS manual 160-2, 5-3;
5-4] Federal ICF/MR guidelines
and the Florida Administrative
Code [Interpretive Guidelines for
45 CFR 249.13; Rule 10D-38.15,
FAC] require documented, periodic
reports from all service pro-
viders.
*Rule 10F-3.14(1), FAC requires annual reassessment and updating of each client's habilitation plan;
client reassessment is not directly addressed.
CHAPTER 3
DOCUMENTS USED IN SERVICE PLANNING
Florida Statutes [S. 393.065(2)] and State Board of Education Rules [6A-6.331(3)]
require that local school districts and agencies providing services through
HRS develop plans for each PMH student prior to delivery of services. As
specified in the legal mandates, the plans are to include statements of planned
services and programs. These statements are to be based on individual needs
identified through formal assessment or evaluation. The written plans serve
as the basis for delivery of programs and services to all school-aged PMH
students.
The document school districts use to plan and manage programs is the Individual
Educational Program (IEP). After the IEP is developed, classroom teachers and
therapists write detailed plans for PMH students outlining instructional se-
quences to be followed. These follow-up plans are referred to as implementa-
tion plans.
Agencies providing services through HRS plan and authorize services for PMH
clients through habilitation plans (hab plans). HRS also requires service pro-
viders to develop implementation documents. The implementation plan required
for PMH clients aged 5 through 18 who reside in ICF/MRs is referred to as an
Active Treatment Plan (ATP). HRS requires other implementation plans for other
clients. Individual Program Plans (IPPs) are written for PMH clients age 21
and older who attend Developmental Training Programs. For PMH clients from
birth through age 5 and from 18 to 22, HRS agencies are required to develop IEPs.
The IEPs developed by HRS and those developed by school districts vary in the
level of specificity required.
School District IEPs
By the mid-1970s, school districts in Florida had begun to implement procedures
to develop educational plans for handicapped students enrolled in exceptional
student programs. IEPs were written to designate the services and the in-
struction to be provided to the student in the special setting. In the early
years of implementation, IEPs often replaced daily lesson plans and, in some
cases, the report card. As the required procedures for IEPs were fully im-
plemented, the focus progressed from that of an instructional tool to a man-
agement tool. The IEP became the means of defining the handicapped student's
needs and the educational program to be provided to meet those needs. Today,
some instructional personnel serving handicapped students use the IEP as an
outline for instruction and as the framework for developing lesson plans or
implementation plans.
In 1980, the Florida Department of Education, Bureau of Education for Excep-
tional Students, funded a project to develop a resource manual (Vol. III-A:
Individual Educational Programs) to assist state and local agencies in devel-
oping, evaluating, and improving the quality of IEPs. Although no IEP format
has been adopted for statewide use, a sample format was presented in the
resource manual. Some school districts have adopted or revised the form;
-45-
others have developed their own formats, which include, all the components
required by SBER 6A-6.331(2) (b). Figure 12 on pages 48 and 49 shows the
sample format that appears in Vol. III-A.
IEP Components
By definition, an IEP must be a written document that addresses the follow-
ing components:
Special education (or exceptional education) assignments. Any program to be
provided to the PMH student that involves significant adaptations in curric-
ulum, methodology, materials, equipment, or environment should be identified
and listed. This may include speech therapy, occupational therapy, physical
therapy, adaptive or specially designed physical education, orientation and
mobility training, and classroom instruction.
Related services. Any appropriate service in addition to instruction re-
quired for the PMH student to benefit from special education, such as trans-
portation; diagnostic and evaluation services; psychological services;
social services; guidance; student counseling; parent counseling; job train-
ing; job placement; school health services; food services; medical services
for diagnostic or evaluation purposes; braillists; typists and readers for
the blind; interpreters; specialized materials and equipment; and therapeutic
recreation, should be addressed.
Participation in regular education programs. Statements describing the PMH
student's participation in basic or vocational education, if any, should
record the student's time in the program (total number of hours and minutes
per week or the percent of time per week) and the organizational pattern of
the instruction.
Anticipated initiation date. The projected date(s) on which the IEP and each
program and related service specified in the plan are expected to begin
should be entered.
Anticipated duration date. The projected date(s) on which the IEP and each
program and related service specified in the plan are expected to end are
to be documented.
Present levels of educational performance. Statements of the PMH student's
performance, as appropriate, in areas including but not limited to pre-aca-
demic or academic, speech and language, sensory (auditory, visual and tac-
tile), accommodation, social, motor, self-help, emotional maturity, physical,
and pre-vocational or vocational areas, as well as a statement regarding
specially designed physical education, are to be provided. The statements
are to include appropriate information on demonstrated skill mastery, grade
levels, or performance in terms of the student's special education needs.
These statements may include a description of both in-school and out-of-school
behavior as relevant.
Annual goals. Statements reflecting a reasonable expectation of what the
student can achieve at the end of one year are to be documented. Annual goal
statements specify expected student performance, as appropriate, in areas
including but not limited to pre-academic or academic, speech and language,
social, sensory, notor, accommodation, self-help, emotional maturity, physical,
pre-vocational or vocational areas, and specially designed physical education.
Annual goals should include statements of expected skill mastery or performance
in terms of the student's special education needs. Goal statements may be
-46-
formulated addressing both in-school and out-of-school behavior as revelant.
Short-term instructional objectives. Statements that include the observable
skill, behavior, or performance to be demonstrated and the conditions under
which the PMH student will demonstrate mastery are to be specified at the time
the IEP is developed. Short-term instructional objectives are to be specified
for each stated annual goal. These objectives must be related to each other
and to the annual goal. The first short-term objective for each annual goal
is to be a reasonable learning step based on the present level of educational
performance. All short-term instructional objectives for the current IEP
should be written at the IEP meeting.
Evaluation criteria, procedures, and schedules. Each short-term instructional
objective must be accompanied by statements that identify:
1. the objective, prestated criterion to be used in
determining mastery/nonmastery of the short-term
instructional objective;
2. the test, measuring instrument, or systematic data
collection device that will provide a direct measure
of skill performance and mastery; and
3. data for administering the devices or collecting skill
performance data.
Signatures of participants. All persons attending the IEP meeting are to sign
the IEP document to indicate their presence at and participation in the meet-
ing.
The exact structure of the IEP form and the length of the document depend on
the amount of detailed information the school district chooses to compile.
For most of the items required in an IEP, the regulatory language is suc-
cinctly stated and self-explanatory (e.g., initiation and duration dates;
signatures of participants). Documentation for these items is highly con-
sistent among districts. The statutory terms covering some of the components
are general, however, and thus open to various interpretations. Among the
components with the widest range of interpretation are present level, annual
goal, and short-term objectives. Thus, statements of present levels and
annual goals may range from vague descriptions of broad categorical skills
(e.g., "completely dependent on others in areas of self-help skills") to
behaviorally stated, observable skill performance (e.g., "can self-feed
blended foods using spoon that has adaptive handle with 40% spillage").
Short-term objectives are also stated in a variety of ways. Some districts
select the key skills the PMH student is to master in proceeding toward
stated goals as the short-term objectives. Other districts consider state-
ments of percentage increase on assessment tests or mastery of given numbers
of skills within a sequence to be short-term objectives.
Regardless of the format the school district chooses, the IEP must be reviewed
and updated at least once a year. The plan may be reviewed and revised more
frequently, either to fulfill time-lines established in the IEP or at the
request of the parent, teacher, or other service provider.
-47-
FIGURE 12
Student Name
Student ID# DOB
Current Assignment
EXCEPTIONAL EDUCATION ASSICNMENT(S):
FLORIDA
INDIVIDUAL EDUCATIONAL PLAN
INITIATION
DATE
DATES
Initial IEP /
Current IEP /
IEP Review /
ANTICIPATED
DURATION
PERSON RESPONSIBLE
(Location / Program / Organization / Time)
RELATED SERVICES:
EXTENT TO WHICH STUDENT WILL PARTICIPATE IN BASIC OR VOCATIONAL USE OF DOUBLE BASIC COST FACTOR FOR FULL-TIME STUDENTS:
EDUCATION: (Specify required special aids, services, or equipment)
Subject hours/% of time
Vocational Education
Physical Education Regular _Adaptive
IN ATTENDANCE AT IEP MEETING:
LEA Representative (Title: )
Parentss, Guardian(s) or Surrogate Parent(s)
Student
Teachers)
Evaluator(s)
Others)
Signature
Date
/
Signature Date
/
Subject
hours/% of time
FIGURE 12, CONTINUED
PERFORMANCE OR SUBJECT AREA:
PRESENT LEVEL:
ANNUAL GOAL:
Student Name
Student ID#
Exceptional Education Assignment
EVALUATION OF SHORT-TERM INSTRUCTIONAL OBJECTIVES
SHORT-TERM INSTRUCTIONAL OBJECTIVES
Evaluation Procedures
Criterion for Mastery and Schedule to be used Results/Date
School District Implementation Plans
Once an IEP has been developed and the student is assigned to and placed in
a special program, districts may develop implementation plans detailing the in-
struction. The student will have only one IEP, but each discipline providing
services may require a separate implementation plan. These implementation
plans establish the framework for the daily instruction and activities to be
conducted.
The plans may consist of a series of behavioral objectives arranged in a de-
velopmental sequence directly related to the short-term objectives and annual
goal specified on the student's IEP. The objectives or activities may be
originated by the teachers or therapists, or they may be taken from canver-
cially developed materials, including curriculum guides, checklists, and
skill charts.
A well-designed implementation plan provides a system for conducting daily
instructional activities, monitoring and evaluating student progress, modify-
ing instructional objectives and activities in keeping with short-term needs,
and providing periodic progress reports to parents and other school personnel.
Statements of specific media and materials to match each instructional step
may be included in the implementation plan.
Implementation plans may take the form of daily lesson plans, individualized
checklists, or specially designed forms developed by the school district. No
specific guidelines or document format have been adopted for statewide use.
Options for consideration are included in Vol. III-A. Figure 13 on page 51
shows a sample group implementation plan included in Vol. III-A.
HRS Habilitation Plans
In the early 1970s, HRS began to use hab plans to outline and authorize ser-
vice delivery to PMH clients. A hab plan is an individualized prescriptive
plan, developed by an interdisciplinary team, that outlines the client's
needs and authorizes the expenditure of funds for the provision of services.
Details for developing hab plans are found in several HRS documents, including
HRSM 160-2 (Client Services Manual) and the Pre-Service Training for ICF/MR-
Cluster Facility Staff.
The hab plan must be recorded on a special form (HRS-DS Form 3033) designed
by the HRS Developmental Services Program Office. The cover pages include
instruction sheets, and additional pages are to be used as needed to describe
evaluation results and projected goals. Information is to be recorded in 19
categories divided into 4 sections. Figure 14 on pages 52-58 shows the hab
plan form.
-50-
FIGURE 13
GROUP IMPLEMENTATION PLAN
Subject Area- Reading
The students will be able to:
Recite the 26 letters of the alphabet.
a)u
C a)
a)V
Cr a)
S.I -
FIGURE 14
DEVELOPMENTAL SERVICES PROGRAM HAB PLAN
DEMOGRAPHIC DATA
Current Hab Plan Date
Reassessed Date
Reassessed Date
Projected Full HPC Date
2. SS#
Mailing
3. Address
Guardian/
6. Next-Of-Kin
Address
Primary Disability:
Autism
Cerebral Palsy
Epilepsy
High Developmental Risk
Mental Retardation
4. Medicaid #
5. Date of Birth CA
County
9. Secondary Disability:
Legal Status
Eligible for Services:
State of
Residency
393, Florida Statutes
Public Law 95-602
Yes No
_ Yes No
Social Worker
HPC Chairperson
Current Residence Type
Recommended Residence Types: 1. 2.
Authorized Level of Care: Optimal /f Interim /7
Foster Care Group and RHC ICF/MR Level of Care
Minimal A
Moderate B
Intensive C
D
E
Level of Care
17. Approved Z= Denied /_7
UC Coordinator
Page 1 of Pages
HRS-DS Form 3:33A, Sep 82 (Obsoletes previous editions)
(StocK NumDer: 5746-OOA3033-8)
Page A
-52-
1. Name
Date
FIGURE 14, CONTINUED
Independent Living................................... 05
Semi-Independent Living.............................. 06
Family Home (parent, relative, guardian).............. 15
Family Home with additional support services.......... 16
Foster Home (adult) ................................. 20
Foster Home (adult) with additional support services. 28
Foster Home (adult) with specialized care
and/or training................................... 29
Foster Home (child) Family Care...................... 34
Foster Home (child) with additional support services. 35
Foster Home (child) with specialized care
and/or training................................... 33
Group Home-Family Care............................... 41
Group Home with additional In-Home support services.. 42
Group Home with specialized care and/or training..... 43
Residential Habilitation Center....................... 44
Adult Retarded Defendant Program...................... 51
Juvenile Retarded Offender Program................... 52
Cluster ICF/MR Developmental/Residential............. 61
Cluster ICF/MR Developmental/Institutional........... 62
Cluster ICF/MR Developmental/Non-Ambulatory........... 64
Cluster ICF/MR Developmental/Medical................. 65
Community ICF/MR Developmental/Residential........... 71
Community ICF/MR Developmental/Institutional......... 72
Community ICF/MR Developmental/Non-Ambulatory........ 74
Community ICF/MR Developmental/Medical............... 75
Sunland Training Center Non ICF/MR.................. 81
Sunland ICF/MR Developmental/Residential............. 82
Sunland ICF/MR Developmental/Institutional........... 83
Sunland ICF/MR Developmental/Non-Ambulatory.......... 85
Sunland ICF/MR Developmental/Medical................. 86
Regional Residential Center.......................... 91
Other HRS Non-Developmental Services Institution..... 92
Non-HRS Psychiatric Facility......................... 93
Nursing Home. ........................................ 94
Jail................................................. 95
Revised HRSM 50-3, Dated July 1, 1982
-53-
FIGURE 14, CONTINUED
MEDICAID INFORMATION SHEET
Name: Medicaid # Date:
I. Categorical Eligibility:
I.Q. Date of Test: I.Q. scores may fluctuate, but do not
effect services. The score is used only for eligibility determination.
Physical Handicap(s):
Behavioral Problem(s):
II. Client is SSI eligible and in need of:
1. Active ICF/MR Treatment in accordance/7__
with Chapter 10D-38, F.A.C. Physician or Psychologist
III. If II (1.), above is checked Level of Care Required (Refer to
Definition on reverse side of page)
1. Developmental/Residential.
2. Developmental/Institutional.
3. Developmental/Non-ambulatory.
4. Developmental/Medical.
IV. Self Administration of Medication:
(This item must be completed regardless of whether the client
takes medication at present or not.)
1. Capable of self-administration of medication.
2. Not capable of self-administration of medication.
Chairperson or Physician Signature:
V. If recommended placement is interim for this 12 month period, justify,
then specify optimal placement.
Page 2 of Pages
Page B
HPS-DS Form 3033B, Sep 82 (Obsoletes previous editions) Page B
(Stock Number: 5746-00B-3033-2)
-54-
FIGURE 14, CONTINUED
Instructions for Page B
1. This page will be used for all clients who are
mentally retarded.
2. For clients residing in ICF/MR, complete each
of the five categories.
3. For LTRC clients, complete each category except
category III.
4. For IFL clients, complete categories I and II.
5. For ICF/MR clients, a physician must sign
category II and IV.
Code 6: Developmental/Residential The client is fully ambulatory and capable
of following directions and taking appropriate action for self-preserva-
tion under emergency conditions. The minimum overall direct care staff
to client ratio is 1:2. (Waiver will allow up to a 1:4 ratio.)
Code 7: Developmental/Institutional The client is fully ambulatory but not
capable of following directions nor taking appropriate action for
self-preservation under emergency conditions and clients who are mobile
with mechanical devices; such as canes, walkers or wheelchairs. The
minimum overall direct care staff to client ratio is 1:2. (Waiver will
allow up to a 1:4 ratio.)
Code 8: Developmental/Non-ambulatory The client requires horizontal transport
and clients who are capable of mobility only with human assistance.
The minimum overall direct care staff to client ratio is 1:1.
Code 9: Developmental/Medical The client is in need of continuous medical/
nursing supervision for chronic health needs. The minimum overall
direct care staff to client ratio is 1:1.
-55-
FIGURE 14, CONTINUED
DISTRICT
DEVELOPMENTAL SERVICES PROGRATTHABILITATION PLAN
CERTIFICATE OF ELIGIBILITY
P. L. 95-602
Name SS# /Date
The above-named client has received an interdisciplinary evaluation and the results of the evaluation substantiate that
(I) The client is at risk of becoming developmentally disabled; the physician's statement is attached
(If this is checked "YES" it is not necessary to complete (II)through (VI).)
(II)' The client has a chronic disability which is attributable to a mental or physical impairment
or a combination of both
(III) Manifested before the person attained twenty-two years of age
(IV) Will likely continue indefinitely
(V) Will result in substantial functional limitations in three or more of the following
(areas of major life activity:
YES NO
YES NO
YES NO
YES NO
1. Self-Care
Eating-Drinking
Hygiene
Grooming
5. Mobility
Movement
Gross Motor Control
Fine Motor Control
2. Receptive and
Expressive Language
Receptive
Expressive
6. Self Direction
Interpersonal/
Family Relations
Initiative
3. Learning
Cognition
Retention
Pre-Academic Skills
Academic Skills
4. Economic Self-
Sufficienrv
Pre-Vocational/
Vocational Skills
Job Finding
Work Adjustment
7. Capacity for Independent Living
Housekeeping
Money Management
Health and Safety
Using Comnunity Resources
(VI) The individual's disability (does) (does not) reflect a need for a combination and sequence of special,
interdisciplinary or generic care, treatment, or other services which are either lifelong or of an
extended duration
(VII) The client is eligible.
YES NO
HPC Chairperson
FIGURE 14, CONTINUED
EVALUATION/GOALS
SS# Date
Evaluation
Goal
Page of Pages
HPS-DS Form 3033C, Sep 82 (Replaces iay 80 edition which may be used)
(Stock Numt>r: 574&.00C-3033-7
Page C
-57-
Name
1 _
I
FIGURE 14, CONTINUED
SIGNA'IURE PAGE
HPC Chairperson
Title
Date Social WorKer
Signature of Others Who Attended HPC Meeting:
Title Agency
Title Agency
Title Agency
Title Agency
Title Agency
Title Agency
Client
Parent/Guardian
Distribution List
Date Sent
P
Date Sent
Client
arent/Guardian
Reassessed
Case Manager Date
Reassessed
Case Manager Date
Home District
Date Sent
Residential Vendor
Date Sent
Others:
Name
Name
Name
Title Agency
Title Agency
Title Agency
The purpose of this habilitation plan is to identify and prescribe all
of the physical, social, emotional, and cognitive needs of the
client, without regard to the availability of the services or the
resources to fund them. The delivery of the services depends on
whether the services and the funds are available.
Page of Pages
Page D
HRS-DS Form 3033D, Sep 82 (Obsoletes previous editions)
(Stock Number: 5746-00>3033-1)
-58-
Name
Date
Date
Date
Date
Date
Date
Date
Date
Date
Name
Name
Name
Name
Name
Name
Date Sent
Date Sent
Date Sent
_ _~ _
HAB Plan Components
By definition, hab plans must address the following components:
Basic client identification information. This includes the client's name;
Social Security number; Medicaid number; address; date of birth and chronolo-
gical age; name and address of guardian; client's legal status; state of
residency; recommended residence type; ICF/MR level of care, if applicable;
and listing of the client's primary and secondary disabilities. This informa-
tion is generally available from the social worker assigned to the client by
the HRS district.
Statement of Eligibility. Indication must be recorded regarding the eligibil-
ity of a client for services, as determined by Chapter 393, F.S. and Public
Law 95-602. The chairperson of the Hab Plan Committee signs the signature page
of the plan indicating eligibility. The chairperson and a physician must also
certify that the client requires the ICF/MR level of care.
Evaluation of present performance level. Statements in various measurement
categories (e.g., psychological, psychosocial, medical, nursing, basic
academics) are to be written in readily understood terms that describe the
client's level of functioning. The statements are to reference the assessment
tool used, if applicable.
Identification of Annual Goals and Services Needed. Statements for each of
the measurement categories addressed in the evaluation section are to de-
scribe, in behavioral terms, the skill or functioning levels that the client
is expected to demonstrate within one year. The goal statements must relate
to the statements of present level. A listing of specific services that will
enable the student to achieve the goals may also be included.
Measurement Categories. Assessment is divided into four sections:
Section A: psychological, psychosocial, medical, dental,
nursing, physical therapy, occupational therapy, and
leisure time activities. These measurement categories do
not always use formal assessment instruments, nor do they
always include statements of goals for the client.
Section B: justification of residential setting and
long-range optimal plan. This section does not include
formal assessment instruments and client goals; rather,
it describes the client's needs in terms of physical
setting and eventual level of independence.
Section C: basic academics, self-care, daily living,
human growth and development, communication, social,
motor, and job-related skills. These areas are to be
addressed in terms of present levels and annual goals,
as appropriate for the student. Assessments and goals in
these skill categories may overlap. All information
recorded in this section is to be stated in behavioral
terms.
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Section D: ability to give consent. This section is
to indicate whether the student is able to give express
and informed consent on the hab plan.
Time-frame for accomplishment of specific goals. If a behavior is to be
mastered before the end of the year, a date for anticipated mastery must be
indicated.
Projected assessment date. This section projects a month and day for the
evaluation of the student's progress toward annual goals.
Signatures. All those attending the hab plan meeting must sign the hab plan.
The committee chairperson may attach copies of evaluation reports submitted
in conjuction with the development of the plan and the number of reports will
vary according to the number of categories in which the PMH client was asses-
sed.
A client's hab plan must be reviewed and revised at least annually. The
social worker must also review the plan at least every six months. For PMH
clients living in ICF/MRs, ATPs must be reviewed monthly. Additional reviews
for other PMH clients may be conducted as needed.
HRS Implementation Plans
HRS requires three separate implementation plans for different groups of PMH
clients. These plans are:
1. Active Treatment Plan (ATP)--required for
PMH clients who reside in ICF/MRs;
2. Individual Educational Plan (IEP)--required for
PMH clients from birth to age 5 and from 18
through 21 who are receiving services in
Developmental Training Programs or other similar
programs; and
3. Individual Program Plan (IPP)--required for PMH
clients over 21 who are receiving services in
Developmental Training Programs or other similar
programs.
Active Treatment Plans. After the hab plan for an ICF/MR client is completed,
a team of ICF/MR staff members1 must develop an ATP within 30 days of the
client's admission to the facility. Unlike the hab plan, the ATP has no re-
quired form. HRS simply encourages its districts and facilities to develop
IThe team must include the QMRP, a social worker, a registered nurse,
direct-care staff, and behavioral staff.
-60-
suitable forms that provide the required information. Figure 15 on page 62
shows a sample ATP form.
Through a series of short-term objectives, the ATP describes how the hab plan
is to be implemented with the PMH client. The ATP consists of behavioral
objectives that include statements of condition and behavior and criteria for
each annual goal on the hab plan. The short-term objectives are to follow a
logical, sequential progression from the client's present level of functioning
to the projected annual goal. Service providers may derive these sequences
through task analyses, or they may adopt or adapt them from developmental
checklists.
In addition to behavioral objectives, the ATP must include:
1. a description of the training methods and
techniques to be used;
2. documentation of consistently applied
training activities;
3. the staff persons responsible for conducting
the training activities;
4. the initiation and duration dates for service
delivery; and
5. the date the short-term objective is achieved.
IEPs and IPPs
The IEP and IPP are also plans that demonstrate how hab plans will be imple-
mented. Written only for HRS clients who are not receiving educational or
other services from public school districts, they serve the same function
as the implementation plans which may be developed by school districts for
school-aged PMH students.
The components of the plans school districts and HRS districts use are similar,
although some of the items vary in the annount of detail required. These items
include present levels, annual goals, and short-term objectives.
Figure 16 highlights the similarities in the requirements for school district
and HRS documents.
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FIGURE 15
ACTIVE TREATMENT PLAN
NAME:
SKILL AREA:
Implementation Date
Projected Completion Date
Habilitation Plan Short Term Objective Service Provider Actual Completion
Goal __(Name and Title) Date
FIGURE 16
SIMILARITIES IN SCHOOL DISTRICT AND HRS SERVICE PLANS
SCHOOL DISTRICT__ HRS DISTRICT
IEP IMPLEMENTATION HAB PLAN ATP
S_________ PLAN
Present
Level
Annual Goals
Short-Term
Objectives
Criteria and
Evaluation
Initiation
and Duration
Dates
Special
Education
statreent describing levels
of educational performance
in the following areas, as
appropriate:
pre-academic/academic
speech and language
social
sensory
motor
accommodation
self-help
emotional maturity
physical
prevocational/vocational
adaptive physical education
Statements of expected skill
mastery, grade levels, or
performance in the following
appropriate areas:
pre-academic/academic
speech and language
social
sensory
motor
accamodation
self-help
emotional maturity
physical
prevocational/vocational
adaptive physical education
observable, measurable steps
leading to annual goals
evaluation criteria
evaluation procedures (test,
instrument, etc.)
schedule for assessment
beginning and ending date of
IEP
beginning and ending date
for each program and related
service
Statement of amount of time
spent in speech therapy;
occupational therapy; phy-
sical therapy; classroom
instruction; orientation and
mobility training
not applicable
not applicable
hierarchy of
skills describ-
ing instruction
criteria
not applicable
not applicable
-63-
measurable statement of
behavior presently ex-
hibited in the following
assessment areas, as
appropriate:
basic academic, comunica-
tion, social
motor/physical/occupational
therapy
human growth and develop-
ment; self-care/daily
living skills; psycholo-
gical; psychosocial
job-related skills;
leisure-time activities;
physical therapy, medical;
dental; nursing
measurable statements de-
scribing expected skill
mastery in the following
areas as appropriate:
basic academic skills; com-
munication; social
motor/physical therapy;
occupational therapy;
coarunication; self-care;
daily living; human growth
and development; psycholo-
gical; psychosocial
job-related skills; lei-
sure-time activities;
medical; dental; nursing
not applicable
date for accomplishment of
goal if expected prior to
one year
date for reassessment of
Hab plan
checklist of recommended
placement
not applicable
hierarchy of
skills described
in behavioral
objectives
criteria and date
of mastery;
anticipated
completion date
beginning date
for implementa-
tion of objectives
not applicable
school districts and HRS agencies differ in the methods of assessment they use
and in the programs they conduct. The assessment information that school
districts collect and use in developing IEPs deals primarily with educational
performance. On the IEP, assessment data are usually summarized in brief
statements that describe the student's exhibited capabilities or demonstrated
skill levels. The present-level statements for a PMH student typically docu-
ment the student's level of ability in curriculum categories such as self-help.
The degree of specificity and the extent to which the statements are measurable
vary among the school districts.
HRS evaluation data on PMH clients relate to more than performance. The hab
plan includes sections for recording a client's present level in psychological,
psychosocial, medical, dental, nursing, and educational categories, all of
which must be stated in readily understood terms. With the exceptions already
noted, the statements should also cite the assessment tool used. Present-
level statements, which are recorded on the hab plan form in the column labeled
"evaluation," usually describe the client's behaviors and the limits of current
functioning.
Both the IEP and the hab plan address the need for accountability in planning.
If programs are planned and provided to meet a handicapped student's needs,
the student should benefit from the programs by acquiring new skills or, at
the very least, maintaining his or her performance level. Annual goals must
reflect reasonable expectations for a student's performance level at the end
of one year.
The annual goals on the IEP must indicate each skill or subject to be addressed.
Although the statutes require only that statements of annual goals be recorded,
Volume III-A, Individual Educational Programs recommends that they also describe
expected skill mastery, grade levels, or performance and be written in measur-
able terms. Schools and school districts vary, however, in the procedures they
use for writing goal statements.
Hab plans must have annual goal statements for each category in which the
client's needs have been identified. Annual goals are generally divided into two
types: client goals and service goals. Client goals, which describe skills
that the client is expected to perform or maintain, should be stated in behav-
ioral terms that enable the client's progress to be observed and measured.
Service goal statements, on the other hand, describe specific services the
client will receive and do not include measures of the client's progress.
Although the Developmental Services manual Client Services and ICF/MR regula-
tions contain stringent requirements for hab plan components, HRS districts
vary in their use of behavioral terminology in the writing of annual goals.
As HRS districts strive to meet these standards, consistency in goal writing
across districts should increase.
The IEP takes the educational planning for a PMH student one step further by
requiring short-term instructional objectives that sequence expected learning
outcomes. According to accepted definition, short-term instructional objec-
tives are to include the observable skill or behavior to be performed and the
conditions under which the student is to demonstrate mastery. The IEP must
also record the criteria, procedures, and schedules for measuring the stu-
dent's attainment of or progress toward mastery of short-term objectives.
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Hab plans do not include short-term objectives. Within 30 days after services
begin, HRS staff develop implementation plans that further define the client's
anticipated progress in educational areas, but only for those clients in
ICF/MRs or those not being served by the local school district. These imple-
mentation plans are to include both short-term objectives and the methods to
be used in reaching these objectives.
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CHAPTER 4
METHODS FOR COOPERATIVE PLANNING
The needs of PMH students are numerous and complex. These students usually
need extensive training in self-help, communication, motor skills, social
skills, pre-academics, academics, and prevocational/vocational skills, In
addition, PMH students often require medical, nursing, psychological, and
other types of therapeutic attention. Traditionally, both school districts
and HRS agencies have provided programs that address the broad range of PMH
students' needs. School districts and HRS agencies are also responsible for
cooperating in the delivery of services to meet these needs. This dual re-
sponsibility makes cooperative planning between school districts and HRS
agencies essential.
This chapter provides a discussion of options for coordinating the review
and revision of service plans for PMH students. These options are based on
the assumption that initial assessments, eligibility decisions, and hab plans
for most PMH clients of HRS are completed when these children are quite young
--before they enroll in public school programs. School districts then use
their own data and information from HRS to determine programs for which the
children qualify. Once students have been determined eligible, school
systems plan for the delivery of educational programs and services.
School districts and HRS agencies document the needs of PMH students on indi-
vidual service plans. The following four methods of cooperation, which
suggest procedures for coordinating the planning of services and programs for
PMH students through these service documents, represent varying combinations
of group interaction and written documentation. Following the descriptions
of the four methods are planning checklists that include premeeting activi-
ties, meeting activities, and post-meeting activities.
1. One meeting/one service plan. A joint meeting of repre-
sentatives from the school district, the HRS district
and HRS agencies, parents, and others who provide
programs for a PMH student to develop one service plan
that satisfies school district and HRS requirements.
2. One meeting/two service plans. A joint meeting of repre-
sentatives from the school district, the HRS district
and HRS agencies, parents, and others who provide
programs for a PMH student to develop an IEP and a hab
plan.
3. Two meetings with cross-representation/two service plans.
Two separate meetings, one of school district personnel
and a representative of the HRS district to develop the
IEP and a second of HRS personnel and a representative of
the school district to develop a hab plan.
4. Two meetings with shared written information/two service plans.
Two separate meetings, one of school district personnel to
develop an IEP based on school system data and information
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provided by the HRS district and a second of HRS
personnel to develop a hab plan based on HRS data
and information provided by the school district.
Method 1: One Meeting/One Service Plan
Implementing a cooperative method that focuses on one joint meeting of agency
personnel and the development of one unified service plan requires an excep-
tionally high degree of coordination and negotiation of responsibilities. At
the same time, this method is potentially the most integrated form of coopera-
tive planning for PMH students.
Conditions. This method might be used under the following circumstances:
1. A large precentage of the school district's PMH
students are housed in agency-operated, multi-
bed facilities.
2. Public school programs for PMH students are
located in one or several centers.
3. The school district employs staffing specialists
or program consultants who are responsible for
chairing planning meetings and who serve as school
district representatives.
4. Both agencies' philosophies include the use of
behavioral, measurable goals and objectives on
service plans.
PMH students living in multi-bed residential facilities generally receive
more HRS services than students living in their own, foster, or group homes
do. Since HRS is more deeply involved in the care and education of these
students, the coordination of services is extremely desirable in order to
avoid program duplication.
School districts that employ a staff person to direct the IEP process might
easily convert to a multi-agency process. The concentration of PMH students
in a few schools would automatically limit the number of school district per-
sonnel, but not the type of professionals involved in interagency procedures.
The fewer the number of staffing specialists, counselors, social workers, and
teachers involved, the less complicated the communication and organization
systems need to be.
Advantages of Method 1 might be:
for the student and parents--
1. documentation of complete and noncontradictory program
offerings to meet the needs of the student
2. improved communication between school districts and
HRS agencies regarding programs for a given student
3. reduction in conflicting programs
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4. fewer meetings for initial service plan development
5. an opportunity for parents to talk with all the service
providers at one time and to get an overview of the total
service plan for the child
for the school district--
6. an opportunity to develop a total service plan
for each student
7. fewer meetings for initial service plan development
8. an IEP that addresses related services in detail
9. opportunities to improve communication with other
service providers
for the HRS district/agencies--
10. an opportunity to develop a total service plan
for each PMH client
11. fewer meetings for initial service plan development
12. a hab plan that addresses educational services in
detail
13. opportunities to improve communication with school
system personnel
Potential advantages of this method of coordination center on the possibilities
for improving services to PMH students. Philosophically, this method conceives
of the student in his or her totality. This concept should lead to a desire
to develop a total program, one that includes complementatary and reinforcing
training in different settings. According to this premise, the student
would benefit the most from this method of cooperation.
The school district and HRS agencies would also benefit from a single meeting
that ensures participation by all required personnel for both agencies.
Staff members could thus obtain all the information required for documen-
tation on service plans, and both the school district and the HRS district
would have a complete and accurate service plan.
Fewer meetings would appear to be cost-effective, not only for the student
and parents, but for school district and HRS personnel as well. At present,
both school district and HRS personnel evaluate and assess students, plan
programs, and communicate with parents and other agencies. This duplication
of effort is costly in terms of time and dollars. Although considerable time
may initially be necessary to establish this model, ongoing costs would be
significantly lower than the costs of producing two documents and attending
two meetings.
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Disadvantages of Method 1 might be:
for the student and parents--
1. feelings of being overwhelmed by the large number of
professionals at the service plan meeting
for the school district--
2. difficulties in scheduling meetings at mutually
agreeable times
3. creation of a lengthy service plan containing infor-
mation considered nonessential to the school district
4. difficulties in resolving philosophical differences
for the HRS district/agencies--
5. difficulties in scheduling meetings at mutually agreeable
times
6. creation of a lengthy service plan containing information
considered nonessential to HRS
7. difficulties in resolving philosophical differences
Many parents and students would undoubtly appreciate participating in a
single multi-agency meeting. Some parents, however, might be overwhelmed
by the large number of professionals attending such a joint meeting.
Considering the legal requirements for representation at IEP and hab plan
meetings, 10 or more agency personnel could be present. The participation
of so many therapists, teachers, and administrators might make parents less
willing to participate. Furthermore, a technical discussion of diagnostic
information and prescriptive planning might confuse parents.
The potential disadvantages of Method 1 are the same for a school district
and for HRS agencies. Scheduling a joint meeting is the major difficulty,
with several factors adding to the problem. First, school districts typically
plan service delivery for the following school year in May or June. HRS
agencies schedule hab plan meetings throughout the year, with programs
beginning as soon as the plan is completed. Second, guidelines for the
development of IEPs and hab plans require participation by direct service
providers (e.g., teachers, therapists, direct-care workers) as well as other
persons related to the student's case (e.g., school district representative,
QMRP, social worker). Providing release time for direct-care personnel
is difficult economically and logistically. Often, substitutes who would
free service providers to participate in meetings are not available; even
when they are available, the money to pay support personnel is often limited
or nonexistent.
Many of the requirements for school system and HRS service plans are similar.
Most components--including time-frames, a list of participants, and services
-69-
to be provided--are common to both the IEP and the hab plan. Each plan in-
cludes specific information not required for the other, however. The IEP
must list related services to be provided, for example, and the hab plan
must contain items such as HRS funding sources and client eligibility for
Medicaid. Including all of these items would increase the length of the
service plan and add details that both the school system and HRS might con-
sider extraneous.
Another factor that could discourage the use of this method is the difference
in interpretation of service plan components. The use of one document would
require that school and HRS personnel interpret content requirements uniformly.
HRS agencies must specify goals and objectives in behavioral, measurable terms,
for example. A joint document would need to reflect this requirement.
Implementing Method 1
Premeeting activities. Concentrated planning is essential for implementing
the one meeting/one service plan method of cooperation. Both the school
system and HRS would need to analyze the legal and auditing requirements for
service plans and develop procedures to ensure that both agencies are in com-
pliance. Planning for one meeting requires that both staffs consider: (1)
the qualifications of the chairperson; (2) who will participate; and (3) time-
frames to be used for developing, implementing, and monitoring the service
plan. Before meetings are held, decision-makers from both agencies should hold
a planning conference at which they designate times for the entire series of
meetings and make a formal commitment to follow the schedule they have set.
Meetings involving public school administrators and staff may need to be
scheduled before or after school hours. In addition, the group will also want
to:
1. Determine who will chair the service plan meetings
(Co-chairpersons may be appropriate).
2. Determine information required and the individuals
responsible for contributing this information.
Similarities, differences, and nuances of required
information should be discussed so that the service
plan meetings focus on information that is beneficial
and purposeful for each agency.
3. Inform meeting participants of information requirements, the
form(s) to be used, and their reporting assignments.
4. Decide on the form or forms to be used and the informa-
tion to be recorded. Develop or collect these forms and
have them ready for each meeting.
5. Complete as much of the identifying information on the form(s)
(the student's name, address, program, social security
number, Medicaid number, and so forth) as possible.
6. Determine procedures for the release of staff to attend
the service plan meetings. School districts may be able
to use P.L. 94-142 or P.L. 89-313 funds to hire substitutes
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for teachers who attend meetings scheduled during
school hours.
Before joint meetings begin, combined inservice sessions for agency staffs
can help both groups become aware of current philosophical trends within
their own and the other agency. Such gatherings also allow individuals to
discuss differences in philosophies and decide how to handle differences in
approaches and points of view. Designated participants in the service plan
meetings will also benefit from joint inservice training that helps them
develop skills in writing goals and objectives that meet the requirements of
both agencies.
Meeting activities. Developing a single plan requires substantial coordina-
tion during the service plan meeting, since participants' comments and obser-
vations must be analyzed and synthesized into one document designed to meet
the needs of two groups of professionals. An effective plan can be produced
only if meeting activities are well managed and directed. Each meeting should
start promptly and end on time and the chairpersons should be capable of
facilitating discussions, reaching conclusions, and making recommendations
regarding programming. To help the parent feel more comfortable and willing
to participate, the chairpersons should:
1. Pair the parent with someone who will explain what is
happening, if this becomes necessary. This person
should be prepared to act as the parent's advocate
when needed.
2. Use name or desk tags and have participants introduce
themselves.
3. Avoid the use of jargon and explain terms that the
parent may not know.
4. Talk to the parent and ask participants to do the same.
5. Ask the parent for his or her opinion when appropriate.
One or more persons should be designated to record information discussed by
participants. To ensure group consensus on what is being recorded, the chair-
persons should ask that this information be read to the group at frequent
intervals.
Postmeeting activities. Following development of the service document, each
agency implements the plan in accordance with its own regulatory guidelines.
At this point, the programs will diverge. Exact procedures will differ, and
one agency's activities may overlap the other's. In such cases, both agencies
must consider the other agency's unique requirements. Agency procedures used
to develop implementation plans, monitor student progress, and communicate
progress may well be different. Some HRS agencies' regulations for these
procedures are more stringent than those of school districts. For example,
ICF/MR staff must regularly monitor client progress, write and review monthly
progress reports, and participate in quarterly meetings. School district
personnel responsible for implementing this model may want to encourage partic-
ipation in such activities in order to benefit PMH students.
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To help ensure postmeeting coordination, the co-chairpersons of the service
plan meeting and agency administrators will want to:
1. Establish a communication system among public school
teachers, agency administrators, and appropriate HRS
direct care staff.
2. Monitor the communication system between the agencies so
that problems or needs for changes can be quickly detected.
3. Determine how periodic documentation of the student's pro-
gress will be accomplished. Procedures should address the
purpose, frequency, format, and exchange of this documenta-
tion.
4. Determine which program modifications can be made by
teachers and HRS training level staff; decide which
changes need administrative approval and which ones need
team meetings.
5. Schedule periodic, face-to-face meetings among teachers
and HRS direct care staff to discuss students' progress,
communication problems, and program concerns.
Meeting Participants. School and HRS districts must invite specific individ-
uals to participate in the review and revision of service plans. These
people include:
1. the parents) of the student;
2. the student, if appropriate; and
3. the student's teachers, therapists, and other direct-care
service providers.
School districts must also involve:
4. a school district representative (to be
determined by the school district);
5. a person knowledgeable of the evaluation procedures,
if it is an initial referral; and
6. others, at the discretion of the parents or school
district.
HRS districts require the attendance of:
7. the hab plan committee chairperson (to be determined
by the HRS agency);
8. the social worker assigned to the student's case;
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9. a nurse, representing the medical professionals;
10. a physician, for initial placement in an ICF/MR facility; and
11. other service providers, as appropriate.
Method 2: One Meeting/Two Service Plans
A second method of coordinating the development of IEPs and hab plans
involves a joint meeting of school district and HRS agency personnel to
develop two separate plans. Each plan would provide the information needed
by the agency completing it. This model would require extensive coordination
but would also reflect a high level of cooperation.
Conditions. This model might be used under the following circumstances:
1. A large percentage of the school district's PMH students
are housed in agency-operated, multi-bed facilities.
2. Public school programs for PMH students are located in
one or several centers.
3. The school district employs staffing specialists or program
consultants who are responsible for chairing planning meet-
ings and who serve as school district representatives.
4. School district and HRS requirements for service plan
information differ only slightly.
As with Method 1, coordinated delivery of services and programs is most
likely to occur when PMH students reside in multi-bed facilities operated
under the auspices of HRS. Because both agencies' training programs for PMH
students center on communication and cognitive, motor, self-care, social, and
vocational skills, the need for cooperative planning is apparent. The skills
within these categories are enhanced by consistent follow-through and rein-
forcement. Again, joint meetings are more easily managed when the number of
participants is limited, as when students are grouped for instruction in
centers or selected schools. Rather than each principal, assistant principal,
guidance counselor, and other potential participant in the school district
receiving planning information, only those employed at PMH centers would need
inservice training in how to coordinate premeeting and meeting activities.
The employment of staffing specialists to manage the IEP process and serve
as school district representatives also makes joint meetings more feasible.
Methods 1 and 2 both require the commitment of school district resources
and a similar commitment from HRS; staffing specialists are generally more
aware of the continuum of programs and services available in a school
district and thus better qualified to commit resources.
Method 2 accommodates differences in interpretations of the legal require-
ments for service plans more than Method 1 does. Indeed, separate documents
may actually promote cooperative planning. Representatives of both agencies
may approach a joint meeting with more positive attitudes if they feel that
the two resulting documents are tailormade for each organization.
-73-
Pages
74-75
Missing
From
Original
and different information. Other meeting activities for Method 1 (refer to
page 71) are equally applicable to Method 2.
Postmeeting Activities. After the IEP and the hab plan are developed, each
agency would follow its own implementation procedures. The use of two docu-
ments implies a need for well-established and frequent communication between
the school district and HRS, in order to ensure coordination of program
delivery. The postmeeting coordination procedures listed under Method 1
(page 72) can also help ensure effective agency cooperation in the delivery
of programs.
Meeting Participants. HRS and public school districts must invite specific
individuals to participate in the review and revision of service plans.
These people include:
1. the parents) of the student;
2. the student, if appropriate; and
3. the student's teachers, therapists, and other direct-
care service providers.
School districts must also involve:
4. a school district representative (to be determined
by the school district);
5. a person knowledgeable of the evaluation procedures,
if it is an initial referral; and
6. others at the discretion of the parents or school
district.
HRS districts require the attendance of:
7. the hab plan committee chairperson (to be determined
by the HRS agency);
8. the social worker assigned to the student's case;
9. a nurse, if the student resides in an ICF/MR facility.
Method 3: Separate Meetings with Cross-representation/Two Service Plans
In a third method of cooperative planning, each agency holds its own service
plan meetings and is responsible for inviting representatives from other
agencies serving the student. This method does not require as much logisti-
cal coordination as Methods 1 and 2, but it does provide an opportunity for
agency coordination.
Conditions. This method might be used under the following circumstances.
1. PMH students live in a variety of settings, including foster
homes, group homes, and multi-bed facilities.
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2. PMH programs are conducted in a variety of public school
settings throughout the district.
3. School district representatives may not have administrative
authority to commit district resources.
When a large number of individuals are required to participate in service
plan meetings, substantial logistical problems may develop. For students
who are served in a variety of school settings or who live in multiple re-
sidential settings, the number of people who need to attend joint meetings
increases substantially. As service delivery spreads across facilities and
the number of staff increase, training, logistical coordination of programs,
and effective communication become more difficult.
The selection of a school district representative may also affect the imple-
mentation of this method. The DOE requires school districts to include in
their district procedures those persons who may serve as the LEA representa-
tive in the development of educational plans. This may be a representative
of the district school system, other than the student's teacher, who is
qualified to provide or supervise the provision of special education and is
empowered to commit district resources. When a school district representa-
tive attends a hab plan meeting, the person will not be required to commit
school district resources, but rather will be asked to provide information
about the student's educational program.
Advantages of Method 3 might be:
for the student and parents--
1. opportunities for cooperative planning with each agency
2. potentially a less-threatening environment for parents
for the school district--
3. service plans specific to the needs of the school district
4. easily handled logistical arrangements
5. latitude in the selection of the school district representative
for the HRS district/agencies--
6. development of service plans specific to the needs of the
HRS agency
7. easily handled logistical arrangements
Although service plans developed in separate meetings may be less compatible,
the attendance of representatives from the other agency at the meetings should
increase coordination. These representatives would provide information on
their agency's programs and services. Such communication encourages the de-
velopment of a plan that is compatible with the other agency's services.
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The position of the person representing the agency will also affect the
amount of coordination achieved. Supervisory personnel acting as representa-
tives might encourage the overall coordination of service provision, while
participation by direct-care providers might lead to cooperative planning of
instructional content and techniques.
The school district may also find logistical advantages to this method. An
IEP designed specifically for the district will record only information tai-
lored to the requirements of the public school system. Such a document will
be shorter, less confusing for personnel, and more economical to develop and
reproduce.
For many school districts, scheduling IEP meetings is time-consuming and com-
plex. Involving representatives from more than one agency might further com-
plicate the process. With cross-representation, a school district can benef:
from cooperative planning without creating additional logistical problems.
IEP meetings that focus on the student's educational program rather than on
the total service plan allow a school district to select a school district
representative who has direct knowledge of PMH students and their programs.
Similarly, the HRS agency will find two advantages to this method. First,
the hab plan would reflect only HRS requirements. Second, scheduling would
be less complicated than with methods 1 and 2.
Disadvantages of Method 3 might be:
for the student and parents--
1. lack of coordination and continuity of programs
2. separate documents that may not reflect the total services
to the student
for the school district--
4. the need to provide release time for school personnel attend-
ing hab plan meetings and the added cost of providing release
time for staff attending these meetings.
5. IEP and hab plan meetings scheduled too close together or
too far apart
6. delayed receipt of current hab plans
7. delayed or no communication regarding revisions in current
hab plans
8. failure of HRS representatives to attend IEP meetings
for the HRS district/agencies--
9. the need to provide release time for HRS agency personnel
attending IEP meetings and the added cost of providing
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release time for staff attending these meetings
10. failure of school representatives to attend hab plan meetings
11. IEP and hab plan meetings scheduled too close together or
too far apart
12. delayed receipt of current IEPs
13. delayed or no communication regarding revisions to current IEPs
14. failure of IEPs to meet HRS standards for the writing of goals
and objectives
Separate planning activities can easily result in disjunctive programs that
do not completely meet the needs of PMH students and thus impede individual
progress. Cross-representation can remedy this situation if the personnel
involved are well versed in the planning processes and well acquainted with
the needs of individual students.
Parents who must attend two meetings and approve two documents may not receive
a complete overview of the services planned for their child. To understand
their child's program, they must piece together information from two settings
and two documents. Parents who do this often identify gaps and redundancies
in service provision.
Several disadvantages of Method 3 are applicable to both school systems and
HRS. Agencies currently using this method have experienced difficulty in
providing release time for personnel attending meetings of the other agency.
Staff members who work directly with the students (e.g., teachers, therapists,
behavior program specialists, and residential training instructors) may have
the most relevant information to share. Providing release time for these
individuals can be extremely difficult, precisely because they are so closely
involved with students. Attempts to resolve this problem have included:
1. scheduling meetings during conference periods or during times
when students are not present;
2. providing substitutes;
3. sending supervisory or support personnel (e.g., a social worker,
staffing specialist) to the meetings; and
4. using supervisory or support personnel in the classroom.
Two other potential disadvantages of this method are the timing of meetings
and the sharing of service plans. If IEP meetings are scheduled to follow
hab plan meetings closely, copies of hab plans are usually not available
when the IEP meeting is held. Since it takes time for hab plans to be typed
and approved, distribution to other agencies can be delayed. Unless the
agency representative is familiar with the HRS programs for the student, par-
ticipants in the IEP meeting will find coordination difficult. Difficulties
can also arise when the two meetings are scheduled months apart. In such
instances, one agency may be incorporating or considering another agency's
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service plans at the same time that the second agency is revising these same
documents.
When separate meetings are held and separate documents developed, agencies
often do not feel responsible for involving or notifying others when they
revise their service plans.
HRS agencies will find one more disadvantage to this method. If HRS agencies
use IEPs to meet the requirements for educational goals on the hab plan
(Section C), HRS requirements for detailed information may not be met.
Because school districts have considerable flexibility in developing IEPs, the
specificity of goal statements and other information varies from school dis-
trict to school district and even from school to school.
Implementing Method 3
Premeeting Activities. Before the service plan meetings, each agency will
need to select representatives to attend the other agency's meeting. These
representatives should contact the other agency to arrange a mutually agreeable
time and location for each service plan meeting.
Meeting Activities. The school district and HRS hold separate meetings with
cross-representation. For each meeting, representatives should share assess-
ment information and other background and progress reports. Each representa-
tive should also inform the other agency of the programs and services the
student is receiving.
Postmeeting Activities. Following development of the two service plans, the
school district and HRS agencies must maintain communication regarding the
student's progress. They may use informal means (e.g., phone calls, visits,
and notes) or more formal channels (e.g., scheduled meetings, report cards,
structured progress reports). Such postmeeting communication is essential to
the success of this method.
Meeting Participants. For the IEP meetings, participants should include:
1. the school district representative;
2. the teachers) of the student;
3. the parents) of the student;
4. the student, if appropriate;
5. a person knowledgeable of the evaluation procedures, if it
is an initial referral;
6. an HRS representative; and
7. others at the discretion of the parents or school district.
For the hab plan meeting, participants should include:
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1. the hab plan committee chairperson;
2. the HRS social worker assigned to the student's case;
3. an HRS psychologist;
4. direct service providers;
5. a nurse, for students residing in ICF/MRs
6. a physician, for initial placement in an ICF/MR facility; and
7. a representative of the school district.
Method 4: Two Meetings with Shared Written Information/Two Service Plans
This method requires little cooperative planning or communication. It may,
however, help school systems and HRS agencies coordinate services and programs.
Conditions. This method might be selected under the following circumstances:
1. A majority of the PMH students receive limited HRS services and
programs.
2. School district and HRS philosophies and purposes for service
plans differ substantially.
PMH students who receive limited services and programs from HRS agencies
typically live with their own parents. Since many of these students require
only educational services, the school district may not need to coordinate
educational programs with HRS.
This method may also be appropriate for districts whose philosophies and
policies prohibit more extensive coordination. Although these districts may
eventually want to increase cooperation, they can begin by establishing
ccmunication through sharing service plans.
Advantages of Method 4 might be:
for the student and parents--
1. opportunities to participate in the planning activities of
both agencies
for school district--
2. service plans that meet the specific needs of the school district
for the HRS district/agencies--
3. service plans that meet the specific needs of HRS
If both the school district and HRS serve a PMH student, sharing documents
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permits each agency to be aware of the other's services. Shared information
might also be used to coordinate other programs and services.
Although school districts and HRS agencies using this method will face few
logistical problems, the lack of communication can hardly be described as an
advantage. The one major advantage of Method 4 is the development of service
plans tailored to the needs of each agency.
Disadvantages of Method 4 might be:
for the student and parents--
1. a lack of coordinated planning
2. separate documents that only partially represent the services
being provided
3. attendance requested at two meetings
for the school district--
4. meetings scheduled too close together or too far apart
5. delays in receiving current hab plans
6. delayed or no communication regarding revisions in current hab
plans
for the HRS district/agencies--
7. meetings scheduled too close together or too far apart
8. delays in receiving current IEPs
9. delayed or no communication regarding revisions in the current IEP
10. failure of IEPs to meet HRS standards for the writing of goals
and objectives
These disadvantages are discussed above, under Method 3.
Implementing Method 3
Premeeting Activities. The school district and HRS should promptly provide
each other with a copy of their respective service plans.
Meeting Activities. Each agency would schedule and conduct its own service
plan meeting and complete its service plan after reviewing the other agency's
plan.
Postmeeting Activities. The ongoing activities would be identical to those
discussed under Method 3.
Meeting Participants. Only those required by law to attend each of the two
separate service plan meetings would participate.
Personnel assigned to coordinate planning should find the checklists on the
following pages helpful in developing and carrying out appropriate procedures.
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METHOD 1: ONE MEETING/ONE SERVICE PLAN
CHECKLIST OF PROCEDURES
PREMEETING ACTIVITIES
Assign chairperson to student case.
Schedule necessary evaluations/assessments.
educational
speech
behavioral
physical therapy
occupational therapy
SNotify personnel responsible for program assessment of deadlines for
completion of reports.
Schedule date and time for service plan review.
Arrange appropriate setting for the meeting.
Invite parents to participate in the service plan review meeting.
letter
phone
Notify personnel in all agencies of date, time, and place of the meeting.
Duplicate and distribute necessary forms to personnel for premeeting
activities.
school
HRS
MEETING ACTIVITIES
Introduce all participants and describe their roles in providing ser-
vices to the student.
SProvide all necessary student identification information.
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Discuss briefly the purpose of the meeting and the service plan.
Review annual goals in existing service plan and progress made toward
accomplishment of the goals.
Discuss and document ongoing and newly identified needs of the student
in terms of: residential placement medical services educa-
tional/training programs
Determine and document annual goals for the student in categories of
residential placement medical services educational/ train-
ing programs
Determine and document agency to provide needed programs and services.
Project and document short-term objectives, criteria, and evaluation
procedures for educational/training areas, including pre-academic/aca-
demic speech and language/communication social sensory
motor/physical therapy/occupational accommodation self-
help/daily living/human growth and development emotional maturity/
psychological physical prevocational/vocational/job-related
skills special physical educational/recreation skills psycho-
social therapeutic visits
Discuss and document the least restrictive environment in which the stu-
dent's needs can be met.
Project and document the initiation and duration dates for each program
and service.
Obtain signatures of all meeting participants.
POSTMEETING ACTIVITIES*
Distribute copies of the service plan to representatives of all agencies
serving the student.
Distribute copy of service plan to the student and the student's parents.
Implement programs as specified on the service plan.
Develop implementation plans, as appropriate.
Monitor student progress toward mastery of objectives and goals.
Notify appropriate person if service plan appears to need modification.
Comnunicate regularly with parents and representatives of other agencies.
* Agencies will carry out most postmeeting activities independently.
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METHOD 2: ONE MEETING/TWO SERVICE PLANS
CHECKLIST OF PROCEDURES
PREMEETING ACTIVITIES
Assign chairperson to student case.
Schedule evaluation or assessments.
psychological
social
educational
speech
behavioral
physical therapy
occupational therapy
SNotify personnel responsible for progress.
Schedule date and time for service plan review.
Arrange appropriate setting for the meeting.
Invite parents to participate.
letter
phone
Notify personnel in all agencies of date, time, and place of the meeting.
school
HRS
Duplicate and distribute IEP forms to school district personnel for pre-
meeting activities.
Duplicate and distribute habilitation plan forms to HRS agency personnel
for premeeting activities.
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MEETING ACTIVITIES
Introduce all participants and describe involvement of personnel with
the student.
Discuss briefly the purpose of the meeting and the two service plans.
Provide all necessary student identification information for the school
district.
Provide all necessary student identification information for the HRS
agency.
Review annual goals and indications of student progress in the current
IEP.
Discuss ongoing and newly identified needs of the student in terms of
residential placement medical services educational/training
programs _
Determine annual goals for the student in specific areas of residential
placement medical services educational/training programs
Determine the agency to provide specific programs needed by the student.
Document present level and annual goal information relevant to the
school district.
Document present level and annual goal information pertinent to HRS pro-
grams to be provided.
Project and document short-term objectives, criteria, and evaluation pro-
cedures for education or training provided in school system programs.
Discuss and document on the IEP the least-restrictive environment in
which the student's education or training is provided.
Discuss and document on the hab plan the least-restrictive environment
in which the student's residential needs can be met.
Project and document the initiation and duration dates for each program
on both service plans.
Complete information requested on the IEP.
Complete information requested on the hab plan.
Have participants sign service plans.
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POSTMEETING ACTIVITIES
School District
SDistribute copies of the IEP to agency representatives and the student's
parents.
Implement programs as specified on the IEP.
SDevelop district-required implementation plans.
Monitor student progress toward mastery of objectives and goals.
Notify appropriate person in the school district and HRS agency of needed
modifications in the IEP.
Meet as necessary to revise the IEP during the implementation period.
Communicate regularly with parents and HRS agency representatives.
HRS District/Agencies
Implement programs on the hab plan.
Develop implementation plan (ATP) required by HRS.
Distribute copies of the habilitation and implementation plans to agency
representatives.
Distribute copy of the hab and implementation plans to the student's
parents.
Monitor student progress toward mastery of objectives and goals.
Notify the appropriate person in the HRS agency if the hab plan or imple-
mentation plan needs modification.
Meet as necessary to review and revise the service plans.
Communicate regularly with parents and agency representatives.
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METHOD 3: SEPARATE MEETINGS WITH CROSS-REPRESENTATION/TWO SERVICE PLANS
CHECKLIST OF PROCEDURES
PREMEETING ACTIVITIES
School District
Schedule date, time, and place for IEP meeting.
Notify and invite parents to participate.
Notify and invite school personnel.
Notify and invite HRS representative to participate.
Duplicate and distribute IEP forms to personnel for preplanning activ-
ities.
Request copy of current hab plan if one has not been previously provided.
letter
phone
HRS Agencies
Schedule necessary evaluations/assessments.
psychological
social
educational
speech
behavioral
physical therapy
occupational therapy
Notify appropriate personnel of deadlines for completion of reports.
Schedule date, time, and place for hab plan meeting.
Invite HRS personnel to participate.
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Invite parents to participate.
Invite school district representatives to participate.
Duplicate and distribute necessary forms to personnel for premeeting
activities.
MEETING ACTIVITIES
School District
Introduce all participants and describe their involvement with the stu-
dent.
Discuss briefly the purpose of the meeting and the IEP.
Provide all necessary student identification information.
Review annual goals listed on the IEP and discuss student progress.
Discuss ongoing and newly identified student needs for educational or
training programs, giving consideration to needs identified by HRS repre-
sentative.
Document needs on the IEP.
Determine annual goals for the student's education and training programs.
Project and document short-term instructional objectives, criteria, and
evaluation procedures for each annual goal.
Discuss and document related services needed by the student, giving con-
sideration to those provided by the HRS agency.
Discuss and document the least-restrictive environment in which the stu-
dent's educational needs can be met.
Determine and record dates for the student's programs and services.
Complete additional information requested on the IEP form.
Have participants sign the document.
HRS Agencies
Introduce all participants and describe their involvement with the stu-
dent.
Discuss briefly the purpose of the meeting and the hab plan.
Provide all necessary student information.
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Review annual goals and indications of student progress from the previous
hab plan.
Discuss and document ongoing and newly identified needs of the student
for residential setting, medical services, and educational and training
programs, giving consideration to needs identified by the school system
representative.
Determine and document annual goals for the residential setting _
medical services educational and training programs .
Discuss and document the least-restrictive environment in which the stu-
dent's needs can be met.
Project and document dates for the accomplishment of goals for service
delivery.
Specify persons or agencies responsible for delivery of programs.
Complete additional information requested on the hab plan.
Obtain signatures of meeting participants on the hab plan.
POSTMEETING ACTIVITIES
School District
Distribute copies of the IEP to school personnel.
Distribute copies of the IEP to the parents.
Distribute copies of the IEP to HRS representatives.
Implement programs indicated on the IEP.
Develop district-required implementation plans.
Monitor student progress.
Schedule interim IEP reviews that include an HRS representative.
Communicate regularly with parents and representatives of other agencies.
HRS Agencies
Request delivery of services and obtain signatures on the hab
plan.
Distribute copies of the hab plan to HRS personnel.
Distribute copies of the hab plan to parents.
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Distribute copies of the hab plan to school district representatives.
SImplement programs specified on the hab plan.
SDevelop implementation plans (ATP).
SMonitor and report student progress.
Schedule interim reviews of the implementation and hab plans.
SInvite school district representative to these meetings.
Communicate regularly with parents and representatives of the school
district.
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