DATE: February
8, 2005
TO: Wisconsin Birth to 3 Programs
FROM: Jean Nothnagel
SUBJECT: Identify
"Needed Medical and Other Services" in IFSP
In the most recent response regarding Part C compliance in Wisconsin, the Office of Special Education Programs (OSEP) determined that DHFS did not ensure that IFSP teams identified needed health and medical services, and the steps to secure these services, as required by 34 CFR 303.344(e) in 100% of IFSPs.
Please refer to the Part C citation:
Sec. 303.344 Content
of an IFSP. (a) Information about the child's status. (1) The IFSP must include
a statement of the child's present levels of physical development (including
vision, hearing, and health status), cognitive development, communication development,
social or emotional development, and adaptive development.
...
e) Other services.
(1) To the extent appropriate, the IFSP must include
...
(i) Medical and other services that the child needs, but that are not required
under this part; and
(ii) The funding sources to be used in paying for those services or the steps
that will be taken to secure those services through public or private sources.
(2) The requirement
in paragraph (e)(1) of this section does not apply to routine medical services
(e.g., immunizations and ``well-baby'' care), unless a child needs those services
and the services are not otherwise available or being provided.
and the HFS 90
citation:
HFS 90.10
...
(5) CONTENT. The IFSP may have several different sections that are completed
at various times throughout the process. All sections of the IFSP shall be maintained
in one file or binder. The parents shall be given a copy, the contents of which
shall be fully explained to the parents and kept current. The IFSP shall contain:
...
(d)
...
5. If appropriate, medical and other services that the child needs that are
not required under the Birth to 3 program and the steps that will be taken to
secure those services from public or private sources. This does not apply to
routine medical services such as immunizations and well baby care unless a child
needs those services and they are not otherwise available or being provided;
The Department of
Health and Family Services has revised the target from 90% to 100% compliance,
and has taken the following steps as OSEP was advised:
IFSP CHANGES
To achieve the required
100% compliance, programs must add a section to the IFSP, or amend an existing
section, that contains documentation that:
> 1) provides identification, if appropriate, of medical and other services that the family needs, but that are not required Early Intervention services, and the steps taken to link the family with the service and/or funding of the service,
or
2) contains comments
from the IFSP team discussion resulting in the finding that no medical or other
services are needed at the time of the IFSP. When no services are identified,
the comment section will confirm that IFSP teams discuss the appropriate need
for medical and other services, and will help assure 100% compliance.
This section of
the IFSP will be referred to as Needed Medical and Other Services for clarity
of implementation. Identifying other services that are not required by Part
C, and assisting families in making links to such services contributes to the
support of families in their efforts to achieve their child.s outcomes. Common
examples of other services are housing assistance; WIC referrals and child care
resources. Examples of medical services are immunization and well baby services
only when families have no current medical provider, or referral to medical
resources for concerns not met by existing providers.
SAMPLE
Richland County and Dodge County submitted samples of the IFSP section they currently use to document Needed Medical and Other Services. The half page sample from Richland County is found in attached to this memo. As with many IFSP sections, it is a table format, and includes a field for location, which is an option. The paragraph that introduces this section addresses the specific language of its purpose, and exclusions as directed in Part C. The Dodge County section (not attached here) is a full page table format, and carries similar introductory language. Both samples contain the needed elements for this section except for a field for comments as discussed above in #2. A box like the one that follows could be added to this section to ensure team consideration of needed services, when appropriate.
No medical or
other services identified / Comments from team discussion.
Alternatively, comments
could be entered into the table as it already looks, with instructions added
to the introduction that direct the team to comment in the table provided, similar
to the purpose of the box above, "Comments from team discussion must be entered
here when no medical or other services are identified." Please see adjusted
samples in this memo also.
CLARIFICATION
OF TERMS
The IFSP includes
many health and medical elements, including "health status" and "medical home."
Adding this Needed Medical and Other Services requirement may seem duplicative,
but there are distinct differences. "Health status" describes the child's current
condition, and/or history of the medical condition, and it may be found in the
intake and/or evaluation areas of the IFSP. "Medical home" or "Health care provider"
identifies individual physicians, medical clinics, or other health care professionals
who are responsible for routine or specialized medical care, and may be found
in the intake. "All About (child's name)", or evaluation sections.
Another section already
found in an IFSP may be referred to as "Other Services" which describes "Other
services the child and family are using that are not Early Intervention services."
In the initial IFSP this information is obtained from the family, and usually
does not include the role of the Birth to 3 program in linking families with
resources or identifying funding. When no new services are identified for the
Needed Medical and Other Services section, and the family has identified
current use of such services, use the Comment box to refer the reader to the
current Other Services as well as remarking on the team discussion.
In IFSP updates the
Other Services section can be used in conjunction with the Needed Medical
and Other Services section, as those identified services may become part
of the current services after Birth to 3 assists with linking the family to
resources.
Please note that
the IFSP must contain documentation of Needed Medical and Other Services
as appropriate and the steps taken to link families to such services, or comments
from the team discussion when no services were identified.
Attachment