The issue in developing initial IFSPs is how detailed the strategies should be, considering we don’t know the child and family that well. In addition, many states are struggling to meet the 45-day limit, and the pressure to develop strategies can result in too much assessment too early in the process. At eligibility determination, for children with potential delays, the question to answer is in or out? Developing strategies requires answering the questions Why doesn’t the child perform the skill and What has the family already done? This entry addresses what the statute says about strategies on the IFSP, what kinds of guidelines states are providing, and what my recommendations are.
A related issue is, if strategies must be on the IFSP, according to State rules, what does it take to change them?
There is a question about whether strategies should be developed and inserted on the IFSP between outcome selection and the initiation of services. In states where strategies are required to be described on the form, this is the usual place in the process where that would happen.
Statute and Regulations
Although most states have a place for “strategies” or “action steps” on their recommended IFSP forms, in fact the law does not specify that such things are required on the IFSP. It says the following:
“(3) a statement of the measurable results or outcomes expected to be achieved for the infant or toddler and the family, including pre-literacy and language skills, as developmentally appropriate for the child, and the criteria, procedures, and timelines used to determine the degree to which progress toward achieving the results or outcomes is being made and whether modifications or revisions of the results or outcomes or services are necessary;
“(4) a statement of specific early intervention services based on peer-reviewed research, to the extent practicable, necessary to meet the unique needs of the infant or toddler and the family, including the frequency, intensity, and method of delivering services;
“(ii) Method means how a service is provided.”
“Procedures” and “method” can be location, model of service delivery (e.g., consultation, direct), and so on. Nowhere does the law stipulate that task analyses, specific activities, or even routines in which to intervene must be documented on the IFSP.
If a form exists, with a space for documenting certain information, the rule or at least common wisdom is that that space must indeed contain information. Many states have therefore conditioned early interventionists, either by the form alone or by actual training, to insert strategies into the IFSP. For example, South Dakota implies that strategies must be on the IFSP, because it gives information about what to do when changing them ((http://www.doe.sd.gov/oess/Birthto3/word/APP_A_PAGE9.doc). A number of states imply that the IFSP must contain strategies by referring to linking “IFSP” and “strategies,” such as Florida’s policies: “Strategies on the IFSP indicate the activities that the family or caregivers will perform to support the child’s acquisition of basic skills needed to obtain the functional outcome and enhance development” ((http://www.doh.state.fl.us/AlternateSites/CMS-Kids/EarlySteps/EarlyStepsPolicy.pdf). Thes policies then do go on to refer to “initial strategies” that would be followed by “intervention activities and experiences that promote learning.” Vermont similarly discusses “IFSP strategies” (http://www.dcf.state.vt.us/cdd/pdfs/SPP_Part_C_12-02-05_Vermont_Final_R.pdf). Indiana discusses strategies that are “written into the IFSP” (http://www.in.gov/fssa/first_step/July2006_Best_Practice.html and http://www.firststepssoutheast.org/forms/bestpractices.pdf). Virginia similarly implies strategies on the IFSP but does acknowledge that “there may be more frequent changes in strategies as the Part C provider continues learning about the activity settings, routine…” (http://www.infantva.org/documents/pr-OrientationToPartC.pdf). Kentucky identifies assisting the team in developing strategies as a service coordination rule during the IFSP meeting (http://chfs.ky.gov/NR/rdonlyres/CA59E944-9947-415E-A83C-6545DB3BA09A/0/RES12PSCResponsibilitiesChecklist.pdf). Maine also mentions strategies in the context of this meeting (http://www.maine.gov/education/speced/cds/plan/cds_plan_submitted113005.pdf). Missouri, however, correctly points out, “Strategies/activities are optional” (http://dese.tekdevelopment.com/422.html).
Consider how much information we have about the child’s functioning at the conclusion of outcome selection. Theoretically, we know there are concerns (intake), we know the child is eligible, we know what the child’s performance is like during routines (assuming a decent needs assessment, such as a Routines-Based InterviewTM, has been conducted), and we know what the family wants as outcomes. What we probably do not know is (a) why the child is unable to do things the family has reported on during assessment and (b) what strategies the family has tried. For practical reasons—and in compliance with the federal law, for initial IFSPs, I recommend the following.
- Eliminate strategies from the form, leave that space empty, or put in minimal information (e.g., “emotional, material, and informational support). Expecting evaluators to capture enough child-functioning information to recommend strategies is asking much of them, considering the 45-day rush. Let them conduct their functional assessments once the rush to get the child in services is over. The assessments will be more valid.
- If it would be helpful to have further information, put in “consultation from ____.” Avoid “assessment from ____” to avoid having to get signed permission and having to write an assessment report.
- Once services have begun, obtain the consultation to understand why the child needs help and to receive suggestions about intervention.
- Develop strategies on the basis of input from any further assessment or consultation (i.e., those that occurred after the child was in services).
- Change strategies as needed, without reconvening the IFSP team or calling official meetings.
Should Strategies Be Documented?
Probably, but not on the official document, which unnecessarily burdens the team trying to meet the 45-day deadline. Functional, family-centered, routines-based strategies could be manifold and dynamic, so capturing them on paper might be problematic. Remember, the law does not require them.