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Documenting Coordinated Services in IEPs

Letter Head: Tom Torlakson, State Superintendent of Public Instruction, California Department of Education

March 13, 2013

Dear County and District Superintendents, Special Education Local Plan Area Directors, Special Education Administrators at County Offices of Education, Charter School Administrators, Principals, and Nonpublic School Directors:

ASSEMBLY BILL 114: DOCUMENTING COORDINATED SERVICES (BUNDLED SERVICES) IN INDIVIDUALIZED EDUCATION PROGRAMS TO COMPLY WITH THE INDIVIDUALS WITH DISABILITIES EDUCATION ACT REQUIREMENTS

On June 30, 2011, Assembly Bill 114, Chapter 43, Statutes of 2011, was signed into law. Under AB 114, several sections of Chapter 26.5 of the California Government Code (GC) were amended or rendered inoperative, ending the state mandate on county mental health agencies to provide mental health services to students with disabilities. With the passage of AB 114, it is clear that local educational agencies (LEAs) are now solely responsible for ensuring that students with disabilities receive special education and related services, including some services previously arranged for or provided by county mental health agencies. As LEAs arrange for the provision of related services, clarification has been requested concerning options through which LEAs may address individualized education programs (IEPs) that were developed following guidelines set by AB 3632 that included related services which were "bundled" together (similar to medication monitoring, Wraparound, and Day Treatment).

This document is intended to assist LEAs in facilitating the transition of coordinated or "bundled" services formerly provided by county mental health agencies (CMHAs) under state law prior to AB 114, to LEAs providing services authorized by the IDEA, and complying with IDEA requirements. Given that service provision requirements under the IDEA differ from those formerly specified in Chapter 26.5 of the GC prior to AB 114, it is likely that some prior service descriptions will need to be amended or entirely replaced with new service descriptions based on current law. This document discusses how some service changes are now appropriately described in a student’s (IEP). However, it must be emphasized that a blanket restriction on any particular service would be contradictory to the IDEA. The IEP team should develop the IEP based on the child’s unique needs and include related services that are necessary to assist the child in benefitting from special education.

The Individuals with Disabilities Education Act General Requirements for Documenting Related Services in Individualized Education Programs
  • Each related service is to be listed separately in the IEP and include the projected beginning date of each service, the anticipated frequency, location, and duration of each service (34 CFR 300.320[a][7]).
  • LEAs are not required to document the specific provider for a service in the IEP. A change in provider can be made at the discretion of the LEA as long as the services continue as stipulated in the IEP. While not required by law, LEAs are encouraged to inform a student’s parent or guardian whenever the student’s service provider changes.
Transition to Individuals with Disabilities Education Act Compliant Individualized Education Program

In some cases, IEP teams have documented related services as a "bundled" service in the IEP. In these cases, the LEA must un-bundle the individual services that are to be provided, and document each related service to be provided in accordance with 34 CFR 300.320(a)(7). It should be noted that both "Day Treatment" (as defined in Medi-Cal) and "California Wraparound" (as defined in statutes) contain services that may not be required under Part B of the IDEA. The table below provides an example of how a bundled service such as "Day Treatment" could be expressed as individual related services in an IEP. Day Treatment services are described in Title 9 of the California Code of Regulations, while Related Services are described in Title 34 of the Code of Federal Regulations.

Day Treatment Services Related Services
Therapeutic Milieu
  • Counseling Services
  • Rehabilitation Counseling Services
  • Behavioral Intervention Strategies*
  • Counseling and Guidance Services
Process Groups
  • Parent Counseling and Training
  • Psychological Services
  • Social Work Services
  • Behavioral Intervention Strategies*
  • Counseling and Guidance Services
Skill Building Groups
  • Parent Counseling and Training
  • Psychological Services
  • Social Work Services
  • Behavioral Intervention Strategies*
  • Counseling and Guidance Services
Adjunctive Therapies
  • Recreation Services
Psychotherapy
  • Psychological Services
Community Meetings
  • Social Work Services

*It should be noted that while "Behavioral Intervention Strategies" are not mentioned as a specific related service in 34 CFR 300.34, which does not provide an exhaustive list, the term does appear in the IDEA. See 20 U.S.C. 1414(d)(3)(B)(i) and 34 CFR 300.34(c)(10)(vi).

The next table provides an example of how a bundled service such as "California Wraparound" could be expressed as individual related services in an IEP.

Wraparound Services Related Services from 34 CFR 300.34
Direct 1:1 Emotional Support
  • Counseling Services
  • Psychological Services
  • Social Work Services
  • Behavioral Intervention Strategies*
  • Counseling and Guidance Services
Direct 1:1 Coaching
  • Counseling Services
  • Psychological Services
  • Social Work Services
  • Behavioral Intervention Strategies*
  • Counseling and Guidance Services
Intensive Behavioral Support
  • Counseling Services
  • Psychological Services
  • Social Work Services
  • Parent Counseling and Training
  • Behavioral Intervention Strategies*
  • Counseling and Guidance Services
Counseling/Therapy/Treatment
  • Counseling Services
  • Psychological Services
  • Social Work Services
  • Parent Counseling and Training
  • Behavioral Intervention Strategies*
  • Counseling and Guidance Services

* It should be noted that while "Behavioral Intervention Strategies" are not mentioned as a specific related service in 34 CFR 300.34, which does not provide an exhaustive list, the term does appear in the IDEA. See 20 U.S.C. 1414(d)(3)(B)(i) and 34 CFR 300.34(c)(10)(vi).

If you have any questions about this subject, please contact Renzo Bernales, Education Programs Consultant, Special Education Division, by phone at 916-327-3637 or by e-mail at rbernales@cde.ca.gov.

Sincerely,

Original signed by Fred Balcom. Hard copy of the signed document is available by contacting the Special Education Division's Director's Office at 916-445-4602.

Fred Balcom, Director
Special Education Division

FB:rb

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