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2011-2012 Answers to Questions about EA Procedures


Destroying IFSP Records Procedure
Tori Lindeman 6/15/12 With a request from a parent, can all the EA/ ISFP records be destroyed upon the child turning three years old? If so is there a specific form we use to document the request? Finally, do the on-line stored records get deleted as well?

Cindy Weigel

Megan Wolfe


The parent can request destruction if and only if the record is no longer relevant to provide educational services and no longer needed for audit/accountability purposes.  The child's record must be retained for 5 years for accountability and audit purposes (Part C Administrative Rule 120.416(3)). In summary, a district needs to honor a parent request only after the time period specified in 120.416(3) expires.  There is no circumstance when the EA records could ever be destroyed on the child's third birthday.

Destruction would include destruction of electronic records, if at all possible. Part C staff will be following ups IMS personnel to see how a request to destroy an electronic record is made by regions.


Give EA reports, etc. to a guardian ad litem
Jeanie Wade-Nagel 6/6/12 Can we give EA reports, etc. to a guardian ad litem without a release?
Cindy Weigel 6/6/12 Yes, for FERPA purposes, the guardian ad litem can access the child's records without parental consent in order to fulfill their duties [because they are serving as a "guardian" - see definition of parent in Rules]. Please note that this cannot be over-generalized to signing consents for the child. That is separate issue from "access to records."


AEA Part B representative at meeting

Cathy Ryba 5/1/12 Can an Early Childhood Specialist be considered the AEA Part B rep at meeting where that attendee is required if the ECS is in a position working with birth to three services only? (She has certification requirements for Spec Ed.)
Cindy Weigel 5/1/12

EA Procedures Manual page 6-12, Step 3 of “Stage 1: Prepare for the transition planning meeting” states that “The discussion of options includes whether the IFSP Team suspects a disability and if the family is interested in considering an FIE to determine eligibility for Part B special education services.  If so, the Service Coordinator arranges for Part B AEA special education staff to attend the transition planning meeting.”

The person that is referred to in this statement must be the AEA staff person who is assigned to Part B special education services.


Date Procedure for: Annual, Exit and Submitted IFSP

Vonnie Ross 2/9/12 When there is an Annual IFSP submitted first, and then an Exit IFSP next and finally an Initial IEP submitted all using the same date, how should this be processed in IMS since the Exit IFSP cannot be dated the same as the Annual IFSP and the Initial IEP has to be dated after the Exit IFSP?

Cindy Weigel

Dee Gethmann


A child with an IFSP can exit Part C at the annual IFSP meeting so the exit date and Annual IFSP date can be the same and should be the same if the child exits at their annual IFSP meeting.  You do not have to hold a meeting to exit the child so a child could have an Annual IFSP of one date and then exit the Part C service system after that date.  In this case, the exit date would not equal the Annual IFSP date.  Both are possible scenarios.  

Use the date of the IEP meeting for the Initial IEP.  If you cannot use the same date as the Initial IEP for the exit date from Early ACCESS, please use the day prior to the Initial IEP date.


"Other Service" Provider Documentation

Teresa Hobbs 1/11/12 Are "Other Service" providers required to document their log/notes on the web-IFSP?

Cindy Weigel

Meghan Wolfe


"Other Service" providers are required to keep documentation. There are 3 possible choices for adding "other service" documentation to the IFSP:

1) type service logs in the web IFSP;
2) upload documentation as an associated file; or
3) type in the log notes the location where documentation for the "other service" can be found.  Ex: "PT notes can be found in patients medical records."


Children referred to Early ACCESS less than 45 days prior to their third birthday

Cathy Ryba 12/16/11 We received a call from a service coordinator in California at one of our regional offices stating a family with twins on IFSPs is moving here, probably arriving around Christmas.  They will turn 3 years old in January.  Can the referrals go directly to Part B since it will be less than 45 days prior to their third birthdays? Or, do we need to complete Intake in Part C since they will arrive on IFSPs?
Cindy Weigel 12/16/11

On page 2-4 of the procedures manual, in the screening section, you will find the following:

Note.  Children referred to Early ACCESS less than 45 days prior to their third birthday are referred to Part B and do not proceed through the Early ACCESS process

The children in question fall into this category.  A Part C intake is not appropriate and these children should be referred directly to Part B since they are in the timeframe described above.


HIPPA Compliant Update

Sara Krogman 12/8/11 One of the AEA9 EA teachers had the Early ACCESS consent form returned to us by the U stating it was not HIPPA compliant. We have looked on the website for the newly updated consent for the U specifically but cannot find this. If you can please send me the updated form.
Cindy Weigel 12/10/11 When getting medical records from the University of Iowa Hospital, use the Authorization to Release Health Information to get medical records/information and then you will need the Authorization for Exchange of Information if you want to exchange information back-and-forth between the IFSP team and the hospital.  The University Hospital has agreed to use these forms.  If they continue to reject the form, we will have the Early ACCESS Liaison for Child Health Specialty Clinics make contact with the appropriate hospital staff in order to resolve this problem.


IFSP Eligibility for High Frequency Hearing Loss

Nancy Sieber 11/14/11 Is a child eligible for an IFSP if there is high frequency loss in one ear only, and there are no other area's that show any delay? The parent is concerned with s and f sounds and the child is 18 months old. Since these sounds are not even expected at this age, and the child is only suppose to wear the hearing aid during play, is this an eligible child? Mom cannot keep the hearing aid on the child and I have spoken with both a SLP and a teacher for the hearing impaired. The SLP said child is too young for those sounds, and the teacher gave me suggestions for Mom on how to keep aid in the child's ear.

Cindy Weigel

Meghan Wolfe

11/23/11 In the Early ACCESS procedures manual, section 2, entitled "Eligibility Determination/Comprehensive Identification Procedures" which gives information about eligibility determination for known conditions. Hearing loss is considered a known condition for eligibility for early intervention services (see page 2-45 dated October 5, 2010).  The IFSP team determines eligibility based on all of the information that is gathered during the evaluation process, including medical records related to hearing. If the team needs assistance in making the eligibility determination, it would be the responsibility of the EA coordinator, liaison, or other appropriate agency staff to assist in that determination.


Not being considered for Part B, PMA?

Joane Amick 10/29/11 When a child is not being considered for Part B because he has never been delayed or is no longer delayed, but they are over 2 yr. 9 mo., is it ok to use PMA? We may continue to serve them up to their transition time.
SLP says she is exiting him prior to age three, but he is not being considered for Part B because she knows he is not delayed and he has met his goals. He is already in preschool.
Cindy Weigel 11/1/11

In the Early ACCESS Procedures (p. 6-4) Transition from Early ACCESS, you find a table with scenarios to assist with decisions around children who are reaching the age to exit Part C.  The scenario that applies to your question is the first one which says:

If data suggest...Child has acquired developmental skills comparable to same age peers,

And...IFSP Team has no concerns about the child's ability to continue to demonstrate age appropriate skills without specialized educational supports and services,

Then IFSP Team...Follows procedures for the Transition Pathway for Transition to Other Community Services Planning Process in Section 6, page 6-25.

The EA Procedures Manual is missing the last bolded information above which refers you to Section 6, page 6-25.  This will need to be corrected in the next revision.

The correct exit code for this child would be EOP: Not eligible for Part B, exited with referrals to other programs.  When a child is older than 2 years 9 months, the transition steps apply to the exit process.  Even though the scenario that you shared has the child meeting program goals, because of the child's age, you must not skip the transition planning process as described in the manual in Section 6, page 6-4.


Annual Review, Multidisciplinary Team Required?

Cathy Ryba 10/27/11 Is a multidisciplinary team required for evaluations at the time of an annual review?  Or, can a single provider evaluate the area(s) of concern and address other areas of development at that time?

Cindy Weigel

Meghan Wolfe


Per the instruction manual page 5-38, the IFSP Team completes the annual evaluation, not one person.  It could be that one person does the required test in the area of concern(s); however, the following procedures must be followed for the entire annual evaluation process:

The IFSP Team shall conduct an annual assessment in preparation for the IFSP Annual Review for infants and toddlers in the Early ACCESS system. The IFSP Team is required to use an assessment framework, referred to as RIOT, to gather information about each child's developmental areas.

RIOT stands for:

R - Record review; I - Interview; O - Observation; and T - Test.

At a minimum, the IFSP Team must complete a Test, using an assessment tool, which measures a child's skills in the developmental areas of concern. Information in the other areas of development that are not of concern must also be assessed; however, the IFSP Team may use any of the four components of the RIOT framework. In addition, a review of progress notes and ongoing assessment information on the IFSP Outcomes will provide important information for the child's annual assessment. The assessment information is shared at the IFSP Annual Review in order to discuss the child's development, progress and whether modifications or revisions of the IFSP outcomes or services are necessary.


Document Transdisciplinary Approach on EI Services Page

Cathy Ryba 9/26/11 How will we document transdisciplinary approach on EI services page?  For example, a child has a delay in communication and cognition.  The team has decided the early childhood specialist will be the in-home provider and support special instruction and speech.  Can the ECS listed for both areas on the EI services form?  
If the team's SLP should be listed as the provider for speech, where is the location, what is the method, and With whom should be checked?  
Cindy Weigel 10/2611

There has been a series of emails going back and forth with some in-depth information related to this questions.  I will summarize in order to have something posted in this electronic system.

Use the EI Services Page to document exactly what services the child will be receiving.  The example listed is not as detailed as the emails.  This missing details show that this child is receiving 3 services: service coordination, special instruction, speech.  All three must be listed on the EI services page of the IFSP.  The person providing each service is the early childhood specialist so her name appears beside both services.  The SLP has a consultative role to the EA Team and does not get listed on the EI Services page.  Use your Outcomes page to describe how you will go about meeting the child's outcome including the use of consultation.

If anyone wants the more detailed series of emails between the DE and Cathy Ryba, please let me know.  I will send you a copy.


Document Procedure to get a parent signature for the consent

Gale Randall 9/26/11

We have looked in the EA Procedures Manual and cannot find anything to address this...

What should the process be following an IFSP meeting in trying to get a parent signature for the consent for services...we have a family who does not know if they are interested in services and we have followed up several times with them. We are just wondering what the follow up process should be for this situation?

Cindy Weigel 9/30/11

There are no specific steps in the EA Procedures Manual that address what to do once an Initial IFSP Meeting is held, parent(s) leave the meeting without signing consent to think about services, and then the service coordinator cannot make contact with the family.  However, guidance in Section 2: Intake, page 2-22 is helpful in determining steps to take. These are procedures for the Intake processes where there is an inability to contact the family. Procedures (paraphrased):

If the service coordinator is unable to contact the family within 7 calendar days, mail a letter to the parents indicating attempts to make contact.  The letter states request for parents to call service coordinator. (See note below.)

If the service coordinator is unable to contact the family within 14 days, a second letter is mailed indicating that referral will be closed.  There is a note that it may be helpful to contact the referral source.  This may also hold true at this point in the IFSP process.  If the referral source has an established relationship with the family (ex: family physician), that referral source may lend a helping hand in working with the family.

If family does not contact the service coordinator after 21 calendar days from the date of referral, close the case. In order to close an IFSP when an Initial Meeting has taken place, make sure all forms, authorizations, and notices (Prior Written Notice) are done.  Follow web IFSP procedures for closing a case using the "family moved/unable to locate family" code.  Think of "unable to locate family" as "unable to locate/contact family" when closing the case.

All of the attempts must be documented in the service coordinator log notes.

NOTE:  There are many reasons why a family may not be ready to give consent for services.  Something to consider is giving the family a different name to contact within your agency rather than the assigned service coordinator. One letter may offer the name and number of a supervisor or other contact in case the family is feeling disconnected from the assigned service coordinator. This is not to suggest that the SC has done something wrong; it is to open up the communication lines with the family should they need a different perspective or simply a different shoulder to lean on.


Provide billing documentation for Medicaid eligible child?

Cathy Ryba 9/19/11 Clarification: if child is Medicaid eligible, each provider needs to enter their own progress notes in order to provide billing documentation?
Or, are their log notes sufficient?
Jim Donoghue 9/2611

A Medicaid auditor would want to see documentation of the service and would want to see that documentation signed.

You were asking about service coordination and the answer is that yes, the web IFSP service coordinator log note that documents the service (date, time, details) can be printed, signed and saved. This would probably be better documentation of the billed service coordination visit  than using the DE drafted documentation forms that are on the IDEA website.


Progress documentation by each provider?

Cathy Ryba 9/8/11 Does each provider on a home visit need to enter progress notes on a joint outcome they are working on together? Or, can progress be noted by only one identified primary provider for that outcome? Is there any other reason besides Medicaid that would require individual progress documentation by each provider? It is understood that each provider is responsible for entering log notes individually after a home visit.

Cindy Weigel

Meghan Wolfe


Each provider would not have to individually enter progress notes. However, someone on the team who is working on that joint outcome needs to provide a progress note that summarizes the work of all providers.

You are correct; each provider is still responsible for entering their own individual logs notes after each visit.


Procedural Requirement if Parents Waive 10 Day Notification

Rae Miller 8/17/11 Is there a procedural requirement for Part C that a note must be added to a meeting notice that the parents waived their 10 day notification of the meeting if the meeting notice is not sent out 10 days in advance of an IFSP meeting?

Cindy Weigel

Meghan Wolfe

8/17/11 There is no procedural requirement for Part C that a note must be added to a meeting notice that the parents waived their 10 day notification of the meeting if the meeting notice is not sent out 10 days in advance of an IFSP meeting.  In fact, there is no Early ACCESS Procedure that states parents must be notified 10 days in advance of an IFSP meeting.  In the Early ACCESS Procedural Manual on page 5-30 and 5-37 the manual states, "Note 2. There is no required number-of-days a notice must be provided in advance. Family centered and collaborative practices indicate notice is timely enough to assure team members’ participation."


Eligibility Due to Placement in Foster Care, When it Ceases

Kathy Bartling 8/12/11 When children are identified as eligible due to placement in foster care, does eligibility cease when they are returned home or are adopted?

Cindy Weigel

Meghan Wolfe


Eligibility is determined at an initial IFSP meeting.  This is the official point at which paperwork is done, including consent for services.  Once eligibility is determined, you do not go back at a later time and determine a child is ineligible.  You do, however, monitor progress towards meeting outcomes. If the outcomes are met and a child no longer needs EA services, the child would exit at the appropriate time that this determination is made.  All of this happens regardless of whether the child is in foster care or with the biological parents or adoptive parents whatever the case may be.

Keep in mind that at any point in time, a family can withdraw from the Early ACCESS process should they feel the service is no longer meeting their needs, the needs of the child, or any other reason they have.  This might be the case when a child who is in foster care either goes home or is adopted.  The IFSP and progress monitoring data should aid a family in making the decision to exit services or continue with Early ACCESS.


New IFSP Services Page, Projected Start Date

Peg Smith 8/3/11 On the new IFSP Services page, what is the "Projected Start" date supposed to represent?  Is this determined at the Initial IFSP meeting, when staff schedule their first visits?
Cindy Weigel 8/3/11 The Projected Start Date is when the provider expects to make their first service visit with the family/child.  This is typically determined at the initial IFSP meeting.


Spanish IFSP forms available?

Tiffany Kuhens 7/26/11 Are there Spanish IFSP forms available?

Cindy Weigel

Meghan Wolfe


The IFSP forms are not available in Spanish.

The only documents that the Dept. of Education has translated are the Early ACCESS Procedural Safeguards for Parents Manual and What Are My Family's Rights-A Quick Guide. These documents can be found on Keystone AEA website, here is the URL:


Individual AEAs may have other documents including the IFSP templates translated into Spanish and you could ask your Regional Liaison to network with the other AEAs to see what is available. The Dept. of Education will also send out an email to all regions to have  them report what documents that have translated and see if they are willing to post those on IowaIDEA.org.


Child exited from IFSP due to displacement, UNK code?

Cathy Ryba 7/14/11 If a child is exited from their IFSP because they have been displaced by the flooding, should the exit code UNK be used? It may/may not be known where the family has relocated. But the Note in the IFSP procedure manual says to include any child who did not complete his/her IFSP, exited Part C before reaching age 3, and who has not been reported as DEC, CMK, CMN or SDP.

Cindy Weigel

Meghan Wolfe

7/18/11 Correct. UNK code should be used to exit this child if they are under the age of 3, had an active IFSP, and for whom Part C staff have been unable to contact or locate the family after multiple attempts. Make sure attempts to reach family are documented.



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