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MONDAY, JUNE 11 INDY FEDERAL GOV HEARING ON NEW FIRST STEPS REGULATIONS
Indianapolis is one of only four sites for national public hearings on
regulations for the Part C Infant Toddler Early Intervention programs known
as First Steps in Indiana. Indiana families have a unique opportunity to
provide a public voice on the Early Intervention regulations! Please
consider attending . Even if you are not "up on" the details of the
regulations, you can express how important the program is and how it has
helped your child. Even if you don't speak- your presence will help show
how much First Steps means to Indiana families. Below is more detailed
information from Family Voices:
Family Voices Indiana is excited that Hoosier families will have the
opportunity to share our VOICE. A public meeting for Part C regulations
will be held:
Monday, June 11, 2007 4:00 p.m. 7:30 p.m.
Indianapolis , Indiana
Indiana Government Center South Conference Center (Auditorium)
402 W. Washington Street
Indianapolis , IN 46204
Families are urged to attend and to consider testifying and/or giving
written comment. The physical presence of people is critical. Family Voices
hopes that 100 families will join us. Only 35 people attended one of the
three other hearings, so we seek to ensure that the public meeting in
Indiana clearly demonstrates the importance and value of early intervention
to Hoosier families of children with disabilities. Even if you are not
comfortable testifying PLEASE plan to attend to show that you believe that
early intervention is important. This is a great opportunity to meet and
network with other families!
Following is some guidance about giving input both orally and/or in written
form. If you want to give written comment you may bring it to the hearing
or mail it to:
Alexa Posny , U.S. Department of Education
400 Maryland Avenue, SW., Room 4109,
Potomac Center Plaza
Washington, DC 20202-2600.
Comments can also be submitted through the Federal eRulemaking Portal:
Families are encouraged to consider commenting on the overall importance of
Part C in the life of your family or the positive impact that the program
has had on your family.
If you are not comfortable commenting on particular regulations, this can
and should be a GREAT way to give input. It is vital that the importance
and value of this program is shared.
-Go to http://www.regulations.gov
-Select "Department of Education" from the agency drop-down menu
-Click "Submit"
-In the Docket ID column, select ED-2007-OSERS-131 to add or view public
comments
Family Voices Indiana suggests the following format for written comments:
* An introductory paragraph that includes information about yourself, your
family and your experience with early intervention, how and why early
intervention was valuable to your family
* BRIEFLY comment on all areas of the regulation that you have questions
and perspective on
* Refer to the numerical code and title of the section
* Share your thoughts
* A conclusion thanking the DOE for the opportunity to share your thoughts,
along with your contact information expressing your willingness to be
contacted with any follow-up questions
If you are interested in making public comments you might keep the
following in mind:
*There will be from two to five representatives taking comments
*Everyone who attends will need to sign in
*You will be limited to five minutes for your comments
*You should briefly introduce yourself then focus on your area of concern
*Some people bring pictures of their children to help illustrate the human
impact of early intervention
*Your oral comments should be limited to one or at the most two topics
*Try not to read from a script -- you don't have to have regulations
memorized or be able to speak in "legal terms"
*Simply share why these issues matter to you, to your family, to other
families and to families who will come in the future
*You will need written comments (four copies ideally) to submit when you
are giving oral comment
*Your written comments can cover more sections of the regulations than oral
comments
Sections of the regulations to consider commenting on:
303.13 Early intervention services
Nutritional and nursing services have been removed from the regulations.
These services provide critical support for families as they access
education and knowledge to help them understand and address their child's
diagnosis and/or disability. Maintaining these services as listed services,
rather than relying on states to offer them under the "other services"
category, will help to ensure that families and provider teams are aware of
these resources.
303.33 (a)(2) Service Coordination Services (case management)
Retain the original language which states that families be provided with
one service coordinator who must help parents to obtain services and
assistance they need and to facilitate the timely delivery of services is
preferred language. Gaining access may be interpreted, for example, to mean
that a family is given a list of providers to hunt out on their own or
brochures, numbers and other contact information to follow-up with and
navigate independently.
303.105 Positive Efforts to Employ and Advance Qualified Individuals with
Disabilities
Expand by adding "and qualified parents of individuals with disabilities in
programs assisted under Part C of the Act." Parents bring critical
expertise to Early Intervention programs.
303.320 (c) Evaluation and assessment of the child and family and
assessments of service needs
Procedures for assessment of the family
Encourage the Department to use the term "family-directed assessment"
consistently. The family-directed assessment should be something done with
a family and not to a family. Encourage the Department to include the
reference to include members of the extended family, as invited by the
parent(s) in the regulation. . Support the inclusion of the language "as
determined not just through the use of an assessment tool, but through a
voluntary personal interview with the family" as being a positive aspect of
the draft regulations.
303.320(e) (1), Evaluation and Assessment of the child and family and
assessments of service needs
Timelines
Currently the 45-day timeline for evaluation and assessment of infants and
toddlers starts when a child is referred. Families may be concerned that
the proposed rules change this to a system where the 45 days is not started
until the parent signs permission to evaluate. An undefined period of time
could pass between when a family either self-refers or is referred by a
professional and when the permission to evaluate occurs. Children could
remain outside of the system for a period of days, weeks or months.
303.434 (d) Filing Complaints
The additional requirement that families (or anyone filing a compliant)
must forward copies of complaints to the provider who is the subject of the
complaint in addition to their filing with the lead agency creates an extra
burden for families. The lead agency should have the responsibility for
sharing the complaint with the subject provider. This creates an additional
barrier for families to ensure they are filing complaints correctly and it
would be burdensome for families to identify appropriate contact
information for provider agencies for the purposes of filling complaints.
303.601(a)(1)(iii) Composition
Recommend that the language proposed be removed, which disallows parents on
the ICC to be employed in the early intervention field. Many parents choose
to utilize the knowledge and skills they gain from their early intervention
experience to pursue employment opportunities in early intervention
professions. Alternative language could be to require that parents with
diverse perspectives be appointed to an ICC, including some parents who do
not work for early intervention providers or other agencies that interact
with families enrolled in EI.
You can find the full text of the proposed regulations at:
http://www.ed.gov/legislation/FedRegister/proprule/2007-2/050907a.pdf
FV Indiana recommends the following resources for guidance analysis and
talking points:
*The DEC/ITCA/CEC side-by-side analysis
· http://www.dec-sped.org/publicpolicy.html#PartCB
* The Early Intervention Family Alliance summary statement
· http://www.eifamilyalliance.org/EIFA_testimony_summary_final.pdf
Family Voices Indiana looks forward to seeing you at the hearing. If you
have questions about the process, attending or giving written input please
don't hesitate to contact us. We are interested in ensuring the Hoosier
VOICE is heard in expressing the value of Early Intervention for children
and families.
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