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July 10, 2012
Children's Law Center submitted comments to the Office of the State Superintendent on Education on proposed changes DC's regulations regarding the Early Internvention Program for Infants and Toddlers with Disabilities. CLC favors the proposed widening of eligibility criteria but offers a few suggestions to improve the proposal. Read a summary below or download the comments (PDF).
The proposed regulations significantly broaden the eligibility criteria for early intervention and potentially double the number of children found eligible for the program; CLC supports this change, but notes that even with this expansion, DC's criteria would still be stricter than those of most other states. Further expanding eligibility would ultimately reduce the burden on the city's special education system, as many interventions are most effective when provided before children begin elementary school.
Under the proposal, families would also be able to extend their child's services until pre-kindergarten, rather than the current cutoff at age 3. CLC suggests allowing for another year's extension until kindergarten.
CLC also has concerns over provisions in the proposal about conducting evaluations and assessments in the child's native language; ensuring DC foster children are entitled to the services if eligible; and several technical suggestions to change wording.
CLC's mission fits perfectly with our "KidsFirst" initiative at McDermott Will & Emery. Our lawyers participate in special education appeals, adoption matters and guardian ad litem work. The commitment and expertise of CLC's staff is extraordinary, and their training and ongoing mentoring are first-rate. This has become one of our broadest and deepest pro bono relationships firm-wide.
-H. Guy Collier
Partner, McDermott Will & Emery LLP
Chair, CLC Board of Directors