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Comments on Proposed Early Intervention Regulations

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.

I will never forget my clients … in fact, I still have their picture on the wall in my office, because it really helps me to put into perspective my work and the work of the Children’s Law Center.

-Carmen G. McLean
Partner, Jones Day
Member, CLC Board of Directors
CLC Pro Bono attorney

 

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