"I was a nervous wreck when Early Head Start recommended that my toddler get an evaluation. I was scared of what the results would be. But the program held my hand every step of the way. And now she's getting the help she really needs. Thank you, Head Start!" – Head Start parent

This chapter describes the referral and evaluation process. Your role is to support families and their children through what is often an unfamiliar, and maybe scary, referral process. You coordinate with the IDEA¹ Parts B and C local agencies to provide timely and effective referrals and to complete the evaluations.

You help program staff and families understand the outcome of the referral and what actions they need to take. The formal evaluation identifies children with disabilities who qualify for IDEA services. Your program must ensure the full participation of children who:

• Qualify for IDEA services
• Don't qualify for IDEA services but still need support and individualized services
• During the interim period, are waiting for a determination of eligibility for IDEA services

Key Ideas

• Programs must follow a specific and timely course of action to address any identified needs based on screening results or other information.
• Parts B and C of IDEA have different eligibility criteria, timing, and other requirements.
• Programs partner with families throughout the eligibility determination process.
• Programs ensure the cultures and languages of the families are respected during the referral and evaluation process.
• Interagency MOU with the Part B and Part C local agencies responsible for implementing IDEA lay out the processes and procedures for referral and evaluation.
• A coordinated approach to ensure full participation in the program must be in place for all children and their families during the referral and evaluation process.

What is the referral and evaluation process in Head Start programs?

45 CFR §1302 Subpart C – Education and Child Development Program Services details the referral and evaluation process. The HSPPS require that a program promptly and appropriately address any identified needs based on the screening results and other information. The needs or concerns might be related to an area of child development, or they may be medical or dental in nature.

A program must receive consent from the parents and family for a referral and evaluation. If parents and family don't consent, the program can document the process and put it in the child's file. A program is required to partner with the child's parents and family and the relevant local agency to support families through the evaluation process.

The child with suspected disabilities or delays is referred to the local agency responsible for implementing IDEA. The agency conducts the evaluation and determines whether the child is eligible for IDEA services.

Which local agency is responsible for implementing IDEA?

• Under Part B for children age 3 years and older, it's the LEA²
• Under Part C for children under 3 years old, it's the early intervention service provider, which can vary from state to state

Sometimes, the Part C local agency is the LEA in your community, but often it is another organization or agency. If this is the case, your program will need to develop a separate interagency MOU with each.

After the formal evaluation, if the child is not eligible for IDEA services, a program must seek guidance from a mental health or child development professional to determine whether the evaluation indicated a significant delay. If the child has a significant delay, a program must partner with the parents and family to help access additional services and supports that may be available through the child's health insurance or under Section 504 of the Rehabilitation Act. A program can pay for services and supports if no other funds are available.

The HSPPS at 45 CFR §1302 Subpart F – Additional Services for Children with Disabilities require programs to ensure children with disabilities receive all services and participate in all activities. When children are going through the process to determine whether they are eligible for IDEA services, a program must provide individualized services and supports.

45 CFR §1302 Subpart A – ERSEA prohibits a program from expelling or unenrolling children because of their behavior. If a child doesn't already have an IFSP or IEP, the program must work with parents and family and with the mental health consultant to consider a referral to the local Part B or Part C agency. This can determine whether the child with behaviors that concern adults is eligible for IDEA services.

The regulations require screenings be conducted or obtained within 45 calendar days of a child's first attending the program or receiving a home visit, and within 30 calendar days for a shorter program. Once the referral is made, IDEA requires that the evaluation occur within 60 days for children over 3 years old and within 45 days for infants and toddlers.

Additional HSPPS in 45 CFR §1303 Subpart C – Protections for the Privacy of Child Records apply to the confidentiality of children's records.

HSPPS Related to Referrals and Evaluation

• Suspension and expulsion, 45 CFR §1302.17
• Child screenings and assessments, 45 CFR §1302.33
• Full participation in program services and activities, 45 CFR §1302.60
• Additional services for children, 45 CFR §1302.61
• Additional services for parents, 45 CFR §1302.62
• Program procedures – applicable confidentiality provisions, 45 CFR §1303.21
• Disclosures with, and without, parental consent, 45 CFR §1303.22

What is your role with families during referral and evaluation?

As a disability services coordinator, you ensure families understand each step in the process, give them timely and needed information, and prepare them to make decisions. You also debrief with families after any meetings. Talk through what you learned, discuss the next steps, and prepare questions for the next meeting. If they need translation or interpretation services, you may need to coordinate with your program management or community partners.

In some states, Head Start staff participate in this meeting as the general education representative. You may want to include the child's teacher as part of the Head Start team. In other states, Head Start staff can't participate unless family members invite them. Most families want Head Start staff to join them. Families may not know that they can invite Head Start staff or other specialists, so it's important for you to check on your state laws.

Plan for Partnerships

Your program works with its Parts B and C local agencies to:

• Describe the roles and responsibilities for the representatives from your program and the local agencies during evaluation, eligibility determination, and IEP or IFSP meetings
• Define timelines
• Determine communication protocols with families to ensure they receive timely, consistent messages during the process
• Anticipate challenges that may occur during the process and actions that partners agree to take to support the family
• Ensure the confidentiality of children's records

Make every effort to inform and engage co-parents and family in decisions. Consider using your program's communication system, such as social media and videoconferencing, to reach a nonresidential parent or family member of a child with a disability. You also may need to reach out to another family member who will be involved in decision-making. Family advocates can help you identify which adults to include. When you and your program's systems and services work together, this is the coordinated approach in action!

Families often have many questions about the process. They may have doubts about the screening or evaluation results, stereotypes about children with disabilities, and concerns about "labeling their child." In some cultures, families may encounter stigmas associated with people with disabilities, and they fear how such a label might affect their child's future. You and other staff can address these concerns. Keep in mind that the goal is to support families and children through a new and often scary process.

As the disability services coordinator, you need to keep families informed about the process of determining eligibility for services. The waiting time for the evaluation and determination of IDEA services may seem to drag on for the family—60 days for preschoolers and 45 days for infants and toddlers. If it helps, check with the IDEA local agency to make sure the process is moving ahead. Your program's interagency MOU with the agency may specify the timelines and what to do when deadlines are missed. Also, keep families informed about the individualized services and supports that ensure their child's participation in program activities during this waiting period.

IDEA Part B Section 619 applies to children ages 3–5. If the school district designates a 619 coordinator, this is the person from the LEA who heads the formal evaluation process for preschoolers.

What is your role with other program staff during referral and evaluation?

The waiting time for determination of IDEA services is valuable learning time for a child. Individualized support must be in place during the interim period. Typically, you coordinate with the child's family, education staff, mental health consultant, and others to develop a Child Action Plan. It may include instructional strategies and environmental modifications for the interim. If the evaluation determines the child is not eligible for IDEA services, your program may decide to keep the Child Action Plan and update it as needed.

During the interim period, you also may need to coordinate with the health services manager. If children with special health concerns have been referred to the IDEA agency because of suspected disabilities, they may need a Child Action Plan to specify their interim services. The health team can support you and the education staff to ensure the children participate in learning activities.

To learn more about how to provide interim individualized services while awaiting IDEA determination for a child, refer to Standards in Action: Interim Services for Children with Disabilities or Special Delays.

How can you help families prepare for an IFSP or IEP meeting?

1. Describe who will be there and why. Explain briefly what the purpose of the meeting is and what kinds of assessments were done. If possible, give the names of the participants and their responsibilities.

2. If parents and families want, rehearse questions or comments they might want to make. Also, ask if there are points they would like you or other program staff to make.

3. Help families gather and present information about their child. They can make a "my child" book that includes previous reports from specialists and teachers along with photos, videos, and work samples that illustrate what the child can do and how they learn.

4. Review the meeting's physical setup with your program staff, the IDEA agency, and the parents and family. A round table where parents and family sit next to familiar Head Start staff sends a message: "We want you to be our partner. We will advocate together for your child." A room with a long table where everyone sits far apart and where eye contact is difficult conveys a different message.

5. Let parents and family know about how long the meeting will take.

6. Explain what rights parents and family have to appeal a decision.

7. Refer families to the PTIC in their state for support in the IFSP or IEP process and understanding their rights under the IDEA.

Your program's management team also works with you during the referral and evaluation process. Accurate and timely recordkeeping is necessary. Your program must develop a system to track referrals and services provided and to monitor treatment plans. If your program is small, you might be able to do this by hand, but it's more efficient to use an online tracking system. If you and program management decide to purchase new software, the cost of the tracking system will have to be figured into the program budget, along with any training costs. Whether tracking is done by hand or online, confidentiality is required to maintain secure records. See Appendix C for a sample tracking sheet.

The Evaluation: Determining Eligibility for IDEA Services

Depending on the age of the child, the early intervention or special education partners complete a diagnostic evaluation. It is used to gather information about the child and family. The partners collaborate with qualified professionals in speech and language, cognitive, hearing, vision, psychology, and physical development. The evaluation team considers all the data your program provides, including the screening results, child assessments, child health records, and information from the family.

After specialists complete their evaluations, the team gathers to determine whether the child is eligible for services. Eligibility criteria differ under Part B and Part C.

Eligibility and Service Delivery Policies: Differences Between IDEA Part C and IDEA Part B compares the legislation. It's important for you to know where the differences lie.

Part B Eligibility

For children and youth ages 3–21, IDEA Part B lists 13 eligible categories for types of disabilities:

• Autism
• Deaf-blindness
• Deafness
• Emotional disturbance
• Hearing impairment
• Intellectual disability
• Multiple disabilities
• Orthopedic impairment
• Other health impairment
• Specific learning disability
• Speech or language impairment
• Traumatic brain injury
• Visual impairment (including blindness)

The federal definitions help states define who is eligible for free, appropriate public education under IDEA. The law allows states to decide whether they include the term "developmental delay" in their definition of a child with a disability and for what age range. Some states are more stringent about the use of the term developmental delay. How your state defines developmental delay affects how your LEA uses the term. This, in turn, affects who in your program qualifies for services under IDEA Part B. You need to learn about your state's laws as well as the federal law.

If a child age 3 or older is eligible for IDEA services, the LEA prepares an IEP that specifies the learning goals and the special education services the child will receive and where these services will be provided. The law requires that the child be placed in the LRE. This means, when possible, the child is in an inclusive learning environment with children without disabilities and participates in activities with supports and services as needed.

Part C Eligibility

Under Part C, an eligible infant or toddler has one of the following:

1. A delay in cognitive, physical (including vision and hearing), communication, social, emotional, or adaptive development

2. A diagnosed physical or mental condition that has a high probability of resulting in developmental delay

3. Is "at risk" for experiencing a substantial developmental delay if early intervention services are not provided to the child or because of biological or environmental factors

Each state determines the percentage of delay that establishes eligibility for a developmental delay. The state establishes the list of physical or mental conditions that have a high probability of resulting in developmental delay. States also determine whether they will add a service eligibility category for at-risk infants and toddlers.

If an infant or toddler is eligible for IDEA services, the local agency team starts writing an IFSP. It specifies the early intervention services the young child and family will receive and where these services will be provided. The law requires the services be provided in natural environments in the context of routines and activities that are part of the child and family's daily life. The natural environment can be a family's home, as in a home-based program or a group care setting.

Supports for Children Who Are Not Eligible for IDEA Services

Your program must continue to provide interventions and individualization to children who received a diagnostic evaluation but are not eligible to receive IDEA services. Programs are also required to support to their families. As the disability services coordinator, you work with your team and the child's family to update or develop a Child Action Plan. The family also has the option to seek eligibility under Section 504 of the Rehabilitation Act.

There are important distinctions:

• A Child Action Plan (or Child Services Plan) is an internal Head Start plan. It specifies supports, goals, and strategies while the family is going through the process to determine whether their child is eligible for IDEA services. It is helpful to have a written plan, but it is not required. You can create the plan with the support of a mental health consultant, education staff, and other staff as necessary. Families should be included and may have information and valuable input to contribute to the development of the plan. The Child Action Plan may be used on a short-term basis or long term in the case of a child who may not have a disability but who does have concerns that require support.
• Only the LEA can determine eligibility for a 504 Plan. If a child is not eligible to receive IDEA services but would benefit from additional supports, a 504 Plan might apply. The law does not require a written plan or the participation of parents and family in decision-making. School districts handle 504 plans differently, and many districts do not write them for preschool-aged children. A 504 Plan doesn't come with any funding.

School districts handle Section 504 plans differently, and many districts do not write Section 504 plans for preschoolers with disabilities. Find out about the policies in your school district so you can guide parents and family.

When a child is determined not to be eligible for IDEA services but needs support, work with the family to consider the options. Your program may have already prepared a Child Action Plan for interim services during the evaluation process.

1. Ask the family if they would like to request that the school district explore a Section 504 Plan for their child. Your input, along with that of specialists, other staff, and the mental health consultant, can help a family make decisions.

2. Parents and family must give their consent to release medical records or other information to help support eligibility for a Section 504 Plan.

3. If the district agrees the child is eligible for services under Section 504, then the Section 504 Plan would replace the Child Action Plan.

4. If the child does not qualify for services under Section 504, then the Child Action Plan would go from being an interim plan to a permanent plan.

Through ongoing assessment and recordkeeping, your team may decide to refer a child again at a later date.

Your program has options to develop plans for children who need support but don't qualify for IDEA services. A Section 504 Plan or a Child Action Plan is tailored for the individual child. A one size fits all approach does not work!

Review this infographic for guidance on choosing the correct plan for children who do and don't qualify for IDEA. It captures the steps from when concerns are identified to when the appropriate plan is in place.

Payment System

It's important to distinguish payment systems under IDEA Parts B and C. Free, appropriate public education (FAPE) is a provision in Part B. It means that special education and related services for children age 3 years and older:

• Are provided at public expense under public supervision and direction and without charge
• Meet the standards of the state educational agency (SEA)
• Include an appropriate early childhood setting, elementary school, or secondary school education in the state
• Conform with an IEP

The statute and regulations provide a payment system for Part C services for infants, toddlers, and their families. States must develop written policy for all families that explains what, if any, responsibility the family must undertake in supporting the costs of services through public or private insurance or family fees.

If a child is not eligible for IDEA services but has a significant delay, the HSPPS require programs to partner with parents and family to help them access services and supports. A child's health insurance may provide some funding. A program might use program funds to provide services and supports when no other funding sources are available. For example, your program might purchase assistive devices or pay for a part-time classroom aide to support a child. This regulation helps ensure all children with disabilities fully participate in the Head Start program.

Tips to Ensure a Smooth Referral and Evaluation Process

As a disability services coordinator, you are the team leader for any evaluation follow-up. Not only do you coordinate the people in the process, but you also remove barriers and challenges at each step.

• Maintain accurate and thorough records. Know where children are in the process. Have referred children seen specialists? Are their families on board? How long before you learn whether the child is eligible for IDEA services? If they are not eligible for IDEA services, what are the next steps?
• Make sure deadlines are met. Ensure everyone is aware of the timelines in relevant legislation and the HSPPS.
• Support parents and family in their role as the primary advocate for their child. Help them to be prepared for the IEP or IFSP meeting. Remind them to identify their child's strengths.
• Facilitate communication. Keep staff, partners, and families informed. Keep communication open to resolve issues that slow down the process or add confusion.
• Work with the health manager. Support the health team when a child with special healthcare concerns is referred to the healthcare provider and, if necessary, to the local IDEA agency.
• Debrief with stakeholders. Find out what could be done better next time.
• Stay informed about legislation. Reach out to your early intervention and special education partners about changes in federal or state legislation that may affect referrals and services.
• Work with program management to review and update interagency MOU. Make sure they reflect the processes and procedures that work. Address partners' concerns.

See Appendix C for a child tracking sheet. For a detailed list of tasks related to referral and evaluation, refer to Appendix D.

People to Help You

• Family service manager and staff
• Health managers and staff
• Education managers, coaches, education staff, and home visitors
• Management team
• Mental health consultant
• Child development professional
• Early intervention providers
• Special education providers

Questions to Consider with Colleagues

• What process is in place in our program for managing referrals? How do we decide to refer a child? How do we refer a child with special healthcare concerns? How do we engage parents and family? Who makes the referral?
• How do we help parents and family understand the process to determine eligibility for IDEA services and support them through it?
• Do we have translators and interpreters available when needed for meetings with the early intervention or special education providers?
• What are some of our past successes in the eligibility determination process? What are some major challenges?
• If a child is eligible for a Section 504 Plan, do we have processes and procedures in place?
• Do our internal Child Action Plans represent the best way to support each child?
• Is our tracking system efficient and accurate? Do we need to make any changes?
• How often does a representative from the Head Start program attend evaluation meetings or IEP or IFSP meetings? How do we select that person? How do we prepare both the program representative and the parents and family for meetings?

Scenario

The results of 4-year-old Leroy's screening, paired with information from his parents and teachers, indicate developmental concerns. He may have delays in language and cognitive functioning. The Head Start disability services coordinator, Hillary, refers him to the LEA evaluation team. They will determine his eligibility for preschool special education services. Samantha, the district's parent coordinator, meets with Leroy's mother and a school psychologist, plus the Head Start team. The school professionals listen to the mother's and the teaching teams' concerns. They also collect observations and comments from the bus driver and the nutritionist, who have noticed Leroy's lack of verbal interaction. Teachers are concerned about his difficulty following two-step instructions and persisting with a task. He also has difficulty regulating his feelings and his behavior in the classroom. They don't think he's learning to his potential.

The psychologist describes the play-based assessment she uses as one part of the eligibility evaluation, and Samantha explains other parts of the process. They offer to answer any questions his mother might have and ask how she wants to be involved. Hillary shares that Head Start is an inclusive program and that staff deliver intervention services for children with disabilities within the classroom setting. This is a relief for Leroy's mother, who likes the program and uses some of the family support services. The father can't attend these meetings, but they write up notes for him.

The Head Start team and his mother agree that it would be a good idea for the evaluation team to observe Leroy during a center rotation in the Head Start program. They think the classroom setting will be a good place to see him where he is comfortable. On the day of the observation, Hillary, Leroy's mother, and the LEA psychologist observe together. Hillary solicits and confirms her understanding of the mother's observations before writing them down. The LEA team conducts other evaluations to assess Leroy's speech and other areas of functioning.

Determining eligibility for IDEA services takes a while. During this time, Hillary knows the program must provide quality services to Leroy and his family. She asks the mental health consultant to work with staff to develop strategies so he can successfully participate in class activities.

Both Leroy's mother and father attend the meeting to determine eligibility. Professionals from the school district and the Head Start program make sure the parents feel like part of the meeting. Hillary invites their questions, solicits their observations, and makes sure they understand the information. She also assures them that their priorities will be included in any proposed special education plans. At this point, the parents feel they can trust the team to invite them to make decisions, and together, they will ensure Leroy gets the support he needs.

(Adapted from Engaging Families as Assessment Partners [DEC Recommended Practices Topic Area: Assessment])

^{1 IDEA refers to the Individuals with Disabilities Education Act.}

^{2 The LEA is a public entity—usually a school district—responsible for the evaluation and determination of a child’s eligibility for IDEA services when the child is age 3 years and older.}

Last Updated: July 16, 2024