Wednesday, September 7, 2011

Part C Regulations



The Part C regulations are out! OK, so the final unofficial Part C regulations are out, but they will be published soon and it is time to begin reviewing. The EIFA Board is busy with our pens, highlighers and sticky notes reviewing the final regulations, our comments  our side-by-side, and our financial side-by-side, on the proposed regulations and the current statute (or law). The OSEP Part C website is now live and you can visit that here.


Reviewing.  Our plan is to review the regulations to see what changes were made between the proposed regulations and the final regulations, how OSEP responded to our comments on the regulations and finally to review the overall changes to the regulations.  We cannot do all of this alone!  We are very grateful that we can partner with the Infant Toddler Coordinator's Association (ITCA), the Division of Early Childhood (DEC), and you our members.  We are still planning calls to discuss the changes.  If you want to be a part of those calls, please email us at eifamilyalliance@aol.com

A little history.  Back in 2003 a few of us got together as family leaders and reviewed the proposed changes to IDEA.  We created a table that looked at the regulations from the family perspective and we shared our insights and comments with others.  After IDEA was reauthorized that same group of family leaders got together and created a new table, again sharing our comments with others and reviewing the comments of ITCA, DEC, ASHA, AOTA, APTA and the like.  By the time the proposed regulations were published, the Early Intervention Family Alliance had been formed and we could formally review, comment and share our insights as an organization.  We were able to partner with ITCA and DEC who helped us to look at the regulations from both a family perspective and a system perspective.

Organizing our thoughts.  We plan to organize our review using the following themes:  

  1. Paying for Part C services (Private Insurance, Public Insurance, Parent fees, State financing)
  2. Transition
  3. IFSP (45-day timelines, timely provision of services)
  4. Child Find/Public Awareness/Evaluation/Assessment
  5. Procedural Safeguards/Confidentiality

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