. UNITED INDEPENDENT SCHOOL DISTRICT GUIDELINES FOR THE PROVISION OF EXTENDED SCHOOL YEAR SERVICES FOR STUDENTS WITH DISABILITIES Revised summer 2011 Page 1
Purpose The purpose of this document is to provide guidance for parents, educators, and administrators regarding the determination and provision of extended school year (ESY) services for eligible students with disabilities. Parents of students with disabilities should be provided information regarding ESY to better enable them to be involved in the decision for or against ESY services for their child. This document contains guidance to some of the most commonly asked questions regarding ESY services. This document includes: A Definition of ESY Services Legal References Regarding ESY Services (Federal and State) General Eligibility Criteria for ESY Services Questions and Answers regarding Extended School Year Services Revised summer 2011 Page 2
Definition of ESY Services Extended School Year Services an individualized instructional program provided beyond the regular school year for eligible students with disabilities. The need for ESY services must be determined on an individual basis by the admission, review and dismissal (ARD) committee. Some students with disabilities have difficulty retaining skills during long school holidays and/or summer. If a student requires a significant amount of time to recoup mastered skills, the ARD committee should discuss whether the student needs extended educational and/or related services during school breaks. The determination of whether a child will receive ESY will be made by the ARD committee; and the individualized education program developed for ESY must include goals and objectives. Revised summer 2011 Page 3
Legal Authority for Extended School Year Services Extended school year (ESY) was first established in federal law by the Individuals with Disabilities Act of 1997 (IDEA 97). Prior to that time, the basis for interpretation of ESY requirements was drawn form case law. IDEA 97 does not create new legal standards for ESY services but brings together well-established case law in this area. IDEA 2004 retained the same requirements for ESY as did IDEA 97. Federal Regulations Individuals with Disabilities Education Act (34 CFR Part 300) 300.309. Extended school year services. (a) General. (1) Each public agency shall ensure that extended school year services are available as necessary to provide FAPE, consistent with paragraph (a)(2) of this section. (2) Extended school year services must be provided only if a child's IEP team determines, on an individual basis, in accordance with 300.340-300.350, that the services are necessary for the provision of FAPE to the child. (3) In implementing the requirements of this section, a public agency may not (i) Limit extended school year services to particular categories of disability; or (ii) Unilaterally limit the type, amount, or duration of those services. Revised summer 2011 Page 4
(b) Definition. As used in this section, the term extended school year services means special education and related services that (1) Are provided to a child with a disability (i) Beyond the normal school year of the public agency; (ii) In accordance with the child's IEP; and (iii) At no cost to the parents of the child; and (2) Meet the standards of the State State Rules Authority: 20 U.S.C. 1412 (a)(1) Texas Administrative Code (TAC) Title 19, Chapter 89. Adaptations for Special Populations, Subchapter AA: Commissioner's Rules Concerning Special Education Services 89.1065. Extended School Year Services (ESY Services). Extended school year (ESY) services are defined as individualized instructional programs beyond the regular school year for eligible students with disabilities. (1) The need for ESY services must be determined on an individual student basis by the admission, review, and dismissal (ARD) committee in accordance with 34 Code of Federal Regulations (CFR), 300.309, and the provisions of this section. In determining the need for and in providing ESY services, a school district may not: (A) limit ESY services to particular categories of disability; or (B) unilaterally limit the type, amount, or duration of ESY services. (2) The need for ESY services must be documented from formal and/or informal evaluations provided by the district or the parents. The documentation shall demonstrate that in one or more critical areas addressed in the current individualized education program (IEP) objectives, the student has exhibited, or reasonably may be expected to exhibit, severe or substantial regression that cannot be recouped within a reasonable period of time. Severe or substantial regression means that the student has been, or will be, unable to maintain one or more acquired critical skills in the absence of ESY services. (3) The reasonable period of time for recoupment of acquired critical skills shall be determined on the basis of needs identified in each student's IEP. If the loss of acquired critical skills would be particularly severe or substantial, Revised summer 2011 Page 5
or if such loss results, or reasonably may be expected to result, in immediate physical harm to the student or to others, ESY services may be justified without consideration of the period of time for recoupment of such skills. In any case, the period of time for recoupment shall not exceed eight weeks. (4) A skill is critical when the loss of that skill results, or is reasonably expected to result, in any of the following occurrences during the first eight weeks of the next regular school year: (A) placement in a more restrictive instructional arrangement; (B) significant loss of acquired skills necessary for the student to appropriately progress in the general curriculum; (C) significant loss of self-sufficiency in self-help skill areas as evidenced by an increase in the number of direct service staff and/or amount of time required to provide special education or related services; (D) loss of access to community-based independent living skills instruction or an independent living environment provided by noneducational sources as a result of regression in skills; or (E) loss of access to on-the-job training or productive employment as a result of regression in skills. (5) If the district does not propose ESY services for discussion at the annual review of a student's IEP, the parent may request that the ARD committee discuss ESY services pursuant to 34 CFR, 300.344. (6) If a student for whom ESY services were considered and rejected loses critical skills because of the decision not to provide ESY services, and if those skills are not regained after the reasonable period of time for recoupment, the ARD committee shall reconsider the current IEP if the student's loss of critical skills interferes with the implementation of the student's IEP. (7) For students enrolling in a district during the school year, information obtained from the prior school district as well as information collected during the current year may be used to determine the need for ESY services. (8) The provision of ESY services is limited to the educational needs of the student and shall not supplant or limit the responsibility of other public agencies to Revised summer 2011 Page 6
continue to provide care and treatment services pursuant to policy or practice, even when those services are similar to, or the same as, the services addressed in the student's IEP. No student shall be denied ESY services because the student receives care and treatment services under the auspices of other agencies. (9) Districts are not eligible for reimbursement for ESY services provided to students for reasons other than those set forth in this section. Why Extended School Year (ESY) The 2004 Amendments to the Individuals with Disabilities Education Act give educators the responsibility for development and delivery of a free appropriate public education (FAPE) to students with disabilities. IDEA 2004 defines FAPE as special education and related services that are public expense and are provided in conformity with an Individualized Education Program (IEP) Revised summer 2011 Page 7
FEDERAL REGULATIONS Free appropriate public education (FAPE) The term free appropriate public education, or FAPE, means special education and related services that Are provided at public expense, under public supervision and direction, and without charge Meet standards of the State Include preschool, elementary school, or secondary school education in the State; and Are provided in conformity with the Individualized Education Program (IEP) Authority: 20 U.S.C. 1401 (8) A central issue in FAPE is the IEP team s (ARD Committee s) determination of what services are appropriate. The process used in development of the IEP ensures that students with disabilities have appropriate education planning, based on appropriate evaluation, to accommodate their unique instructional needs and these needs are met in an appropriate learning environment. Revised summer 2011 Page 8
The IEP process ensures that students with disabilities receive a free appropriate public education. Another issue regarding appropriate education is whether the educational program is sufficient to provide meaningful educational benefit. The concept of benefit is an integral part of the IEP process. The ARD committee examines a student s present level of development or skill acquisition, as well as the student s ability to progress beyond that level if provided with an effective program. If that program results in measurable advancement toward goals that are appropriate for the student, then the student has received an appropriate education Some students with disabilities may not receive FAPE unless they receive needed services during time periods when other students normally would not be served. because he/she has benefited from his/her schooling. Thus progress towards goals and documentation of that progress becomes core concerns in the provision of FAPE. Some students with disabilities may not receive FAPE unless they receive needed services during time periods when other students normally would be serviced. As part of the IEP process, the ARD committee must determine if a student needs a program of special education and related services extending beyond the normal school year. For such a student, restricting services to a standard number of school days per year does not allow development of an education program that is truly individualized. A student may require ESY services in order to receive FAPE. Revised summer 2011 Page 9
A critical question that each ARD committee must ask regarding ESY services is whether the learning that occurred during the regular school year will be significantly jeopardized if ESY services are not provided. Reasons why ESY services may be needed vary from student to student, but the end result is that some students may experience severe losses of social, behavioral, communication, academic, or self-sufficiency skills during interruptions in instruction. This is particularly true during long breaks such as summer vacations. Losses suffered by a student may be so General Criteria for ESY Services Regression / Recoupment Degree of progress Emerging skills/breakthrough opportunities Interfering behaviors Special circumstances This list is not all-inclusive extensive that when school resumes, unreasonable amounts of time are needed to recover (recoup) lost skills. Other students may experience losses because they reach critical learning stages at the end of a school year and need ESY services to avoid irreparable loss of learning opportunity. For some students, skills that support continued placement in the least restrictive (LRE) can be maintained only by ESY services. The determination of whether a student with a disability needs ESY services must be made on an individual basis by the IEP team. The remainder of these guidelines is structured in a question ad answer format to assist in clarifying common ESY issues. Revised summer 2011 Page 10
DETERMINING NEED FOR EXTENDED SCHOOL YEAR SERVICES 1. Who is eligible for ESY services? All students with disabilities who have a current IEP must be considered for ESY services at least annually. To ensure FAPE, the IEP team must consider and document whether ESY services are needed for each student regardless of the student s disability. A school may not limit ESY services to particular or unilaterally limit the type, amount, or duration of those services. These requirements apply to all students with a disability between the ages of three and twenty-one. 2. Who determines the need for ESY? Determination of need rests with the ARD committee, which must be composed of the following individuals: parent(s) of the student, the student, if appropriate, general education teacher(s), special education and related service providers, administrator or school representative, and others as appropriate. All persons involved in the ARD process should be active participants. Each person fulfills an important role by bringing and sharing information. 3. What factors should be considered when determining ESY? The primary criteria in determining a student s need for ESY services are the likelihood of significant regression of previously learned skills during a break in service and limited or delayed recoupment of these skills after services resume. The courts have found that the regression/recoupment measures are an integral part of the determination of need for ESY. However, in Reusch v. Fountain (D. MD 1994), the courts listed five other factors that the ARD committee Revised summer 2011 Page 11
should consider in deciding if the child is eligible for Extended School Year Services. The six factors are listed below: 1. Regression and recoupment is the child likely to lose critical skills or fail to recover these skills within in a reasonable time; 2. Degree of progress toward IEP goals and objectives (if progress is very slow, student may need ESY services in order to continue to make progress); 3. Emerging skills/ breakthrough opportunities (e.g. student just beginning to communicate, accomplish self-care skills, read or write) 4. Interfering Behavior does the child s behavior interfere with his or her ability to benefit from special education; 5. Special circumstances (e.g. student missed significant amount of time because of illness, surgery or other personal circumstances, student at risk of more restrictive placement, student moving from restrictive placement to inclusive placement, vocational training, facilitate transition) 4. How is the need for ESY services measured? Determination of the need for ESY cannot be based on a formula. Formulas lack the individualization to ensure that students with disabilities have appropriate educational planning to accommodate their unique needs. Case law supports this conclusion; the determination of need for ESY services cannot be based on a policy that prohibits or inhibits full consideration of the needs of each student with a disability. The information that is needed by an ARD committee to determine a student s need for ESY services is gathered through ongoing measurement of the student s progress toward the current IEP goals. An essential component of a student s goals is the method to measure progress. Information can be gathered through a variety of Revised summer 2011 Page 12
informal and formal measures. Those measures may include a record of daily performance, criterion-referenced and norm-referenced test date, anecdotal records from information collected throughout the year, behavior checklists, or student work samples. 5. Does receipt of ESY services one summer ensure such services the following summer? No a student s involvement in ESY services one year, does not automatically guarantee services in the following years. Similarly, the fact that nor ESY services were provided the prior year does not mean ESY services are not needed in the current year. The decision is made on an annual basis. 6. If a student does not meet all of his or her IEP goals during the regular school year, does he/she automatically qualify for ESY services? No, ESY services should not be granted solely on the basis of the student with disabilities not achieving one or more IEP goals. The critical question that each ARD committee must ask regarding ESY services is whether the learning that already occurred during the regular school year will be significantly jeopardized if ESY services are not provided. 7. Is the ARD committee required to document the justification of the need for ESY services? Yes. After the student s IEP team has completed the discussion regarding ESY written justification must be provided on the ARD document. 8. When should the ARD committee meet to determine ESY services? The committee must consider the needs for ESY services at the annual ARD meeting. However, under some circumstances, the need for ESY services and the characteristics of ESY services may not be known at the time of the annual ARD Meeting. In that case, the committee can identify the date it will reconvene to determine the need and services to be provided. The committee may also plan what data Revised summer 2011 Page 13
should be gathered to assist in making those later determinations. An addendum documenting ESY determinations would then be completed and attached to the current IEP at that later time. The regulations do not specify a minimum timeline in terms of how many days in advance of the end of the school year that committee determinations must be finalized. According to the analysis of IDEA final regulations, public agencies are expected to ensure that these determinations are made in a timely manner so that students with disabilities who require ESY services in order to receive FAPE can receive the necessary services. The ARD committee meeting during which ESY needs and services are determined should be accomplished in sufficient time to permit any party to exhaust administrative remedies prior to the break in service. Thus, the ARD document will serve to notify the parents of whatever ESY determinations have been made. As part of the ARD Process, the parents are fully informed of their rights and the procedures through which they may question a decision of the ARD committee. 9. Should new goals be developed for ESY services? No. ESY services address the maintenance of previously learned skills, as identified in the current IEP. The intent of ESY services is not to teach new skills. Therefore, new goals should not be added to a student s IEP for implementation of ESY services. 10. How does the ARD committee determine the amount of ESY services for each student? The determination of the extent of services must be made on an individual basis after a thorough review of the student s specific ESY goals and objectives. 11. How do the least restrictive environment (LRE) requirements relate to ESY decisions? The requirements regarding placement in the least restrictive environment (LRE) during the academic year also apply to ESY. However, while ESY services must be provided in the LRE, a school Revised summer 2011 Page 14
is not required to create new programs as a means of providing ESY services to students with disabilities in integrated settings if the school does not provide services at that time for its non-disabled students; (Federal Register, Vol.64, No. 48, 1999, pg 12577). Therefore, LRE considerations that apply during the regular school year are not the same for ESY. The full continuum of educational options is usually not available during ESY and the school district is not required to create a program for that sole purpose. The school district is not prohibited from providing ESY services to an individual student with a disability in a non-educational setting if the ARD committee determines that the student could receive necessary ESY services in that setting. The characteristics of services, including location and LRE considerations, should be based upon the unique needs of the student. The IEP team should consider a flexible service model that takes those needs into account. For some students, the appropriate LRE could be at home with the other family members, receiving only very limited ESY services. 12. Where can ESY services be provided? Individualized ESY services could be provided in a traditional classroom setting: however, the location and nature of service delivery can vary with the needs of the student. Other appropriate service delivery options could include the following: School-based programs that vary in length of schedule Grouping of student with similar needs Limited student contact. Perhaps three to four times during the summer to prevent repression A period of time (1,2,3 weeks) just prior to the beginning of the school year Multi-school shared programs or services Community-based programs (e.g., parks and recreation activities) Home-based services provided by the parent and support by school personnel Revised summer 2011 Page 15
Some student may need services provided in the home or at an alternative location. Others might benefit most by providing training to the parent in advance of long breaks in regular school schedules. The teacher could provide materials and periodically monitor progress. Such home consultation prior to vacation and in intervals during vacation, if needed, could provide support and instruction to parents so as to prevent regression. It offers the additional benefit of increased opportunities for practice and generalization across settings. However, a school cannot simply chose to delegate its responsibilities for providing ESY services to parents. The option of home consultation would depend upon availability of parents throughout the ESY day, their desire to assist, and the complexity of their student s needs as well as many other factors. For other students and depending upon the nature of the skill to be maintained, a summer camp, recreational program, or a school s optional summer school program could provide opportunities for maintenance of skills. 13. Must the ARD committee consider the provision of related service as ESY services? Yes. The ARD committee must consider whether the students require related services, including transportation, in order to benefit from special education. 15. May a school provide a related service as a sole component of ESY services? Yes. When determining eligibility for ESY services, the IEP team must also review and consider related services. While a student may not need extended school year special education, that student may need extended school year related services in order to benefit from special education when school resumes during the school term. In this instance, one or more related services may be the sole component(s) of the ESY program. Revised summer 2011 Page 16
16. Who can provide ESY? It is necessary to use certified and qualified staff for ESY services. Noncertified staff can be used if they are trained and supervised by certifies staff. Staffing options might include supervised practicum students, supervised student teachers, supervised paraeducators, or contracted/ purchased services from agencies. 17. May the student s ESY services be provided in a school s optional summer school program? Yes. The summer school setting could offer unique and appropriate opportunities. For a student to enhance generalization of skills in a setting very similar to that of the regular school year, as well as provide frequent practice for maintenance of skills. However, ESY services must be tailored to the unique needs of the student and cannot be based solely on availability of services during the summer. The IEP documentation should provide justification of how the summer school program would address the student s IEP needs. The amount and the duration of ESY services cannot be limited arbitrarily by the school summer school schedule. It is recommended that special education personnel collaborate with summer school staff, informing them of needed modifications and accommodations based upon the student s needs. The ARD committee will determine and document goals to be addressed by ESY services and delivered through summer school programming. Progress reports are required at least as often as those provided to the parents of students without disabilities. Note: You must still complete Documentation of Regression Form to justify the recommendation for ESY. 18. What are the responsibilities of a school for providing modifications and accommodations for a student with a disability who chooses to attend summer school and is not in need of ESY services? All students with IEPs are entitled to accommodations. Since these students are also eligible under Section 504 of the Rehabilitation Act of 1973, it is best practice to consult with the summer school Revised summer 2011 Page 17
teachers and inform them of the needed modifications and accommodations as stated in the student s IEP. Under Section 504, a school cannot discriminate against a student with a disability in any program and/or activity offered by that school. The summer school course is a program offered by the school; therefore, the school cannot discriminate against the student because of his or her disability. 19. Is ESY the same as summer school? The following table provides a comparison of ESY services and summer school SUMMER SCHOOL Definition: An optional or permissive program provided beyond the regular school year. A school may elect whether to operate summer classes Purpose: Teaching new content or enrichment and/or offering recreational or academic opportunities not present during the regular school year. Students with and without disabilities benefit from additional educational opportunities. Cost: Free or on a fee basis Duration: Typically operated on a set schedule for a number of weeks during the summer for al those who participate. Location: General education setting; based on needs and interests of students. Eligibility: A student s participation does not depend on a committee s determination of need. EXTENDED SCHOOL YEAR SERVICES Definition: Services required b IDEA 2004 are to be provided beyond the traditional school year for any student with a disability who needs special education services and/or related services in order to receive FAPE Purpose: Ensuring a student s meaningful progress during the regular school year (FAPE) by maintaining learned skills and preventing loss of critical skills. If services are not provided, student s skills are temporarily or permanently lost, jeopardizing progress. ESY services are not provided for the purpose of helping student with disabilities advance in relation to their peers Cost: Free to parents Duration: Schedule, setting, and extent of services designed to meet the individual needs of a student in order to ensure FAPE. The amount and duration of services cannot be determined arbitrarily by a school s summer school schedule. Location: Varies depending upon each student; the IEP has more flexibility regarding location of services Eligibility: ARD committee determines need ad extend of services to meet the unique needs of the student. Revised summer 2011 Page 18
20. How does an ARD committee document ESY services? Documentation of ESY services should specify which goal(s) will be reinforced during ESY services. Documentation should describe the type of services (such as direct instruction, specific related services, consultation, or supervision), the beginning date of services and the ending date of services, the minutes per week of each service, service provider, and where the service will be provided. 21. What process should be followed if the parent does not agree to the student receiving ESY services? Some parents will decide not to have their child participate in ESY services, even if hey qualify. If the family chooses to reject all ESY service options, the team should document this decision. Because compulsory attendance laws do not extend to days beyond the traditional school year, a school cannot compel a student to participate in ESY services. 22. What process should be followed if the parent initiates a request for ESY services or a change in the extent of those services outside of the IEP meeting? If a parent requests reconsideration of need for or extend of ESY services outside of the team meeting and the team has already made a determination regarding ESY services, then the school must provide prior written notice to the parents, documenting either the date and time of a new IEP team meeting to reconsider the request, or denial of the request along with reasons for the denial. State policy strongly recommends that the parties attempt to resolve any disagreements at the school level through informal means, working through local administration whenever possible. In addition to informal dispute resolution processes, a parent has the right to file a complaint or to request a due process hearing when disagreeing with an ARD committee s decision regarding ESY. Revised summer 2011 Page 19
23. What is the status of a student s ESY service when there is a dispute over proposed services? It is important for the ARD committee to make decisions regarding the provision of ESY services early enough in the school year to allow parents the time to request administrative remedy when they disagree with a committee s denial of services. If the parents disagree with the decision of the committee not to provide ESY services and the timing of the decision does not allow sufficient time to obtain resolution of the dispute, then it is recommended that the student be provided with ESY services pending the outcome of the dispute resolution process. Parents need to be given reasonable amount of time after being notified to express their disagreement with the denial of ESY services. It is recommended that a school develop a policy regarding timelines that are reasonable. It is also recommended that the policy be clearly explained or made known to the parent. If the parents do not provide a timely response, then the school should not be required to provide the student with ESY services pending the outcome of the dispute resolution process or administrative proceedings. 24. How are ESY services determined for a student turning three over the summer months? A student with a disability must receive FAPE no later than his or her third birthday. The IEP or IFSP will specify whether services must be initiated on the student s third birthday for students who transition from the Part C to the Part B program if the student turns three over the summer. Measuring the vulnerability of skills acquired by young students is difficult. It is not necessary or advisable to wait until delays occur before providing services to very young students. When a student with disabilities reaches their third birthday during the summer, necessary personnel may not be available. Therefore, personnel should ensure that a meeting is held at least 90 days prior to the third birthday while necessary personnel are available. The school must assume responsibility for planning and directly implementing services to the initiated on the student s third birthday. Revised summer 2011 Page 20
25. Can students with disabilities who have been placed by their parents in private school receive ESY services? The school district makes the decisions regarding services for students with disabilities placed in private schools by their parents. If a determination is made that ESY services is the service or one of the services that a school will offer, federal funds could be used for this purpose. EXTENDED SCHOOL YEAR (ESY) IS: Based only on the individual student s specific critical skills that are critical to his/her overall educational progress as determined by the ARD committee. Designed to maintain student mastery of critical skills and objectives represented on the IEP and achieved during the regular school year. Designed to maintain a reasonable readiness to begin the next year Considered as a strategy for minimizing the regression of skill, skill proficiency that existed at the end of the school year. Deliverable in a variety of environments and structures such as: a) Home with the parent teaching and staff consulting b) School based c) School based with community activities d) Related services alone or in tandem with the above Revised summer 2011 Page 21
EXTENDED SCHOOL YEAR (ESY) IS NOT: mandated 12-month service for all students with disabilities. SSI intervention. If a SE student must attend summer school as accelerated instruction for success on the third attempt on state assessment, it must be documented as such on the student s ARD even if the student will receive this instruction in a self-contained unit setting. required for the convenience of the school or parents and, therefore, cannot serve as a day care or respite care service. required or intended to maximize educational opportunities for any student with disabilities. necessary to continue instruction on all the previous year s IEP goals during the ESY period, rather, the focus should be on those specific critical skills where regression, due to an extended vacation period, may occur. to be considered to help students with disabilities advance in relation to their peers. for those students with disabilities who exhibit regression, which is solely related to medical problems resulting in degeneration, to transitional life situations such as divorce or death of a family member. This type of regression is not due to the interruption of summer vacation. required solely when a child fails to achieve IEP goals and objectives during the school year. to provide a child with education beyond that is prescribed in his/her IEP goals and objectives. Revised summer 2011 Page 22
Examples Revised summer 2011 Page 23
Extended School Year (ESY) Eligibility Profile Student Name DOB Grade Home School Service School School Year Criteria #1 Criteria #2 Criteria #3 Criteria #4 Criteria #5 ESY Factors That May Be Considered Regression Recoupment Is the amount of time required to relearn skills or behaviors so significant that or interferes with the student s ongoing educational process? Check area(s) to be considered for regression/recoupment evidence: Mobility and Muscular Control Functional Academics Toileting Receptive/Expressive Communication Feeding and Eating Aggressive, Threatening Behavior Dressing Unusual or Repetitive Habits Extreme Reactions to the Extreme Disruptions of Relationships with Others Environment Withdrawal or Inattentive Behavior Reference Chart for Average Recoupment (take individual learning rate into account) Length of Break Approximate Average Recoupment Time 11-12 week break (summer) 20-30 (instructional days (4-6 weeks) 2 weeks (winter) 3-4 instructional days 1 week (spring) 2 days To qualify for ESY, the period of recoupment following the beginning of review and re-teaching must significantly exceed the guidelines. Degree of progress toward IEP goals and objectives (if progress is very slow, student may need ESY services in order to continue to make progress) Emerging skills / breakthrough opportunities (e.g. student just beginning to communicate, accomplish self-care skills, read or write) Interfering Behavior does the child s behavior interfere with his or her ability to benefit from special education Special circumstances (e.g. student missed significant amount of time because of illness, surgery or other personal circumstances, student at risk of more restrictive placement, student moving from restrictive placement to inclusive placement, vocational training, facilitate transition OTHER FACTORS / COMMENTS: YES NO Student eligible for ESY services: Yes No Revised summer 2011 Page 24