Administrative Advisory SPED 2016-1

SIMS Data Reporting

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The purpose of this advisory is to clarify both the purpose of several student information management system (SIMS) data elements and appropriate responses for certain situations. The situations that this advisory addresses include:

1. Reporting of the disability category of "Developmental Delay"
2. Reporting special education placement when a student is six (6) years of age
3. Reporting a student who has rejected special education services previously provided
4. Reporting a student with an IEP who is not attending school but who has not formally withdrawn
5. Reporting a student with an IEP who is living in a residential school placed by DCF
6. Reporting initial evaluations

Generally, I want to ensure that readers of this advisory fully understand that correctly reporting data is related to, but not the same as, appropriately serving students who are eligible for special education. Throughout this advisory, to the extent that I see the confusion, I will make efforts to clarify that difference.

Section 1: Reporting of the Disability Category of "Developmental Delay"

In the special education regulations at 603 CMR 28.02 the term "Developmental Delay" is defined, in part, as pertaining to students between the ages of 3-9. The upper age limit of nine (9) years of age is also consistent with the upper age limit under federal regulations.¹ One of the required data elements that must be collected for federal reporting purposes is type of disability. The report to the USDOE does not allow continued use of "Developmental Delay" (DD) beyond age nine (9). Therefore, our state collection of this data will also not allow reporting a student in the category of DD beyond age 9. We have now set our system to show any reporting of this category for eligible students beyond age 9 as an error. A district will need to decide what action it will take to resolve this error. In the long run, we expect districts to ensure that general procedures include appropriate identification and reporting of students in one of the other types of disabilities for all students previously identified as DD who are about to be older than nine (9) years of age.

This is a good example of a difference in data being different than practice in some situations. While a school district may find that it makes more sense to retain a student's disability identification as DD beyond age nine because of the timing of the student's scheduled annual review-- that decision results in a data reporting error. Data reporting for DD must meet specifications related to student age.

In the few incidences where there is a conflict between practice and data reporting, the data reporting conflict must be resolved in one of two ways:

1. The first (and preferred) choice: School district personnel may identify a different disability category based on their best knowledge of the student and report that category in DOE036 (Nature of Primary Disability). This data resolution is the best choice when a student is clearly disabled and the district strongly believes the student will continue to be eligible for special education beyond the child's 10th birthday. N.B. The district's reporting of a different disability category for the student in SIMS resolves the data issue, but does not replace the requirement for the Team to consider and make a decision about the student's disability identification. The district must take the necessary steps to determine with the Team (including the parent) the correct disability category for this student after the student turns 10 years of age and the DD category is no longer applicable. At the next data input period, the disability choice can be corrected, if necessary.
2. The second choice: The district may report the student as no longer eligible for special education by using DOE034 (Special Education Placement) and Code 01 (not currently a special education student but was previously during the school year). The other special education elements should remain populated with the data for the student for the remainder of that school year. DOE036 may be coded as Developmental Delay, DOE038 should be coded as previously, and DOE040 may be coded as either 03 - re-evaluation found the student no longer eligible, or 09 - student is eligible but parent declined. Once appropriate evaluation and Team decision-making has occurred, the district can change these choices at the next data collection period (if the student remains eligible).

Section 2: Reporting Special Education Placement When a Student is Six Years of Age

Similarly to Section 1, this section deals with a placement report change that takes place when a student turns six (6) years of age. The early childhood placement codes for 3-5 year olds (DOE032) are different than those for school age children from 6-21 years old (DOE034). Again, the Department understands that in practice, a child may stay in an early childhood setting beyond age five, , but there are no data exceptions that allow it to be reported this way. The data must be reported appropriately based on the age of the student.

Below is a crosswalk between the relevant placement categories of DOE032 and DOE034 that may be used to appropriately report placement (using school age placement codes) for a six year old who remains in an early childhood setting.

N.B. The table above states that for a student who is six years of age or older and is only receiving special education services at a service provider location (with no other public education services provided), there are two choices based on whether the student is being served in a hospital or not. Any services provided in a hospital or associated medical clinic must be reported using code 70. If services are provided in a school or home or clinic that is not hospital-based, then reporting must use code 40 for this student.

Section 3: Reporting a Student Who Has Rejected Special Education Services Previously Provided

Our SIMS data system has previously used "exceptions" to allow districts to report students who have rejected² special education services, whether or not an evaluation was completed. The Department recognizes that there is a limitation with regard to the coding that fits this scenario in DOE040.

Currently, DOE040 has a code for a student continuing in special education, but not evaluated that year (Code 01) and a several codes for circumstances when the student has been evaluated (initial or reevaluation) and not found eligible. There is only one code that can be used when the student was found eligible but declined services (Code 09). According to prior practice, districts were to report DOE040 Code 09 only for initial evaluations. We have corrected the use of this code in SIMS so that DOE040 Code 09 should now be used for any instance when a student who was found eligible rejected services during the reporting period in question, whether or not an evaluation was completed prior to the rejection of services. This is an appropriate code only if the student has rejected all services on his/her IEP. DOE040 Code 09 should not be used if only one service is rejected among a number of services on the student's IEP. There is no need to report to the state in such a circumstance.

When a student (or his or her parent or guardian) has declined services, it is usually also appropriate to show the student placement in DOE034 (Placement for 6-21 year olds)³ as Code 01 (Not currently a special education student…but was during the current school year).

Section 4: Reporting a Student with an IEP Who is Not Attending School But Who Has Not Formally Withdrawn

Another data reporting issue arises with DOE012 (Enrollment Status at Time of Data Collection). Districts have stated their belief they cannot report students with disabilities who are age 16 or over (the end of compulsory attendance) as dropouts but must continue to report any student with disabilities as "enrolled" despite a students' continued "non-attendance." That belief is incorrect. Districts may and should report students correctly as a "dropout" if a student is not attending school if the student is 16 years old or older. All students, including students with disabilities, should continue to be reported as enrolled if they are younger than age 16, even if they are consistently not attending.

As required by G.L. c. 76, § 18, districts should have in place and be following procedures for contacting a non-attending student who is 16 years of age or older and/or his/her parent or guardian prior to a formal withdrawal to discuss the reasons for the student's nonattendance and to explain the options that are available to the student, if appropriate, prior to his/her withdrawal or choice to permanently not attend school.

If the district has had contact with the student and it is clear that the student has withdrawn, then the student should be reported as a dropout, using the applicable codes available in DOE012. If the district has tried multiple times to contact the student and been unsuccessful, but the student has not been attending for over a month with no explanation, then the district should use DOE012 code 36 (Dropout-and/or student status/location unknown).

N.B. For any student having an IEP at the time that he/she stops attending school, the district of residence must re-enroll a student without delay until the student is age 22, if he/she indicates a desire to resume special education services. If this occurs, the district may change the student's enrollment status at the next data reporting period.

Section 5: Reporting a Student with an IEP Who is Living in a Residential School Placed by DCF

An advisory was written on this subject a number of years ago⁴ which goes into greater detail about student placement by children in the care and custody of the Department of Social Services (now Children and Families, or DCF). While that advisory remains current, it does not address coding in DOE034 (Special Education Placement, ages 6-21).⁵

Sometimes DCF places a student with an IEP in an approved special education residential school for its own clinical reasons. This is true even though the student's IEP Team may have specified placement in a public special education day school setting or a private special education day school setting for educational reasons. If this is the case, and DCF makes a non-educational placement decision for the student to live in a residential school, the school district's responsibility for the "day school" portion of the student's placement continues.

Private and public special education day schools are equivalent programs under the Department's regulations. Therefore, even though DCF's placement of a student in a special education residential school for non-educational reasons may result in the student moving to a residential school location and receiving educational services in that setting, the move by DCF does not, by itself, alter the placement decision by the IEP team or change the type of special education placement in which the student is receiving educational services. If such move has taken place, and it is time for data reporting, the responsible school district should report the student in DOE034 using the Code 50 for a private separate day school (at the time of this advisory there is no public residential school approved in Massachusetts). The school identification code at DOE015 (School Identification Number) should be the code for the residential school.

Corresponding to the data reporting, the PL1 form (Special Education Placement Form) should also identify a private day school (even if the student was previously in a public day school) and should name the residential school where the student is currently receiving services. The Department recommends that districts annotate the PL1 form to state that the placement was non-educational and made by DCF. No district is obligated to identify the student's special education placement as "residential" simply because he/she resides in a residential school.

Section 6: Reporting Initial Evaluations

Special education evaluation results are reported in DOE040. Districts appear to have no difficulty using this data element correctly for students who are eligible for special education services or were eligible at one time. However, a large number of districts consistently do not use Code 02 at all. Code 02 reports initial evaluations conducted that found the student not eligible for special education. It is very important for both district level records and state level records to represent correctly the numbers of students who are initially evaluated each year. Evaluations take resources. School districts and the state must be able to see if we are using our resources well and, if not, how better to use them. Ultimately, the state is dependent on you appropriately reporting when a student is initially evaluated for eligibility for special education. I strongly encourage you to make sure that you also report for those students who are found not eligible using Code 02. Thank you for your efforts in this area.

I hope this information is helpful. As previously, all SIMS reporting inquiries for your district should continue to be addressed to the data collection support specialist for your district.

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¹ See 34 CFR Part 300.8(b)(1-2). Children aged three through nine experiencing developmental delays…

² Rejecting services may be accomplished by a student who has reached the age of majority saying that he/she does not want services; or for a student under age 18, by a parent or guardian rejecting services on the student's behalf.

³ Or DOE032 (Placement for 3-5 year olds) if the student in question is 3-5 years of age. The Code for either age is "01."

⁴ Administrative Advisory SPED 2004-4: School District Responsibility For Children in Special Education Day Schools Who Are Transferred to a Residential School by the Department of Social Services

⁵ Also, but rarely, DOE032 (Special Education Placement, ages 3-6)

Last Updated: August 31, 2015