Updated August 20, 2021
ASHA is here to assist audiologists and speech-language pathologists, who are key early intervention (EI) professionals, in modifying individualized family service plan (IFSP) services, planning alternate interventions, and supporting staff in learning new methods of remote and in-person service delivery.
Find information on states’ responsibilities to infants and toddlers with disabilities and their families/caregivers PDF], and to the staff serving these children in Part C programs, from the U.S. Department of Education (ED). Current ED guidance allows states to develop temporary solutions and exception policies to initial evaluation, assessment, re-assessment, and transition timelines without risk of noncompliance with federal regulations while the pandemic is ongoing.
State governments are considering federal guidance from the ED and the Centers for Disease Control and Prevention (CDC) as they take steps daily to address COVID-19 for their constituents, making this a highly fluid situation. Because of this, ASHA strongly recommends that members also look to leaders in their states, including their state/local health departments, EI lead agencies, local EI programs, and state licensing boards for specific information about serving their children and families/caregivers. Check ASHA's state-by-state information to find contact information for various state boards and agencies and current telepractice regulations.
Under ED guidance, if the office of the state lead agency or EI program or provider is closed, EI services under Part C of the IDEA are not required. If the office remains open, and services cannot be provided in a particular location (e.g., the child’s home or childcare setting) or by a particular provider, the state lead agency must ensure continuity of services. If an office has closed, after it reopens the IFSP team determines whether the IFSP is still appropriate or needs updating.
If a state’s EI system is open and operational, determining specific methods of service delivery (e.g., alternate location, different service provider, consultative services, telepractice) should be done on a case-by-case basis, consistent with the most updated public health and safety guidance, in coordination with the child, family/caregiver, and state lead agency or EI program/provider. You also need to follow existing payer policies and state and federal regulations for telepractice.
There are special considerations for telepractice in EI settings. In addition to the child’s clinical presentation, clinicians need to consider their skills/competency (in various techniques, such as coaching, how families/caregivers feel about telepractice delivery, their access to technology, and their current responsibilities at home.
Visit ASHA’s telepractice COVID-19 page for more resources.
As pandemic-related restrictions ease, the process of resuming in-person services will look different across state and local EI systems. One constant is that the health and safety of EI providers and the children and families/caregivers they serve remains paramount. Expect that recommendations, requirements, and considerations will need to be adjusted over time, given evolving Part C program regulations and health metrics in each community.
The EI population is one of the most challenging for providing in-person services while trying to follow lead agency, CDC, and other public health guidance. Recognizing that infants and toddlers will not be vaccinated and most likely will not use masks or understand social distancing, providers will need to consider ways to raise their level of protection and that of the other adults and older children in the home. The level of risk must be weighed against the benefits of in-person services. Asking families/caregivers what they are comfortable with and establishing procedures for wellness checks before visits is critical as well. Families/caregivers and providers need to be in agreement regarding in-person visits and expectations, per informed consent.
Ultimately, providers need to determine if they can deliver services in a safe and effective manner using established protocols and/or alternative means. This may take some creative problem solving, such as
If providers are not able to modify services, they will want to discuss with their IFSP teams, explain the risks and/or compromises in service to families/caregivers, and consider obtaining informed consent. For some families/caregivers, it may be helpful to continue via telepractice unless there are mitigating factors.
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