Can OT Serve on Speech-Only IEPs?

Have you ever wondered if OT can serve on speech-only IEPs? Like many questions in special education, there’s not an easy yes or no answer. But by understanding the law and background behind this question, you can determine if this is the right option for your student.  

What is a “Speech-Only” IEP?

First off, let’s define what people mean when they say “speech-only” IEP. This comes down to the special education eligibility categories. Basically, for a child to receive special education, they must have an educationally-related disability. These categories are fairly broad and cover a lot of different types of disability – from Autism to Orthopedic Impairment. Some students may even fall into two or three categories depending on their disabilities.

One of these eligibility categories is Speech and Language Impairment (SLI). So when you hear “speech-only” IEP, it means an IEP for a student that qualifies for special education under this eligibility, but no others. 

How is Speech and Language Impairment Defined?

Per the Individuals with Disabilities Education Act (IDEA), the Speech and Language Impairment eligibility is defined as follows:

(11) Speech or language impairment means a communication disorder, such as stuttering, impaired articulation, a language impairment, or a voice impairment, that adversely affects a child’s educational performance.

Pretty short, right? While some states further define this eligibility and offer specific qualifying scores, in most areas this eligibility determination is left up to the speech-language pathologist’s professional judgment. 

Let’s put a pin in the SLI eligibility for now and take a look at what IDEA has to say about occupational therapy.

IDEA’s Definition of Occupational Therapy

IDEA defines OT as:

“Occupational therapy—

(i) Means services provided by a qualified occupational therapist;

(ii) Includes—

(A) Improving, developing, or restoring functions impaired or lost through illness, injury, or deprivation;

(B) Improving ability to perform tasks for independent functioning if functions are impaired or lost; and

(C) Preventing, through early intervention, initial or further impairment or loss of function.” 

Again, you’ll notice this is a fairly short and vague definition. 

Further, IDEA goes on to state that certain things related to OT must be included in an IEP:

“(4) A statement of the special education and related services and supplementary aids and services, based on peer-reviewed research to the extent practicable, to be provided to the child, or on behalf of the child, and a statement of the program modifications or supports for school personnel that will be provided to enable the child—

(i) To advance appropriately toward attaining the annual goals;

(ii) To be involved in and make progress in the general education curriculum in accordance with paragraph (a)(1) of this section, and to participate in extracurricular and other nonacademic activities;

(iii) To be educated and participate with other children with disabilities and nondisabled children in the activities described in this section;”

You’ll notice nowhere in these definitions does IDEA require specific qualifying scores or other criteria to receive occupational therapy services. This is by design. The idea is that a student should be able to receive whatever services are educationally necessary to them, and this is always an individualized decision. 

In fact, despite sorting students into various eligibilities, these categories aren’t actually supposed to impact the services a student is eligible to receive at all.

So why sort kids into these categories in the first place if they don’t (or at least shouldn’t)  impact their services, goals, placement, and accommodations? That’s a great question that again, doesn’t have an easy answer.

But regardless, the takeaway here is that occupational therapy can serve a student no matter what their IEP eligibility is – as long as it is shown to be educationally necessary.

But if that was the be-all, end-all – this would be a much shorter article.

ot serve on speech-only IEPs

OT on Speech-Only IEPs in Practice

So now let’s move beyond theory to actual practice. When we say a student qualifies for special education under SLI – and only SLI – we are saying that they have no other educationally related disabilities.

This should already be raising red flags for you because in theory – kids who only have articulation, voice, or language disorders don’t tend to require occupational therapy for those concerns.

While there is some connection between delayed fine motor skills in the hands and certain speech disorders (oral motor skills are fine motor skills too), this represents a minority of kids.

Yet, in practice, I’ve known many, many students who were receiving occupational therapy services that were on an SLI-only IEP.

Now, which do you think is more likely? That these students all fit into that previously mentioned minority? Or that perhaps some of these students are miscategorized? 

If a student supposedly only has a language disorder, but is also having trouble with writing, academics, transitions, and sensory processing – maybe there’s something deeper going on there. 

And again, remember that OT is defined by IDEA as a related service. So technically, you’re supposed to be supporting and relating to the special education that they’re already receiving. This is hard to do when supposedly the only other service the student requires is articulation therapy. 

Okay, but wait. Why does this matter? If the student needs OT, isn’t it a good thing that they’re getting it? Since the eligibility categories don’t impact services, why should we care?

This hits another point where what is true in theory doesn’t turn out well in practice.

What Gets Missed

So, going back to those eligibility categories set out by IDEA. You may think that whenever a student is recommended to be tested for special education, these categories are all equally considered and the most appropriate ones are chosen.

But that doesn’t really make sense. There’s no need to make a student prove they’re blind or deaf through school-based testing for example – medical info from their doctor will suffice. And if your student is cool as a cucumber, you probably already know they wouldn’t qualify under Emotional Disturbance. 

So in reality, the IEP team only looks for eligibility in the areas in which they already suspect the student of having an educationally-related disability.

And that’s all well in good, but in this case, it leads to kids getting missed.

Take a new general education kindergarten student, for example. Say their teacher notices within the first few months of school that their speech is delayed compared to their peers. This teacher does their due diligence and puts in a referral to the speech-language pathologist. The SLP tests them and finds that they do qualify for special education under the SLI eligibility, and that they require speech and language services.

This isn’t an uncommon story, and luckily, for many kids, it really is all that they need.

But here’s where things get dicey. Take that same kid and follow them throughout the rest of their kindergarten year. Their speech improves somewhat, but they struggle in other areas. When they get to first grade, their teacher notices their handwriting is illegible compared to their peers.

Because this student is already eligible for special education, they can now start receiving occupational therapy. So, a referral is sent, the OT tests, and again determines that they require occupational therapy services.

But, as time goes on, the OT and SLP working with the student still have concerns. The OT notices that the student improves with copying letters, but still isn’t writing anything independently. They find that the student still can’t identify all of their letters or letter sounds. They aren’t reading, and their general education teacher notes that they’re struggling badly in math as well.

In theory, the OT now has grounds to suspect that the student has a further disability, and legally should recommend academic and cognitive testing done by a school psychologist or diagnostician. 

In practice, the OT is so busy that she doesn’t get around to this referral for a few weeks. When she does, that school psychologist is overworked and already has too many evaluations on her plate. Eventually, a Child Study Team (CST) is formed. More data collection is recommended. The general education teacher is given strategies to implement. The student makes a little progress. Then they slide back down. Their struggles are blamed on other factors, like attendance, home life, and lack of exposure.

Before you know it, it’s second grade, and this struggling student has started to internalize that they aren’t good at school or as smart as the other kids. They stop trying as hard. They aren’t paying attention because they don’t understand the content anyways. They start distracting other students and acting out in class.

Eventually, this kid gets tested by the full team and immediately and obviously qualifies under the Specific Learning Disability eligibility. Academic support is recommended in all subjects. Accommodations and modifications are put in place.

But by that point, some damage has already been done.

Damage that could’ve been prevented if this student had a comprehensive assessment when they first exhibited signs of difficulty. 

This isn’t an uncommon story.

How We Got Here

So why is this happening? Well, the lack of funding for special education is probably the largest factor. Districts have a legal obligation to test students in all areas of suspected disability, but in practice, this often gets put off due to lack of appropriate staffing.

Another issue is the lack of appropriate eligibility categories for younger students. While IDEA defines a Developmental Delay eligibility that many of these inappropriately-identified SLI students would fall into, using this eligibility category is optional and left up to the states.

This means that many states and districts don’t utilize this category at all, or severely restrict it.

But even without the perfect categories, we’d be better off if everyone was following the law and adding whatever services a student needs to their IEP, regardless of eligibility.

But in practice, I’ve only seen academic support added for students on SLI-only IEPs a handful of times. 

Of course, not every student who struggles academically really does have an educationally-related disability. There can definitely be other factors. (Also, we should be supporting kids who are struggling regardless of if they have a disability or not – but that’s a whole other huge conversation.)

But the special education testing and eligibility process is designed to rule out these other factors. The problem is that kids aren’t even getting tested in the first place.  

What OTs Should Do with Speech-Only IEPs

So, the short answer to this very convoluted question is yes, OTs can absolutely serve students on speech-only IEPs. And if that student really needs school-based OT, you should find a way to see them. 

But it can’t stop there. OTs should advocate for a full and comprehensive assessment anytime they are referred to a student who currently only qualifies under SLI. This means that OTs shouldn’t be the only ones to test – the school psych and special education teacher should also be included. 

Some districts won’t like this and you will receive pushback. Don’t get discouraged. This is a battle worth fighting. 

Perhaps it will be the case that the student really does only require speech and OT. But either way, you’ll be able to feel confident in knowing you did your due diligence in getting this student the support they need and are entitled to. 

And that type of advocacy is one of the truest forms of OT.

ot serve on speech-only IEPs

Being a school-based OT isn’t easy. This is just one of many questions in special education that don’t have an easy answer and reveal larger inequities in the system. If you’re looking for support with tricky situations like this one, come join us in The Dynamic School OT Course. You’ll learn everything you need to know about laws, common practice, and advocacy to become the most effective therapist you can be for your students.

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