Information you should know to understand the changes to the law and its impact on postsecondary education.
Q & A - Frequently Asked Questions about the SOP
Q: What is SOP?
A: Section 614 of the IDEA 2004 indicates that as of July 2005 all special education students who leave secondary education through graduation or exceeding state age eligibility are to be provided with a Summary of Performance (SOP) to use as they pursue their transition goals. The SOP is to be developed in lieu of an exit IEP, with which many DSS personnel are familiar, and is designed to provide useful information to agencies and schools to which the exiting student might go next.
The language in Section 614 mandates secondary personnel to provide “recommendations on how to assist the child in meeting the child’s postsecondary goals” IDEA § 614, H.R.1350, (c)(5)(B)(ii).
Q: What is the SOP Template?
A: A multidisciplinary group of secondary and postsecondary education representatives developed an SOP template to address concerns raised by IDEA 2004. They wanted to attempt to ensure that secondary educators would develop a thorough SOP, and not just some cursory comments verifying a student’s disability.
Please see the next section, “Historic Perspective and Process” for a full explanation of the development of the SOP Template.
Q: Is the current SOP Template at the AHEAD website a final draft?
A: Absolutely not; that is why AHEAD is involved and wishes all concerned individuals look at it closely and submit thoughts.
Q: Is an SOP Template absolutely needed?
A: Section 614 of IDEA 2004 requires the SOP for students exiting the special education system but does not spell out what is needed in the document. Post-secondary education is not subject to this legislation; however, it may be impacted by it. As each state and/or local educational agency works to define the SOP for its own purposes, AHEAD feels it is in the best interest of exiting students, their parents, and disability professionals to be involved in a collaborative effort to identify what to include in an SOP to facilitate the transition from secondary to postsecondary education. A rubric for the SOP is not mandated by the federal government nor by any other body, including AHEAD.
Q: Does use of a SOP Template force postsecondary professionals to:
* lower their standards for disability documentation?
* provide students with the accommodations and modifications offered in public school or those that would maximize the student’s success?
A: Absolutely not. The laws that govern postsecondary are ADA and Section 504, which are not at all special education related; they are access and non-discrimination based. The SOP is seen, however, under IDEA as a guidance document that students who have received special education services during their K-12 education will take with them to their next destination, which for many will be a college or university setting.
Q: The current draft of the SOP Template uses terms related to students’ “success” throughout the document. Isn’t the role of the DSS professional to ensure access and not success?
A: The SOP Template was composed by a multidisciplinary team and reflects language used by K-12 and postsecondary entities, thus the use of words like “success.” While DSS personnel have traditionally focused on access to higher education in following the mandates of 504 and the ADA, many have also become involved in their campuses retention efforts, and have played a kind of role in students’ success, even if it has been peripheral. AHEAD encourages its members to explore this concept, while continuing to support a thorough understanding of the ADA and 504 in higher education.
The SOP Template is a work in progress; your comments about the language and format are encouraged.
Historic Perspective and Process
In advance of the reauthorization of IDEA, AHEAD wanted to be proactive and monitor the process closely knowing that changes in the K-12 special education arena typically have had, at least indirect if not direct, impacts for disability professionals in higher education. AHEAD followed the legislation through the services of a professional firm in Washington, DC that regularly attends hearings and meets with congressional members on educational topics and was also in dialogue with other organizations that shared interest in the reauthorization proceedings. Some of you may have been aware about the activities of some of these other organizations such as the National Joint Committee on Learning Disabilities, the Council for Exceptional Children and PACER. Much discussion, as is often the case, centered on the proposed changes as they would relate to students with learning disabilities.
President Bush signed the reauthorization, which took well over 18 months to finalize, in December 2004. Following signature, the period to develop regulatory language that would form the basis of guidance and mandates for the states as they implement IDEA 2004 began. The regulations came out recently and can be reviewed at The National Center for Secondary Education. The National Center for Secondary Education and Transition at the University of Minnesota put together a wealth of information including a comparison of the language between IDEA 1997 and IDEA 2004. We encourage you to read the particulars of the new regulations.
In the summer of 2004, at the AHEAD Conference in Miami, representatives of 12 national organizations, representing a broad compliment of stakeholder groups, met to discuss expected changes to IDEA. Again AHEAD was at the table as a leader and active participant regarding an issue that directly impacts our field. Additionally, (1) since AHEAD members around the country are active on state transition committees, (2) AHEAD conferences typically have a number of sessions addressing transition issues, and (3) AHEAD members often express concern about secondary personnel and parents not understanding the requirements of postsecondary education, the AHEAD Board of Directors saw this collaboration as an opportunity to impact and educate. It was generally known at that time that the new regulations would include features specific to documentation and transition.
In the fall of 2004, AHEAD was one of a number of organizations that addressed the transition features of the expected IDEA reauthorization in detail. Through continuing collaboration, a template for a model Summary of Performance (SOP) that would be helpful to students, parents and disability service providers in postsecondary settings was developed. After a series of revisions, the SOP Template was posted to the AHEAD Website for comment and in anticipation of refinement. The SOP Template attempts to address 1) the recognized need to have comprehensive information on the SOP, 2) the trend that indicates that diagnostic testing will be less and less “fresh” over time, 3) the fact that information contained in the SOP will, in many cases, not be sufficient to meet the standards of postsecondary disability documentation and/or documentation of the sort required by testing agencies.
Significant Changes in IDEA 2004 with Potential Impact on Higher Education
These changes have been made and are included in the new legislation (emphasis added):
1. Triennial assessments: In part to address realistic concerns that special education teachers and others involved in assessments spend an inordinate amount of their time on paperwork and to reduce cases of unnecessary testing, IDEA 2004 continues the removal of the mandatory requirement for testing children in special education every three years established in the 2000 reauthorization. Assessments will now be done, not on a cyclic basis as in the past but when deemed appropriate by the special education team.
2. Transition: IDEA has for some years included the requirement that students have a transition component to their IEP. IDEA 2004 continues this but now says that it should begin at age sixteen (16) rather than fourteen (14).
3. Specific Learning Disabilities: IDEA 2004 has changes in this domain. While in previous legislation a child had to demonstrate a severe discrepancy between achievement and aptitude, the new language removes this requirement in recognition of the fact that often students had to fail repeatedly before they could be identified as having a specific learning disability. For more information on this you may want to go to www.ncld.org.
4. Exit assessments: IDEA, while strongly endorsing and mandating that all students in special education have transition plans as they conclude their K-12 education, has never stated that complete reassessments would be routine for exiting students. In higher education we have often encouraged parents to ask for such a reassessment to obtain updated diagnostics; parents have had varying degrees of success in making these requests.
5. Summary of Performance: The IDEA 2004 language indicates that all exiting special education students are to be provided with a Summary of Performance (SOP) to use as they pursue their transition goals. The SOP would then be in lieu of an exit IEP and designed to provide useful information to agencies and schools to which the exiting student might go next.
Consistent with AHEAD’s mission, “…promotes leadership and exemplary practices”, intentional effort was made to be at the table as a participant in the IDEA reauthorization process. The other option was to passively accept the results determined by others. AHEAD’s involvement in drafting a template for the newly required SOP:
As an outgrowth of the Miami meeting of organizations monitoring the IDEA changes, AHEAD began to ask how the new SOP would impact disability services in postsecondary institutions. Through a close examination of the language in Section 614, it became clear that the SOP portion of the regulation was brief and open to considerable interpretation. Recognizing that many students coming to colleges and universities in upcoming years would come without recent IEPs or test results, the national organization reps/participants thought it wise to draft a proposal of what a comprehensive SOP should include. AHEAD was active in the crafting of what has come to be called the SOP Template; again, mindful that this document would be just one piece that students would bring to colleges and universities for review in the disability determination process. Those who drafted the SOP did so attempting to address the K-12 mandate while keeping in mind the needs of postsecondary understanding that the SOP alone may not satisfy documentation requirements for eligibility under 504/ADA in the higher education arena.
The SOP Template that is posted on the AHEAD Website stems from the detailed discussions and collaborative efforts among many professionals in the fields of disability services and special education.
Both AHEAD members and non-members are invited to review the SOP Template and contribute feedback via email to IDEA2004@ahead.org The other organizations involved in the development of the SOP Template are, like AHEAD, asking for input from their stakeholders on it.
What will AHEAD do with the SOP feedback it receives?
Richard Allegra, the Associate Executive Director of AHEAD, is compiling comments on this vital topic. The semi-qualitative report of these comments will be posted to the AHEAD Website when completed for all to view. In addition to a summary analysis of these comments, he will gather input at two open forum sessions at the upcoming AHEAD Conference. Those forums will be on Wednesday, August 3, 12:45 - 2:00 pm and Thursday, August 4, 7:30 - 8:45 am. Members wishing to express their thoughts, and listen to those of others on the reauthorization of IDEA and its implications for disability professionals in postsecondary education are encouraged to attend. The Board of Directors will review the comprehensive summary of responses and share its thoughts with the membership; this will likely occur by the end of September.
After taking time to review the resources presented and the draft SOP, please take time to e-mail your feedback on the content of the draft SOP to IDEA2004@ahead.org
In addition, people who attend the upcoming AHEAD Conference in Milwaukee will have an opportunity to discuss IDEA reauthorization and the new required Summary of Performance as well, of course, the proposed SOP Template. There will be two open forum sessions at the Conference on Wednesday, August 3, 12:45 - 2:00 pm and Thursday, August 4, 7:30 - 8:45 am. Come to a session, listen, learn, and contribute. We are all made better through collaboration.
Click here to learn more about IDEA 2004 and the SOP.