Report 2015-112 Recommendation 12 Responses

Report 2015-112: Student Mental Health Services: Some Students' Services Were Affected by a New State Law, and the State Needs to Analyze Student Outcomes and Track Service Costs (Release Date: January 2016)

Recommendation #12 To: Riverside County SELPA

To ensure that it complies with federal and state requirements, Riverside should develop a process to ensure that IEP teams record, in student IEP documents, the rationale for residential treatment and any potential harmful effects of such placement.

6-Month Agency Response

Rationale for placement and potential harmful effects is documented within the IEP. RC SELPA's current IEP forms are in accordance with all federal and state mandates. The components of the IEP that address the required rationale include:

1) Describe how student's disability affects involvement and progress in general curriculum ... (Eligibility Page)

2) Describe areas that student will not participate in the general education environment ... (Educational Setting Page)

3) Describe "why" student will not participate in the general education environment ... (Educational Setting Page)

4) Describe the consideration given to any potential harmful effect on the child or on the quality of services that he or she needs ... (Educational Setting Page)

Evidence supporting the full implementation of this item includes copies of student IEPs reviewed and monitored monthly by RC SELPA Mental Health Manager, Case Manager, and Program Specialist in the same manner that RC SELPA will monitor justification of placement decisions. In the event RC SELPA Mental Health Manager or Case Manager is not present at IEP meeting and justification of harmful effects is determined not adequate based on document review, LEA Special Education Director will be notified within 48-hours of finding and recommended corrections.

California State Auditor's Assessment of 6-Month Status: Fully Implemented


60-Day Agency Response

The Riverside County SELPA has implemented the process outlined in "Mental Health in Schools". In April 2015 we also adopted a document about "Research on Intensive Mental Health Services". We have reduced the number of residential placements by implementing intensive community based services. We have implemented an ERMHS Needs Review Form for LEAs to submit to the SELPA to access the centralized funds set aside for Tier 3 to ensure interventions have been implemented at lower levels of care. We also require justification and evidence of consideration of potential harmful effects. Evidence includes SELPA documents, the form, and sample training materials.

California State Auditor's Assessment of 60-Day Status: Pending

Riverside's guidance materials do not directly address the need to document in the student IEP the rationale for residential placement and the potential harmful effects of such a placement. Further, Riverside has not yet developed a process to ensure that this documentation occurs. Therefore, this recommendation is still pending implementation.


All Recommendations in 2015-112

Agency responses received are posted verbatim.