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Guidance and Answers to FAQs on COVID-19 Compensatory Services

This page was updated on June 15, 2021. Updates are marked with an asterisk (*).

What are COVID-19 Compensatory Services?

In this guidance document, the term "COVID-19 Compensatory Services (CCS)" refers to services as determined by an IEP team needed to remedy a student's skill and/or behavior loss and/or lack of progress that resulted from an LEA's inability to provide Free Appropriate Public Education (FAPE) while using alternative instructional models due to the COVID-19 pandemic.  CCS should be considered only after the student receives services as set forth in their IEP for a period of time (“recoupment period”).  This will give the student an opportunity to recoup the lost skills or behavior or to make progress to the level(s) determined appropriate prior to the extended school closure.

What is the process to determine if a student eligible under the Individuals with Disabilities Education Act (IDEA) needs CCS?

As soon as appropriate, but no later than the first two weeks of resuming normal operations, the LEA should:

  • Gather baseline data on each student's current educational levels; and

  • Compare above baseline data to 2019-20 school year pre-COVID 19 progress monitoring data for each student to determine if there is a regression in skills and/or behavior patterns and/or a lack of progress.

As soon as appropriate, but no later than the end of the third month of school resuming normal operations, the IEP team should review the progress of any student who regressed while LEAs were using alternative instruction due to the COVID-19 pandemic and who received services since the start of the school year using multiple data sources. With this data, the IEP team should determine whether, and to what extent, the student recouped the lost skills and/or behaviors and/or has made meaningful progress. If a student is continuing to evidence a loss of skills and/or behaviors and/or failing to make progress due to the LEA's inability to provide FAPE while LEAs were using alternative learning models due to the COVID-19 pandemic, then the IEP team should determine whether and to what extent the student needs CCS. 

What factors and sources of data should an IEP team consider when determining if a student needs CCS?  

The IEP team should consider the following factors and sources of data collected while LEAs were using alternative instructional models due to the COVID-19 pandemic and during any period in which a student receives services:

  • Levels of academic and functional performance, including levels of performance on all IEP goals prior to the mandatory school closures as compared to the student's current level of performance as measured from the baseline data collection.

  • Information and observations from teachers, related services providers, parents, caregivers, and other family members.

  • The student's ability to access remote learning opportunities and special education services while LEAs were using alternative learning models due to the COVID-19 Pandemic.

  • The student's engagement in the learning process while the LEAs were using alternative learning models due to the COVID-19 pandemic. 

  • The amount of skill and/or behavior loss and/or lack of progress the student experienced while the LEAs were using alternative learning models due to the COVID-19 pandemic.

  • Historical data regarding the student's ability to recoup lost skills and/or behavior.

  • Services provided while the LEAs were using alternative learning models due to the COVID-19 pandemic. 

  • Data collected through progress monitoring and progress reports.

  • Results from informal and/or formal assessments.

How should an IEP team calculate CCS? 

The IEP team should calculate CCS on an individualized basis. The IEP team should consider the student's loss of skills and/or behaviors and/or lack of progress due to an LEA's inability to provide FAPE while LEAs were using alternative learning models due to the COVID-19 pandemic, as well as whether the student was able to recoup the lost skills and/or behaviors and/or to make meaningful progress during any period in which the student received services. If there is any remaining loss in skills and/or behaviors and/or lack of progress after the recoupment period, but no later than the first three months following school resuming normal operations, the IEP team should determine whether and to what extent the student needs CCS.  If the student needs CCS, the IEP team should determine the type and amount of CCS and how CCS will be delivered. CSS should not supplant the student's current IEP, and the IEP team should refrain from altering the least restrictive environment if CCS are offered during the school day.

*Are Local Education Agencies (LEAs) required to provide transportation to and from COVID Compensatory Services (CCS) for students with disabilities? 

Since CCS is not part of FAPE, transportation to and from CCS is only required if it is agreed upon by the student’s LEA and parent. If so, it is the responsibility of the student’s LEA. It is recommended that LEAs offer transportation to and from CCS, within reason, to ensure students have access to those services. CCS is the responsibility of the LEA in which the child lost skills or did not make meaningful progress, so any associated transportation is the responsibility of that entity. 

*May LEAs use ESSER funds to provide transportation to and from CCS? 

LEAs may use ESSER funds to pay for transportation exclusively for CCS. If transportation is for CCS and FAPE, ESSER funds may not be used.