Guidance and Answers to FAQs on COVID-19 Compensatory Services
was created on June 30, 2020, and revised on September 25, 2020.
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 FAPE during the
extended school closure. CCS should be considered only after the student receives
services as set forth in his or her 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 in-person instruction restarts, LEAs should
resume implementation of each student's current IEP.
Within the first few weeks of in-person instruction
resuming, LEAs should:
baseline data on each student's current present educational levels;
Fall 2020 baseline data to 2019-20 school year 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;
No later than the end of the third month of the 2020-21 school year, the IEP
team should review the progress of any student who regressed during the
extended school closure 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 during the extended school closure, then
the IEP team should determine whether and to what extent the student needs
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 during the extended school closure and during any
period in which a student receives services:
of academic and functional performance, including levels of performance on
all IEP goals prior to the extended school closure as compared to the
student's current level of performance as measured from the baseline data
and observations from teachers, related services providers, parents,
caregivers, and other family members.
student's ability to access remote learning opportunities and special
education services during the extended school closure.
student's engagement in the learning process during the extended school
amount of skill and/or behavior loss and/or lack of progress the student
experienced during the extended school closure.
data regarding the student's ability to recoup lost skills and/or behavior
(i.e., comparing the rate of progress during periods of interrupted
educational programming prior to the extended school closure to the rate
of progress after the extended school closure).
provided during the extended school closure.
collected through progress monitoring and progress reports.
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
during the extended school closure and 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
associated with the COVID-19 pandemic, but no later than the first three months
of the 2020-21 school year, 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