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Guidance and Answers to FAQs on COVID-19 Compensatory Services

This page 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:

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

  • Compare 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 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 during the extended school closure 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 extended school closure 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 during the extended school closure.

  • The student's engagement in the learning process during the extended school closure.

  • The amount of skill and/or behavior loss and/or lack of progress the student experienced during the extended school closure.

  • Historical 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).

  • Services provided during the extended school closure.

  • 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 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 school day.