Letter to the South Carolina Department of Education

We have sent the letter below to the South Carolina Department of Education. We have heard from school psychologists across the state express concern with recent guidance related to face-to-face and virtual assessments. We hope you find the letter useful and we appreciate similar guidance from other state associations such as Florida, Texas, California, and Michigan that guided our response. You can find a PDF copy of the letter and the recommendations document here. 

RE: Special Education Evaluations During COVID-19

I am writing on behalf of the South Carolina Association of School Psychologists and school psychologists practicing across the state, in response to the South Carolina Department of Education Memorandum that was sent to District Superintendents on May 4th, 2020 entitled Face-to-Face Services and Support to Students and Families. We are concerned with the guidance that face-to-face assessments, evaluations, and screenings can be considered if agreed upon by districts and parents. The COVID-19 pandemic presents unique challenges in regards to ethical assessment and decision making practices. We ask you to consider the following:

• We believe that bringing students in for evaluations negates the spirit of the social distancing guidelines provided by DHEC and the CDC and puts children, school psychologists, and school staff in undue risk.
• In addition, the unique circumstances pose validity issues which must be addressed when assessments are taking place in a time of anxiety for youth, their families and caregivers, and school personnel. The likelihood of making inappropriate eligibility determinations based on invalid assessment data is high.
• School Psychologists are not typically trained or competent in completing evaluations through electronic means. The standardized tests used (i.e. IQ tests, formal achievement tests) are not designed to be administered electronically more or less outside of a school setting during a pandemic crisis. In short, the administration of tests must be given through the means in which they were standardized. Deviations from standardization must be reported and, at times, can invalidate test results, which could potentially impact eligibility determinations.
• If evaluations are to be conducted remotely, they should be conducted through platforms specifically designed for that purpose. At this time, such delivery would also require training beyond the evaluator, but also include training for the student and adult facilitator (likely parent/caregiver) who is assisting the student at home. It is unlikely the appropriate supports can be developed quickly.

With consideration of the ethical implications and irresponsible assessment practices, the South Carolina Association of School Psychologists strongly recommends upholding the advice provided by the U.S. Department of Education, Office of Civil Rights as follows, "If an evaluation of a student with a disability requires a face-to-face assessment or observation, the evaluation would need to be delayed until school reopens. Evaluations and re-evaluations that do not require face-to-face assessments or observations may take place while schools are closed, so long as a student’s parent or legal guardian consents." We ask that South Carolina adopt similar guidelines during this delicate and uncertain time. In addition, we recognize that a one size fits all approach likely will not work; districts have unique needs. However, we would like to make general recommendations to the various educational stakeholders involved in service provision. We have summarized these recommendations in the attached Recommendations for Stakeholders document. Our goal as school psychologists is to consider the best interests of the students and families we serve, while not abandoning their social, emotional, academic, and mental health needs. We have an ethical responsibility to maintain the highest standard for professional practices in educational and psychological assessment.

Respectfully,

Philip Young

SCASP President (on behalf of the SCASP Board)

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