I oppose the elimination of Child Study Committees as currently required in the existing regulations.  VDOE's proposal to leave the referral procedures up to LEAs removes the guarantee that parents be participants in the referral process and the protection of timelines.  The proposal also eliminates the requirement that classroom interventions not delay the evaluation. 
 
3.  Functional Behavior Assessments (FBAs)  [8 VAC 20-81-10, pg. 27-28]
I oppose permitting the development of a Functional Behavior Assessment (FBA) to be merely a review of existing data that does not require input of the parent.  This definition should clearly state that an FBA is "an evaluation that consists of a systematic collection and analysis of direct and indirect data, may include a review of existing data", and that parents must participate as a matter of parental consent.
 
4.  Individualized Education Program and Transition. [8 VAC 20-81-110, pg. 155]

I support the continued allowance in the proposed regulation that directs transition services be put into effect when the child turns 14, two years younger than the federal guideline.  Parents and children need to plan for postsecondary goals well before the age of 16 in order to devise a correct curriculum that aims to improve long-term outcomes and to accumulate necessary information for decision making on further education, employment and independent living.
 
5.  Timelines for Evaluations and Reevaluations.  [8 VAC 20-81-60, pg. 97]
I oppose the proposed 65 business day timeline for an eligibility decision rather than adhering to the federal guideline of 60 days from the date of parental consent for evaluation.  Intended by federal law to prevent a child who may need services from waiting unnecessarily to receive them, the 60 day limit provides ample time for an evaluation in most cases.  In addition, this timeline should apply to both initial evaluations and reevaluations.