Thank you for all the work that has went into this guidance document.  You are appreciated!

Please consider reviewing entire document to ensure person first language is used consistently throughout – a child/student with a disability instead of disabled, or a student who is a challenged by an Emotional Disability instead of as having an emotional disability.

Specific Learning Disability

“The child should have a recent vision and hearing screening, and the IQ or other measure of General Intellectual Ability should be in the normal range to rule out intellectual disability” and “Students with intelligence test scores between 70 and 85 frequently fall into the gap between general and special education” – Including these statements seems to imply that an average IQ score is required for special education eligibility, especially regarding the identification of a Specific Learning Disability.  The DSM-V generally refers to normal intelligence as scores above 70.  Also, the exclusionary criteria requires teams to rule out the classification of ID when determining eligibility for Specific Learning Disability and does not require obtaining an “average” IQ score.  This type of language puts a label on an explanation of something that is not explained.  It may lead to comments like, “your child or student is not eligible for SLD because their general intellectual ability is just not average."  We used to say, “just a slow learner”.  I think we should just stick to providing an explanation of what we know, based on our data, which would be that current data and information is consistent or not supportive of SLD.  Any additional explanation, especially to try to explain why a student is not eligible for SLD, can simply be unkind, unhelpful, and hurtful. 

Emotional Disability and Social Maladjustment

I appreciate the guidance relating to some of the criteria for Emotional Disability including “marked degree” and “long period of time”.  However, there seems to be too much focus on Social Maladjustment, especially since Social Maladjustment is not exclusionary in and of itself and the category of Emotional Disability tends to only apply to less than 1% of students in Virginia.  It is another example of putting a label on something to explain the unexplained.  The language used also seems to be comparing or implying that Social Maladjustment is synonymous with Conduct Disorder.  I have never known Social Maladjustment to be viewed as a diagnostic category and it can also be made based on judgments of others, not data, and usually from those in a position of power.  On the other hand, Conduct Disorder is included in the DSM-V as a mental disorder.  Conduct Disorder is also a risk factor for the development of many additional mental disorders.  A focus on Social Maladjustment distracts teams from the bigger picture of focusing on the criteria of Emotional Disability.  Some of the differences and signs listed as Social Maladjustment (i.e substance abuse, poor motivation, situation specific vs. pervasive) and many other behavioral and physical symptoms can be signs of other more common mental disorders such as anxiety and depression.  The aspect of “control” can lead to inaccurate perceptions and beliefs about behavior, behavioral challenges, and behavioral/emotional disorders.  Focusing on whether a child has and does not have control of their behavior misses the more important message of how behavior can be a form of communication and that what we may see is only a small glimpse into the bigger story.  For many of our youth, that bigger story may often lead to tears instead of anger.  How Social Maladjustment tends to be situation specific instead of pervasive and responds to behavioral interventions offers no hope for recovery for individuals challenged by other behavioral or emotional issues.  Behavioral interventions can be effective for students with Emotional Disabilities too, and I am not sure it would be a distinguishing factor.  Focusing on Social Maladjustment can also pass blame and shame to the students and families we are trying to help, which leads to distance instead of connections.  We are battling the stigma associated with mental health enough, and I know we can do better. 

Thank you for considering these comments!