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Presence Thinking About - October 2024

Legally Defensible IEPs for SLPs: The PLAAFP

Legally Defensible IEPs for SLPs: The PLAAFP
Marva Mount, MA, CCC-SLP
August 22, 2024

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Editor's Note: This text is an edited transcript of the course Legally Defensible IEPs for SLPs: The PLAAFP, presented by Marva Mount, MA, CCC-SLP.

Learning Outcomes

After this course, participants will be able to:

  • Explain why the PLAAFP statement is so important in an Individualized Education Program (IEP) meeting.
  • Describe the four essential elements that make a solid PLAAFP statement in an IEP.
  • List at least two guiding questions to ask when developing a PLAAFP statement for an IEP.

Why is the PLAAFP so Important?

First, we'll discuss why the PLAAFP statement is so important. As we go through the course, I want you to think of that statement as the story of the student in front of you. When writing those statements, we need to ask ourselves, "Would it pass the stranger test?" In other words, if someone who has never met the student reads it, could they understand what's going on in the IEP?

In addition to passing the stranger test, we need to view the PLAAFP as the cornerstone or foundation of the IEP. It is the core of goal development. If we want those goals to be SMART—specific, measurable, achievable, relevant, and time-bound—we need to start with a solid PLAAFP statement.

That statement drives all components of the IEP. Once the PLAAFP is written, everything else we decide in the IEP meeting is based on it. It truly influences everything we do, and of course, we know it's required by law. 

What Does the Law (IDEA) Say?

We all know the PLAAFP is required by law. It's mandated by both federal and state governments as the way we manage a student's IEP and services. But what does the law actually say about it? Under U.S. Code 1414, it defines the IEP as a written statement for each child with a disability, developed, reviewed, and revised according to this section. It specifically outlines the requirement for a statement of the child's present levels of academic achievement and functional performance, including how the child's disability affects their involvement and progress in the general education curriculum.

Most IEP systems also include a question about this, asking how the disability impacts the student's performance. Can they perform at the same level as their peers? These are key points to consider. The law also emphasizes that the IEP must be developed, written, and revised to reflect these present levels, which are crucial in determining how the student is functioning within the same curriculum as their non-disabled peers.

We have to address these issues and consider how the student's identified disability affects their ability to engage with the general curriculum. What accommodations will be necessary? What modifications will be required? Addressing these factors from the outset is essential to ensuring the IEP meets the student's needs.

Developing the PLAAFP

When developing the present level statement, we're balancing two key components. On one side, we have the student's current level of functioning, based on all the information we've gathered about them. On the other side, we have the state standards, which set the expectations for where students should be. By comparing the two, we can identify areas where the student may face challenges due to their disability.

Once we recognize these areas, we look at the state standards through the lens of how we can modify and accommodate the curriculum so that the student can participate. While their participation may not be the same as that of other students, the goal is to ensure they have access to the curriculum in a way that works for them.

Assessment, Instruction, and Curriculum

Regardless of the child's type of disability, we must consider three major components when developing this PLAAFP statement.

Assessment

The first component is always the assessment or evaluation of the child's instruction, followed by the curriculum. We need to understand what is happening in those grade levels in terms of both instruction and curriculum.

Then, we consider how this aligns with the assessment information we've gathered from various sources. This can include the child's initial evaluation or the three-year reevaluation using standardized assessments. But it's much more than just test scores—it's also parent input, teacher feedback, and observations of the student in their general education classrooms.

We also take into account the data we collect, including grades and information that teachers monitor regularly. All these pieces of data help us determine the next steps for the student. The assessment portion tells us how learning is being evaluated. It can include formative assessments that are ongoing in the classroom, instructional adjustments, and general good teaching practices. Additionally, we look at summative assessment data, such as final evaluations of learning, tests the student has taken, or any task analysis that the teacher conducts as they become familiar with the student's needs. This helps the teacher understand what the student requires to successfully complete classroom tasks.

Instruction

Instruction is the part where we determine how to teach the student. We focus on the materials that will be used, the lesson plans, and the activities the student will encounter. This includes the strategies we suggest for use in the classroom, the units of instruction, and how the student performs in those units. It also involves any projects the student may be required to complete.

Additionally, we need to consider the scope and sequence of the instruction. How do we maintain that scope and sequence to ensure the student progresses and advances in the educational environment? 

Curriculum

So what is expected of our students? Some states adhere to the Common Core standards, while others have their own state standards. However, if you compare them side by side across states, these standards generally look quite similar. They provide specific statements of what students are expected to know and what their expectations are from the outset. This not only guides the teacher's instruction but also helps us, as special educators and speech-language pathologists, determine our next steps. It allows us to modify what is being produced or presented through classroom instruction to meet the needs of our students.

What is a PLAAFP

So, what is this statement that we always discuss and agonize over during IEP meetings? It's a detailed description of the student's current performance in relation to grade-level standards. When writing this statement, we must be mindful of the expectations: for example, if the child is in second grade, we need to outline what they should be accomplishing by the end of that year and what they need to do to move on to third grade.

As we craft this statement, we need to ensure we're using measurable and objective terms, drawing on current and relevant data from a variety of sources—because that’s what the law expects. The statement should clearly describe the student's disability and explain how it impacts their ability to engage in the general education curriculum. It must also identify specific areas of need.

We examine the student’s strengths in the classroom, as well as their challenges, and we assess how these factors will impact their instructional experience in the academic setting, all in relation to the standards set for that particular grade level.

PLAAFP: The Basis of the IEP

If you're a visual person like me or a visual learner, this graphic can help you understand the foundation of the present-level statement we're going to write.

I need to first look at where the student is now. This involves examining their current academic performance, how it relates to grade-level expectations, and how their disability impacts their ability to meet those expectations. At the same time, we have to consider the timeframe we have to work with—essentially, twelve months.

We’re waiting for that annual IEP meeting to be scheduled, where we’ll review progress and assess what has happened over the past year. We're also focusing on how we’ll measure that progress and when we’ll report on it. This twelve-month cycle repeats, so everything we plan has to fit within that timeframe. As we develop SMART goals and objectives, we must be realistic about what can be achieved in that period, considering the student's needs and capacity for progress.

Without the present level of performance and the annual cycle, the IEP lacks the data needed to show the student's current performance or the impact of their disability. If we rely on outdated evaluation data, it becomes much harder to move forward with the process effectively.

What a PLAAFP is NOT

A PLAAFP is not just a place to report grade and age levels. Throughout my career, I've received IEPs that simply state, "John is functioning at a first-grade level in reading" or "John is functioning at a first-grade level with vocabulary." This tells me nothing. It tells the parent nothing. It also fails the stranger test, making it difficult for anyone picking up the IEP to know where to start. If I inherit John as a student, I’m left wondering, "Where do I begin?"

It's also not the place to just report standardized test scores. Standardized scores might tell us if the child is functioning below expectations for their age or indicate a moderate to severe issue, but they don’t really convey much about the child's present performance. For example, knowing that a student struggled on a test or scored in the average range doesn’t provide the detail we need to write an effective present-level statement.

Additionally, subjective observations that are not backed by current data don't belong in the PLAAFP either. I've seen statements like, "Susie made great progress this past year and now has a standard score of XYZ on the CELF." But that doesn't help me understand where Susie is right now or what I need to do to support her going forward. It leaves me unsure of how to best assist her in the classroom.

What Are the Core PLAAFP Components

There are four core components to the PLAAFP, but I like to break them down a bit because it's easier for me to remember what I need to do that way.

1. Data-based, student-specific information about the student's current academic achievement. I'm always talking with classroom teachers, just like you are. I ask about the student's grades and what their biggest concerns are. For example, why is the student getting a D in math or an F in reading or language arts? Understanding this helps us build a clearer picture of their academic challenges.

Student-specific information about functional performance. It's not just about academics. That's why we have all those letters in the acronym—PLAAFP. Functional performance includes areas like articulation or fluency disorders. Maybe a student struggles with speaking in front of the class, participating in group work, or reading aloud. These issues may not be strictly academic, but they impact their overall functioning. Executive functioning skills, like organization, task management, or flexibility, can also be a significant challenge. These difficulties may not directly tie into academic performance but still create barriers to success.

2. The student's strengths. What do they do well? It's important for us to identify these, but it's also crucial for parents and classroom teachers to hear them. Meetings shouldn’t feel like a list of problems. Even for students with more severe impairments, we need to take the time to comb through their classroom and functional experiences to find and acknowledge their strengths.

3. The needs resulting from the disability. Once we've identified the disability, we need to explore how it affects the student. For example, if the student has a speech or language impairment, we need to understand how this impacts their learning compared to a student without that disability.

4. The effects of the disability on involvement and progress in the general education curriculum. It's not just about whether they're passing classes—how involved are they in the classroom? This is particularly important for speech-language pathologists, as we need to assess not only academic progress but also the student's level of engagement and participation.

Think about...

As we move into writing those PLAAFP statements, we need to think about the student's needs and challenges, but we should frame them in a more positive light. It’s not all negative. We also need to include information about how these needs affect their progress in general education. Specifically, we should consider what we’re doing in our sessions that is impacting their progress in the general education setting.

We need to gather baseline information on the student. How does this data connect to the goals and services we're about to recommend on the IEP? After all, the PLAAFP is the foundation for the goals and objectives we'll be outlining, and it should logically lead us to the recommendations we make for services.

Think of the PLAAFP as a story that evolves. The student's needs are the plot, the effect on general education is the big crescendo, and we present all the facts to help the team understand what's happening for that particular student. 

Student Needs – Guiding Questions

Some guiding questions I always like to ask myself, as well as any classroom teachers involved, relate to the student's needs. First, what are the impacts of the disability as identified during the evaluation process? I revisit the evaluation, whether it's brand new, a year old, or even two years old, to examine how the identified disability affects the student. Then I ask, "What are the academic and functional needs resulting from this disability?" Are these needs the same as when we initially evaluated them, or have they changed?

If they’ve changed, how so? Have we seen progress or, in some cases, regression? If regression has occurred, we need to address that. Another key question involves parental concerns. While we spend a lot of time with students at school, parents still see their child the most. They help with homework, witness struggles, and experience the emotional toll that school challenges can bring. The law requires that we consider parental concerns, and often, they offer valuable insights. Even when their concerns seem unrelated at first, a discussion can reveal connections between home issues and the child's speech or language impairment.

What kind of instructional adaptations does the student need? Strong classroom teachers are often excellent at adapting on the fly—what didn’t work can quickly be replaced by another strategy. If something does work, teachers can monitor it over time to see if it improves the student’s performance. This kind of adaptability is crucial.

Finally, we need to ask how the student’s strengths can help address their identified areas of need. Many students have strengths that are off the charts, and sometimes we can leverage those strengths to help them in areas where they struggle. Not only does this help the student, but it also boosts their confidence, which is essential. Our students often struggle with confidence because they learn early on that things are harder for them than for their classmates. If we can help them build confidence through their strengths, they’re more likely to take risks and trust the process. Once that trust and confidence are there, we often see them soar in other areas.

Baseline Information - Guiding Questions

Some guiding questions I always use are: Is the data being reviewed to determine whether the student is making progress? It sounds simple, but sometimes we get into a routine, and it’s easy to overlook this basic step. Are we really examining the data we collect in a way that clearly demonstrates progress?

That leads to another pressing question: Did we set goals and objectives that allow us to measure that progress? Are the goals specific, measurable, objective, and timely? Can they be measured using various data points?

Then we need to consider, what does the data actually relate to? Sometimes, we find ourselves collecting data without fully understanding its purpose or how we’re going to use it. It’s easy to fall into the habit of just collecting for the sake of it. This can be particularly challenging when we're providing inclusive services in classrooms, where data collection can become tricky.

Does the data relate to something that can be collected easily and frequently? If it does, it will help us write SMART goals and objectives. And does the data tie back to the student’s identified areas of need? It’s also important to connect it to state content standards, especially in English Language Arts (ELA), where many of our students with language impairments often struggle. We know that children with language impairments frequently have difficulties in literacy, and students with severe articulation impairments—particularly those identified at three or four years old—can struggle with reading due to challenges with phonological and phonemic awareness.

What Data?

What kind of data are we talking about? We always emphasize that you need to include data in your PLAAFP statement. You need to address the data that’s been collected—the elephant in the room, so to speak. But what does that data look like? It can come from a variety of sources. For instance, you can pull from the full and individual evaluation results. If the report is current, it will serve as a foundational starting point, your roadmap. However, if that information is a year old, two years old, or nearing three years old, you'll need to supplement it with more recent, on-the-spot data.

Look at performance on previous IEP goals and objectives. If this isn’t an initial IEP meeting, make sure to reference how the student progressed on these goals in your PLAAFP statement. Include details on how the progress was achieved—whether it was with cues, prompts, or other supports. This provides a clearer picture of their performance.

Behavior data is always important to review, particularly for students with language impairments who also face significant behavior challenges. Additionally, consider the student's learning style preferences. Teachers are great at pinpointing this right away. They might tell you, "He's not an auditory learner; I have to show him things visually and have him practice hands-on before reviewing auditorily. Then, he gets it."

Classroom-based assessments are also critical. Where I am, we test students constantly—benchmarks, post-benchmarks, state assessments, federal assessments—it's non-stop. So, I need to pay attention to classroom assessment data and ensure I understand the benchmarks used by teachers. If I’m unclear, I’ll have conversations with the teacher to ensure I understand what’s being collected and what those scores mean, especially since assessments can use scaled scores, standard scores, or rubrics.

In my PLAAFP statement, I review work samples, teacher-kept portfolios, and my own anecdotal records.

For older students, I value their input. I ask them directly, "Do you think this is helping you?" If they do, I’ll ask what aspects are most beneficial. Sometimes, my middle and high school students tell me, "I think this is stupid. I don’t want to come anymore." That feedback speaks volumes. Often, it reflects a lack of confidence, or perhaps I haven’t explained the relevance well enough. When that happens, I step back and regroup because their input is crucial. If they're not getting what I want them to from our sessions, it’s a sign that I need to adjust my approach to better suit their needs and make it more functional and relevant to their grade level and situation.

Classroom Data

Some teachers are great at sharing information, while others aren’t, just like in the medical field. Everyone is different—some people naturally share, while others hold on tightly to what they can control, even to the point of not sharing it with you. But we need that classroom data. We need to understand whether the services the student is receiving are actually working. If they’re not, what are we going to do about it? What are we going to suggest? Are the accommodations or modifications truly helping the student?

Sometimes I shake my head when I see an accommodation sheet with every box checked, and I realize I probably didn’t explain the assignment clearly enough. That’s on me. When I explain to teachers that checking every box means they need to implement every one of those accommodations daily, they usually say, “Oh, I thought we were just listing things that might be helpful.” So, sometimes you have to have that conversation to clarify expectations.

The PLAAFP statement makes it easier to guide those discussions about accommodations. When you’ve clearly laid out the student’s needs and current performance, it becomes simpler to discuss what accommodations are necessary. That conversation with the classroom teacher or the IEP team is much more productive when it's based on what you’ve reported in the present-level statement.

Functional Data

Functional data goes above and beyond academics. It includes social interactions, emotional responses, and communication with peers and adults—whether or not the student can engage in these interactions successfully. Are they able to communicate effectively with others? Are they able to communicate appropriately with adults?

We also need to consider executive functioning skills, such as time management. Many of our students struggle in class because they aren’t good at managing their time, and without someone externally managing it for them, they fall behind. Teachers are busy with many responsibilities, but if time management is a significant concern for a student, we need to be aware of it and offer suggestions to help.

Self-advocacy is another critical area for our students. Do they know how to ask for help when they need it? Do they feel comfortable doing so? I’ve had students tell me they’re afraid to ask their teacher for help because they think the teacher will get mad. Whether that’s true or simply their perception, it’s important to address. We need to help students develop the confidence to advocate for themselves in a way that feels safe and comfortable.

Determination is also a big issue. Many of our students have already learned that they’re behind their peers, and because of this, they tend to give up easily. If this is a concern, we need to focus on strategies that encourage determination and resilience, so they become more willing to take risks and push through challenges.

Finally, behavior plays a significant role, particularly for students with autism who may struggle with self-regulation. These behaviors can be misunderstood by teachers and seen as disruptive, but they often stem from the student’s need to calm their nervous system. We need to spend time understanding how these behaviors interfere with their learning and how we can help them self-regulate more effectively, without causing disruptions in the classroom.

Parent Information

Parent information is so important because they observe their child’s behavior across a variety of settings. They see them at church, on the playground, at Mother’s Day Out, at camp, and at school. They know how their child reacts in different situations and how those settings affect their behavior. Changes in the home environment are also critical to know about. Is something going on at home that might be affecting their determination, time management, or ability to focus?

We also need to consider outside training, therapies, and tutorials. Sometimes, children receive tutoring or other services outside of school, and we may not know about it because we haven’t asked. It’s essential to have those discussions with parents: "Are you seeking outside tutorial services? Oh, you are? How’s that going?" or "You see a private speech therapist? Would you mind if I reached out to them?" From there, we can work on the necessary paperwork to collaborate with those professionals.

Additional Supports

We discuss these additional supports in the IEP as well as in the PLAAFP statement, but we can’t answer questions about these supports if we haven’t set them up properly in the PLAAFP. For example, does the student require any related services? Do they need assistive technology? Are there any consultative or collaborative services specific to the student's needs?

Some districts offer a wide range of these collaborative and consultative services, while others do not. Based on what you know about your district's resources, you'll write the PLAAFP statement in a way that clearly identifies whether the student needs additional related services or assistive technology. It’s important not to simply check a box indicating "no" to assistive technology without thoroughly considering whether it could be beneficial—or without first determining if the student might need it.

For Speech and/or Language Students

Many of our mediation and due process hearings with parents stem from not discussing these issues adequately and not relating them back to the student's present levels, strengths, and challenges. That’s why I’m emphasizing this for our speech and language students: How does the speech and/or language disorder affect their performance in content areas?

We need to examine all content areas, even the ones that may not be our personal strengths. For reading and ELA, we’ve likely got that covered, and for subjects like science and social studies, we do a great job as well. These areas are very language-based and vocabulary-focused—our wheelhouse. But then there’s math. Many of us, myself included, didn’t go into speech pathology because of a love for math. In fact, I avoided math. My own kids didn’t even try to ask me for help with it. So, for those areas, we often need the classroom teacher’s support.

Additionally, we need to ask: How does the speech or language disorder affect the student's current functional performance? What current data do we have to support our answers? Is the data concise, understandable, and relevant? Most importantly, does it pass the "stranger test"? If it doesn’t, we probably need to revisit and strengthen our present-level statement.

Connection to Goals and/or Services – Guiding Questions

When connecting goals and services through our present levels of academic and functional performance, we need to ask guiding questions here as well. For instance, is there enough current information within the PLAAFP statement to develop a challenging, ambitious, measurable, and specific goal?

If there isn't, we have a problem. The keywords here are "challenging" and "ambitious." I often struggle to understand how some students can keep the same IEP goals and objectives for years at a time. It’s not clear how that can be beneficial, and it’s also easy to see why parents might be upset by that. We’re not challenging the student or acknowledging their potential to excel if we just push them a little further.

We also need to ask: Is there enough current information within the PLAAFP statement to determine the necessary special education services, related services, supplementary aids and services, or program modifications or supports for school personnel? Without a solid present-level statement, we can’t answer those questions properly. That's why current and accurate information is so crucial—and it’s required by law to gather that data from a variety of sources. We cannot be the only source of information.

If you can't answer "yes" to these questions before moving into the goals and services for a student, it’s a sign that we need to backtrack. We may have missed the mark, and we need to rethink the goals and objectives. Those conversations can be challenging, but they are necessary.

Sometimes, when a student receives additional services, we encounter conflicting feedback. They may be doing great in one area but struggling elsewhere. That’s why it’s essential to have these discussions prior to the IEP meeting, ensuring everyone is on the same page and understands where we’re heading.

The connection between goals and services is the core element of your legal statement—the bridge between present levels and measurable annual goals and objectives. That’s why we create a present-level statement. If we simply state, "This child has an IEP for speech, and here are the goals," without discussing the student’s current performance, strengths, and needs, we can’t write goals that are truly ambitious or measurable. And we won’t be able to accurately track progress.

Have they made progress on previous goals? If we didn’t write the goals well, we may not know. Sometimes, we include too many components in one goal, making it difficult to measure. As we review progress, we may need to reassess. Perhaps we didn’t write the previous goals as well as we thought, or maybe they weren’t truly SMART goals. We need to take what we’ve learned from those mistakes and ensure the goals we’re writing now are more precise and measurable.

For some students, this process can be tough, especially when progress has been minimal. We need to examine what might have been missing and tweak the goals accordingly. Maybe we wrote the goal in a way that wasn’t as clear or measurable as it should have been. This is where we can learn from our past mistakes and ensure we don’t repeat them moving forward.

Effect on Progress in General Education – Guiding Questions

The guiding question here is: How does the student's disability affect their involvement in general education? Are they capable of some level of involvement? Since we’re always working toward the least restrictive environment (LRE), we want to provide opportunities for interaction with same-age peers as often as possible. While we understand that some students may need to be in self-contained programs because that’s what’s best for them, we still need to ask ourselves how they might participate in activities like art, music, PE, or computer classes.

As we work through the IEP process—from the PLAAFP to the SMART goals, accommodations, and modifications—we also need to consider how the student will access the general education curriculum. How are they progressing within that curriculum? If they aren’t progressing, it’s a signal that the accommodations and modifications from the last IEP cycle may not have been effective. In such cases, we need to reevaluate and take a deeper dive into what changes or new supports are necessary for that particular student.

Guiding Questions to Always ASK

Guiding questions to always ask as we wrap up the process include: Is it clear how the disability affects the student's involvement and progress in the curriculum compared to non-disabled students? Do we understand how the speech or language impairment affects our students in relation to their peers? This comparison can often help us determine exactly what accommodations or modifications are needed for these particular students.

Is there information about the amount of progress made over the past year? If there isn’t, that’s problematic. Without a clear picture of the student’s progress—where it occurred and in which areas—it becomes difficult to set meaningful goals and objectives. We also need to know how the student performs with accommodations versus without. Sometimes, teachers will report that a student was doing well with extra time, for example, but when the accommodation was removed, their performance declined. These are essential details we need to document.

I also ask these questions to ensure that teachers are consistently implementing the accommodations. It’s easy for them to forget, so periodic check-ins are important.

Is there information from a variety of settings? That’s why we conduct classroom observations, gather input from teachers about classroom performance, and sometimes monitor students in less structured environments like the lunchroom or playground. Collecting data across different settings is crucial for a comprehensive understanding of the student’s performance.

Finally, are measurable and observable baseline data included in the present-level statement? Were we able to measure what we intended and report it clearly and concisely? Additionally, how does the student compare to same-age peers, especially in relation to benchmarks or statewide assessments? I often ask teachers to provide some perspective on how the student’s performance compares to the rest of the class—not individual students, but broadly across non-disabled peers. This helps us better understand where our student stands in relation to others who are not affected by a language or speech impairment.

Non-Examples

The following are not examples of effective present levels because they don’t really tell you anything meaningful. I often come across statements that simply outline what the student struggles with but without any detail. For example, "Jacob has difficulty with reading." Well, what part of reading is difficult for him? Is it decoding, comprehension, fluency? We need more specific information.

  • Sammy scored an 89 on the CASL2
  • Sammy struggles with word problems, needs text read aloud to him
  • Jacob has difficulty with reading
  • Jacob has a limited vocabulary
  • The FIE indicates that Jacob has an expressive vocabulary of 19 months and a receptive vocabulary of 26 months

Statements like this don't serve us well in a present-level statement because they lack the depth we need to build appropriate goals and interventions. And they definitely won’t serve you well if you inherit one of these vague statements for a student. It’s important to avoid these types of generic descriptions and instead provide detailed, specific information about the student's challenges.

The Beginning of an Example of a PLAAFP Statement

The following is an example of how I begin a present level of academic achievement and functional performance.

Based on parent and teacher input, observations by teacher and SLP, anecdotal notes from speech therapy, and data collected consistently during speech sessions, SS uses one-word utterances to communication wants and needs to adults only. She will not use one-word utterances to speak to adults of which she is unfamiliar and will either shutdown or become dysregulated by flapping her hands and screaming. When Sally receives moderate to significant cueing, she will stay in the area with a peer and play for up to 5 minutes but does not attempt to communicate with them unless prompted. Sally will request a toy from a peer with one word “want” with prompting such as “Sally, what toy do you want?” paired with a gesture.

I typically say, "Based on parent and teacher input," because I aim to involve both parties. Hopefully, you have parents who are participatory. However, I know that some of us work in schools where parent involvement is limited, whether due to their availability or other constraints. We have to take that into consideration, but ideally, you've gathered input from both parents and teachers.

After that, I get very specific. I start by referencing the student’s goals and objectives, especially if they've been receiving services for a while. I compare their current performance to the goals we’ve set. Then, I outline the student’s strengths and how we can leverage those strengths in their progress. Afterward, I move on to the challenge areas, detailing how we will address those challenges in a robust IEP that supports the student’s growth and ensures they make meaningful progress.

Questions and Answers

You mentioned that subjective data is not ideal. Is it appropriate to use the teacher's rating of functional skills?

Absolutely. I may have misspoken. What I meant to say is that you don’t want all of your data to be subjective—you need a mix of both objective and identifiable data points. But subjective data, especially in areas like soft skills, is essential. We often don’t have another way to objectively assess those skills unless we’re using a formalized assessment. So, yes, subjective data, including strengths, interests, and teacher ratings of functional skills, is absolutely appropriate.

How do we help students become more engaged when they have low motivation, no inherent motivation or have a harder time working without an external reinforcement like a prize or a game?

That’s a tough challenge, especially the longer students have been in speech therapy. It often feels like we’re constantly pulling rabbits out of our hats to keep things exciting and engaging. I find this is particularly true with older students, who are usually the most unmotivated group, especially around fourth grade and beyond—they’ve been in speech therapy since kindergarten.

When I sense this happening, I talk to them directly. I might say, "Okay, you know what we need to do? I think Miss Marva needs to pivot. I need to better understand what you want to get out of speech therapy." At first, they usually look at me like they have no idea what I’m talking about. But then I ask them to think more functionally about their lives: "You have difficulty expressing yourself verbally. Let’s think about all the situations in a day, a week, or a month where you need to communicate with others."

I then try to align our therapy sessions around those real-life situations. Sometimes they’ll respond with, "I don’t do that much because I don’t like it." That gives us a chance to explore why they don’t like it. This approach has helped me, especially with older students, to re-engage them by making therapy feel more relevant to their daily lives.

Obtaining current information to inform the PLAAFP doesn't always mean we need assessment, correct? I'm thinking for time, and paperwork purposes.

Absolutely. You won’t always need to conduct formal assessments. First, they’re not always required by IDEA, and second, we simply don’t have the time or resources to focus on assessments constantly. In those cases, you can refer back to previous standardized or formal assessments and then use other data points. Look at the data you’ve collected, consider your anecdotal notes, and review the progress reports for that particular student. You’re right—continually reassessing students isn’t practical, and it’s often neither productive nor helpful. In fact, over-assessment could lead to students becoming frustrated with us.

When you inherit a student with incomplete answers to the guiding questions that you presented, when do you modify the class?

I’ve had students where the PLAAFP is essentially non-existent. As soon as the child transfers to my school, we have a transfer meeting, and I bring that up. I explain that I don’t have enough information to make informed decisions. In those cases, I initiate the process for a notice of assessment and get consent for assessment. I assess the student during the transfer period. 

If you're in a district that doesn’t hold transfer IEP meetings—since many states don’t require them—you can always try calling the previous school to gather information from the SLP or other relevant staff. It’s not always easy to get them on the phone, but it’s worth the effort. Additionally, you can talk with the parents and teachers to gather insights. I often ask teachers to collect specific data points in class and request that parents observe certain behaviors at home to help me build a clearer picture of the student’s current performance. I’ve used all these approaches to ensure I have enough data to modify the PLAAFP when needed.

Could you discuss how the statement doesn't affect academic performance?

It’s not all about academic performance. Our caseloads in schools are large, and we’re often running a marathon from the first day of school to the last. With so much going on, it’s easy to focus solely on academics, but we have to consider how the disability also affects the student’s functional performance in class.

For example, when we have students who stutter, we know they’re going to face challenges. While they may do well academically, functionally, they may struggle. That’s why the statement includes both academic and functional aspects—it’s not just about how they perform on tests. It’s also about whether school is a safe space for them, whether they feel confident, and whether they can navigate social interactions and the environment. These factors play a huge role in their overall school experience, even if they aren’t directly related to academics.

Can you project down the road that if you don't do interventions at this time, that that child is probably going to start having academic problems?

I believe we can. If a child isn’t confident in their abilities, they’re unlikely to participate in discussions or engage in activities where they feel uncertain. That’s why it’s so important to consider functional performance when developing the PLAAFP statement. Functional performance matters just as much as academics. 

If you're only looking at a student’s grades and considering dismissing them because their grades are good, make sure to also evaluate their functional areas. Academic performance isn't the only indicator of a student’s strengths and challenges. For example, a student who hasn’t been progressing in speech for several years, even when goals and prompting have been adjusted in each IEP, may still need support despite good grades. Functional issues could lead to academic problems if not addressed early.

Is there room to believe this student has plateaued?

Absolutely. Children do plateau, just like adults do. I know I’ve plateaued in some areas—it’s tough to keep learning new things. But when it comes to students, we owe it to them to assess what's been happening in their educational lives, especially over the past three years. We do triennial evaluations (or whatever they’re called in your state), but we also need to think about other factors.

For example, we should consider whether speech therapy might actually be detrimental at some point. Does it lead to behavior issues? Are students skipping school or becoming less confident because they’re being pulled out of class for therapy? Do they have such an aversion to the transition from the classroom to therapy sessions that it’s no longer productive? These are all important questions to consider when we think about plateauing.

And yes, sometimes students plateau. Often, students with language skills that have lagged behind their cognitive abilities catch up to their cognitive level. In some cases, that’s exactly what we need—to help them reach that point. However, we also have to recognize that, depending on other disabilities they may have, they might never become advanced communicators, and that’s okay. Our job is to help them reach their potential, whatever that may look like.

When we are writing the present levels for new goals, it is sometimes difficult due to time constraints to get a quantitative baseline. What is your advice for this?

It certainly is challenging, isn’t it? I think it all goes back to how we write our goals and objectives. If we write them smartly—so they are very measurable and not overloaded with too many components—it becomes easier to collect data. The key is to avoid having 35 components in one goal, where at the end you’re left wondering, “How am I supposed to measure all of this?” If you set up your goals and objectives correctly, focusing on measurability, you can collect data over time.

That’s really all you need to inform your present levels of performance statement, along with input from parents and teachers. So, it starts with writing clear and concise present levels, and then ensuring that your goals are measurable, allowing you to gather the data you need.

How do you find teachers and relevant staff are supporting you in writing and providing accurate information for present levels?

I’ve developed a system that’s worked well for me. At the beginning of the school year, I do a quick in-service with the staff. I ask the principal for a few minutes to introduce myself (if I’m new to the building) and explain that there will be periodic times throughout the year when I’ll need information from them. I talk about the best ways to get that information, trying to make it as easy as possible for teachers.

I’ve used Google Sheets, Google Forms, or SmartSheets—whatever the district has access to. I don’t just send a vague email asking, "How is John doing?" because, first, they probably won’t answer, and second, even if they do, it may not be very detailed. Instead, I create a form where I ask very specific questions about the data points I need. I make sure to include sections for them to note if something isn’t applicable, like if the student is only working on articulation, so they don’t have to worry about irrelevant information.

This system has been really helpful for me in gathering the information I need efficiently and ensuring that teachers provide accurate, targeted data.

When PLAAFPs have so much text, I would imagine it can be overwhelming for parents. Do you use any sort of paragraph breaks, titles, or headings to make it easier to follow?

Absolutely. I try to break it down much like I would if I were writing chapters in a book. I create sections like "Strengths Area," "Needs Area," and so on. Dividing it this way helps make the information more digestible for parents, and it allows them to focus on specific areas without getting overwhelmed by large blocks of text.

Do you add any verbal summaries?

Adding verbal summaries is a great way to ensure clarity during IEP meetings. I always make sure to summarize key points verbally, especially if the written PLAAFP has a lot of detail. It helps reinforce what was discussed and ensures that everyone is on the same page. Additionally, if you're documenting minutes or any other form of proof about what happened in the IEP meeting, those verbal summaries can serve as a helpful recap of the major takeaways and decisions.

*See handout for complete list of references. 

Citation

Mount, M. (2024). Legally defensible IEPs for SLPs: the PLAAFP. SpeechPathology.com. Article 20691. Available at www.speechpathology.com

 

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marva mount

Marva Mount, MA, CCC-SLP

Marva is a nationally certified and licensed speech-language pathologist with over 38 years as an SLP.  In 2018, Marva was awarded the Texas Speech and Hearing Association (TSHA) Hall of Fame Award for her outstanding contributions to the field of speech-language pathology and audiology.  In 2022, Marva was inducted as a Distinguished Fellow into the National Academies of Practice (NAP).  She is a chapter author/contributor to the Sixth Edition of Professional Issues in Speech-Language Pathology and Audiology and has authored a number of articles in the ASHA Special Interest Group (SIG) Perspectives on Supervision, Telepractice, and School-Based Issues.



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