impairment. Does the new definition go beyond acuity to include ocular motor
issues under the VI eligibility category?
4. As you are no doubt aware, staffing shortages in the area of visual impairment
are an ongoing issue for districts across the state. If this rule change has the
effect of increasing the number of students who are found eligible under the
category of VI (as we believe it may), these staffing shortages will become
even more problematic. We believe it will be important for MDE/OSE to take
a leadership role with institutions of higher education to a) project future
eligibility rates and related staffing needs, and b) ensure that there are
adequate teacher preparation programs in our state to serve this area of
exceptionality. MDE/OSE also might explore alternate routes to certification
in this specialty area, as well as permitted flexibilities that ISDs might
incorporate into ISD plans to address shortages.
R340.1721e
We are aware that this proposed rule change was originally intended to relieve
parents of the burden of inviting the resident district to the IEP meeting, and we
strongly agree that the parent should not have this burden. We also appreciate that
this proposed change corrects more stringent language that was not intended in the
February 2020 rule revision. We believe it is appropriate for the resident district to
continue to be involved with programming decisions for students who are placed in
center programs outside the district, and we agree that meaningful consideration of
the full continuum of placement options on an annual basis is not possible without
the involvement of the resident district.
While we support this proposed change, we believe it will be important for
MDE/OSE to provide written guidance regarding how the process will work. Some
areas of potential confusion that we have identified include:
1. For purposes of monitoring or state complaints, what constitutes acceptable
documentation of an “invitation” to the resident district representative?
2. If the resident district does not attend the IEP meeting, will a written
excusal be necessary? May the meeting proceed without the resident
district representative if the parent does not agree to an excusal, or must
the meeting be rescheduled?
3. Are there specific qualifications for the person who represents the resident
district at the IEP meeting? Must this person meet all the criteria for serving
as “representative of the public agency”?
Again, we appreciate this opportunity to provide input on matters that impact our
members and the students we serve. Please do not hesitate to contact Michigan CEC
if our Board of Directors or our Legislative Action and Advocacy Committee can be of
any assistance going forward. You may reach us via our Executive Director, Ann
Respectfully,
Ann Walton, Executive Director of Michigan CEC