Holly Ridge Center serves 300 children with special needs yearly. That number will be cut in half. Why? A federal regulation pivots therapies to children with special needs on “natural environments.” The US Department of Education defines natural environments as places where typical children live and play in the community.

Holly Ridge Center supports the philosophy that children with special needs be integrated among typical children. Kid City, the new childcare division in Bremerton, will offer integrated childcare. Preschool classes in Bremerton, Poulsbo and Port Orchard offer integrated preschool.

However, Holly Ridge Center’s therapeutical clinics, in Bremerton, Poulsbo and Port Orchard, serve only children with special needs. Thus, the natural environments regulation eliminates therapeutical services in clinics, stealing clinical services from children with special needs.

“Parents are intelligent and creative,” said Kathy Fortner, Infant Toddler director. “Insisting that services be provided in a ‘natural environment’ assumes that parents cannot generalize the skills they learn in a clinical-based program to the home environment. Parents are much more resourceful than that. Parents often take what I teach them and improve upon it, making it fit their needs at home.”

Holly Ridge Center asks public support to change the federal regulation. As the regulation now stands, it steals parental choice. It steals services from children. It steals a proven philosophy.

Federal regulation states that parental needs cannot be used as justification for providing services to children with special needs. Holly Ridge Center gives parents a choice of settings. Therapists visit homes and childcare centers, which meet the federal definition of natural environments. However, the majority of parents choose to take their children to therapeutical clinics. Why?

Federal regulations steal services from parents.

Parents need time to be empowered, counseled and trained by professionals, safe from inquisitive eyes and ears. Parents need support from other parents in the same situation.

“Parents share while participating in therapy sessions,” Fortner said. “At Holly Ridge Center, parents can better cope with the challenges of raising a child with special needs. They have support of professionals, caregivers and parents, they have the opportunity to see parents interact with their own children. Parents must know that they are not alone. When families are restricted to receiving services in their homes, the sharing support and acceptance are gone.”

In addition, parents want home privacy. They want to avoid scrutiny of their home. They have no strength to cope with a stranger in their home.

Some parents stay home with their children. These parents have no desire or the financial means to place their children in childcare centers. Sixty-five percent of Holly Ridge Center children are on Medicaid. Thus, if parents want home privacy and have no outside childcare, where do they take their children for therapeutic exercises?

Alternative natural environments suggested by Mary Beth Bruder, Ph. D., University of Connecticut Health Center, include playgrounds, libraries, pet stores and churches.
Federal regulation requires that therapeutical services in clinics be justified, on a case-by-case basis. Justification indicates that a minority will receive services in clinics. Justification implies a slow approval process, for which government is infamous, stealing time from children with special needs.

Federal regulations steal services from children.

The federal regulation states that justification of where children receive services should not be based on the state’s (Washington state’s) fiscal limitations. Federal monies are channeled through the state.

Federal regulation gives no additional monies to the state for restricting services to natural environments!

If therapists have to drive throughout Kitsap County and surrounding counties to give children therapy in natural environments, half the children will be served. Costs will rise. Salaries will be spent driving to each child’s home.

Federal regulation suggests that therapists teach daycare workers to give therapies. A reasonable idea, until you look at the monetary reality. Federal monies pay a small portion of the total cost of services. Private insurance companies and federal/state insurance programs share the costs. These payers only pay for hands-on services, directly to a child. Therefore, these payers have no provision to reimburse Holly Ridge Center for teaching daycare workers therapeutic techniques.

In order for natural environments to make monetary sense, federal monies would have to assume a very large percentage of the cost. Again, federal regulation gives no additional monies to the state for restricting services to natural environments.

Federal regulation steals a proven philosophy

Clinical intervention at Holly Ridge Center has demonstrated substantial benefits to children, their parents and professional staff. However, natural environments represent a philosophy not yet supported with outcome data for children, birth to 3.

Comments to change the federal regulation should addressed to:

Thomas B. Irvin, Office of Special Education and Rehabilitative Services
US Department of Education
Room 3090, Mary E. Switzer Building
330 C Street SW
Washington, D.C. 20202-2570.
Send comments by email to Comments@ed.gov. Use “IDEA-Part C regulations” in the subject. “IDEA” stands for Individuals with Disabilities Education Act.