615 - Part C Early Intervention Procedural Safeguard Notices: Can Families Know Their Rights?

Poster Number: 615
Publication Number: 615.2270

Background: The Individuals with Disabilities Education Act Part C Early Intervention (EI) system requires all states, territories, and commonwealths receiving EI funding provide Procedural Safeguard Notices (PSNs) to families which illuminate their rights and support their navigation of the EI system. Yet, the extent to which these documents adhere to federal guidelines and are informative to families with limited English proficiency or lower educational attainment is not known.

Objective: Perform comprehensive content review to assess the PSNs of all state EI programs (N = 50) for understandability, availability in multiple languages, and website accessibility.

Design/Methods: PSNs from all 50 US states were downloaded from program-specific EI websites. Programs were contacted to confirm the accuracy of the PSN. To measure understandability, the Flesch-Kincaid scale was used to predict the reading grade level of each PSN as well as a team-developed Plain Language Checklist to determine compliance with plain language standards. This checklist was iteratively developed using the 2011 Federal Plain Language Guidelines and iteratively tested and refined with 6 PSNs by three team members. The number of PSN language translations available was counted on each EI website. The Total Validator tool measured the degree to which the program websites housing PSNs met the Web Content Accessibility Guidelines 2.1 for perceivable, operable, understandable, and robust websites. Interrater reliability was excellent for all measures.

Results: Of the 50 US states’ PSNs, the average grade level score was 13.5 (SD = 2.2), above a high school education. The average Plain Language Checklist score was 25 out of 45 points (SD = 3.7), suggesting moderate understandability. PSNs were available in 5.1 languages on average (SD = 6.7), most commonly English and Spanish. On average, the PSN websites had 18.0 (SD = 32.9) accessibility errors.

Conclusion(s): Though they should be an available resource to support family advocacy and participation, literacy, language, and accessibility barriers inhibit PSN access for parents from varied educational, language, and (dis)ability backgrounds in EI. Results suggest that PSNs need substantial improvement to ensure families can accessibly understand their rights throughout their EI journeys; current federal law is not sufficient to ensure PSNs meet federal guidelines.