Schools for decades used “as needed” on our kids’ IEP modification forms which allowed school staff to use discretion on if/when an accommodation is provided. MODESE recently saw the light and has now determined “as needed” without descriptors is no longer acceptable. 
The Oct. 17, 2014, update from MODESE Special Ed compliance section:
Indicator 200.850.d (Frequency of Program Modifications and Accommodations): Indicator 200.850.d requires the IEP to state how often program modifications and accommodation will occur (i.e. -, daily, weekly, monthly). The frequency of “as needed” was removed as an option on the model Form F because it is not a clear description of the frequency. If an IEP team determines that an accommodation or modification is to be provided “as needed,” then we would expect a description of how “as needed” will be determined. The IEP must be clear to parents and LEA staff so that it can be implemented as written.
This new requirement may make a huge difference in how our kid’s day at school plays out.
Advocates at The IEP Center help parents solve IEP problems by providing information so they can advocate for the child with special needs. Don’t be bamboozled! Waiting and hoping for problems to go away allows our children to regress. Hoping the problem will go away will only delay getting the problem addressed.
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Special Education Parent’s Advocacy Link LLC dba The IEP Center provides information to parents regarding the problems of children with disabilities. We are not attorneys and do not give advice. Consult an attorney.
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