How IEPs and 504 Plans Help Support Mental Health in School
Schools are critical in addressing mental health for children, especially as education and mental health can be so intricately linked developmentally. According to a report from The National Center for Youth Law, “Childhood development and learning are impacted by a variety of factors, including psychological, social, and emotional processes…When students receive the social, emotional, and mental health support they need, they can focus on engagement in school and learning. Conversely, untreated mental health needs can interfere with school attendance; research shows a connection between a child’s unwillingness to attend school and conditions such as depression, separation anxiety disorder, and generalized anxiety disorder.”
The first step is to touch base with the school, whether that’s your child’s teacher or their IEP team. Express what is happening and tell them that your child may need mental or emotional services. You may arrange for someone like the school psychologist to reach out to your child. You can also talk to your child about what’s happening at school and which supports can be available to them. Ask what they feel comfortable participating in. Knowing your child’s rights to mental health services at school will empower you to advocate for them to get the help they need.
Can IEPs and 504 plans address mental health?
Section 504 and the Individual with Disabilities Education Act (IDEA) are both federal regulations meant to protect the rights of children with disabilities, including those with mental health concerns. IEPs and 504 plans may be commonly thought of as educational support tools, but they can also be used to support emotional and mental health in the school setting. Students can receive school-based mental health services in connection with their special education needs. These can include emotional supports, accommodations, and services, as well as goals and objectives related to mental health.
Lisa Carey tells us, “A lot of times, some of the accommodations for anxiety might include getting a preview from the teacher at home of what's going to be covered. For example, the teacher might send their agenda for the week, so the kid’s aware that in history, we're going to talk about WWI. That helps them know what's going to happen. I've seen a combination where the school lets the child know of any significant changes or events that might be happening. For example, maybe there's going to be an earthquake drill this week. They can let the child know in advance, so there can be things like those big headphones or little earplugs for noise.”
Special education advocate and owner of KnowIEPs, Dr. Sarah Pelangka (BCBA-D), adds that while every child is different, some mental health accommodations are more common than others, such as, “Silent agreed upon cues to request help/breaks; access to calming area within classroom; access to movement breaks; allowance to wear hoodie/hat in class; access to comfort items from home; access to listen to music; allowance to pull phone out (to contact parents); access to safe person on campus whenever needed; access to Wellness Center whenever needed; Coping menu; allowance to have snacks throughout the day.” And for performance anxiety, “Not being called on to read aloud in class; not being required to present in front of class.” For test anxiety, “Not priming too far in advance; ensuring study guides are provided in advance; and not extending time for assignments too far out as the piling up of assignments can induce even more anxiety.”
She adds that some students can have a modified day where they show up later due to not being able to wake up on time for school — due to medications, poor sleep patterns, etc. — and this can all be written into the IEP. In an IEP, any kind of emotional or mental health would be listed under the “social/emotional” section, and would have their own goals. Undivided Special Education Advocate Lisa Carey explains more about this below:
How does a child qualify for mental health services in an IEP or 504 plan?
A child can qualify for mental health services in an IEP under the categories “Emotional Disturbance (ED)” or “Other Health Impairment (OHI),” or, if they already have another qualifying diagnosis, through having a mental health diagnosis (ED or OHI) listed as a secondary qualifying diagnosis in the IEP (although the format this appears in the IEP can vary from state to state). To receive mental health services through the IEP, their mental and/or emotional health must be affecting their social emotional performance, access to learning, self-help and/or vocational needs in school. A child can also qualify for a 504 plan if they have a diagnosis that affects their learning — and depression, anxiety, and OCD can all do that. Like anything else in an IEP or 504 plan, receiving mental health services will require a thorough assessment. You can make a formal request in writing for an assessment. The school will arrange the evaluation, which may be provided by a school psychologist or through an outside professional.
This evaluation is necessary even if your child has already received a medical diagnosis from a psychiatrist, pediatrician or a neurologist. Having a DSM diagnosis may help a child qualify for an IEP or 504 plan, but it’s not required as the school is a separate entity and must do its own evaluation. Carey explains: “If you have a diagnosis from the outside, that can help in the assessment process. But an IEP is an educational document and not a clinical or medical document. So a diagnosis is never actually required. Even when a child has something like autism, a medical diagnosis of autism can be different than an educational diagnosis of autism, meaning it has to affect their ability to access school, in one way or another, in order for them to need an IEP or even a 504 plan.”
Once the evaluation is complete, you and your child (if appropriate) will meet with the IEP Team to go over the evaluation and the recommendations for accommodations, modifications and other related services to create a plan to support your child.
What are specific mental health services a child can receive at school?
In the IEP, mental health services can be found listed as a related service. These include:
- Counseling and guidance: Used to support students both academically and personally, and can be provided by social workers, psychologists, guidance counselors, or other qualified providers. The counselor can work with a student to set and reach goals, develop a more positive attitude toward school, and identify their strengths. They can also work with students on social-emotional needs, including developing self-knowledge, responsibility, and better decision-making.
- Psychological services: In California, these services include psychological and educational assessments as well as collaboration with school staff to implement services and intervention strategies. Services might include support outside of school (for example, counseling for a student and their family) and services in the classroom, such as putting positive behavioral intervention strategies into place.
- Social worker services: Dr. Pelangka explains that school-based social work services are provided on a consult basis and not as a direct service. They can include the following:
- working with a student’s family and others to address home-based issues that affect the student’s life at school
- identifying school and community resources needed to help a child learn
- developing positive behavioral intervention strategies.
According to Dr. Pelangka, “If a parent feels their child would benefit from counseling, they can request it be added to the student’s IEP. Depending on the severity of needs, the IEP team generally starts at the lower level service (school-based) and moves up from there as needed.” She explains that students can access three tiers of general counseling services:
- General school based counseling with a school counselor, which is a Gen Ed service and wouldn't be written into the IEP as any and all students can access this service. “It’s not prescribed at a certain rate,” she says, “but the team can come up with an agreed upon rate (e.g. 30-min weekly for 6 weeks).” IEP teams can offer social skills groups with a school counselor as well, if needed.
- Individualized Counseling offered by a District Contracted provider or a District Therapist/School psychologist.
- Educationally Related Intensive Counseling Services (ERICS) — formerly called Educationally Related Mental Health Services, or ERMHS, which are provided by a licensed clinician. “Different districts have either in-house therapists, SELPA provided therapists, or they contract out,” she explains.
Dr. Pelangka tells us that, “In order for a student to qualify for these counseling services, they have to be able to benefit from the service. So, for example, if a student has a very low cognitive profile, the team may not agree that talk therapy would prove beneficial to him/her. If a student has a short attention span, sessions can be broken up into shorter session times, and/or therapists can make use of different therapy approaches.”
Under IDEA, intensive counseling as a related service is a necessary service for a student to benefit from their special education program. These can include assessment of needs for intensive counseling services, crisis intervention within the educational setting, outpatient counseling, therapeutic learning class placements, case management, parent consultation, and/or residential placement recommendations. In California, this is often called Educationally Related Intensive Counseling Services (ERICS) — formerly called Educationally Related Mental Health Services, or ERMHS — and are considered for students whose social-emotional needs directly affect their ability to benefit from special education.
According to LAUSD, "ERICS is designed to address: 'student(s) whose social-emotional and behavioral needs are documented to be more significant in frequency, duration, or intensity; affect their ability to benefit from their special education program; and are manifested at school, at home, and in the community.'" Services are measured by assessments in the area of socio-emotional performance, student’s progress on goals and objectives, their grades and attendance, and other measures. ERICS is usually for students with severe behavioral and emotional symptomatology, and is often the last effort to prevent the need for a more restrictive environment. Parents can request an assessment for ERICS or ERMHS if the student isn’t benefiting from other interventions or supports, such as school-based counseling, behavioral intervention support, socio-emotional learning opportunities, referrals for services in the community, etc.
Lisa Carey explains: "When you request the assessment for the child, you want to include that you want an assessment for either ERMHS or ERICS. ERMHS and ERICS are the same thing — different schools and different districts are using different terminology. Both of these are an assessment that they will do, and if the child qualifies for that service, they will meet with the school psychologist in whatever way it is set in the IEP. So it could be once a week for 30 minutes, or twice a month or whatever they decide the IEP meeting is appropriate.”
Once a student does qualify, Dr. Pelangka tells us that students also have access to wraparound services in which the student can have access to a student partner who will meet with the student both at school and in the home, which is great because, as Dr. Pelangka explains, “it serves as a bridge between both settings.” ERICS and wraparound services do have to be linked to goals within the IEP, she says, as they are considered direct service providers.
What happens if a child has more significant mental health needs at school or is in a mental health crisis?
Some sources estimate that approximately 70% of students who receive mental health services access them through their schools. It’s evident that the school setting is an important piece in addressing mental health in our kids, but what happens if the child needs more support?
California law requires local educational agencies (LEAs) to adopt suicide prevention, intervention, and post-vention policies. The plans must specifically address high-risk students, including youth bereaved by suicide; youth with disabilities, mental illness, or substance abuse disorders; youth experiencing homelessness; youth in foster care; and LGBTQ youth. There are also many school-based mental health services, supports, and structures that can be IEP safeguards for our kids, specifically toward behavior. These can include Positive Behavioral Interventions and Supports (PBIS), which help encourage good student behavior and can improve social, emotional, and academic outcomes. A student can also have a Behavioral Intervention Plan, or a BIP, which documents safety concerns and creates intervention strategies to address them, such as a 1:1 aide.
Dr. Pelangka explains that if a child is at a high risk of suicide or self harm, safety factors should be in place at school: “A safety plan should be in place and all staff should be made aware. And if it’s very serious, they can request an adult be with the child to have eyes on them at all times. Of course, if the student is currently in a space where the threat is real (not just ideation but at risk of following through), and anyone is in the know about that, authorities should be called and the student should be placed on a 5150 hold (potentially longer, the doctors will decide). It may be the case that the student requires a Residential Placement if they are suicidal and require ongoing monitoring.”
If a child is taking medication to address mental health challenges, they would be added to their health plan. Undivided Specialt Education Advocate Lisa Carey says, “There's a part in the present levels in the IEP, where the parents, and the nurse who does the assessment every three years, writes in the medications that the child is on in any conditions. And this isn't just about mental health — the child could be taking Claritin for allergies. A child with brain health concerns could potentially need a health plan, but it doesn't feel like that's as common."
Below, Carey explains a bit more about what happens in crisis situations at school and what parents can consider if their child needs extra support:
What if parents don’t want the school to know about their child’s mental health?
As founder and clinical director of CARE-LA, Dr. Lauren Stutman, Psy.D., explains, there is definitely a stigma around mental health, especially for kids with disabilities. They might feel embarrassed about receiving mental health services or seeing a therapist. Bullying is a common stressor and can impact a teen’s self-image, self-esteem, and emotional well-being. We want to shelter our kids from being targets at school, but sometimes, it’s not enough to just address mental health at home where we may feel they are safe and protected.
Carey tells us, “If you as the parent feel that your child is safe at school, and they're not struggling, then maybe you don't need to bring the school on. But I would say that most brain health concerns that I'm aware of, they tend to be across settings, meaning the child doesn't only experience this at home and never at school. And so if there was any concern of self-harm, or anything like that, I do think it's important that the school is aware so that they can be on the watch for things. Because if the school is not aware, they can't help. How are the teachers going to keep this child safe and help them if they don't know that this is a concern? But it is ultimately up to the parents what they disclose or don't disclose.”
With treatment across settings, it’s also important to remember that team members, school-provided and private, are communicating. Carey tells us, “With mental health, whatever you’re doing with the school, you should very much make sure that any outside providers are involved and giving their input, especially when it comes to brain health. If there's an outside psychologist or therapist or psychiatrist, whatever you have, make sure that the plans at school fit with the treatment plans that are going on outside of school so that they're working together.”
Mental health at school: 3 key takeaways
Carey shares her top three tips for parents when it comes to mental health services in an IEP:
Note to parents:
If your child is exhibiting dangerous behavior and you need to intervene to stop an attempted suicide, or prevent one, call 911 or or your local emergency mental health access number, or take your child to the hospital. Here are some options for immediate support:
- Call the National Suicide Prevention Hotline at 800-854-7771, and find more resources on the DMH website. You can also use the the national suicide line by calling or texting ‘988’ or chat online on 988 Suicide & Crisis Lifeline’s website (website for Deaf and hard of hearing here).
- Disaster Distress Helpline: Call or text 800‑985‑5990 for 24/7 support.
- Crisis Text Line: Text HOME to 741741 for 24/7 crisis support.
- California Suicide & Crisis Hotlines
- CalHOPE Peer-Run Warm Line: Call 833‑317‑HOPE (4673) 24/7 for non-emergency support specific to COVID-19 stressors.
- California Warm Peer Line: Call 855‑845‑7415 for 24/7 for non-emergency support to talk to a peer counselor with lived experience.
- California Youth Crisis Line: Youth ages 12-24 can call or text 800‑843‑5200
- TEEN LINE: Teens can talk to another teen by texting “TEEN” to 839863 from 6pm – 9pm, or call 800‑852‑8336 from 6pm – 10pm.
- National Suicide Prevention Deaf and Hard of Hearing Hotline: Access 24/7 video relay service by dialing 800‑273‑8255 (TTY 800‑799‑4889).
- If you have Medi-Cal, you can call the number on your membership card for mental health services. You can also call your local county mental health line. To find out what services are covered, call the Medi-Cal Managed Care and Mental Health Office of the Ombudsman at 888‑452‑8609. They are available Monday through Friday, 8 a.m. – 5 p.m.
- Parents, caregivers, children, and youth up to the age of 25 can receive support at the California Parent & Youth Helpline. Call or text 855‑427‑2736 to speak to caring and trained counselors. Live chatting is also available on their website.
- NAMI California has resources for family members supporting loved ones with mental health conditions. You can call their HelpLine at 800‑950‑NAMI to get information, resource referrals and support from 7 a.m. – 3 p.m.
Find more mental health resources in our articles Mental Health for Kids with Disabilities 101, Supporting Kids' Mental Health at Home and in Crisis, and Mental Health Treatment Options for Children and Teens with Disabilities.