In the first part of this series, Emotional Disability (ED) in the IEP, we explore the unique challenges families may face — from understanding how ED eligibility is determined to common co-occurring conditions and school-related struggles. We also look at how students identified under ED often experience disproportionately high rates of discipline, stigma, and school disengagement.
When a child qualifies for an ED under an IEP, the goal isn’t just to address behavior — it’s to understand what’s driving it and put the right supports in place so the child can learn, regulate, and participate at school. Understanding what kinds of supports may be available can help parents advocate for an IEP that meets their child’s needs both academically and emotionally.
To learn more, we spoke with Saran Tugsjargal, a disability advocate and former commissioner for the California Department of Education’s Advisory Commission on Special Ed; Sarah Pelangka, PhD, BCBA-D, special education advocate and owner of Know IEPs; Hadassah Lynn Foster, non-attorney education advocate; and John Maag, PhD, the Larry and Sharon Roos professor in special education at the University of Nebraska-Lincoln.
An IEP can provide students who meet ED eligibility with a range of services, primarily those pertaining to mental health. 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 a 504 plan, receiving mental health services will require a thorough assessment.
Due to the broad language used in IDEA, there is no universal methodology for assessing a student for an emotional disability; states, counties, and schools may differ in their approaches and tools used. There are, however, guidelines enforceable by law outlined in the Legal Rights of Persons with Disabilities that determine the timeliness of the IEP assessment.
Sources say that assessments for emotional disabilities are most often initiated by a teacher or by the school, based on how they perceive that child’s externalized behaviors and how these behaviors may be impacting the classroom dynamic. But parents can absolutely initiate an IEP assessment if they suspect their child has an emotional disability.
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. 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 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. 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. Parents should remain in touch with the school, including the student’s teacher, a school counselor, the principal, and the school psychologist to discuss an IEP.
“If there’s a suspicion of emotional disability, there may be obviously different assessors as part of the process. Generally, school psychologists conduct the social emotional section, but sometimes they’ll bring in a licensed therapist (here in our county, we call it ERMHS — educationally related mental health service providers) to be part of that assessment process,” says Dr. Pelangka. “They should be assessing in all suspected areas of disability” that may not be as evident, which can include assessments for autism, a specific learning disability, an intellectual disability, or other health impairment. In some cases unaddressed mental health needs or external factors may be at play as well.
“There should be a very deep dive into history. Trauma is a really important component that, similar to autism, oftentimes is misrepresented as emotional disability. . . . If there is, they get as much information about that as possible to see if that’s really speaking to what they’re seeing in the student or if it’s a true emotional disability that’s causing it.” (More on this later!)
These assessments may also include interviews that ask parents to divulge personal information that may seem embarrassing or stigmatizing. While many families may not feel comfortable divulging more intimate aspects of their and their child’s lives outside of a school setting, transparency during the IEP assessment is critical for the assessment’s accuracy and services rendered. Parents should expect that the professional conducting the assessment will ask about any history of trauma, changes or tensions in family dynamics, big life changes for the child, and other personal details to determine the root cause of the child’s behavior and how to address it.
An ED assessment can take many forms, including:
Most often, sources say, the school will defer to a qualified school employee to conduct the assessment. But if a parent feels unsure of a school employee’s credentials, especially as they relate to ED, they can request that an ERMHS or ERICS provider, such as a licensed therapist, be brought in for the assessment.
Parents can always seek other opinions about their child’s IEP assessment and can ask for a new assessment any time outside of the three-year renewal cycle. But parents should keep in mind that if they are having their child assessed and ED is their only qualifying category, contesting the assessment likely means forfeiting the IEP and preventing their child from receiving the higher-tier services they need. Reluctance from parents about their child’s ED eligibility often comes from internalized stigma about mental health and a desire to not have their child labeled with an emotional disability and the associated negative stereotypes. Foster recommends that if parents truly think the assessment was wrong, parents can seek out an experienced advocate for the IEP process and can request an independent evaluation by a licensed therapeutic professional unrelated to the school.
Parents can also request a new evaluation at any time if they suspect their child may have a co-occurring disability under which their ED may be labeled as secondary or if they believe their child does not have an emotional disability. “Have a meaningful discussion with that team. Express your opinion and have your thoughts clear as to why you disagree,” says Dr. Pelangka. “Here in California, they are a part of the IEP team, and we’re a dual-consent state, so if parents don’t consent, then it can’t go into implementation mode right now. If this is an initial [IEP]and parents don’t agree with eligibility and that’s the only thing that the student’s qualifying under, then they can’t proceed with writing the IEP at all.”
If parents choose not to seek IEP services for emotional disability but the child has a co-occurring disability, [the child] can still access mental health services through their IEP. If parents do not want to continue with an IEP, some 504 services (if the child has an appropriate diagnosis) as well as general school accommodations are still available to them, including counseling.
For students with ED, accommodations in the classroom and through the school campus can help ameliorate the student’s learning and social experience. No two students with emotional disabilities need the same accommodations in order to thrive, so parents and educators must collaborate on a precise plan.
Dr. Pelangka recommends that parents explore as many accommodations for their children as possible; for children with ED, this often means exploring higher-tier services, which allow for accommodations that apply to both school and home settings. “Some students can come in needing a lot of support right away. Maybe they’re engaging in dangerous activities, or they’re not showing up to school at all. So I think it depends on the severity of the needs and the presentation of the student at that time. Accommodations are the lowest level of support. They’re just environmental supports and strategies that are added or removed to support the student and their curriculum. If we have a student who’s qualifying under emotional disability, they’re automatically going to have more than just accommodations.”
These accommodations can include but are not limited to:
Accommodations can also involve educating a student’s peers about their needs and inviting their participation as well. A recent student Dr. Pelangka worked with had an accommodation in his IEP that let him bring a stuffed toy to school. “It was really something that made him feel safe, and he would sometimes talk through it. That was how he felt comfortable having conversations with peers.” To create an inclusive classroom environment, the student’s teacher made a presentation to the class about how it helped him, and the presentation went over so well that “other kids started bringing their own stuffies; that was cool. So it can be very individualized, but accommodations that help them feel safe, I’d say, are really important.”
A crucial point Dr. Maag emphasizes to his students is to make clear that accommodations work best in tandem with perception changes by educators. “Most teachers, and you can say, for parents, we expect kids to be good, and we react to them when they’re bad,” he says. One of the most important accommodations for students with ED is ensuring that the child’s teachers recognize how they’re using accommodations in the classroom to address the child’s needs. “When a kid misbehaves and a teacher can tell themselves, ‘What is he telling me? What does he want? What purpose does this behavior serve?’ If a teacher can have that mentality, then instead of being reactive, they start going into problem-solving mode.”
Beyond the accommodations that may help prevent disruptive behaviors, implementing positive reinforcements for good behavior gives students momentum for better educational and social outcomes. This also involves parents communicating with educators and requesting insight about their child’s behavior that have observations of both positive behaviors and recommendations for improvement. One of Dr. Maag’s favorite forms of reinforcement is also one of the easiest to implement: once a day, the student’s teacher should “catch the kid being good” by acknowledging a positive behavior the student is exhibiting. “If the kid is smiling or just sitting, say, ‘I like the way you’re smiling, I like the way you’re sitting, I like the way your feet are on the ground.’ That needs to be operationalized as an IEP goal or objective,” he says.
Sources agree that many students with ED benefit from related IEP services for mental health and behavior, which go beyond the accommodations listed above. Related IEP services are tailored to a student’s individual needs and encompass numerous resources and access to mental health professionals. While some related services may require additional assessments and collaborators outside a student’s IEP team, Dr. Pelangka encourages parents to discuss lower-tier options first.
Parents can request what she calls “baseline data” from the school to help collaboratively identify the student’s operational behaviors. Oftentimes, in her experience, pursuing related services helps parents and IEP teams identify co-occurring conditions; the behavior may be a reaction to an unmet need that additional accommodations and evaluations can address.
“Maybe this is a kid who’s nonspeaking and is having behaviors — maybe they need an AAC evaluation. Or maybe it’s a kid who’s struggling every time they’re assigned written work because they have a disability in dysgraphia,” she says. “Let’s look at assistive tech. Do the behaviors go away?” If these evaluations reveal that the student may have a co-occurring disability that was not previously on their IEP, parents can request a new assessment at any time.
Some common related services for students with emotional disability include:
Psychological services, such as psychological and educational assessments by a school psychologist, to help the IEP team craft individualized intervention strategies.
Counseling services outside of school for a student and their family by a licensed therapist, as well as services in the classroom.
A positive behavioral intervention plan (PBIP). Not to be confused with a behavior intervention plan (BIP), a PBIP is not exclusive to students with an IEP. Parents and students work with the school to help regulate a student’s engagement with their environment to encourage better behavior outcomes.
Social worker services. Many children who have emotional disability in their IEP often deal with external factors that may impact their behavior, such as an unstable home life. In some cases, parents and the IEP team may want to contact a county social worker. However, Dr. Pelangka explains that school-based social work services are provided on a consult basis and not as a direct service, and should be discussed with the IEP team. They can include the following:
Counseling and guidance by school personnel, including social workers, psychologists, guidance counselors, or other qualified providers. These services are implemented to support students both academically and personally, and have three tiers that students can access depending on their IEP eligibility. The counselor can work with a student to set and reach goals that complement their IEP. For long-term goals after graduation from high school, these counselors can also help students with EDs identify their strengths and find institutions or programs that suit their skills and needs.
Dr. Pelangka explains that public schools in California have three tiers of mental health services for students; the needs of the student, relevant medical diagnoses, and IEP assessments determine which level may work best for them. Every student has access to general school-based counseling, which is generally conducted by a counselor or school-based mental health professional. If the student requires a specialist and has demonstrated need within their IEP, they can meet with a district therapist or school psychologist, who may have specialties related to their disability needs.
The third tier is for students who need a licensed clinician, who would fall under Educationally Related Intensive Counseling Services (ERICS) — also called Educationally Related Mental Health Services, or ERMHS depending on your district; school districts may use either name to refer to the same set of services. As a related mental health service, services through ERICS can help students and parents access “intensive counseling services, crisis intervention within the educational setting, outpatient counseling, therapeutic learning class placements, case management, parent consultation, and/or residential placement recommendations.” These are highly recommended by multiple sources interviewed in this article for students with emotional disabilities, especially when their ED may manifest as significant needs, such as students who consistently demonstrate school refusal, explosive outbursts, and antagonistic behaviors at home and at school.
“If there are pretty significant needs across settings, like school refusal, or some of the more explosive, challenging outward behaviors, there’s also a level of service that can only be accessed through ERMHS,” says Dr. Pelangka. “That can be really useful, where it’s a provider that sees the student in both settings, home and school.” Both parents and students can receive respective partners, who act as peer supporters both at school and at home. Student partners can offer the child a person of trust but also of accountability, ensuring their accommodations lead to improved social and educational outcomes. Parents can also request a parent partner for themselves, who acts as a mentor with experience navigating the IEP process with their own child with similar needs.
But as Dr. Pelangka, Dr. Maag, and Foster have noted, many school-based counselors do not receive extensive training in mental health and emotional disability. Foster recommends that parents thoroughly vet the mental health professionals at their children’s schools before establishing consistent sessions with their child, as not all counselors or therapists in schools are licensed to handle the nuances of students with emotional disabilities.
“School counselors/guidance counselors are there to help students at the high school level figure out college or what classes they’re going to take in high school. They are not licensed to provide mental health services to children who are experiencing mental health distress, whether or not they have been diagnosed,” Foster says. Asking counselors directly about their educational background, qualifications, and work experience can help mitigate meetings that may prove less productive than with other licensed professionals.
Behavioral health services can be an immense asset to students with emotional disabilities. Districts and schools offer multiple tiers of services to students, which parents can collaborate on to find the best system for their child; behavioral services, unlike general accommodations or in-school counseling, are considered a higher-tier service and thus are designed to address a student’s mental health needs and how they manifest in their day-to-day experience at school.
Positive Behavioral Interventions and Supports (PBIS)
As mentioned earlier, all students in California public schools have access to mental health and behavioral services. Many school-based services, supports, and structures available, such as Positive Behavioral Interventions and Supports (PBIS), can complement services that a student with ED receives as part of their IEP. A PBIS serves as a lower-tier accommodation that addresses how the individual student, their peers, and the school staff can holistically work toward addressing the student’s needs and meeting specific goals and directives as determined by the IEP team.
As Dr. Maag describes it, “There should be rules for behavior in the hall, classroom, and the cafeteria, at recess . . . and there should be reinforcers for it. Schools have done this before, and it works well. When you get to tier two, you’re looking at either the classroom or the small-group level. That’s where you can use group reinforcement programs that impact not only the target student, but also the other students that are in that class or in that small group.”
The effective implementation of a PBIS can help students with ED connect with their peers, reduce behavioral challenges in the classroom, and more clearly communicate with their teachers and other school staff. Reinforcing these positive ties has been shown to help students, regardless of disability status, with discipline referrals and risk of suspension and expulsion.
Functional behavioral assessments (FBA) and behavior intervention plans (BIP)
If a student is exhibiting behavioral challenges at school that consistently affect their social and educational learning, educators typically recommend to parents that the school give their child a functional behavioral assessment (FBA). An FBA helps parents, children, and their IEP teams identify the root causes of a student’s behaviors or what results they seek from their behaviors.
For students under ED, an FBA creates time and opportunities for more extensive conversations around the child’s emotional needs and the most effective ways to address their behaviors, as well as access to more in-depth assessments. Some students may act out because they want a break from class, for example, and they know that certain behaviors lead to seclusion. Because of the IDEA criteria for an IEP under emotional disability, students with ED are more likely than other children with disabilities to have an FBA done.
An FBA is not a legally required aspect of an IEP unless the parents, IEP team, and LEA are discussing a change in placement for the child. But parents can request an FBA as a means of better identifying the child’s needs and supports. These supports and applicable strategies can include accommodations, counseling services, a 1:1 aide, and, if determined by the FBA, a behavioral intervention plan, or BIP. A BIP helps identify how the school can better serve the individual needs of the student and thus help prevent the escalation of negative behaviors that may lead to discipline or a mandatory change of placement.
Both Dr. Pelangka and Foster recommend that parents approach an FBA as a deeper approach to identifying the underlying psychology behind behaviors, rather than as a quick fix. If a parent requests an FBA, the district must provide an assessment plan in 15 days. If parents approve and sign the plan, the FBA and a coordinating IEP meeting must take place within 60 days. There are a number of professionals technically qualified to conduct an FBA for a student, such as a Board Certified Behavior Analyst (BCBA) or a Registered Behavior Technician (RBT), but their availability isn’t guaranteed. Dr. Pelangka advises parents of students with ED to research their options; Foster and Dr. Maag concur that many mental health professionals who serve students are undertrained in the nuances of ED. While parents do not have final say in who conducts the FBA, they can work with their IEP team to find the analyst with the best credentials to evaluate their child’s behavior triggers, sources, and reactions.
“I think what’s really important is, if we are going to do an FBA and we are going to draft a behavior intervention plan, that the individual doing so is very well-versed on trauma, trauma-informed care, and how to identify beyond the surface-level functions of behavior,” says Dr. Pelangka. “Oftentimes with these kids who have emotional needs, maybe they are avoiding [school] because they feel so self-conscious. . . . They’re so uncomfortable with making mistakes and they don’t want to fail. So, we might say, ‘Oh, it’s avoidance, it’s escape. We’re going to teach them how to ask for a break.’ Well, that’s great, but how is that going to help the real problem? If we’re going to go the route of behavioral support, it has to be a behaviorist who is open to recognizing that internal states exist, mental health needs exist.”
Once the FBA has been conducted and approved, parents also have the right to collaborate on how to design and implement the subsequent BIP. Dr. Maag encourages parents to push back on FBAs and BIPs that they feel are ineffective. He advises parents to pay close attention to the language used in determining the best goals for their child. Vague and subjective language, or goals that can’t be tracked with clear metrics, can make it harder to recognize when the child demonstrates progress.
IEP goals for students with an ED eligibility category often extend from academic performance to social goals and behavioral regulation. These can include managing emotional regulation, establishing consistent coping mechanisms, implementing learning strategies to improve classroom focus, completing non-desired tasks, and reframing a student’s language when they talk about themselves. Below is a list of goals that Dr. Pelangka, Dr. Maag, and Foster have all worked with parents and students to implement:
Dr. Maag recommends being specific in goals and avoiding subjective language that may skew how a goal is monitored and identified. Sitting quietly at a desk, for example, is not a productive goal. He has what he calls “the dead man’s test” to help both parents and educators evaluate the student’s ideal outcomes. “If a dead man can do it, it’s not a good target behavior, because that means you want to stop everything rather than trying to improve things,” he says.
Under IDEA, students with IEPs for emotional disability can receive services in a range of school settings, often called a “continuum of placements.” This means support can look very different from child to child. Some students are fully included in general education classrooms with accommodations and supports, while others may temporarily or for the long-term receive services in more specialized settings, such as alternative programs, therapeutic schools, or residential placements. A child’s placement is not one-size-fits-all. It’s based on their individual academic, social, and emotional needs — and schools are required to choose the least restrictive environment where your child can still make meaningful progress. Placement decisions are made after the IEP is developed, by the full IEP team, which includes parents.
Many factors can affect placement decisions, including identification of emotional and behavioral needs, whether a child has overlapping disabilities, and broader issues like disproportionality in identification. Placements can also change over time if a child’s needs change, such as when behavior or academic challenges increase or improve.
Unfortunately, the data shows that students with ED are more likely than other students with disabilities to be educated in more restrictive settings. According to the most recent Annual Report to Congress on the Individuals with Disabilities Education Act (IDEA), only around 56% of students with ED spent most of their school day in a general education classroom. The same data found that while only about 4.7% of students with disabilities overall were placed in separate schools, also called “other educational environments,” that number jumped to 13.6% for students with emotional disabilities — highlighting how often these students are excluded from general education environments.
“When we’re talking about ED, there’s definitely an emotional instability component,” says Dr. Pelangka. “So there needs to be a very therapeutically supportive environment at whatever placement is being offered. And parents should obviously do their research and look into, you know, is this a school that specializes or supports this population? Because there are non-public schools that are primarily for autism or primarily for learning disabilities. So you want to make sure that is the right fit.”
Both Foster and Dr. Pelangka advise families to tour as many schools as possible and actively engage with faculty about how the school supports students with ED. On a tour parents should consider:
Observations should include the state of facilities as well as the agency of other enrolled students. Foster likes to spend as much time on campus as possible and has a checklist of questions for parents:
In some cases, a student’s IEP may determine that they need a residential placement. This is a placement specifically designed for children with higher-level needs that previous schools and services cannot provide. Parents and schools may consider a residential placement if the student has already received the full extent of services through their IEP and explored other school placements, but continues to struggle with emotional regulation, meeting learning goals, and communicating with others. As Foster discussed earlier in this article, residential placements are recommended primarily for students with severe mental health needs.
Students at a residential placement live together on a school campus away from their home and have more direct access to therapeutic services alongside their educators. Residential placements are also, as Foster notes, year-round programs. This can be good for students who need to catch up on academic credits, but Foster advises that parents investigate the standard of instruction; the limitations of parental oversight means that parents cannot monitor their child’s progress as closely, and not all residential placements employ teachers.
Due to the limited number of residential facilities and their locations, a residential placement can also limit how often a family can see their child. California law does not allow locked facilities to keep students in their classrooms or living spaces, so students who have a record of school avoidance may be recommended for placements out of state — this is common with students who are prone to elopement from school. The accessibility of mental health and related services can provide students the therapeutic tools they need, but students may not necessarily receive the socialization needed to thrive after they age into adulthood. Foster recommends that parents should look not only at the school’s scholastic achievements through test scores and awards, but also at the social and behavioral tools the students cultivate.
“There are good schools out there, and parents have to ask questions like, ‘How long is it going to take to get their credits?’ and ‘What happens if they turn 18 and you say they’re ready for a diploma?’” says Foster. “We know they have enough credits, but they’re really not ready to leave. . . . School is not just ‘get a diploma and learn to read, write, and do arithmetic.’ It’s more, and kids with emotional disabilities are often really behind in other things. They can do the math right, they can pass the SAT, but they can’t hold a job and they can’t handle going to college or a vocational program.”
Working with a child’s IEP team, maintaining open and consistent dialogue with the school and their child, and including an advocate for the family can help prepare both parents and their children for graduation and the next phase of their lives. Some important questions to consider when choosing a residential placement for a child with ED:
Sources agree that for a student with severe emotional disability, changing school placement can have a huge impact on their learning and mental health outcomes. A change in placement can vary depending on the district where families live, but alternative placements refer to alternative educational institutions outside of a family’s local school district such as non-public schools, private schools, charter schools, residential placements, homeschooling, and home hospital.
Recommendation for a change in placement usually comes from the school after the student has faced disciplinary action and accumulated at least 10 days of suspension. In cases where a student has brought a weapon or drugs to school or has inflicted serious bodily harm on another person while on school grounds, an immediate change of placement for at least 45 days is required by law. A family may also want to consider a change in placement if their child consistently refuses to attend school, expresses extreme unhappiness with their school and services, or is not meeting academic requirements.
“It’s a difficult decision for families to make in terms of a change of placement when it comes to day treatment, school, or residential facilities,” says Dr. Maag. “Those things typically only occur when the school cannot provide the level of services necessary. What parents can do if they see things that are not in the IEP that they want is request an IEP meeting and say, ‘Here are my concerns, here’s what I’d like to see, put it in effect.’ Then you just have to see how the people in the IEP meeting from the school respond. Some of them may say, ‘We don’t have the resources to do that. We don’t have the time to do that.”
When a change of placement for a student with ED is needed, public school districts will provide families with a list of potential placement options, such as non-public schools, private schools, charter schools, residential placements, and home hospitals. But parents should know that their IEP team and local school district cannot guarantee a placement at the school of their choice. Any of these schools can decide not to accept a student if they do not believe they can meet a student’s needs, and ideally families and schools should minimize the number of times a child changes placement.
Connect with the school
In her experience as a mother of a child with autism, Foster says that connecting with her daughter’s principal made her educational experience exponentially better because they had rapport. Similarly, Dr. Maag says that creating lines of communication with a student’s teachers and IEP team that do not revolve around negative consequences for a student helps everyone maintain an optimistic attitude.
Get supports early
There are effective ways to support students with emotional disabilities, but too often help comes later than it should. More than half of students with ED (52%) in 2016-2017 were identified between the ages of 13 and 17; by comparison, children with other disabilities such as autism or cerebral palsy, can receive a diagnosis at as young as two years old. That’s partly because some mental health challenges show up in adolescence, and others aren’t diagnosed until behaviors become hard to ignore.
However, schools can support students earlier and more effectively. Proven approaches include bringing mental health providers into schools, increasing access to trained counselors, and using universal mental health screening. These aren’t quick fixes, but they work — and they focus on connection and support, not on punishment.
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