On behalf of The Faison Center, I write in support of the proposed regulations and to request revision to some of the language to ensure ease of and consistent interpretation.

(1) Regarding Section A of 8VAC20-750-80 (Prevention; multiple uses of restraint or seclusion) and for clarification purposes: 

If an incident of physical restraint or seclusion occurs early in the school year and the IEP Team meets within the prescribed 10 day period, how are future instances in the same school year to be handled? Following any/all future use of restraint of seclusion during the same school year, is the Team to meet again, within 10 days? 

(2) Regarding Section C of 8VAC20-750-100 (Training), we recommend expanding on the term "advanced" and providing specific language as to what that means—as it could be interpreted quite differently from district-to-district and from school-to-school. 

Regarding Section D of 8VAC20-750-100, we offer a similar recommendation but related to the use of "evidence-based," which is a term that is used frequently in education and other disciplines, but often not objectively or otherwise well-defined. There are a number of crisis deescalation training curricula; is the intent of this language to ensure schools utilize a cohesive, comprehensive, and curricular-based approach to training, or something entirely different? 

For both Sections C and D, we believe that clarification on these terms is necessary if schools are to be positioned to adhere to the regulations.