The Office of the Superintendent of Public Instruction (OSPI) is collaborating with the Washington State Association of School Psychologists (WSASP) as well as the Washington School Counselors Association (WSCA) and the School Nurse Organization of Washington (SNOW) on guidance pertaining to the coordination of 504 plans following the statewide implementation of the ASCA model for school counselors. This implementation precludes school counselors from coordinating 504 plans, particularly the clerical duties associated with the work. OSPI has already made statements that the nature of this recommendation indicates that this work is equally inappropriate for other education staff associates (ESAs), whose skills and qualifications are best  utilized in non-clerical duties.

WSASP has been made aware of concerns from our members that school administrators may transfer work from school counselors to school psychologists or other ESAs. We believe that all ESAsare trained to provide specialized services to our students. We are working with OSPI on guidance to support appropriate implementation of changing responsibilities, which we hope will clearly indicate that no ESA should be assigned to clerical duties associated with 504 plans. This guidance should be released this fall, but we wanted to issue a statement about this work to keep our membership informed.

We have confirmed with Dr. Tania May at OSPI that staff who are paid fully from categorical special education dollars cannot be assigned to coordinate 504 plans, as this is not part of IDEA. For those who are funded in this way, this is one point you may leverage in your advocacy work if you are being impacted by the policy change. We are sharing the WSASP Advocacy Tool Kit which is filled with information to help guide local advocacy efforts that may parallel the state level advocacy we are engaged in with OSPI. We must remember that OSPI will offer guidance, not mandates, and that we are a local control state. This may result in the need for local advocacy, for which these tools can support your work.