January 26, 2021- Is Your Physical Restraint and Time Out Procedure Up-to-Date?

Is Your Physical Restraint and Time Out Procedure Up-to-Date? 
Franczek P.C.: Dana Fattore Crumley & Kendra Yoch

ISBE issued final rules related to physical restraint and time out last April. Given the series of updates to the rules dating back to November 2019, a bill that proposed further changes, and the disruption caused by the pandemic, many districts took a “wait and see” approach before revising their procedures.  Now that the dust has settled,  you may find that your procedure needs some work.

As was previously required, districts must have a policy before using time out and restraint. The policy should state that the techniques will be used only in accordance with the requirements in the School Code, ISBE rules, and your district’s procedure.  If your district will permit these techniques, the regulations require that five components be addressed in your procedure:

1.     The circumstances when isolated time out, time out, or physical restraint will be applied.

2.      A written procedure to be followed by staff when the techniques are used.

3.      Designation of a school official who will be informed of incidents and maintain the documentation required when the techniques are used.

4.      The process the district will use to evaluate any incident that results in an injury to the student.

5.      An annual review process, including but not limited to:

                        a.        The number of incidents involving the use of these techniques.

                        b.      The location and duration of each incident.

                        c.       Identification of the staff members who were involved.

                        d.      Any injuries or property damage that occurred.

                        e.      The timeliness of parental notification, agency notification, and administrative review.

Designating a school official to maintain the required documentation is critical. That person may also be the point person to lead the update to your procedure when needed (😊), oversee training and related documentation, and lead the review required in #5.

The real meat of the procedure is #2, the procedures for staff to follow. If you use PRESS, the model procedure incorporates the ISBE rules rather than spelling out the requirements. The benefit of this less-is-more approach is that when the ISBE rules change, your procedure may not need significant revision. So as one of our favorite old commercials says, “That was easy!” The downside is that staff need to access a separate document, and that document is not the most-user friendly to read and understand. Not so easy.

If you are considering drafting your own procedure for staff to use, check with your attorney to make sure it is properly aligned with the rules. To get you started, here are the key points to include:

·       Definitions of isolated time out, time out, and physical restraint. Consider also including examples of interventions that do not qualify as time out or physical restraint.

·       When the use of the techniques must end.

·       When a review is required due to the length or repeated use of the techniques.

·       Safety requirements for the use of each of the techniques.

·       Prohibition on the use of chemical and mechanical restraints. Whether prone and supine restraint are allowed (if so, additional procedures are needed).

·       Required documentation, notification (to ISBE and the parent/guardian), and record keeping.

·       Required review meeting when the techniques are used with a student on 3 days within a 30-day period.

 You can find a summary of the rule here, and detailed guidance from ISBE here. Happy updating!


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Don’t forget about our new feature: Ask an Attorney. This is your opportunity to ask our IAASE Attorneys (Dana Crumley and/or Kendra Yoch) any questions. They will provide monthly updates via the IAASE Blog. Click here for the IAASE ASK an ATTORNEY form.


SEAPAC UPDATE

Thank you to so many of you for answering the call to join SEAPAC. We had 3 new members join this week: 
Kathy Gavin, Laurin McWhorter, Luan Statham, Carole Allert, Kyle Muldoon, Margaret Childs, Alyssa Madsen, & Jera Pieper

Thank you to our SEAPAC Committee for making it easier to become a member. It is a $20 donation (minimum), and your contribution helps our legislative efforts. You can access a NEW feature and sign-up for SEAPAC online through Givebutter! Please consider signing up through this link. You can also text SEAPAC to (202) 858-1233 to get the link delivered directly to your phone. You will be able to pay with Venmo, Paypal, or via credit/debit card. 



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