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Traumatic brain injury at school: eligibility and accommodations

By the IEP Atlas editorial teamLast updated

Short answer

Accommodations for a traumatic brain injury match the student's current symptoms: reduced workload and rest breaks for fatigue, written directions and notes for memory, extra time for slow processing, and a quiet space for light or noise sensitivity. Because recovery changes needs quickly, the IEP or 504 plan should be reviewed often, sometimes every few weeks at first.

A traumatic brain injury changes what a student can do, sometimes overnight, and then keeps changing as the brain recovers. Accommodations have to follow that curve. What a student needs in the second week back is rarely what they need in the fourth month.

Under IDEA, traumatic brain injury means an acquired injury to the brain caused by an external physical force, resulting in total or partial functional disability or psychosocial impairment, or both, that adversely affects educational performance. It applies to open or closed head injuries affecting areas such as cognition, language, memory, attention, reasoning, judgment, problem-solving, sensory and motor abilities, behavior, physical functions, information processing and speech. It does not include brain injuries that are congenital, degenerative, or caused by birth trauma.[1]

The low-incidence disabilities pillar explains how TBI fits with the other low-incidence categories.

Accommodations by need area

Pick accommodations from the student's current symptoms, not from the diagnosis. The table groups common ones by the need they address.

Need areaWhat it looks like in classAccommodations to consider
FatigueHead on desk by mid-morning, work quality drops after 20 minutesScheduled rest breaks, shortened day at first, hardest classes in the morning, reduced homework
MemoryForgets directions, loses track of assignments, cannot recall yesterday's lessonWritten directions, copies of notes, a daily planner checked by an adult, recorded lessons
Processing speedAnswers correctly but slowly, falls behind in discussionsExtended time, fewer items showing mastery, advance questions before discussion
AttentionDrifts after a few minutes, distracted by hallway noiseSeat away from doors, chunked tasks, check-ins every 10 minutes
Sensory sensitivityHeadaches under fluorescent lights, overwhelmed in the cafeteriaSunglasses or a hat indoors, quiet lunch option, early hallway passing
Executive functionCannot start or organize multi-step workTask checklists, step-by-step models, graphic organizers
PhysicalBalance problems, weakness on one sideElevator pass, extra passing time, adapted PE, help carrying materials
Emotional and behavioralIrritability, low frustration tolerance, mood changesBreak space, a trusted adult check-in, a predictable routine
TestingSymptoms worsen under timed testsSeparate setting, extended time, breaks, delayed testing while symptoms peak

Some changes are modifications, not accommodations, because they change what the student is expected to learn, such as fewer standards covered. The accommodations vs modifications guide explains the difference. The IRIS Center module on accommodations is a useful primer for teachers new to the student.[4]

One student's return to school

This scenario is fictional. Carlos is a 9th grader injured in a bike crash on March 2. He has a closed head injury and spends 9 days in the hospital and 3 weeks in outpatient rehabilitation.

March 25: re-entry meeting. The school nurse, counselor, case manager, Carlos's parents and his rehab therapist (by phone) meet. Carlos has headaches after 30 minutes of reading, is very tired by noon, and has trouble recalling new information. The team writes a 504 plan for an immediate return: half days for 2 weeks, no tests for 2 weeks, notes provided in every class, and a rest pass to the nurse.

March 28: referral. Because his symptoms affect learning and may last, the team asks his parents for consent to a special education evaluation. They sign that day.

April 14. He returns to full days with two scheduled rest breaks.

April to May: evaluation. The school psychologist finds processing speed and working memory far below his earlier testing from 6th grade. His teachers report he completes about half of assigned work. Reading comprehension on a timed task is low, but untimed it is close to grade level.

May 20: eligibility and IEP. The team finds Carlos meets the definition of traumatic brain injury and needs specially designed instruction in memory and organization strategies. The IEP includes 30 minutes a day of strategy instruction, extended time, copies of notes, a reduced assignment load, and a check-in with the case manager each morning. The team schedules an IEP review for early October, because his needs are likely to change over the summer.

October 3: review. Carlos no longer needs rest breaks. Work completion is up to about 80% of assignments. Processing speed is still slow, so extended time stays. The team removes the reduced assignment load and adds a goal for independent planner use.

Rules at a glance, and where states differ

TopicFederal ruleWhere states differ
DefinitionAcquired injury from external physical force; excludes congenital, degenerative and birth-trauma injuries[1]Some states include acquired brain injuries from other causes, such as stroke or infection
Medical documentationNot required by the federal definitionSome states require a medical diagnosis or history of the injury
ReevaluationAt least every 3 years, and sooner if conditions warrant or a parent or teacher asks[2]Some states recommend more frequent review after a TBI
Concussion return-to-learnNot addressed in IDEAMany states have concussion laws that cover school return; supports may be informal or under a 504 plan
504 planSection 504 covers students whose impairment substantially limits a major life activity[3]Practice varies on when to start with a 504 plan versus an IEP

Why the IEP needs frequent review

Most IEPs are reviewed once a year. A student recovering from a brain injury can change a lot in a few weeks. Build in check-ins: a short review at 4 to 6 weeks after return, another after the first grading period, and a full review before the next school year. Use data, not impressions: work completion rates, the number of rest breaks used, and quiz scores with and without extended time.

When a support is no longer used, remove it. Students who keep supports they no longer need can fall behind on independence.

Goals that go with the accommodations

Accommodations give access. Goals teach skills the injury disrupted. Common TBI goals target memory strategies, planning, self-monitoring, and recognizing and reporting fatigue. The IEP goals for traumatic brain injury hub has templates, including executive function goals. The working memory strategies and executive function accommodations guides go deeper on the two most common need areas. For students with ongoing health needs, the medical accommodations guide may also help.

Other low-incidence guides cover accommodations for visual impairment and deaf and hard of hearing students. The CPIR overview of the federal disability categories gives families a plain-language summary of traumatic brain injury and the others.[5]

Frequently asked questions

Does a concussion qualify a student for an IEP?

Sometimes. Most students recover from a concussion with short-term supports, often informal or through a 504 plan. If symptoms last and the student needs specially designed instruction, the team can evaluate under traumatic brain injury.

Should a student with a TBI have a 504 plan or an IEP?

Many students start with a 504 plan for an immediate return, because it can be written quickly. If the student needs specially designed instruction, not just accommodations, the team should evaluate for an IEP.

Does a stroke count as traumatic brain injury under IDEA?

Not under the federal definition, which requires an external physical force. A student with a stroke may qualify under another category, such as other health impairment. Some states define brain injury more broadly.

Use it in IEP Atlas

Sources

  1. 34 CFR §300.8: Child with a disability, Legal Information Institute, Cornell Law School
  2. 34 CFR §300.303: Reevaluations, Legal Information Institute, Cornell Law School
  3. Parent and Educator Resource Guide to Section 504 in Public Elementary and Secondary Schools (2016), U.S. Department of Education, Office for Civil Rights
  4. Accommodations: Instructional and Testing Supports for Students with Disabilities, IRIS Center, Vanderbilt University
  5. Categories of Disability Under Part B of IDEA, CPIR

Written and checked by the IEP Atlas editorial team under our editorial policy. This guide describes general practice and federal rules. It is not legal advice; your state may add requirements, and the IEP team makes the decisions for each student.

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