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requirement in §303.117 that States maintain an accurate

and up-to-date directory.

Changes: None.

Comprehensive system of personnel development (CSPD)

(§303.118)

Comment: Some commenters requested that this section

require a State’s CSPD to include training that is targeted

to particular groups of service providers or training on techniques and services that address the specific needs of particular groups of infants and toddlers. For example, one commenter requested that the CSPD provide training specific to serving children who are homeless and children who have been exposed to, or have experienced, violence or trauma. Another commenter requested that training for occupational therapists be explicitly included. Other commenters requested that the regulations require that all training available under the CSPD be mandatory.

Discussion: The requirements for a CSPD in §303.118

incorporate the requirements in section 635(a)(8) of the

Act. With respect to the request that a State’s CSPD

specifically require training that is targeted to address the early intervention service needs of infants and toddlers with disabilities who are homeless or who have been exposed to or experienced violence or trauma, we do