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Note:  This document has been delivered to the Office of the Federal Register but has not yet been scheduled for publication.  The official version of this document is the document that is published in the Federal Register.

not believe that it is appropriate for the Department to

require that a State’s CSPD mandate particular types of

training or training targeted to specific populations. Each State is in the best position to evaluate the training needs of personnel providing early intervention services in that State and to design the CSPD to meet those needs.

Similarly, it is the Department’s position that it is not

necessary to list in the regulations occupational therapy or other specific fields in which training must be

provided, particularly given that §303.13(a)(7) requires

that qualified personnel provide all early intervention services, including occupational therapy. Moreover,

§303.119(a), which requires that a State’s system include

policies and procedures relating to the establishment and maintenance of qualification standards to ensure that personnel are appropriately and adequately prepared and trained, is sufficiently broad to ensure that each State will address, as appropriate, the needs of its specific subpopulations and identify any providers or personnel that may need more specific training.

We disagree that the regulations should require a

State’s CSPD to mandate all training, including the

training described in §303.118(b). As noted in the

preceding paragraph, we want to provide each State with