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Title: Response to Intervention (RtI) in General, Remedial and Special Education


1
Response to Intervention (RtI) in General,
Remedial and Special Education
Daniel J. Reschly dan.reschly_at_vanderbilt.edu Ore
gon School Administrators Eugene, OR September
19, 2005
2
What To Do With Egbert??
  • 1st Grade, falling behind in reading
  • Slow progress compared to peers
  • Likely to miss benchmarks related to passing 3rd
    Grade reading test
  • Distractible, inattentive, disruptive
  • Sound Familiar
  • WHAT HAPPENS NEXT? Driven by Federal Legislation

3
Progression of Federal Education Legislation
1960s 2000s Assistance
Results __________________________ ESEA EHA Goa
ls NCLB/ 2000 Rdg
1st Process Results Number Served Goals
4
NCLB Long-term Goals
  • By 2013-2014, all students will reach high
    standards, at a minimum, attaining proficiency or
    better in reading and mathematics.
  • By 2005-2006, all students will be taught by
    highly qualified teachers.
  • All students will be educated in learning
    environments that are safe, drug free, and
    conducive to learning.
  • All students will graduate from high school.

5
Scientifically-based Interventions
  • Strong internal validity, did the intervention
    actually make a difference
  • Rigorous experimental designs
  • Random assignment
  • Subjects described in detail
  • Contrasting intervention conditions

6
Not Scientifically-based
  • Absent experimental designs-no control group no
    random assignment
  • Simple pre post-test designs
  • Theoretically-driven, but no data
  • Claims not supported by data
  • Claim that it is impossible to conduct
    experimental investigations
  • Claims from small N studies, no control group,
    data not published in refereed journals

7
Policy Analysis Influences
  • Snow, C. E., Burns, M. S. Griffin, P. (Eds.)
    (1998). Preventing reading difficulties in young
    children. Washington DC National Academy Press.
  • Teaching children to read An evidence-based
    assessment of the scientific research literature
    on reading and its implications for reading
    instruction http//www.nichd.nih.gov/publications/
    nrp/smallbook.pdf
  • Minority Disproportionality Report, National
    Academy of Sciences/National Research Council
    Panel Report
  • http//www.nap.edu/catalog/10128.html
  • LD Summit Researchers Recommendations (Bradley et
    al., 2002)
  • Presidents Commission on Excellence in Special
    Education (2002) report, http//www.ed.gov/inits/c
    ommissionsboards/whspecialeducation/reports.html

8
What Next for Egbert?
  • Chapter I tutoring
  • Pull out, brief
  • Poor results
  • Little benefit despite billions spent
  • Poor instruction, little progress monitoring,
    rare changes in instruction based on results
  • Billions spent, dubious benefits

9
What Next for Egbert?
  • Pre-referral Intervention
  • For most, meaningless step
  • Behavioral Definition? 15
  • Data prior to intervention? 10
  • Written Plan? 15
  • Progress monitored/changes? 5
  • Compare pre to post 10

10
PROBLEM SOLVING CHART
Does the damn thing work?
Yes
No
Dont mess with it!
Did you mess with it?
You Idiot!
Yes
No
No
Will you catch hell?
Hide it!
Yes
Does anyone else know?
No
Yes
You poor slob!
Ignore it
Can you blame somebody else?
No
Yes
NO PROBLEM
11
Refer Egbert for Special Education Consideration
  • Comprehensive Evaluation-Battery of Tests,
    common battery?
  • Assessment largely outside of the natural context
  • Dubious generalizations from test behavior to
    classroom
  • Eligibility assessment unrelated to intervention
  • Team decision-making
  • Egbert not eligible at 1st, 2nd, or 3rd grade
  • WAIT TO FAIL EFFECT

12
Categories Meaningful?
  • OR
  • MR 0.4 (NJ) to 3.0 (WV) 7Xs 0.6
  • ED 0.1 (AR) to 2.0 (MN) 20Xs 0.8
  • LD 2.7 (KY) to 9.3 (RI) 3Xs 5.7
  • Sp/L 0.8 (HI) to 3.8 (WV) 5Xs 2.8
  • OHI 0.1 (MS) to 2.1 (RI) 21Xs 1.0
  • All 9.7 (CO) to 17.9 (RI) 2Xs 12.0
  • What Accounts for the Differences?? Also
    differences between LEAs within states
  • 2002-2003, age 6-17, school enrollment, Table
    AA-13, www.IDEAdata.org

13
Foundations for Policy Changes What Does Work?
Sp Ed Placement??
  • Treatment/Intervention aEffect Size
  • EMR/Sp. Ed. Placement (IQ 60-75) -.14
  • Slow Learner/Sp. Ed. IQ 75-90 -.34
  • SLD and E/BD Sp. Ed. .29
  • Traditional Placement Practices???
  • Weak Relationships to Outcomes
  • Note Effect size is expressed in SD units,
    analogous to a z-score

14
IDEA 2004 Statute Re LD Identification
  • Re SLD, the local educational agency shall not
    be required to take into consideration whether
    the child has a severe discrepancy between
    achievement and intellectual ability
  • The LEA may use a process which determines if a
    child responds to scientific, research-based
    intervention
  • RTI

15
IDEA 2004 Proposed Regulations Re LD
Identification 300.307 Specific learning
disabilities
  • (a) General. State must establish criteria and
    LEA must use state criteria
  • (1) State can prohibit use of severe discrepancy
    between achievement and intellectual ability
    (severe discrepancy)
  • (2) State cannot require use of severe
    discrepancy
  • (3) State must permit the use of a process that
    determines if the child responds to scientific,
    research-based intervention (Response to
    Intervention or RtI)
  • (4) State may permit the use of other
    alternative research-based procedures

16
IDEA 2004 Proposed Regulations Re LD
Identification
  • 300.308 Group members. No significant changes
  • 300.309 Determining the existence of a specific
    learning disability.
  • (a) The group described in 300.308 may
    determine that a child has a specific learning
    disability if
  • (1) The child does not achieve commensurate with
    the childs age in one or more of the following
    areas, when provided with learning experiences
    appropriate for the child's age
  • Adds Reading fluency to the existing 7 areas

17
300.309 Determining the existence of a specific
learning disability continued
  • (2)
  • (i) The child fails to achieve a rate of learning
    to make sufficient progress to meet
    State-approved results in one or more of the
    areas identified in paragraph (a)(1) of this
    section when assessed with a response to
    scientific, research-based intervention process
  • or

18
300.309 Determining the existence of a specific
learning disability continued
  • or
  • (ii) The child exhibits a pattern of strengths
    and weaknesses in performance, achievement, or
    both, relative to intellectual development, that
    is determined by the team to be relevant to the
    identification of a specific learning disability,
    using appropriate assessments consistent with
    300.304 and 300.305 and

19
300.309 Determining the existence of a specific
learning disability continued
  • NEW AND SIGNIFICANT
  • (b must consider, as part of the evaluation
    described data that demonstrates that
  • (1) Prior to, or as a part of the referral
    process, the child was provided appropriate
    high-quality, research-based instruction in
    regular education settings, consistent with
    section 1111(b)(8)(D) and (E) of the ESEA,
    including that the instruction was delivered by
    qualified personnel and
  • (2) Data-based documentation of repeated
    assessments of achievement at reasonable
    intervals, reflecting formal assessment of
    student progress during instruction, was provided
    to the child's parents.

20
Multi-Tiered Academic Interventions of Increasing
Intensity and Measurement Precision
  • Academics (Empirically validated instruction)
  • Level I General Education All students
  • Level II Standard Protocol and Problem Solving
    Small group and individualized interventions with
    eligibility determination if response is
    insufficient
  • Level III Special education More intense
    services brought to student

21
Multi-Tiered Academic Interventions of Increasing
Intensity and Measurement Precision
  • Behavior-Empirically validated
  • Level I General Education School wide positive
    discipline
  • Level II Standard Protocol Treatments and
    Problem Solving Classroom organization and
    management and targeted individual interventions
    in general education. Eligibility determination
    if necessary.
  • Level III Special education More intense
    services brought to the students

22
Tier I Primary Prevention
  • Scientifically-based instruction
  • Curricula-content
  • Teaching methodology
  • Periodic Assessment of Progress
  • Screen all students, begin in mid-kindergarten 3
    times per year
  • More intense instruction and monitoring for
    students below class medians
  • Connect results to benchmarks, additional
    assistance to non-predictors
  • Emphasis on Prevention

23
Tier I cont.
  • Low performing students
  • Assess progress monthly
  • Establish additional learning opportunities using
    specialized materials and instruction
  • In general education classroom
  • Grouping students
  • Tutoring by paraprofessionals
  • Train parents when appropriate

24
Tier I Case Example Behavior
  • Egbert middle of Ktg.
  • Teacher observation of behavior
  • Eggie is aggressive toward other children and,
    occasionally, toward adults
  • Disrupts classroom activities, large and small
    group settings
  • Now What?
  • Ensure effective classroom organization and
    management Rules, expectations, examples,
    consistent application, etc.
  • Focus attention on positive behaviors, ignore
    (when possible) negative behaviors
  • Clear consequences for aggressive behavior toward
    others (inclusion time out)

25
Reading Benchmarks
Big Idea of Literacy CBM Measure
Indicator of Risk-KTG Letter Naming Fluency
Phonemic Awareness Initial Sound Fluency Phoneme Seg Fluency
Alphabetic Principle Nonsense Wd Fluency
Accuracy and Fluency with Text Oral Rdg Fluency (ORF)
Comprehension ORF and Retell Fluency
Vocabulary Word Use Fluency
26
Reading Benchmarks (DIBELS)
Age/Grade Measure Fluency (FL) Criterion
Winter KTG Letter Naming Fl Initial Sound Fl 25 sounds per minute (pm)
Spring KTG Phoneme Seg 35 sounds pm
Winter 1st gr. Spring 1st gr. Spring 2nd gr. Spring 3rd gr. Nonsense WD Oral Rdg Fluency Oral Rdg Fluency Oral Reg Fluency 50 sounds pm 40 wds pm 90 wds pm 110 wds pm

27
Tier I Case Example Academics
  • Egbert middle of Ktg.
  • Screening data, Eggie below benchmarks for Ktg in
    letter-sound recognition
  • Now What?
  • Classroom instruction for all children
    emphasizing phonemic recognition skills
  • Increase assessment once per month for Eggie and
    others similar to him
  • Additional small group instruction in the
    classroom with continued monitoring

28
Tier I Case Example Behavior
  • Egbert middle of Ktg.
  • Teacher observation of behavior
  • Eggie is aggressive toward other children and,
    occasionally, toward adults
  • Disrupts classroom activities, large and small
    group settings
  • Now What?
  • Ensure effective classroom organization and
    management Rules, expectations, examples,
    consistent application, etc.
  • Focus attention on positive behaviors, ignore
    (when possible) negative behaviors
  • Clear consequences for aggressive behavior toward
    others (inclusion time out)

29
Tier I Screening in General Education
30
3rd Grade Classroom Example
  • Did not pass Passing Scores

31
Results of Tier I
  • Prevention Effect
  • Measure progress monthly for children below
    benchmarks
  • Many children below Curriculum Based Measurement
    Reading benchmarks respond to general education
    classroom interventions.
  • Non-responders?
  • Tier II interventions provided

32
Tier II Secondary Prevention
  • Academics Standard protocol treatments
  • Small group, pull out, similar needs
  • More intense instruction and monitoring
  • 5-component reading interventions, with emphasis
    on weak components
  • 10-20 weeks of intervention
  • Not individualized, may not deal with behavior
  • Early identification-early intervention

33
Tier II cont. Academics
  • Direct instruction, explicit teaching
  • I do it We do it together You do it with
    feedback You do it to automaticity
  • Focus on skills in weak areas, alphabetic
    principle, fluency, vocabulary, comprehension
  • All components included and taught explicitly
  • Progress monitoring weekly, graphed, formative
    evaluation
  • 20 weeks of explicit instruction
  • Decisions based on level and rate of learning in
    relation to benchmarks

34
Tier II cont. Behavior
  • Eggie Classroom disruptive behaviors and
    aggression continue at unacceptable levels
  • Targeted individualized interventions
  • Formal behavior observations using a structured
    protocol
  • IL (location), Noisy, Attending, PN (physically
    negative) plus other aggression
  • Time sampling plus event recording
  • Peer comparisons

35
Tier II Behavior cont
  • Behavioral Intervention
  • Precise Definition-Observable Behavior
  • 2. Valid/Reliable Measure in the Natural Setting
  • 3. Validate the Existence of the Problem
    Estimate the Severity (Age Norms/Peer
    Comparisons)
  • 4. Intervention Goals in Terms of the Target
    Behavior
  • 5. Analysis of Antecedent (including prior
    knowledge), Situational, and Consequent
    Conditions

36
Tier II Behavior cont
  • Behavioral Intervention, cont.
  • 6. Intervention Plan Based on Principles of
    Behavior Change or Instructional Design
  • 7. Systematic Implementation, Treatment
    Integrity, Frequent Monitoring of Progress
  • 8. Formative evaluation-revisions as needed
  • 9. Evaluate effects after 20 weeks
  • 10. Systematic Plan for Maintenance and
    Generalization of Behavior Change

37
Effects of Tier I and Tier II
  • Potentially identifies more students in general
    education with reading problems through universal
    screening
  • Reduces number of students with very poor reading
    and increases number of students meeting
    benchmarks, but
  • Non or insufficient response rate of 3-5
  • Generalizations of improved performance to
    classroom without pull out support
  • What Next?

38
Limitations of Tier II in LD Identification
  • Small group interventions, NOT individualized
  • Does not meet requirements for a full and
    individual evaluation
  • Academic focus, probably ignores behavior
  • Multi-factored assessment required
  • Exclusion factors must be assessed

39
(No Transcript)
40
Foundations for Policy Changes What Does Work?
ABA, DI, CBM
  • Treatment Effect Size
  • Applied Behavior Analysis. 1.00
  • CBMGraphingFormative
  • Evaluation .70
  • CBMGraphingFormative
  • EvaluationReinforcement 1.00
  • Comprehension Strategies gt1.00
  • Many other effective instructional and behavior
    change principles

41
PS-RTI Challenges
  • Fidelity of Treatment, steps and decision making
  • Paradigm Shift Change thinking and priorities
    about services
  • Continuing education needs of practitioners
  • No bright lines to separate eligible from
    non-eligible students

42
Prevention-Early Intervention
  • LEA can use 15 of federal IDEA funds to support
    prevention and early identification-treatment
  • Purpose minimize over-identification and
    unnecessary sp ed referrals
  • Provide academic and behavioral supports
  • Supports professional development and provision
    of interventions including early literacy
    instruction
  • Scientifically-based
  • Golden opportunity for schools!!

43
SEA/LEA Choices RELD Identification
  • IF Tier I and Tier II are done well and are
    insufficient THEN WHAT???
  • Four Options Implications and Value
  • Cognitive assessment, processes, pattern of
    strengths and weaknesses??
  • IQ-achievement discrepancy?? Revised?
  • Intense, individualized problem solving
  • Nothing-child is eligible based on Tier II
    results

44
What Is A Specific Learning Disability?
  • Many plausible answers
  • Social and political reality in need of a
    foundation in theory and research
  • Definition (psychological processes) ignored for
    30 years in federal regulations on identification
    of LD. Why?
  • Research for 30 years on LD identification and
    student characteristics
  • State policies and practices

45
LD Is Relative to Context and Expectations
  • Large differences in achievement levels depending
    on context and expectations
  • Key feature LD is very low achievement compared
    to peers that, associated with other behaviors,
    provokes referral
  • Many persons with low ach not referred,
    especially girls with reading problems
  • LD is real in the sense of low relative
    achievement, often complicated by mildly
    disruptive classroom behavior, that places
    children and youth on a negative educational
    trajectory

46
Origins of IQ-Achievement Discrepancy
  • 1975 Congress passed mandatory special education
    legislation, LD included
  • Processing definition adopted
  • Processing measures and interventions repudiated
    in research published in early to mid 1970s
  • Huge concerns about over-identification and
    consistency prevalence estimates varied from 2
    to 32
  • Congress mandated the development of LD
    classification criteria OR 2 cap imposed
  • Deadline of December 31, 1977

47
Origins of IQ-Achievement Discrepancy continued
  • Enormous disagreement in the field in 1975-1977,
    gt1000 letters to BEH
  • No consensus on LD identification
  • Rutter Yule studies-2 groups of poor readers
  • Severe discrepancy between achievement and
    intellectual ability
  • Best alternative to a very difficult problem
  • Marker for LD, but never thought to be the
    essence of LD
  • Problems recognized immediately (Danielson
    Bauer, 1978)

48
Implementation of Severe Discrepancy Overall
Trends
  • Increasingly adopted by states in 1970s and 1980s
  • Little consistency regarding method to determine
  • Little consistency regarding magnitude of
    discrepancy
  • Considerable evidence of frequent nullification

49
Implementation of Severe Discrepancy State
Policies and Practices
  • Reschly Hosp (2004)
  • 48 of 50 states (exceptions-IA and LA)
  • Standard score or SD differences 10 states
  • Regression methods or some variation 20 states
  • Idiosyncratic, uninterpretable methods or no
    stated method in 18 states

50
Implementation of Severe Discrepancy State
Policies and Practices
  • Criterion for severe discrepancy (how large?)
    (Reschly Hosp, 2004)
  • 30 of 48 states provide guidance to LEAs
  • Determined the magnitude of the required
    discrepancy if the IQ100
  • States vary from 15 to 30 points (still verifying
    some states)
  • No statistically significant relationship between
    magnitude of discrepancy and LD prevalence

51
Control of PrevalenceKY 2.85 to RI 9.43
www.ideadata.org Table AA13
Mean5.8, SD1.19
52
Discrepancy Method Criticized
  • IQ-Achievement Discrepancy
  • Unreliable-especially stability over short time
    intervals and different pairs of tests
  • Questionable Validity
  • Expensive
  • CAUSES HARM THROUGH DELAYING TREATMENT TO AGE
    9-11

53
Ability-Achievement Discrepancy What Next?
  • Strong proponents exist (Kavale, Scruggs and
    Mastropieri)
  • Essential marker of LD, necessary but not
    sufficient
  • Implementation fidelity is the main problem
  • Revise to overcome weaknesses
  • Better than nothing, a flawed bright line is
    better than no line

54
Ability-Achievement Discrepancy Conclusions
  • Rejected by LD Summit Researchers
  • Must overcome research indicating
  • Questionable validity and reliability
  • Wide variations in how applied
  • Enormous variations in prevalence
  • Harmful, wait to fail effects in early grades
    when intervention is most likely to be effective
  • Absence of prevention or early identification-earl
    y intervention effects

55
Processing Basis for LD Identification
  • Terminology
  • Basic psychological processes related to learning
  • Neuropsychological intact and non-intact areas,
    or strengths and weaknesses
  • Learning Styles
  • Information processing modality (visual-auditory)
  • Cognitive processing (simultaneous-successive-
    plus others)

56
Origins of Processing in LD Identification
  • Original definition, Kirk et al.,
  • Adopted in Federal legislation in 1967 and in EHA
    in 1975, 1977 IDEA 2004
  • Dominant definition in states
  • Conforms to essence of LD according to many LD
    experts
  • Theory driven
  • Claims of positive benefits always precede
    research examining the claims

57
Applications of Processing Constructs in LD
Identification and Treatment
  • LD Identification A child with LD displays a
    pattern of cognitive strengths and weaknesses
    that account for the inefficient learning and
    poor achievement
  • LD Intervention-Process Training Interventions
    are designed to improve cognitive weaknesses,
    with the assumption that improved achievement
    will follow.
  • LD Intervention-Aptitude by Treatment
    Interaction Instructional content and
    methodology matched to cognitive (neurological)
    strengths

58
Applications of Processing Constructs in LD
Identification
  • LD Identification
  • Focus on pattern of strengths and weaknesses
  • Assumption that LD is caused by or is related
    to cognitive weaknesses that interfere with
    efficient learning
  • Clinical insight integrate test scores with
    clinical observations and other data sources to
    offer insightful answers to referral questions.
  • Greater profile variability seen as indicator of
    LD

59
Processing Constructs in LD Identification State
Policies and Practices
  • Most states use Federal LD definition (82)
  • Most states ignore processing disorder in
    classification criteria (37/50 or 74)
  • The 13 states do NOT provide explicit guidelines
    or criteria to guide identification of processing
    deficit
  • Unrelated to LD prevalence
  • Trend toward diminishing state specification of
    processing disorder in LD classification,
    1980-2005

60
Processing in LD Identification Research Results
  • No unique pattern associated with LD
  • High base rates for processing strengths and
    weaknesses
  • Test scatter is normal and more tests, more
    scatter
  • Nearly all (if not all) children with low
    achievement with have processing deficits (as
    will normal children)
  • Profile reliability is questionable

61
Processing in LD Identification Research Results
  • Poor consistency due to high subjectivity in
    profile interpretation
  • No evidence that greater stress on cognitive
    processing will control LD prevalence (more
    likely to exacerbate over identification)
  • Always new processes related to new theories
    with promise of improved results with new
    processes
  • Intense debates between authors of new tests
    and processes vs researchers appeared in 1970s,
    1980s, 1990s, and 2000s

62
Cognitive Processing in LD Interventions Process
Training Research 1970-2005
  • Many processes, many claims, little research
  • Rare positive results
  • Even rarer demonstration of near transfer of
    gains No evidence of far transfer
  • No evidence of achievement gains related to
    alleged processing gains
  • No studies that meet standards for scientifically
    based research
  • Claims of advocates virtually never confirmed in
    research by others

63
Use of Processing in Aptitude by Treatment
Interaction Matching
  • Match Up Teaching Methodology to Aptitudes
    Avoid Dead Tissue (Reynolds, 1992)
  • Many Applications in School Psychology and
    Special Education (e.g..., Neuropsychology,
    Learning Styles, Multicultural Teaching
    Methodology, Simultaneous vs Sequential,
    Information Processing Modality, Right Hemisphere
    -- Left Hemisphere, visual vs Auditory Learners)

64
Aptitude by Treatment Matching???
  • Treatment/Intervention aEffect Size
  • Modality Matched Instr. (Aud.) .03
  • Modality Matched Instr. (Vis.) .04
  • Simultaneous/Successive .??
  • Right Brain/Left Brain .??
  • Cultural Leaning Style .??
  • NOTHING FOR KIDS
  • FEEL GOOD ASSESSMENT

65
Results of ATI Research
  • King of England describing his Danish
    brother-in-law There is nothing there.
  • Cronbach, (1975). Once we attend to
    interactions, we enter a hall of mirrors that
    extends to infinity. (p. 119)
  • Kavale (1999) No supportive data, but cannot kill
    Phoenix-like processing claims
  • Vaughn and Linan-Thompson (2003), There is no
    empirical support for the use of modality-matched
    instruction or learning styles as a means to
    enhance outcomes for students with LD. (p. 142).

66
Digression Neuropsychology and Neuroscience
  • Distinguish between neuropsychology and
    neuroscience
  • Neuropsychology is dependent on psychometric
    profiles
  • Difference scores are less reliable
  • Scatter is normal
  • Base rates for profile variations
  • Flat profiles are atypical
  • Nearly all have profile variations

67
Neuroscience Findings
  • Instruction in decoding changes brain functioning
    on fMRI
  • Neuroscience findings generally refute
    traditional neuropsychology with learning
    problems
  • Neurological functioning more dynamic, less
    static
  • Little practical application of fMRI to current
    school psychology practice
  • No unique LD markers!!

68
Neuroscience
  • Instruction in decoding changes brain functioning
    on fMRI
  • Neurological functioning more dynamic, less
    static
  • Little practical application of fMRI to current
    school psychology practice
  • No unique LD markers!!

69
Digression fMRI Studies
  • Science article fMRIs of boys and girls engaged
    in decoding-Girls used both hemispheres, boys one
  • Implications??
  • Do fMRI to find real LD?
  • Abandon IQ and go to fMRIs
  • Trade the hatchback for an 18 wheeler
  • Cost issues 3m per machine, plus maintenance

70
Strengths of Cognitive Processing as a Key Factor
in LD
  • Consistent with traditional (widely ignored)
    unvalidated LD definition
  • Consistent with advocates feelings about
    essence of LD
  • Preserves traditional clinical practice for many
    professionals

71
Problems with Cognitive Processing and LD
Identification and Intervention
  • Absence of empirical evidence to support claims
  • Clinical interpretationnot testable
  • Identification? Must overcome the base rates for
    profile variations
  • Treatment? Must show that processes can be
    trained AND that changes in processes produce
    better achievement
  • Treatment? Must should statistically and
    practically significant ATI
  • Flawed assumptions refuted to date in research

72
Problem Solving and RtI
  • Improves behavior and achievement outcomes in
    general, remedial, and special education
  • Links diagnosis with treatment
  • Facilitates application of scientifically-based
    interventions
  • Self-correcting methodology
  • Accountability enhanced
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