GUIDELINES: FREQUENTLY ASKED QUESTIONS ABOUT QUALIFICATIONS REQUIRED OF PERSONNEL CONDUCTING MEDICAL REVIEWS
What qualifications are required under the State Board of Education’s rules?
Section 226.840 of rules governing Special Education (23 Ill. Adm. 226.840; see http://www.isbe.net/rules/archive/pdfs/226ark.pdf)
sets forth the qualifications of personnel who may conduct medical reviews, as follows:
Until June 30, 2013, School Service Personnel Certificate endorsed for school nursing (23 Ill. Adm. Code 25.245), or a license to
practice medicine in all of its branches, or under Section 60 or 65 of the Nurse Practice Act [225 ILCS 65].
Beginning July 1, 2013, a School Service Personnel Certificate endorsed for school nursing (23 Ill. Adm. Code 25.245); or a license to
practice medicine in all of its branches; or a bachelor’s degree or higher and a license issued under Article 60 or Article 65 of the
Nurse Practice Act [225 ILCS 65/Art. 60 or Art. 65], provided that only a person holding a School Service Personnel Certificate
endorsed for school nursing shall make recommendations regarding educational interventions, accommodations or modifications
based on the findings of the student’s medical review.
How do the rules affect personnel who are currently employed by a cooperative or school district and assigned to conduct
medical reviews?
Beginning July 1, 2013, the medical review required for a student who is being evaluated or re-evaluated for special education
services shall be conducted by one of these three qualified personnel:
1) School nurse (hereinafter defined as any registered professional nurse who holds a school service personnel certificate with an
endorsement in school nursing, or any noncertificated registered professional nurse who was employed in the school district of
current employment before July 1, 1976); or,
2) Physician licensed to practice medicine in all its branches (i.e., a medical doctor, an osteopathic doctor or a chiropractor who
holds a license to practice medicine in all of its branches); or,
3) Registered Nurse with a bachelor’s degree or higher, or Advanced Practice Nurse.
Illinois State Board of Education - December 2012
In addition, the (1) school nurse (2) physician, or (3) RN (non-school nurse) with BA/BS or higher, may delegate portions of the
medical review to other school staff, such as other nursing level staff, vision/hearing technicians, or assistants, as allowed by these
other individual’s education and training.
As noted in the rules above, only a school nurse who holds a school service personnel certificate endorsed for school nursing (i.e.,
“certified school nurse”) may make recommendations regarding educational interventions, accommodations or modifications to the
student’s individualized educational program (IEP) based on the findings of the medical review. Special education cooperatives and
school districts that currently employ physicians licensed to practice medicine in all of its branches, registered nurses or advanced
practice nurses to make these recommendations must use only certified school nurses for this purpose beginning July 1, 2013,
although physicians licensed to practice medicine in all of its branches, registered nurses with a bachelor’s degree or higher and
advanced practice nurses may continue to conduct reviews relative to the student’s medical and health status after that time.
What exactly is a medical review?
A medical review is not a single act but a process with a number of activities resulting in a complete review of the student’s medical
and health status that provides the answer to the question: Is a health condition adversely affecting a student’s educational
performance? Neither state nor federal law defines “medical review.” However, federal law requires that a student who is being
evaluated or re-evaluated for special education services must be provided an assessment “in all areas related to the suspected
disability, including, if appropriate, health, vision, hearing….” (U.S. Department of Education, 34 CFR 300.304, Evaluation
procedures). The assessment must also be sufficiently comprehensive to identify all of the child's special education and related
services needs, including related services such as school nursing services and school health services under 34 CFR 300.34(c)(13). This
assessment has come to be commonly known as the “medical review”.
How is a medical review conducted?
A medical review begins with obtaining information in a process referred to by its acronym SOAP, or Subjective, Objective,
Assessment, Plan.
a. Subjective information is collected, such as the parent’s concerns about the student’s health, the student’s own perception of his
or her health, emotional feelings that are communicated, recollection of health history, teaching staff perceptions about how
student’s health is affecting academic program requirements, other signs of health or illness that may or may not be able to be
verified by lab tests or examination (such as pain, depression, etc.)
b. Objective information is noted, such as information that is contained in the student’s health records or can be obtained at
school, including vital signs, hearing tests, vision tests, height/weight/BMI, heart and lung sounds, and other data collected in the
past or present. Review of the student health record or potential health problems revealed by subjective information may lead
to a need for additional records, possibly requiring a release from a parent for physician or hospital records.
c. Assessment is first made of the quality of the data and a determination is made about whether more information or study is
needed. That assessment is made by school nurse, advanced practice nurse, registered nurse with a bachelor’s degree or higher,
or a physician licensed to practice medicine in all of its branches. Assessment is then made by the individual conducting the
medical review (school nurse, advanced practice nurse, registered nurse with a bachelor’s degree or higher, or a physician
licensed to practice medicine in all of its branches), about what, if any, appropriate nursing services are required to maintain the
student during the school day, and reported to the certified school nurse. Assessment concludes when the certified school nurse,
and only the certified school nurse, reviews the findings of the medical review and reports his or her educationally relevant
medical findings to the IEP team (and others in attendance). This report should summarize the findings, including information
about the educational significance of the student’s medical status. This report takes the medical review to its conclusion, as
required by IDEA, in the form of a statement or summary of “the educationally relevant medical findings, if any.” (34 CFR
300.311, Specific documentation for the eligibility determination). To arrive at findings, the certified school nurse is “exercising
instructional judgment or conducting an educational evaluation” (105 ILCS 5/10-22.23) when he or she makes any
“recommendations regarding educational interventions, accommodations or modifications” (23 IAC 226.840). In accordance
with Section 10-22.23 of the School Code, only a certified school nurse may conduct duties that require “exercise of instructional
judgment or education evaluation of pupils” (105 ILCS 5/10-22.23).
d. Plan – a) if there are no educationally relevant medical findings, a student may nonetheless have some medical issues that need
to be addressed by the school. A plan that covers only the medical recommendations regarding nursing interventions needed at
school may be developed by the school nurse, advanced practice nurse, registered nurse with bachelor’s degree or higher, or
physician licensed to practice medicine in all of its branches. b) If there are educationally relevant medical findings, a plan that
provides for educational accommodations, educational modifications, annual goals, short-term objectives, and ongoing
evaluation related to the educationally relevant medical findings is developed by the certified school nurse (in collaboration with
other members of the IEP team if relevant). The school nurse also makes recommendations regarding educational interventions
related to the health condition(s) that are adversely impacting the student’s educational performance. (Other personnel who
are qualified to conduct the medical review may participate in the planning process, but they are not qualified to determine the
specific educational-related provisions that may be needed in the student’s IEP, including identification of student goals that may
result from the provision of nursing interventions.)
What is the role of the certified school nurse in the IEP goal-planning process for a student with educationally relevant medical
findings?
The certified school nurse:
o assists with IEP development;
o integrates any needed school nursing services, as defined in 34 CFR 300.34(c)(13), into the student’s academic and/or
functional goals;
o makes recommendations regarding educational interventions, accommodations or modifications to instruction or in the
learning environment;
o provides or delegates (in accordance with provisions in the Illinois Nurse Practice Act) nursing interventions, which are the
activities the nurse provides for the student (or patient) and may be direct interventions (direct nursing care, such as
medications, tube feedings, dressing changes, skin care, respiratory care, etc., as well as teaching the client or other
providers about the student’s care, and indirect interventions, including case management activities, development of health
component of the IEP, and in-service classes for staff and faculty);
o make recommendations regarding student health-related goals, including frequency of evaluating student’s progress;
o make recommendations regarding specific school health services and school nursing services, 34 CFR 300.34(c)(13), to be
documented in the IEP; and
o writes progress reports relative to the established goals and evaluates the effectiveness of the interventions.
What can be done about shortages of certified school nurses available to conduct educationally evaluative provisions of the
medical review?
 ISBE is working with a number of partners to identify quicker paths to school nurse certification.
 ISBE is working to identify retired or otherwise non-working certified school nurses who may be able to return to work at least
part time.
 For a registered nurse who does not hold a bachelor’s degree, avenues for accelerated bachelor degree programs in nursing are
available at many of the state’s colleges and universities.
 Small school districts may wish to enter into multi-district contracts for employment of one or more certified school nurses to
carry out educational evaluations and medical reviews.
 Certified school nurses may delegate portions of the tasks in a medical review to other school staff, as allowed.
 School districts may wish to reorganize the school health services staff to best utilize existing personnel.
Appendix A
Summary of Medical and Nursing Professionals and Qualifications to Conduct Medical Review
Type of License issued by
Illinois Dept. of Financial and
Professional Regulation
Educational Degrees, Diploma or
Certificate
Qualified to Conduct
Medical Review
Qualified to make
recommendations regarding
educational interventions,
accommodations or modifications
based on the findings of the
student’s medical review
Licensed Practical Nurse (LPN)
One year in length; no academic
degree
No
No
Registered Professional Nurse
(RN)
Two years in length; associate
degree in nursing (ADN)
No, unless practicing as
school nurse prior to
1976 in the same district
(grandfathered)
No, unless practicing as school
nurse prior to 1976 in the
same district (grandfathered)
Registered Professional Nurse
(RN)
Hospital training program, 3 years
in length; grants a diploma (no
academic degree); one such
program remains in Illinois
No, unless
grandfathered (see
above)
No, unless grandfathered (see
above)
Registered Professional Nurse
(RN)
Baccalaureate degree in nursing
(BSN); four years in length
Yes
No, if not also holding Type 73
certificate issued by ISBE or
grandfathered (see above)
Yes, although a
baccalaureate degree in
nursing is preferred.
No, if not also holding Type 73
certificate issued by ISBE or
grandfathered
Registered Professional Nurse Baccalaureate degree in any field
(RN) holding baccalaureate
other than nursing
degree in another field
besides nursing (either pre- or
post-hospital training program
or an associate’s degree
program)
Type of License issued by
Illinois Dept. of Financial and
Professional Regulation
Educational Degrees, Diploma or
Certificate
Qualified to Conduct
Medical Review
Qualified to make
recommendations regarding
educational interventions,
accommodations or modifications
based on the findings of the
student’s medical review
Advanced Practice Nurse
(APN)
Graduate degree or post-master’s
certificate (unless grandfathered
prior to 2007)
Yes
No, if not also holding Type 73
certified issued by ISBE or
grandfathered (see above)
Certified School Nurse (RN
license issued by IDFPR and
Type 73 certificate issued by
ISBE)
Post-baccalaureate minimum of
one year to incorporate internship
and related courses aligned to
learning standards to address
educational principles, special
education, school law, and school
and public health rules and
regulations, among others. See 23
IAC 23.120 for details.
Yes
Yes
Physician (licensed to practice
medicine in all its branches)
Varies
Yes
No
Appendix B
Components of Medical Review (including level of health care worker required)
Components of a Medical
Review; description; type of
information
Responsibility of which of the
above professionals
May this component be
To whom
delegated by the
Illinois Nurse Practice Act: "A
professional who
registered professional nurse
maintains the
or advanced practice nurse
responsibility and
retains the right to refuse to
accountability of the
delegate or to stop or rescind
activity? (Illinois Nurse
a previously authorized
Practice Act: " 'Delegation'
delegation.”
means transferring to an
individual the authority to
perform a selected
nursing activity or task, in
a selected situation. ")
Vision Screening – as directed CSN, MD, APN, RN/BSN who holds
by Subpart C of Illinois
IDPH certificate as vision
Department of Public Health
screening technician
(IDPH) rules governing Vision
Screening (77 Ill. Reg.
685.Subpart C;
http://www.ilga.gov/commiss
ion/jcar/admincode/077/077
00685sections.html) and
Illinois law (objective data)
Yes
Any person holding certificate
issued by IDPH as vision
screening technician
Hearing screening -- as
directed by IDPH rules
governing Hearing Screening
(77 Ill. Reg. 685.Subpart C;
Yes
Any person holding certificate
issued by IDPH as hearing
screening technician
CSN, MD, APN, RN/BSN who holds
IDPH certificate as hearing
screening technician
Components of a Medical
Review; description; type of
information
Responsibility of which of the
above professionals
May this component be
To whom
delegated by the
Illinois Nurse Practice Act: "A
professional who
registered professional nurse
maintains the
or advanced practice nurse
responsibility and
retains the right to refuse to
accountability of the
delegate or to stop or rescind
activity? (Illinois Nurse
a previously authorized
Practice Act: " 'Delegation'
delegation.”
means transferring to an
individual the authority to
perform a selected
nursing activity or task, in
a selected situation. ")
rules governing Vision
Screening (77 Ill. Reg.
685.Subpart C;
http://www.ilga.gov/commiss
ion/jcar/admincode/077/077
00675sections.html) and
Illinois law (objective data)
Health History – Review of
student health records
(objective data, such as
immunization record, health
room visits, medications on
record, health-related
absences, etc.)
CSN, MD, APN, RN/BSN
Health History – Recall
CSN, MD, APN, RN/BSN
Yes
By CSN, APN, RN/BSN to
another RN
By CSN, APN, RN/BSN to an
LPN
By MD to any licensed health
worker as provided by
Medical Practice Act of 1987
[225 ILCS 60]
Yes
By CSN, APN, RN/BSN to
Components of a Medical
Review; description; type of
information
Responsibility of which of the
above professionals
May this component be
To whom
delegated by the
Illinois Nurse Practice Act: "A
professional who
registered professional nurse
maintains the
or advanced practice nurse
responsibility and
retains the right to refuse to
accountability of the
delegate or to stop or rescind
activity? (Illinois Nurse
a previously authorized
Practice Act: " 'Delegation'
delegation.”
means transferring to an
individual the authority to
perform a selected
nursing activity or task, in
a selected situation. ")
reported by parent and, if
applicable, by student, and
recorded by health care
worker (subjective data)
Health History – Recall
reported by student’s other
teachers and caregivers
(subjective data)
another RN
By CSN, APN, RN/BSN to an
LPN
By MD to any licensed health
worker as provided by
Medical Practice Act of 1987
CSN, MD, APN, RN/BSN
Yes
By CSN, APN, RN/BSN to
another RN
By CSN, APN, RN/BSN to an
LPN
By MD to any licensed health
worker as provided by
Medical Practice Act of 1987
Physical Assessment (Head to
toe ROS: Review of Systems)
CSN, MD, APN, RN/BSN
Yes
By CSN, APN, RN/BSN to
another RN
Components of a Medical
Review; description; type of
information
Responsibility of which of the
above professionals
May this component be
To whom
delegated by the
Illinois Nurse Practice Act: "A
professional who
registered professional nurse
maintains the
or advanced practice nurse
responsibility and
retains the right to refuse to
accountability of the
delegate or to stop or rescind
activity? (Illinois Nurse
a previously authorized
Practice Act: " 'Delegation'
delegation.”
means transferring to an
individual the authority to
perform a selected
nursing activity or task, in
a selected situation. ")
objective data obtained
during physical examination
By MD to any licensed health
worker as provided by
Medical Practice Act of 1987
Health Assessment (evaluate
findings to determine
whether a student has any
health needs that the school
must provide)
CSN, MD, APN, RN/BSN
Summary of Educationally
Relevant Medical Findings
and, for initial placement,
determining whether the
student’s past or present
health status is or is not
adversely related to
educational performance.
May serve as the Statement
CSN
Yes
By CSN, APN, RN/BSN to
another RN
By MD to any licensed health
worker as provided by
Medical Practice Act 0f 1987
No, except to another CSN
Components of a Medical
Review; description; type of
information
Responsibility of which of the
above professionals
May this component be
To whom
delegated by the
Illinois Nurse Practice Act: "A
professional who
registered professional nurse
maintains the
or advanced practice nurse
responsibility and
retains the right to refuse to
accountability of the
delegate or to stop or rescind
activity? (Illinois Nurse
a previously authorized
Practice Act: " 'Delegation'
delegation.”
means transferring to an
individual the authority to
perform a selected
nursing activity or task, in
a selected situation. ")
of Present Level of
Educational Performance (as
it relates to health) in the IEP.
Educational
Recommendations (Including
Annual Goals and Short-Term
Objectives) –
recommendations for
educational interventions,
accommodations and
modifications (including but
not limited to
recommendations that would
ameliorate the adverse
impact of the health
condition); report on how
current conditions affect
CSN
No, except to another CSN
Components of a Medical
Review; description; type of
information
Responsibility of which of the
above professionals
May this component be
To whom
delegated by the
Illinois Nurse Practice Act: "A
professional who
registered professional nurse
maintains the
or advanced practice nurse
responsibility and
retains the right to refuse to
accountability of the
delegate or to stop or rescind
activity? (Illinois Nurse
a previously authorized
Practice Act: " 'Delegation'
delegation.”
means transferring to an
individual the authority to
perform a selected
nursing activity or task, in
a selected situation. ")
educational environment,
including least restrictive
environment; and
recommendations on changes
to educational interventions,
methods or services that may
improve student’s ability to
function within the regular
classroom and/or least
restrictive environment
(Within the IEP)
CSN
No, except to another CSN
CSN
No, except to another CSN
Statement of Specific Nursing
Related Services to be
provided, duration, by whom,
when and where
Regular evaluation of the IEP
student health goals,
Components of a Medical
Review; description; type of
information
provided nursing
interventions, and student
progress
Responsibility of which of the
above professionals
May this component be
To whom
delegated by the
Illinois Nurse Practice Act: "A
professional who
registered professional nurse
maintains the
or advanced practice nurse
responsibility and
retains the right to refuse to
accountability of the
delegate or to stop or rescind
activity? (Illinois Nurse
a previously authorized
Practice Act: " 'Delegation'
delegation.”
means transferring to an
individual the authority to
perform a selected
nursing activity or task, in
a selected situation. ")