Natural Environments:
A Call for Policy Guidance

Janet DesGeorges, Hands & Voices, Cheryl DeConde Johnson, University of Colorado, Boulder, Arlene Stredler Brown, University of Colorado, Boulder

Editor’s Note:  The IDEA 2004 Part C regulations have been released and are seeking public comment through June.  More information and for location of public meetings to be held may be found at:

Natural environments, in many ways like its IDEA Part B counterpart, “least restrictive environment” (LRE), is not well understood as it applies to children who are deaf or hard of hearing (D/HH). A special Part B policy guidance was issued by the U.S. Department of Education in 1992 to clarify the accessibility and education issues associated with LRE for school-age children and communication access specifically for these children and youth who are D/HH. These same issues apply to the intent of Part C’s natural environment stipulations.

The purpose of this article is to identify factors that should be considered when determining learning environments for infants and toddlers who are D/HH and to call upon the US Office of Education to provide policy guidance on the ways in which natural environments are considered for this population. Policy guidance is necessary to assist families and service providers with the development of appropriate Individualized Family Service Plans (IFSPs).

IDEA Requirements for “Natural Environments”

The requirements in federal law provide for early intervention services to take place, to the maximum extent appropriate, in natural environments. Part C of the Individuals with Disabilities Education Act (IDEA) states that early intervention services “… To the maximum extent appropriate, are provided in natural environments, including the home and community settings, in which children without disabilities participate…” [34 CFR 303.12(b)]; Part C defines natural environments as “settings that are natural or normal for the child’s age peers who have no disabilities”. (34 CFR 303.18)

Equally relevant, the requirements in federal law provide the opportunity to justify why a child’s early intervention may be conducted in settings other than those provided in natural environments when the IFSP team determines that a child’s needs cannot be met in a natural environment: The provision of early intervention services for each eligible child occurs in a setting other than a natural environment only if the IFSP team determines that early intervention cannot be achieved satisfactorily for the child in a natural environment [34 CFR 303.12(2)].  This section of the law is interpreted to mean that the provision of early intervention services for any infant or toddler occurs in a setting other than a natural environment only if functional goals cannot be achieved satisfactorily in a natural environment. While the IFSP team is required to justify why services may need to be provided in settings other than a natural environment, the team should not feel compelled to provide an “undue burden of justification,” as this would violate the spirit of the requirement that the IFSP be based on the individual needs of the child. (34 CFR 303.340)

The balance between these two components of the law must be taken into consideration.  For a child who is deaf or hard of hearing, the most important factor is providing a language-rich environment.  A unique set of considerations arise in defining the characteristics of a language-rich environment for a deaf or hard-of-hearing child.  Simply stated, a language-rich environment is one in which language is complete and it is expanded and reinforced to provide appropriate repetition.  In addition, the child is actively supported to learn language experientially, freely and naturally by communicating directly with adults and peers. When a child who is deaf or hard of hearing is immersed in a language-rich environment, the potential exists to override the adverse influences of hearing loss.  This language-rich environment defines the context of least restrictive environments and natural environments for infants and toddlers who are deaf or hard of hearing.

To recognize these unique communication needs, the 2000 proposed Part C Rules (Federal Register, 65, p.172), included the following language:

“Consider the communication needs of the child, and, in the case of a child who is deaf or hard of hearing, consider- (A) The appropriateness of oral stimulation and language-development activities; and (B) opportunities for direct communication with peers, professional personnel, and deaf adults in the child’s language and communication mode, consistent with the developmental level of the child.” [303.342 (a)(2)(iv)(A)(B)] 

Considerations of a Unique Population:  Rationale for Policy Guidelines for Deaf and Hard-of-Hearing Infants and Toddlers Served by Part C

All populations of children with disabilities have unique characteristics and needs. For infants and toddlers who are deaf or hard of hearing, the special considerations include: (1) the consequences of hearing loss for auditory, language and cognitive development, (2) the critical period of intervention in the first months and early years of life, and (3) the availability and accessibility to a language-rich environment. Standards of practice for this population of young children recognize the importance of both family-centered and child-centered activities and services (Colorado Department of Public Health and Environment, 2004; Watkins & Clark, 1993). Once a child begins to interact with peers, those interactions must be communication accessible if the child is to benefit from opportunities for spontaneous acquisition of language. Toddler play and language groups, which are set-up to provide these necessary acoustical, language, and communication accommodations, are therefore essential.

Audition, Language, and Cognitive Development. Infants and toddlers who are born with hearing loss, or acquire hearing loss shortly after birth, are insulated, in varying degrees, from the sounds of everyday life. In order to compensate for this auditory isolation, alternative and/or supplementary methods for accessing language need to be developed. Because language is linked to cognitive development, every opportunity to eliminate barriers to language input will promote cognitive development (Laughton & Hasenstab, 2000). Children with hearing loss must receive appropriate services to minimize the barriers of hearing loss and to provide them the opportunity to actualize their learning potential.

The First Three Years – A Window of Opportunity.  As a result of the implementation of hospital-based newborn hearing screening programs throughout the United States, most infants now have their hearing screened at birth. With this early identification initiative, we now have the opportunity to turn a potentially language-debilitating disorder into one where the impact of hearing loss is minimized. To do so, every and all opportunities to promote language development during this critical period must be captured. Research shows that appropriate early intervention maximizes an infant or toddler’s potential for language development (Yoshinaga-Itano, Sedey; Coulter; & Mehl, 1998).  With this in mind, infants and toddlers benefit from an environment that supports language development during this critical period. This opportunity for language development for children with hearing loss has proven to be is most critical during the first months and years of a child’s life (Yoshinaga-Itano et al, 1998). Further, a recent analysis of state standardized assessment scores of students who are identified as D/HH in Colorado indicated that participation in early intervention was the most significant variable associated with increased performance (Johnson, 2005).

Language-Rich Environment.  Infants and toddlers who are immersed in language-rich environments are more likely to achieve age-appropriate language skills. The language-rich environment requires the use of specific language experiences including modeling, expansion, reinforcement, repetition, and learning through experience.  A language-rich environment is accessible, is provided using the child’s and parent’s preferred communication modes, and affords opportunities for active and consistent communication with peers and adults using the selected approach. While many natural environments (e.g., places where typical children without disabilities participate) are language-rich, they often do not offer communication access for children who are deaf or hard of hearing. As a result, natural environments may not be able to provide sufficient stimulation, language immersion, and language redundancy necessary to promote development of the child’s full potential and the desired outcomes of the family.

Recognizing the need to clarify the interpretation of natural environments for this population of children, the Western States Early Intervention Administrators Coalition for Young Children with Sensory Disabilities issued the following statement in 1999 regarding natural environments for infants and toddlers who are deaf or hard of hearing.

Natural Environments: Considerations for Infants and Toddlers
(Birth-3) who are Deaf/Hard of Hearing

  • Minimizing a family’s isolation by increasing the family’s sense of involvement by supporting/providing a network with other parents of children who are Deaf /Hard of Hearing
  • Assuring equal access to communication through a visual, auditory, and/ or tactile communication system specific to that child/family
  • Encouraging and assisting families in identifying their child’s and family’s strengths and resources
  • Supporting families to build relationships which enhance a child’s communication
  • Supporting families in developing meaningful communication utilizing a visual, auditory and/or tactile communication system so that the child may become a full participating member of the family
  • Providing typically developing children positive interactions with children who are Deaf/Hard of Hearing.

The following quotations further illustrate the importance of building language and communication for children who are deaf or hard of hearing.

…the communication nature of the disability is inherently isolating, with considerable effect on the interaction with peers and teachers that make up the educational process. This interaction, for the purpose of transmitting knowledge and developing the child’s self-esteem and identity, is dependent upon direct communication. Federal Register, (1992), p. 49274.

The need and right to communicate is the most fundamental of human rights.  To deny it is to harm the human spirit; to foster communication is to reveal all the possibilities of life. NDEP-Strategies for Systemic Reform (2000), p.1.

Communication is at the core of our existence.  Individuals thrive on their ability to convey ideas and express feelings, concepts are formed, vocabulary expanded, values instilled, and educational horizons broadened - all through the channel of communication.  For the heart of expressing oneself lies in language – the basic tool which in turn links us to our culture, home, community, and surrounding environment.  By being provided with the opportunity to share our thoughts, feelings, and knowledge with others, our lives become enhanced and we are able to transmit our information base to others, thus creating a bond with previous and future generations. N. A. Scheetz (1992), Orientation to Deafness, p. 72.

No environment that is communicatively isolating, and does not provide a child with the quality and quantity of linguistic input necessary to become linguistically competent, can humanely be considered “natural”. N. Sager (2001), Defining “Natural Environments for Deaf & HH Infants, Toddlers, and Preschoolers, p. 2.

Hearing impairment is unlike many other disabilities. It involves an impaired sense, which in turn, often causes delays in speech and language development. As such, many of the early intervention techniques involve intensive personal interaction with a service provider, extensive testing, and a high level of training and involvement of parents. These services may best be performed in teacher’s offices or in facilities that have extensive audiological services close at hand. Comments of the Alexander Graham Bell Association for the Deaf and Hard of Hearing for IDEA Notice of Proposed Rulemaking, Early Intervention Program for Infants and Toddlers with Disabilities, December, 4, 2000, p.3.

It should be recognized that diverse deliveries of services and access to a peer group are important for enhanced socialization and learning of language: T. Kregan, (2001), comments of Self-Help for Hard of Hearing People in the matter of reauthorization of IDEA, Nov.29, 2001.

A deaf or hard of hearing child … is fully capable of developing language—spoken or manual—and becoming a complete person.  A communication difference is not the same as a communication disability. L. Siegel (2000), the educational and communication needs of deaf and hard of hearing children: A statement of principle on fundamental educational change, p. 66.

Recommendations for Natural Environments

1. Early intervention services for all children who are deaf or hard of hearing shall be communication accessible.

A language-rich environment for an infant or toddler may be defined as including the following:

a. An environment in which language is enhanced using principles of modeling, expansion, reinforcement, redundancy, and learning through experience.

b. An environment where the communication mode of the child (as determined by the parents with the support of the early intervention team) is available.

c. An environment that utilizes early intervention providers who are proficient in the communication mode that the child uses.

d. An environment in which peers using the child’s communication mode is available. “Typical” children in a “natural environment” may be unable to communicate using the features and language approach of the child who is deaf or hard of hearing.

e. An environment that is adapted to facilitate access to auditory and visual information.

  • The acoustic environment promotes access to language and communication and supports auditory training and language development activities..  Auditory distractions (e.g., background noise) are minimized and noise reduction is accomplished with carpet and other sound absorption materials. 
  • An environment that supports visual enhancement of language by using appropriate lighting, providing hands-on materials, and minimizing visual distractions (clutter).
  • An environment where the child’s use of personal amplification is supported and hearing assistance technology is made available when it is recommended.  All personal and hearing assistance technologies are monitored to assure they are functioning properly.  And, the child’s functional performance is monitored to assure the child’s amplification goals are being met and the child is acquiring functional auditory skills. 

f.  An environment where specialized technology is available including, but not limited to, captioned videos, flashing fire alarms, TTY, and other visual alerting and reinforcement technology.

2. A Communication Plan shall be developed as part of the IFSP process.

The Communication Plan shall address the unique needs of the infant/toddler who is a deaf or hard of hearing to identify appropriate communication-based supports and strategies. This Plan is a roadmap that focuses on evaluation, mode of communication, direct communication with peers and adults, provider competencies, and natural environments. The Communication Plan insures that these critical areas are considered and that action steps are taken when gaps are identified. Table 1 describes the specific steps in the development of the Communication Plan.

Table 1. Components of the Part C Communication Plan

The IFSP team has considered each area listed below, and has defined services based on the child’s communication needs.

  1. The family and their IFSP team evaluate language development opportunities, communication approaches, and intervention program options.
  2. Communication modes are chosen by the family for use with their child. These approaches are demonstrated either in person or through the use of videotapes.  The professionals support the parents as they identify the approach they want to use.
  3. Opportunities for direct communication with peers and adults who are deaf or hard of hearing are explored and offered.  These role models receive training to work with families of infants and toddlers.  Parents may request peers and adults who represent the language and communication mode chosen by the family, as well as other modes/languages that are of interest.
  4. Opportunities for intervention services are available from professionals who have demonstrated proficiencies providing early intervention services to children who are deaf or hard of hearing and who can directly communicate with the child in a manner consistent with the child’s developmental level and communication mode.
  5. Early intervention services should be provided in natural environments that are fully accessible and offer active and consistent communication employing the approach used by the child.


3. IDEA Part C reauthorization regulations should include language specifically addressing the communication needs for children who are deaf or hard of hearing.

What is it about the issues and concerns that are raised by hearing loss that make it unique? Why do services for children with hearing loss need to be specifically identified in the Part C regulations? Language and communication access are the most fundamental of human rights. Therefore special programming is required to fill in the gaps that result from a hearing loss. The need to assure the development of an appropriate IFSP to facilitate a deaf or hard of hearing child’s unique and individual language-learning needs, all of the associated developmental needs, and ultimately, their resulting quality of life, is essential. Part C of IDEA must address the specific needs of young children who are D/HH for the very same reasons that the U.S. Department of Education created the Deaf Students Education Services Policy Guidance in 1992, and subsequently the specific language in the law regarding deaf and hard-of-hearing students in the reauthorization of IDEA, Part B. Part B of IDEA states that the IEP team must:

Consider the communication needs of the child and in the case of the child who is deaf or hard of hearing, consider the language and communication needs, opportunities for direct communication with peers and professionals in the child’s language and communication mode, academic level, and full range of needs including opportunities for direct instruction in the child’s language and communication mode, 34 CFR 300.324(2)(iv).


Hearing loss results in a unique challenge because communication reflects the individual needs of each child and relies on the unique characteristics of the family, their culture and their values.  The advantage of early identification can be sustained by insuring families have access to the supports and services that serve their individual child and their family. These supports and services can occur in a variety of environments. While provision of services in natural environments is a worthy goal for every infant and toddler with hearing loss, this standard should not limit access to services that build language and communication skills. Providing a language-rich environment for an infant or toddler with hearing loss promotes their capacity for full participation later. Specific language in Part C of IDEA assures these unique considerations for infants and young children who are D/HH are addressed.   ~


Article References

Alexander Graham Bell Association for the Deaf and Hard of Hearing (2000) Comments for IDEA Notice of Proposed Rulemaking, Early Intervention Program for Infants and Toddlers with Disabilities, December, 4, 2000, p.3.

Colorado Department of Public Health and Environment (2004). Colorado infant hearing advisory committee: Guidelines for infant hearing screening, audiological assessment, and early intervention. Denver, CO: Author.

Johnson, C.D. (2005). Colorado Individual Performance Profile (CIPP) Data Trends. Extracted from

Kregan, T. (2001). Comments of Self-Help for Hard of Hearing People in the matter of reauthorization of IDEA, Together we can make a difference for all people with hearing loss. US Department of Education, Before the President’s Commission on Excellence in Special Education input Meeting, Nov.29, 2001.

Laughton, J. & Hasenstab, S. (2000). Auditory learning, assessment, and Intervention with school-age students who are deaf or hard of hearing. In J Alpiner & P McCarthy (Eds.), Rehabilitative Audiology: Children and Adults (3rd Edition) (pp 178-225). Baltimore: Williams & Wilkins.

National Deaf Education Project (2000). Strategies for Systemic Reform to Address Short and Long Term Educational Issues for Deaf and Hard of Hearing Children. Lawrence Siegel, Director. [].

Sager, N.G. (2001). Defining “Natural Environments” for Deaf &Hard-of-Hearing Infants, Toddlers, and Preschoolers. Independently Merging Parent Associations of California (IMPACT), Nov 2001 [].

Scheetz, N. (1992). Orientation to Deafness. Boston: Allyn & Bacon.

Siegel, Lawrence (2000). The Educational and communication needs of deaf and hard of hearing children: A statement of principle on fundamental educational change. American Annals of the Deaf 145(2), p. 66.

U.S. Department of Education (1992). Deaf Students Education Services Policy Guidance. Federal Register (57 Fed. Reg. 49274, October 30, 1992).

Watkins S., & Clark T. (1993) Eds. SKI HI Resource Manual.

Western States Early Intervention Coalition for Sensory Impairments (1999). Natural environments for infants and toddlers who are deaf and hard of hearing. (January 14, 1999).

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