PANS/PANDAS Meets IDEA’s Definition of Other Health Impairment
Students with PANS/PANDAS may experience sudden and severe symptoms that significantly disrupt school functioning across academic, cognitive, emotional, behavioral, and sensory domains. A student may function near baseline one month and then experience a flare that leads to fatigue, cognitive slowing, impaired attention and memory, sensory overload, tics, OCD symptoms, emotional dysregulation, school avoidance, and difficulty completing both academic work and routine tasks. Attendance is often greatly affected, with many students requiring frequent or extended absences, homebound instruction, supplemental tutoring, or temporary placement in alternative educational settings. For many students, these changes result in declining grades, impaired test performance, and a need for formal educational supports, including IEPs or 504 plans.
PANS/PANDAS is a medical condition with a relapsing-remitting course, so students often need flexible school supports without repeated eligibility reviews. For IEP eligibility, Other Health Impairment (OHI) is the most accurate and protective category because it covers health conditions that affect strength, vitality, or alertness (including heightened alertness to stimuli) and adversely impact educational performance.
Clinical guidance recommends writing school plans based on the student’s most challenging days to avoid frequent revisions.
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- PANS/PANDAS Meets IDEA’s Definition of Other Health Impairment
- What OHI Means Under IDEA
- Why OHI Is the Appropriate Eligibility Category for PANS/PANDAS
- IEP Eligibility Is Not Only Based on Grades
- IDEA Disability Categories: A Brief Overview
- OHI vs. ED vs. SLD for PANS/PANDAS
- Why the Tourette Syndrome Precedent Matters
- How to Talk About OHI at the IEP Meeting
What OHI means under IDEA
IDEA defines Other Health Impairment (OHI) as having limited strength, vitality, or alertness (including heightened alertness to environmental stimuli) that results in limited alertness in the educational environment due to chronic or acute health problems and adversely affects educational performance.
Two points matter for PANS/PANDAS:
- OHI is not limited to the conditions listed. IDEA uses “such as,” which signals the list is an example—not a closed list.
- Educational performance is not just academics. The U.S. Department of Education has clarified that educational performance under IDEA is not limited to academic performance and schools must consider non-academic impacts (social, behavioral, functional domains).
Why OHI is the appropriate eligibility category for PANS/PANDAS
PANS/PANDAS commonly affects exactly what OHI describes:
Limited strength / vitality
- fatigue, reduced stamina, sleep disruption
- increased absences, late arrivals, early dismissals
- reduced endurance for a full day of instruction
Limited alertness (including heightened alertness to stimuli)
- difficulty filtering noise, movement, and classroom stimulation
- sensory sensitivities and overwhelm
- hypervigilance, panic, “fight/flight” responses that make learning inaccessible
A flare-based course that requires flexibility
Needs can change day-to-day and week-to-week. OHI is broad enough to support a plan built around functional access, rather than a narrow snapshot of a single symptom cluster.
IEP eligibility is not only based on grades
Families are often told: “They’re smart,” “They test well,” or “Their grades aren’t low enough.” That’s not the legal standard.
Office of Special Education Programs (OSEP) has stated clearly that educational performance is not limited to academic performance. IDEA requires IEP teams to consider the child’s academic, developmental, and functional needs when developing the IEP.
For PANS/PANDAS, the “adverse effect” is best shown through functional impact – by looking at how the condition affects what the student can do at school, such as:
- inability to initiate or complete work (even when skills are strong)
- school avoidance, panic, separation anxiety interfering with attendance
- cognitive slowing/brain fog, executive dysfunction
- OCD/tics interfering with classroom participation
- eating restrictions at school (ARFID/restrictive eating), bathroom avoidance
- frequent visits to the nurse or time out of class to regulate
A student can be academically capable and still require special education and related services to access FAPE when health symptoms disrupt functional school performance.
IDEA Disability Categories: A brief overview
Under the Individuals with Disabilities Education Act (IDEA), a student may be found eligible for special education services if they meet criteria under one or more of the federal disability categories and the disability adversely affects educational performance. These categories serve as eligibility frameworks, not diagnoses, and are used to guide evaluation, services, and data reporting. A student may meet criteria under more than one eligibility category. The IEP team should select the category or categories that best reflect the primary cause of disability, and use the IEP to address the full range of academic, functional, and emotional needs.
IDEA currently recognizes 13 primary disability categories (some states recognize a temporary 14th category, Developmental Delay, for young children):
- Specific Learning Disability (SLD) – Difficulties in reading, writing, math, listening, or reasoning that reflect a learning disability pattern, such as dyslexia, dysgraphia, or dyscalculia. Best used when evaluation shows a consistent learning disability pattern, not only flare-based regression.
- Speech or Language Impairment (SLI) – Communication disorders that affect articulation, fluency, voice, or language processing and interfere with educational performance.
- Other Health Impairment (OHI) – Chronic or acute health conditions that limit strength, vitality, or alertness (including heightened alertness to environmental stimuli) and adversely affect educational performance.
- Autism Spectrum Disorder (ASD) – A developmental disability that affects communication, social interaction, and behavior, and is the primary driver of educational impact. Used when autism is present and is a primary driver of educational impact. ASD may also be a dual qualifying category alongside Other Health Impairment (OHI) when a student has both ASD and PANS/PANDAS. In some cases, PANS-related symptoms may be mistaken for ASD-like behaviors, making careful evaluation essential.
- Intellectual Disability (ID) – Below-average intellectual functioning with concurrent deficits in adaptive behavior that affect learning and daily functioning.
- Emotional Disturbance (ED) – A category addressing significant emotional or behavioral conditions that persist over time and adversely affect educational performance. Can overlap with PANS symptoms, but does not reflect the medical driver.
- Developmental Delay (DD) – A temporary category used by some states for young children (typically birth to age 7–9) who show delays in developmental milestones. Availability and age limits vary by state.
- Multiple Disabilities (MD) – Used when a student has two or more disabling conditions whose combined impact requires intensive, specialized, and multifaceted support, and where no single category adequately captures the student’s needs.
- Hearing Impairment (including Deafness) – Hearing loss that affects access to instruction and communication in the educational environment.
- Visual Impairment (including Blindness) – Vision loss that cannot be corrected adequately with standard glasses and affects educational performance.
- Orthopedic Impairment (OI) – Physical impairments affecting mobility or motor functioning, such as those resulting from congenital conditions, disease, or injury.
- Traumatic Brain Injury (TBI) – An acquired brain injury caused by external physical force that results in functional disability or psychosocial impairment. While most commonly associated with accidents, this category is sometimes considered when a student has significant, acquired brain-based functional impairments, depending on state interpretation.
- Deaf-Blindness – Combined hearing and vision impairments that create unique communication and learning needs not adequately addressed by services for either condition alone.
OHI vs. ED vs. SLD for PANS/PANDAS
PANS/PANDAS students can present with anxiety, mood symptoms, behavior changes, handwriting regression, or academic decline. The category choice matters because it shapes how teams interpret needs and what the IEP team builds the plan around.
Other Health Impairment (OHI)
Appropriate category when a medical condition drives fluctuating symptoms that impact stamina, alertness, regulation, attendance, or functional access to school.
- Keeps the plan anchored in the student’s health-related disability impact
- Supports broad, flexible accommodations and services across domains
- Helps prevent reducing complex flare symptoms to “behavior” alone, as they are symptoms of a neuroimmune disorder
IDEA explicitly includes heightened alertness to environmental stimuli within OHI, which is often directly relevant for PANS/PANDAS students.
Emotional Disturbance (ED)
Emotional Disturbance (ED) is sometimes raised in IEP discussions because students with PANS/PANDAS may present with anxiety, emotional dysregulation, aggression, refusal, or school avoidance. While these symptoms can look “behavioral,” ED does not reflect the true medical nature of PANS/PANDAS and is therefore inappropriate for most students with this condition.
In PANS/PANDAS, emotional and behavioral symptoms are manifestations of a neuroimmune medical flare. When ED is used as the primary eligibility category, it can mischaracterize the student’s needs and shift the focus away from the health-driven mechanisms that are actually limiting access to education.
In some cases, emotional or behavioral needs may warrant attention within the IEP and can be addressed as a secondary area of need, but this is very different from defining the student’s disability as an emotional disturbance.
Using ED as the primary category can lead teams to over-reliance on behavioral frameworks, such as Functional Behavioral Assessments (FBAs) or Behavior Intervention Plans (BIPs), as the main solution. For students with PANS/PANDAS, this approach is often insufficient and sometimes harmful if it ignores the medical context. These students typically require robust, medically informed accommodations, such as:
- reduced cognitive and academic demands during flares
- sensory load adjustments
- flexible attendance and workload expectations
- regulation supports that acknowledge loss of neurological control, not willful behavior
Specific Learning Disability (SLD)
Sometimes appropriate if a student has a true learning disability pattern. But for many PANS/PANDAS students, academic struggles (especially writing output, processing speed, working memory) can be episodic and inflammation-driven, not a stable learning disability profile.
When SLD becomes the primary category for a flare-based condition, the plan can unintentionally narrow toward academics and miss the broader functional and health-related needs that are central to access.
In short, if PANS/PANDAS is the main issue, OHI is the appropriate overall category. It still allows the IEP team to address specific academic, emotional, and functional needs.
Why the Tourette syndrome precedent matters
Tourette syndrome is explicitly named under OHI in IDEA’s definition. In the IDEA regulatory commentary, the U.S. Department of Education explained that Tourette’s is often misunderstood as behavioral or emotional rather than neurological, and naming it in OHI helps correct misperceptions and prevent misdiagnosis of needs.
Tourette syndrome can involve motor and vocal tics, involuntary movements or sounds, difficulty suppressing symptoms in structured settings, and increased symptom severity under stress or fatigue, symptoms that have historically led to misinterpretation as disruptive or intentional behavior rather than manifestations of a neurological condition.
This matters for PANS/PANDAS because many hallmark symptoms like sudden OCD, tics, extreme distress, refusal, rage are still frequently misinterpreted as willful or purely psychiatric, especially when teams don’t understand the medical context. OHI supports a framework that keeps the plan grounded in disability impact, not blame.
How to talk about OHI at the IEP meeting
Here’s practical language that keeps the conversation clear and grounded:
1) Anchor to IDEA’s OHI definition
“PANS/PANDAS is a medical condition that limits strength, vitality, and alertness—especially during flares. It also creates heightened alertness to environmental stimuli, which directly affects access to the educational environment. That aligns with IDEA’s OHI definition.”
2) Shift from “grades” to “functional access”
“Educational performance isn’t just grades. The impact here is functional—attendance, stamina, regulation, ability to initiate and complete work, and access to instruction.”
3) Use flare-based evidence
“Needs fluctuate. We can show adverse effects through patterns: missed school, time out of class, inability to complete routine demands during exacerbations, and sensory overload impacting participation.”
4) Ask the team to write for the worst days
“We want the plan written with worst-day needs in mind, so supports are available when symptoms escalate, without restarting eligibility every time symptoms change.”
5) If the school pushes ED or “behavior-only” framing
“We’re not denying emotional or behavioral symptoms. We’re saying the driver is a health condition with a relapsing course. OHI keeps the plan medically accurate and broad enough to address the full functional impact.”
Gabriella True
