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my son is autistic and adhd. He has become dysregulated in stressful situations. What is stressful for him is not for other students. He makes noises or comments not related to the class when he experiences stress or anxiety. In his IEP, we have steps to help him regulate and to express himself.

In my area, a preschooler who needs speech would have an IEP and a teacher/speech therapist would come to them at their private preschool (because we don't have public preschool where I live). There has to be a way to have an IEP in preschool - it's required under IDEA. Definitely request a special ed eval and list the areas of need: speech, OT, anxiety, sensory processing and a medical diagnosis of ADHD. (How are her social skills? With this combo, social skills will often lag.) The last page of this has a template to request an eval: https://www.elc-pa.org/wp-content/uploads/2021/08/getting-a-special-education-evaluation.pdf

You need to get on your state department of education's website and see if they have a list of when Prior Written Notices are required (some do). If you can't find one, call the compliance section of special education and ask if a Prior Written Notice would be required in this instance. If yes, get the name of the compliance officer you spoke with, ask if there if is a policy or guideline that you could print out/see, and forward both to the director of special education.