Treating the Tiers: Play Therapy Responds to Intervention
in the Schools
Amanda Winburn, Denise Gilstrap, and Mandy Perryman
University of Mississippi
This article explores the potential of play therapy as a school-based intervention for
children who are experiencing behavioral difficulties within the K-12 school setting. A
model is presented describing the use of play therapy within the Response to Inter-
vention (RtI) model at the Tier 2 and Tier 3 level. This article explores the RtI model
and how play therapy can be incorporated by school counselors or school-based play
therapists using individual and small group sessions.
Keywords: behavioral interventions, response to intervention, school counseling
Research and practice support the notion that
play therapy fits well within the school environ-
ment. Play therapy helps students develop a pos-
itive self-concept, assume personal responsibility,
become more self-directed and self-accepting, cre-
ate an internal source of evaluation, and enhance
coping skills (Landreth, 2012). These life tasks
parallel the lessons and goals of early childhood
education. Through the use of play therapy in
schools, students can problem-solve, motivate
themselves, and improve social skills (Schaefer &
Drewes, 2012). Because play therapy fosters re-
sponsibility, emotional awareness, and communi-
cation, it is a useful tool for school counselors and
teachers (Perryman & Doran, 2010). In addition,
play therapy aligns well with the American School
Counseling Association’s (ASCA) national model
because it is developmentally appropriate, multi-
culturally sensitive, and empirically supported.
Developmentally Appropriate
Children play naturally and spontaneously
for sheer enjoyment. They play without prompt-
ing or goal direction. As they play, they can
address their feelings about themselves, others,
and the world through metaphors and the ma-
nipulation of toys, rather than with words (Lan-
dreth, 2012). Because young children lack ab-
stract reasoning skills and the verbal ability to
articulate thoughts and feelings, it is through
play that they express themselves early in life.
Play provides children with a nonthreatening
means of bridging the gap between their expe-
riences and cognitions, thereby providing op-
portunities for learning.
Kottman and Meany-Walen (2016) outlines
how using play therapy with children provides
empowerment and self-understanding and also
improves self-control and responsibility. This
Adlerian approach outlines how counselors can
work with children through active and direct
engagement and promotes a partnership of
equal power and responsibility between the
counselor and child. According to Kottman
(2011), the goal of this approach is to provide a
sense of personal power to the child and support
the child to choose how to interpret situations,
events, and relationships.
Multiculturally Sensitive
Children from diverse backgrounds with dif-
ferent types of distress and dysfunction all at-
tend school together. They bring with them a
variety of mental health and social issues need-
ing attention. It is imperative school counselors
be aware, knowledgeable, skillful, and effective
as they serve a diverse student body (American
Amanda Winburn, Denise Gilstrap, and Mandy Perry-
man, Department of Leadership and Counselor Education,
College of Education, University of Mississippi.
Denise Gilstrap is now at Marriage & Family Therapy
and Counseling Studies, University of Louisiana at Monroe.
Correspondence concerning this article should be ad-
dressed to Amanda Winburn, Department of Leadership
and Counselor Education, College of Education, Univer-
sity of Mississippi, 109 Guyton Hall, University, MS
38677. E-mail: [email protected]
This document is copyrighted by the American Psychological Association or one of its allied publishers.
This article is intended solely for the personal use of the individual user and is not to be disseminated broadly.
International Journal of Play Therapy © 2017 Association for Play Therapy
2017, Vol. 26, No. 1, 1–11 1555-6824/17/$12.00 http://dx.doi.org/10.1037/pla0000041
1
School Counselor Association, 2010, E.2.d).
Because play therapy accepts each student as a
unique individual and does not attempt to re-
shape their life or alter them in definitive ways
(Axline, 1947; Landreth, 2012), it is a multicul-
turally sensitive approach to counseling. Addi-
tionally, “play is an integral component of most
cultures, and mental health professionals must
determine the role of play therapy for children
from multicultural backgrounds” (Coleman,
Parmer, & Baker, 1993, p. 68). Play is a volun-
tary action without a specified goal that assists
children in addressing their feelings about
themselves, others, and the world through the
manipulation of toys. Particularly in Child Cen-
tered Play Therapy (CCPT), the relationship
between the child and the counselor is the cat-
alyst for therapeutic healing and development,
further emphasizing that children are the best
resources about themselves and are capable of
directing their own growth (Axline, 1947). For
the counselor, the focus is on being present with
the child, as opposed to the application of spe-
cific procedures. It is that freedom to attend to
the unique needs of the client that makes play
therapy universal across cultures (Drewes,
2005). The counselor recognizes and respects
children’s innate capacity to grow, heal, and
make choices that will help them flourish with-
out direct intervention on the part of the coun-
selor, who may have a completely different
background and worldview.
Empirically Supported
Play therapy draws on decades of research. In
the field’s history it has evolved to include
numerous theoretical frameworks and treatment
modalities. Axline (1947) was among the first to
study the effects of play therapy to validate her
work and outcomes with children. Her research
was rudimentary especially on issues of reliabil-
ity compared with today’s methodological stan-
dards. However, she was key in broadening the
acceptance of play therapy.
Over the last 15 years, four meta-analyses
have been conducted (Leblanc & Ritchie, 2001;
Bratton, Ray, Rhine, & Jones, 2005; Ray, Arm-
strong, Balkin, & Jayne, 2015; and Lin & Brat-
ton, 2015) to examine the effectiveness of play
therapy. According to Lin and Bratton (2015),
these four meta-analytic findings clearly con-
firm the effectiveness of play therapy, specifi-
cally CCPT approaches including filial therapy.
ASCA’s National Model calls for accountabil-
ity and inherently requires empirically sup-
ported evidence for school-based interventions,
such as play therapy. Behavioral, social, and
emotional issues have been successfully ad-
dressed through various forms of play therapy
(Bratton, Ray, Rhine, & Jones, 2005), such as
reduced stress and more positive interactions
with teachers (Ray, Schottelkorb, & Tsai,
2007). Further, when reviewed across more than
20 studies, CCPT has been found effective spe-
cifically in the elementary school setting (Ray et
al., 2015), which includes benefits in the area of
academic achievement (Blanco & Ray, 2011).
Response to Intervention and School-Based
Play Therapy
Clements and Sabella (2010) state that once a
counselor becomes familiar with the Response
to Intervention (RtI) process, he or she can
begin to understand that the foundation of RtI
highly correlates to the components of a com-
prehensive counseling program. Specifically,
the model stipulates that counseling programs
work to identify specialized services, such as
play therapy, based on the child’s level of risk
(2012). According to the U.S. Department of
Education (2005), counselors should have a
comprehensive knowledge and understanding
of how to recognize barriers to equal educa-
tional opportunities for students. These early
interventions are critical to a child’s success,
and school counselors play an integral part in
identifying children’s needs and assisting teach-
ers with differentiated instruction. School coun-
selors who are trained in play therapy can use
the modality to intervene with students who are
at risk of failure. These school-based play ther-
apy interventions can be employed individually
or in a small group setting.
Emergence of Response to Intervention
In 1975, the Education for all Handicapped
Children Act (PL 94 –142) was passed, and
since that time, there has been endless debate
about how to best serve students with disabili-
ties. According to Ysseldyke, Algozzine, and
Thurlow (1998), special education has been a
controversial topic since the Education for all
2 WINBURN, GILSTRAP, AND PERRYMAN
This document is copyrighted by the American Psychological Association or one of its allied publishers.
This article is intended solely for the personal use of the individual user and is not to be disseminated broadly.
Handicapped Children was first mandated. This
controversy directly contributed to debates re-
garding the diagnostic procedures used to iden-
tify students with possible disabilities. The 1975
legislation included the discrepancy model,
which only labeled children as learning disabled
if there was significant gap in achievement com-
pared with the student’s score on the intelli-
gence scale.
The discrepancy model has come under tre-
mendous criticism. Bradley, Danielson, and
Doolittle (2007) found that the model was not
useful in enhancing services for students, par-
ticularly in the area of early intervention. These
authors continued their criticisms by calling it a
“wait-to-fail” model, stating that students did
not receive services when first observed, but
had to wait until there was a wide enough gap
between achievement and intelligence scores to
qualify for special education services.
Carbo (2010) claimed, “The use of the dis-
crepancy model meant teachers could not help
students with learning until they had fallen sub-
stantially behind and were struggling” (p. 121).
Other critics of the model have identified it as
culturally insensitive with its use being to overi-
dentify minority students for special education
services (De Valenzuela, Copeland, Qi, & Park,
2006; MacMillan & Reschly, 1998). In re-
sponse to these critics, leaders within the field
of education proposed changes to the way stu-
dents are identified for special education ser-
vices.
The National Research Council’s study con-
ducted by Heller, Holtzman, and Messick
(1982) marked the emergence of Response to
Intervention (RtI). As a result, researchers
found that the quality of instruction and the
organization of special education services have
an impact on the effectiveness of student out-
comes. In 1983, The U.S. Department of Edu-
cation published the A Nation at Risk report.
This report once again spurred debate about the
nation’s education system, stressed the need for
educational reform, and increased discussion of
accountability measures (Ravitch, 1999).
In 2001, The No Child Left Behind Act
(NCLB) required the measuring of every stu-
dent’s educational skills and academic progress.
This act included students who fell within the
subgroup of special education and led to the
Individuals with Disabilities Education Im-
provement Act (IDEIA; 2004) reauthorization
law, which specified that students could not be
labeled as eligible for special education until
“the child fails to achieve a rate of learning to
make sufficient progress to meet state-approved
results” (P.L. 108 446, 300.309). These two
laws have established new guidelines for stu-
dent identification as well as new accountability
measures for students and teachers in both the
general and special education classroom.
With these new guidelines, researchers and
educational leaders have greatly enhanced the
knowledge base from which educators now
practice. Research on student learning and ef-
fective interventions have dramatically in-
creased over the last two decades, and meta-
analytic research has been able to identify best
practices for learners (with and without disabil-
ities) who are struggling with core curriculum
(Kavale & Forness, 1999; Swanson, Hoskyn, &
Lee, 1999).
RtI was developed as an early intervention
for children who continue to fail to meet basic
standards within the school system. Several na-
tional studies, such as the Common Ground
Report (Roundtable, 2002), have made recom-
mendations regarding identification, eligibility,
and intervention for students who are experienc-
ing difficulties. Researchers such as Marston
(2005) studied national reports such as the
Common Ground Report to see whether RtI
standards fulfilled the requirements outlined in
the report. Marston found that RtI positively
corresponded to each of the recommendation
statements; thus, the research study concluded
that RtI is a valid option for identifying whether
a student has a barrier to success.
In 2004, reauthorization of IDEIA took place
and continued to spur the debate about best
practices. The law states that a local education
agency “must use a process that determines if a
child responds to scientific, research-based in-
terventions as a part of the evaluation process”
(P.L. No. 108 446 614 b 6 A). This law is the
basis for a great deal of change and continued
debate within the educational system (Burns &
Gibbons, 2008).
In the reauthorization of IDEIA, the federal
government outlined objectives to improve spe-
cial education services within the United States,
and, while RtI is not federally mandated, IDEIA
does include RtI approaches within its regula-
tions and guidelines. This suggests a systematic
framework for screening, intervening, and mon-
3TREATING THE TIERS
This document is copyrighted by the American Psychological Association or one of its allied publishers.
This article is intended solely for the personal use of the individual user and is not to be disseminated broadly.
itoring to help determine a student’s response to
evidenced-based interventions (Burns & Gib-
bons, 2008). In 2015, the Every Student Suc-
ceeds Act (ESSA) was authorized by President
Obama. This most recent education legislation
expands upon No Child Left Behind and adds
flexibility to the previous policies. The ESSA
legislation focuses not only on academic stan-
dards but also place emphasis on college and
career readiness.
Response to Intervention
Carbo (2010) defines RtI services as an ap-
proach that serves as a safety net to catch stu-
dents at risk of failure early and immediately
provide carefully monitored interventions to en-
sure academic and behavioral improvements.
Simply put, RtI is a process of implementing
high quality instructional practices that are
based on students’ needs, monitoring progress,
and then adjusting instruction based upon the
data collected from the students’ responses.
Moores (2008) states that the goal of RtI is to
prevent failure and ensure success for all stu-
dents using early identification and progress
monitoring, along with research-based instruc-
tion. RtI focuses on evidenced-based interven-
tions and proven data to drive instructional de-
cisions that align with the goals of early
intervention. Effectively used, RtI will allow
teachers, counselors, and administrators to
know how to identify students who are at-risk
for failure using interventions grounded in re-
search and shown to be valid and reliable. Ac-
cording to Vaughn, Fuchs, and Fuchs (2008),if
these research-based interventions are intro-
duced to students in the early stages of their
education when struggles are initially identified,
no longer will students have to “wait to fail.”
Howard (2010) states that the tiered system is
designed to offer instructional support at in-
creasing levels of intensity according to the
student’s needs along with specific attributes.
Models for RtI are divided into a three-tier
system; each tier varies and is used to support
the needs of all learners. The three tiers provide
a framework for best practices.
Tier 1 serves as a universal foundation for
student learning and focuses on quality instruc-
tional strategies. This tier contains core curric-
ulum standards which help determine the effec-
tiveness of instructional delivery of core content
to students. Allington, (2011) states that Tier 1
interventions are the most critical. Students who
experience difficulties at the Tier 1 level and are
not growing at a pace equal to their peers should
be provided with additional differentiated in-
struction. According to Justice (2006), Tier 1
instruction should provide school personnel
with the opportunity to provide direct services
with a concentration on high-priority targets for
academic or behavioral development. Other
strategies include small groups or other best
practice interventions.
Tier 2 is for students who continue to dem-
onstrate difficulty with academic and behavioral
performances after receiving additional differ-
entiated instruction. Tier 2 interventions are
supplemental to Tier 1 instruction (Vaughn &
Roberts, 2007). Tier 2 interventions provide
small group experiences for those students who
were unable to experience success at the Tier 1
level. The Tier 2 groups are generally small so
that school personnel can attend to the needs of
the students while explicitly focusing on the
skill in need of development. Fuchs et al. (2008)
states that Tier 2 interventions should be exe-
cuted in small groups of four to six students and
should be designed to provide a strong focus on
skills that the students need to become profi-
cient.
By design, Tier 2 is are highly structured
requiring consistent application. Recommenda-
tions for Tier 2 interventions are that each in-
tervention be provided within a 30-min time
frame and be monitored on a biweekly schedule
(Marston, 2005). As cited in Marston (2005),
Tilly states that Tier 2 instruction is a combina-
tion of core instruction and supplemental in-
struction. These interventions should include
structured tasks and be executed within an al-
lotted amount of time. Previously conducted
research suggests that, for Tier 2 instruction to
be effective, the interventions should reinforce
the learning goals and materials used in the Tier
1 instruction (Speece, Case, & Molloy, 2003;
Vellutino, 2003).
If students are still underperforming at the
Tier 2 level, they are then referred to Tier 3
instruction. Only a small minority of the student
population needs this level of instruction
(Coyne et al., 2004). Tier 3 is a much more
intensive set of instructional interventions. This
level of instruction should provide more strate-
gic planning and direct interventions than the
4 WINBURN, GILSTRAP, AND PERRYMAN
This document is copyrighted by the American Psychological Association or one of its allied publishers.
This article is intended solely for the personal use of the individual user and is not to be disseminated broadly.
previous two tiers. The frequency and intensity
of the Tier 3 interventions should increase from
the Tier 2 model.
Tier 3 interventions are the most intensive
level of intervention available within general
education. These interventions should center di-
rectly on the needs of the child (Stecker, 2007).
At the Tier 3 level, students generally receive
personalized interventions in individual ses-
sions or in smaller groups (no more than three
students). The length of interventions and fre-
quency of progress monitoring typically are
longer and more intensive than at the Tier 2
level. General education teachers often find the
detail and involvement that is required with Tier
3 interventions to be overwhelming; therefore,
additional school personnel can be instrumental
at this level to help provide additional services
to these Tier 3 students.
While Tier 3 instruction does not automati-
cally qualify a student for special education
services, it may indicate the possibility for ad-
ditional testing and exploration of special edu-
cation services. According to Kashi (2008) after
a student has participated in Tier 3 instruction
for several weeks without any documented
progress, the student is then in a situation for
referral to special education services.
Tier 2 Group Play Therapy
Students may be referred for Tier 2 interven-
tion when Tier 1 support has not been effective
in changing behavior adversely impacting aca-
demics. There are various factors that may lead
to challenging behavior. For example, the be-
havior may be related to symptoms of attention-
deficit/hyperactivity disorder (ADHD), which
can affect academic achievement and overall
functioning in the school environment
(McConaughy, Volpe, Antshel, Gordon, & Ei-
raldi, 2011; Voogd, 2014). Other behavioral
factors that may lead to Tier 2 intervention are
aggressive and disruptive behaviors, which can
cause difficulty in developing positive peer re-
lationships (Powers & Bierman, 2013). At an
early age, lack of quality friendships can affect
school adjustment and academic motivation
(Vitaro, Boivin, Brendgen, Girard, & Dionne,
2012). Additionally, students who show aggres-
sive behaviors may experience peer rejection,
which is important to address as peer accep-
tance can be crucial to academic achievement
and increased school engagement (De Laet et
al., 2015; Powers & Bierman, 2013).
Group-centered interventions can be effec-
tive in addressing deficiencies prohibiting stu-
dents from reaching their full academic poten-
tial (Harpine, 2008). Play therapy is a
developmentally appropriate intervention for
young children shown to be effective in treating
ADHD, aggression, anger management, and
disruptive behavior (Barzegary & Zamini,
2011; Fischetti, 2010; Meany-Waley, Bratton,
& Kottman, 2014; Ray, Blanco, Sullivan, &
Holliman, 2009; Swan & Ray, 2014). Group-
centered play therapy is one approach for school
counselors to use when combining group-
centered interventions and play therapy for Tier
2 interventions (Harpine, 2008). In small
groups, students can work through behavior and
emotional issues while increasing positive peer
relationships.
Group-centered play therapy allows children
to work through challenges in a positive, sup-
portive environment (Harpine, 2008). The envi-
ronment is primarily established through the
school counselors’ use of empathy and accep-
tance, modeled through interactions with stu-
dents (Allen & Barber, 2015). The school coun-
selor’s unconditional positive regard within a
safe environment is a form of modeling for
students participating in the behavior interven-
tion group. Expressing genuine acceptance and
teaching this to students helps them build rela-
tionships and develop empathy for others.
Group counseling with children in schools takes
much preparation and planning (Kestly, 2010).
Therefore, planning for Tier 2 group play ther-
apy should be done deliberately (see Figure 1).
Tier 2 group play therapy ideally consists of up
to 6 students in accordance with RtI recommen-
dations (Pierangelo & Giuliani, 2008). The
group is structured so the school counselor can
actively focus on the students’ goals (Kottman,
2011). Time should also be a consideration, as
the frequency and duration of Tier 2 interven-
tions are limited based on district or state reg-
ulations.
An Adlerian Approach to Group
Play Intervention
In consideration of an effective theoretical
framework for group play therapy, an Adlerian
approach is supportive of developing positive
5TREATING THE TIERS
This document is copyrighted by the American Psychological Association or one of its allied publishers.
This article is intended solely for the personal use of the individual user and is not to be disseminated broadly.
relationships, gaining insight into students’ per-
ceptions, and understanding the purposes for
misbehavior (Kottman, 2011). In addition,
Adlerian play therapy acknowledges that all
behavior is purposeful (Kottman, 2001, 2011).
This view aligns with the use of functional
behavior assessments in determining reasons
for students’ behavior, and an Adlerian ap-
proach in Tier 2 intervention supports the infor-
mation-gathering process. Studies have shown
the effectiveness of Adlerian play therapy in
decreasing hyperactive, aggressive, and defiant
behaviors and increasing social skills (Meany-
Walen, Bratton, & Kottman, 2014; Meany-
Walen, Kottman, Bullis, & Dillman Taylor,
2015; Meany-Walen & Teeling, 2016). More
specifically, Adlerian group play therapy has
been researched and found to be effective in
improving on-task behaviors (Meany-Walen,
Bullis, Kottman, & Dillman Taylor, 2015).
An Adlerian approach to group play therapy
allows the school counselor to strategically im-
plement directive and nondirective techniques
throughout the process (Kottman, 2011). The
school counselor begins phase one with a non-
directive approach with a focus on student em-
powerment and relationship-building. The rela-
tionship is essential in this approach because of
its recognition as a catalyst for encouraging
change (Kottman, 2001). The second phase is
more directive as the school counselor works to
understand how students perceive the world and
themselves, which may give insight to underly-
ing causes of behavior. In the third phase, the
school counselor alternates between a support-
ive, nondirective role to a challenging role. Be-
cause of emphasis on supporting students in
making changes, this phase could be conducive
to working with the students in goal-setting for
behavior improvement. The final phase focuses
on actively helping students learn and practice
new skills and gain new perceptions. In the
small group play environment, students can
practice appropriate classroom behaviors and
engage in positive peer and adult interactions.
Limit Setting in Adlerian Group
Play Therapy
Limits are set to maintain safety in the play
environment (Kottman, 2011). For instance,
limit setting is important in working with chil-
dren with aggressive behaviors. Because group
play therapy can help foster positive peer rela-
tionships, limits should be set and maintained
for protection of all children in the group. In
addition, limit setting can allow the school
counselor to redirect inappropriate behaviors,
which may be an issue experienced in the larger
classroom setting.
The four-step process of limit-setting in
Adlerian play therapy aims to support students
in redirecting their own behavior (Kottman,
2011). The school counselor sets the limit,
makes a guess about the students’ feelings and
purpose of behavior, supports students in redi-
recting their own behavior, and discusses con-
sequences for continued limit violations (Kott-
man, 2001). In determining behavioral growth,
an assessment of progress could be the students’
Group
Focus
Behavior
Objective
Replacement
Behavior
Intervention
Method
Expected
Behavior
Outcomes
Duration
Assessment
of Progress
Increasing
positive
peer
interaction;
developing
social
skills
Student
will engage
in
cooperative
play
without
aggression
toward
peers
during free
play
activities at
least 4 days
a week.
Appropriately
express
needs;
engage in
acceptable
social
interaction
with peers.
Adlerian
Group Play
Therapy
Students
will
reduce
behavior
incidents
by 60%
within the
next 9
weeks.
9 weeks,
3 times a
week,
30-45
minutes
per
session
Child
Behavioral
Check List
(CBCL);
Teacher &
Parent
report; daily
behavior
report
Figure 1. Group play therapy plan summary. In this sample plan summary, a goal-focused,
directive approach to group play therapy is chosen as the best method for a small group of
students who collectively struggle in the class environment. The desire is to help students
develop a positive sense of play and healthy feelings expressions.
6 WINBURN, GILSTRAP, AND PERRYMAN
This document is copyrighted by the American Psychological Association or one of its allied publishers.
This article is intended solely for the personal use of the individual user and is not to be disseminated broadly.
ability to acknowledge feelings and purpose for
behavior, as well as a decrease in defying limits.
Tier 3 Individual Play Therapy
Intervention at the Tier 3 level is more inten-
sive and individually focused (Burns & Gib-
bons, 2008; Pierangelo & Giuliani, 2008). As
with Tier 2, play therapy should be used as
remediation for the student’s presenting prob-
lems. However, work with the student at this
level is now one-on-one instead of whole class
or small group. The school counselor’s ap-
proach with Tier 3 intervention still centers on
the child’s behavior goals or objectives outlined
in the behavior improvement plan (see Figure
2). The goal of Tier 3 therapy should be to show
adequate progress (Burns & Gibbons, 2008)by
eliminating or decreasing the severity of prob-
lematic behaviors. At this level, the student’s
progress is more closely monitored to determine
if a special education ruling is necessary.
Determining a play therapy approach is depen-
dent on the child’s individual goals. Understand-
ing the child’s needs is integral to utilizing an
approach that encourages progress through play
therapy. In addition, this understanding helps the
school counselor measure progress inside the
playroom and, with parents’ and teacher’s help,
outside of therapy. Whether the behavioral chal-
lenges result from defiance, impulsivity, or poor
relational skills, the school counselor should con-
sider what approach works best for the child. For
example, a nondirective approach may be consid-
ered if the focus is on using the therapeutic rela-
tionship to help students develop healthy commu-
nication and feelings expression (Kottman, 2011).
This may also be considered for students who
have trouble with aggression toward others. If the
student needs more structure with attention to
specific behavior goals as determined by the in-
tervention plan, then the school counselor may
consider a directive approach necessary. Directive
play therapy may be more efficient at this level
because Tier 3 intervention is time-limited and
goal-oriented.
School counselors should still be deliberate
in planning with students at the Tier 3 level.
Consideration should be given to best interven-
tion approaches to address presenting problems
(Burns & Gibbons, 2008). Research-based ap-
proaches can assist school counselors in decid-
ing what approaches are beneficial for decreas-
ing the unwanted behaviors. School counselors
should also be reflective of goals in the behavior
improvement plan and ways to assess progress.
This is pertinent to determining the next steps in
the special education referral process.
Application of Play Therapy: Brandon
The following is a presentation of how play
therapy can be applied as a tiered behavior inter-
vention. Brandon is a first grader at Davis Ele-
mentary. Brandon has exhibited behavioral chal-
lenges since the beginning of the school year that
have affected his academic progress. Although he
is capable of performing at-level academically, he
struggles behaviorally in the classroom environ-
ment. Initially, Brandon had trouble following di-
rections and obeying classroom rules. His teacher
worked with his parents throughout the beginning
Current
Behavior or
Summary
Behavior
Objective
Replacement
Behavior
Intervention
Method
Expected
Behavior
Outcomes
Duration
Assessment
of Progress
Difficulty
engaging in
positive
social
interactions
with
classmates.
Student
will engage
in positive
social
interaction
during play
at least 3
out
of 5 school
days.
Sharing with
peers during
center time;
playing
without
pushing or
taking items
from peers
without
asking.
Child-
Centered
Play
Therapy
Participate
in
group/center
play without
incident
during 70%
of the
school day.
Twice a
week,
30-45
minutes
per
session
Child
Behavior
Checklist
(Parent and
Teacher
Report);
behavior
referrals
reduced by
50%
Figure 2. Behavior improvement plan summary for kindergartner. This sample plan focuses
on intervention for a kindergarten student struggling with peer interactions. Child-Centered
Play Therapy has been shown to be effective for children with aggressive behaviors and for
improving social skills. By emphasizing an accepting, supportive relationship, it is hoped that
the student builds self-confidence and vocabulary to aid in feelings expression.
7TREATING THE TIERS
This document is copyrighted by the American Psychological Association or one of its allied publishers.
This article is intended solely for the personal use of the individual user and is not to be disseminated broadly.
of the semester to implement a positive reinforce-
ment system to help Brandon improve his behav-
ior. Brandon continued to have problems, which
affected his relationships with peers. He became
aggressive toward classmates, refusing to wait his
turn and often pushing or hitting others when he
did not get what he wanted. Brandon was sus-
pended twice during the first half of the first se-
mester for displaying aggressive behavior. After
additional suspensions and lack of improvement
with Tier 1 classroom-based interventions, the RtI
team and Brandon’s parents decided to move
Brandon to Tier 2 intervention with a 9-week
progress check date.
The RtI team decided on interventions to im-
plement to assist Brandon with engaging in posi-
tive peer interactions during free play and follow-
ing instructions without redirection during
instructional time. In addition to specific interven-
tions implemented in the classroom, it was de-
cided that Brandon would receive intervention
from the school counselor, also a member of the
RtI team. The school counselor met with Bran-
don’s teacher and parents to gather more informa-
tion about his behavior and requested they com-
plete the Achenbach Child Behavior Checklist
(CBCL; Achenbach & Rescorla, 2001). The
school counselor also observed Brandon’s inter-
actions with his peers during class activities. With
this information gathered, the school counselor
decided to implement group play therapy as an
evidence-based behavior intervention.
The school counselor relied on previous play
therapy training to begin the process of group
play intervention. Prior to forming the play
group, the school counselor screened for stu-
dents who functioned at similar developmental
levels and who could model target behaviors for
Brandon (Reddy, 2012). After receiving paren-
tal consent to involve selected students in group
play, Brandon was placed in a small group with
two other students. Because of Brandon’s diffi-
culty functioning in the classroom setting, ses-
sions were structured with a routine that was
manageable for the school counselor and easy
for students to follow. Also considered were the
group rules. These rules were written on a chart
to be reviewed with students before each group
play session. The school counselor was sure to
limit the number of rules and understood to
phrase them in “positive, proactive language”
(Reddy, 2012, p. 33).
Each group play session began with a review of
the routine and group rules. Group play included
interventions that supported cooperative peer in-
teractions and social skills building. The school
counselor used behavior management strategies
such as positive reinforcement, corrective feed-
back, and verbal prompts to support Brandon as
he engaged in interactions with the group (Reddy,
2012). The school counselor reiterated these strat-
egies with the other group members so they could
serve as models for Brandon. Appropriate behav-
ior and positive interactions were also modeled by
the school counselor. There were moments when
a less directive approach was taken to allow the
group to problem-solve on their own, with specific
attention to Brandon’s role in these interactions.
At times, he struggled with cooperative group
play. Brandon sometimes pretended not to hear
when the school counselor set limits and ignored
reminders of group rules. When this occurred, the
school counselor would give corrective feedback
and allowed Brandon an opportunity to change his
behavior. If this did not work, the school coun-
selor would deliver an effective command, being
specific and using a positive, encouraging tone.
At Brandon’s 9-week target monitoring up-
date, the RtI team reconvened to discuss
Brandon’s progress based on group play obser-
vations and classroom monitoring reports.
Brandon’s progress was further assessed using
follow-up CBCL reports. It appeared that Bran-
don’s classroom behavior was not improving.
His aggression toward classmates was still an
issue. The RtI team and Brandon’s parents
agreed to involve Brandon in Tier 3 intervention
as he needed a more targeted, individualized
intervention. A functional behavior assessment
(FBA) was completed by the RtI coordinator,
which consists of “methods and procedures that
are used to identify associations between the
behavior and variables in the environment”
(Dunlap et al., 1993, p. 275). A behavior im-
provement plan was created, and further inter-
ventions included weekly individual play ther-
apy sessions with the school counselor.
The school counselor began sessions with a
nondirective approach to establish a trusting rela-
tionship and to transition Brandon from group
play therapy. By using a child-centered approach,
the school counselor wanted to help Brandon to
understand the time in the playroom was for him.
Initially, sessions consisted of a lot of aggressive
play. Brandon often directed aggression at the
8 WINBURN, GILSTRAP, AND PERRYMAN
This document is copyrighted by the American Psychological Association or one of its allied publishers.
This article is intended solely for the personal use of the individual user and is not to be disseminated broadly.
school counselor by throwing balls or attempting
to hit with the play sword. To ensure a safe envi-
ronment, the school counselor set limits on ag-
gressive behavior (Kottman, 2011). Observation
of Brandon’s actions during sessions allowed the
school counselor to recognize when a limit needed
to be set prior to aggressive behavior. The school
counselor engaged in the session by tracking and
reflecting, making attempts to identify Brandon’s
feelings and emotions.
After six weeks of biweekly individual play
therapy, Brandon began talking more and inviting
the school counselor to play with him during ses-
sions. His aggression occurred less frequently. Be-
cause Brandon sometimes struggled with express-
ing feelings or emotions, the school counselor
incorporated activities to help Brandon create feel-
ings statements. In class, Brandon’s teacher no-
ticed him engaging in more frequent positive in-
teractions with adults and demonstrating less
aggression toward classmates. During the 9-week
Tier 3 progress monitoring meeting, reported ob-
servations and weekly behavior assessments re-
vealed a decrease in adverse classroom behaviors.
However, the teacher recognized that Brandon
still needed support as he continued to have occa-
sional challenges in group activities. Based on
Brandon’s progress and ongoing needs, the RtI
team decided to continue with Tier 3 support.
Brandon’s behavior improvement plan was mod-
ified to include weekly individual play therapy
sessions and small group therapy. An additional
progress monitoring date was set for continued
evaluation of Brandon’s behavior.
Conclusion
If utilized properly, the RtI model offers numer-
ous opportunities for counselors to work and act
with students on both individual and group levels.
School counselors can promote the integration of
school-based play therapy and the RTI model to
advocate for and empower students to achieve
greater success. Through consultation, collabora-
tion, and direct services, school counselors can be
at the center of a successful RtI program that
advocates for the needs of all students. The mis-
sion of the RtI model and of play therapy align
naturally with a comprehensive school guidance
program. Counselors who engage in school-based
play therapy are in a unique position to work
simultaneously within the goals of each to facili-
tate an agenda that dynamically works to meet the
needs of children.
References
Achenbach, T. M., & Rescorla, L. (2001). ASEBA
school-age forms & profiles.
Allen, K. B., & Barber, C. R. (2015). Examining the
use of play activities to increase appropriate class-
room behaviors. International Journal of Play
Therapy, 24, 1–12. http://dx.doi.org/10.1037/
a0038466
Allington, R. L. (2011). What really matters in re-
sponse to intervention: Research-based designs.
Pearson Higher Ed.
American School Counselor Association. (2010).
Ethical standards for school counselors. Alexan-
dria, VA: Author.
Axline, V. M. (1947). Play therapy: The inner dy-
namics of childhood. Boston, MA: Houghton Mif-
flin.
Barzegary, L., & Zamini, S. (2011). The effect of
play therapy on children with ADHD. Procedia:
Social and Behavioral Sciences, 30, 2216 –2218.
http://dx.doi.org/10.1016/j.sbspro.2011.10.432
Blanco, P. J., & Ray, D. C. (2011). Play therapy in
elementary schools: A best practice for improving
academic achievement. Journal of Counseling &
Development, 89, 235–243. http://dx.doi.org/10
.1002/j.1556-6678.2011.tb00083.x
Bradley, R., Danielson, L., & Doolittle, J. (2007).
Responsiveness to intervention: 1997 to 2007.
Teaching Exceptional Children, 39, 8 –12. http://
dx.doi.org/10.1177/004005990703900502
Bratton, S. C., Ray, D., Rhine, T., & Jones, L. (2005).
The efficacy of play therapy with children: A
meta-analytic review of treatment outcomes. Jour-
nal of School Psychology, 3, 117–143.
Burns, M. K., & Gibbons, K. A. (2008). Implement-
ing response-to-intervention in elementary and
secondary schools: Procedures to assure scientif-
ic-based practices. New York, NY: Taylor &
Francis.
Carbo, M. (2010). What helps at-risk adolescent
readers? Educational Leadership, 67, 1– 4.
Clements, K. D., & Sabella, R. A. (2010). Make it
work. The ASCA Counselor, 47, 32–35.
Coleman, V. D., Parmer, T., & Baker, S. A. (1993).
Play therapy for multicultural populations: Guide-
lines for mental health professionals. International
Journal of Play Therapy, 2, 63–74. http://dx.doi
.org/10.1037/h0089381
Coyne, M. D., Kame’enui, E. J., Simmons, D. C., & Harn,
B. A. (2004). Beginning reading intervention as inocu-
lation or insulin: First-grade reading performance of
strong responders to kindergarten intervention. Journal
of Learning Disabilities, 37, 90 –104. http://dx.doi.org/
10.1177/00222194040370020101
9TREATING THE TIERS
This document is copyrighted by the American Psychological Association or one of its allied publishers.
This article is intended solely for the personal use of the individual user and is not to be disseminated broadly.
De Laet, S., Colpin, H., Vervoort, E., Doumen, S.,
Van Leeuwen, K., Goossens, L., & Verschueren,
K. (2015). Developmental trajectories of chil-
dren’s behavioral engagement in late elementary
school: Both teachers and peers matter. Develop-
mental Psychology, 51, 1292–1306. http://dx.doi
.org/10.1037/a0039478
De Valenzuela, J. S., Copeland, S. R., Qi, C. H., &
Park, M. (2006). Examining educational equity:
Revisiting the disproportionate representation of
minority students in special education. Exceptional
Children, 72, 425– 441.
Drewes, A. A. (2005). Play in selected cultures:
Diversity and universality. In E. Gil & A. A.
Drewes (Eds.), Cultural issues in play therapy (pp.
26 –71). New York, NY: Guilford Press.
Dunlap, G., Kern, L., dePerczel, M., Clarke, S., Wil-
son, D., Childs, K. E., & Falk, G. D. (1993).
Functional analysis of classroom variables for stu-
dents with emotional and behavioral disorders. Be-
havioral Disorders, 18, 275–291.
Education for All Handicapped Children Act of 1975.
U.S. Public Law 94 –142. U.S. Code. Vol. 20, secs.
1401 et seq.
Fischetti, B. A. (2010). Play therapy for anger man-
agement in schools. In A. A. Drewes & C. E.
Schaefer (Eds.), School-based play therapy (2nd
ed., pp. 283–305). Hoboken, NJ: Wiley. http://dx
.doi.org/10.1002/9781118269701.ch14
Fuchs, D., Compton, D. L., Fuchs, L. S., Bryant, J., &
Davis, G. N. (2008). Making “secondary interven-
tion” work in a three-tier responsiveness-to-
intervention model: Findings from the first-grade
longitudinal reading study of the National Re-
search Center on Learning Disabilities. Reading
and Writing, 21, 413– 436. http://dx.doi.org/10
.1007/s11145-007-9083-9
Harpine, E. C. (2008). Group interventions in
schools: Promoting mental health for at-risk chil-
dren and youth. New York, NY: Springer. http://
dx.doi.org/10.1007/978-0-387-77317-9
Heller, K. A., Holtzman, W., & Messick, S. (Eds.).
(1982). Placing children in special education: A
strategy for equity (pp. 322–381). Washington,
DC: National Academy Press.
Howard, M. (2010). What is RTI? Teacher, 3, 12.
Justice, L. M. (2006). Evidence-based practice, re-
sponse to intervention, and the prevention of read-
ing difficulties. Language, Speech, and Hearing
Services in Schools, 37, 284–297. http://dx.doi
.org/10.1044/0161-1461(2006/033)
Kashi, T. L. (2008). Response to intervention as a
suggested generalized approach to improving mi-
nority AYP scores. Rural Special Education Quar-
terly, 27, 37.
Kavale, K. A., & Forness, S. R. (1999). Effectiveness
of special education. In C. R. Reynolds & T. B.
Gutkin (Eds.), The handbook of school psychology
(3rd ed., pp. 984 –1024). New York, NY: Wiley.
Kestly, T. (2010). Group sandplay in elementary
schools. In A. A. Drewes & C. E. Schaefer (Eds.),
School-based play therapy (2nd ed., pp. 257–281).
Hoboken, NJ: Wiley.
Kottman, T. (2001). Adlerian play therapy. Interna-
tional Journal of Play Therapy, 10, 1–12. http://
dx.doi.org/10.1037/h0089476
Kottman, T. (2011). Play therapy: Basics and beyond
(2nd ed.). Alexandria, VA: American Counseling
Association.
Kottman, T., & Meany-Walen, K. (2016). Partners in
play: An Adlerian approach to play therapy.
Hoboken, NJ: Wiley.
Landreth, G. L. (2012). Play therapy: The art of the
relationship.
London,
UK: Routledge.
Leblanc, M., & Ritchie, M. (2001). A meta-analysis
of play therapy outcomes. Counselling Psychology
Quarterly, 14, 149 –163. http://dx.doi.org/10.1080/
09515070110059142
Lin, Y. W., & Bratton, S. C. (2015). A meta-
analytic review of child-centered play therapy
approaches. Journal of Counseling & Develop-
ment, 93, 45–58. http://dx.doi.org/10.1002/j
.1556-6676.2015.00180.x
MacMillan, D. L., & Reschly, D. J. (1998). Overrep-
resentation of minority students the case for
greater specificity or reconsideration of the vari-
ables examined. The Journal of Special Education,
32, 15–24.
Marston, D. (2005). Tiers of intervention in respon-
siveness to intervention: Prevention outcomes and
learning disabilities identification patterns. Journal
of Learning Disabilities, 38, 539–544. http://dx
.doi.org/10.1177/00222194050380061001
McConaughy, S. H., Volpe, R. J., Antshel, K. M.,
Gordon, M., & Eiraldi, R. B. (2011). Academic
and social impairments of elementary school chil-
dren with attention deficit hyperactivity disorder.
School Psychology Review, 40, 200.
Meany-Walen, K. K., Bratton, S. C., & Kottman, T.
(2014). Effects of Adlerian play therapy on reduc-
ing students’ disruptive behaviors. Journal of
Counseling & Development, 92, 47–56. http://dx
.doi.org/10.1002/j.1556-6676.2014.00129.x
Meany-Walen, K. K., Bullis, Q., Kottman, T., &
Dillman Taylor, D. (2015). Group Adlerian play
therapy with children with off-task behaviors.
Journal for Specialists in Group Work, 40, 294
314. http://dx.doi.org/10.1080/01933922.2015
.1056569
Meany-Walen, K. K., Kottman, T., Bullis, Q., &
Dillman Taylor, D. (2015). Effects of Adlerian
Play Therapy on Children’s Externalizing Behav-
ior. Journal of Counseling & Development, 93,
418 428. http://dx.doi.org/10.1002/jcad.12040
10 WINBURN, GILSTRAP, AND PERRYMAN
This document is copyrighted by the American Psychological Association or one of its allied publishers.
This article is intended solely for the personal use of the individual user and is not to be disseminated broadly.
Meany-Walen, K. K., & Teeling, S. (2016). Adlerian
play therapy with students with externalizing be-
haviors and poor social skills. International Jour-
nal of Play Therapy, 25, 64 –77. http://dx.doi.org/
10.1037/pla0000022
Moores, D. F. (2008). Improving academic achieve-
ment: Can a Response-to-Intervention (RTI)
model help? American Annals of the Deaf, 153,
347–348. http://dx.doi.org/10.1353/aad.0.0053
No Child Left Behind Act of 2001, Public Law
107–110, 5, 115 Stat. 1427 (2002), et seq.
Perryman, K., & Doran, J. (2010). Guidelines for
incorporating play therapy in schools. In A. A.
Drewes & C. E. Schafer (Eds.), School-based play
therapy (2nd ed., pp. 59 86). Hoboken, NJ: Wi-
ley. http://dx.doi.org/10.1002/9781118269701.ch3
Pierangelo, R., & Giuliani, G. (2008). Frequently
asked questions about response to intervention.
Thousand Oaks, CA: Corwin Press.
Powers, C. J., & Bierman, K. L., & the Conduct
Problems Prevention Research Group. (2013). The
multifaceted impact of peer relations on aggres-
sive-disruptive behavior in early elementary
school. Developmental Psychology, 49, 1174
1186. http://dx.doi.org/10.1037/a0028400
Ravitch, D. (1999). Student performance: The na-
tional agenda in education. In M. Kanstoroom &
C. E. Finn (Eds.), New directions: Federal educa-
tion policy in the twenty-first century. Washington,
DC: Thomas B. Fordham/Manhattan Policy Insti-
tute. http://dx.doi.org/10.2307/20080827
Ray, D. C., Armstrong, R. A., Balkin, R. S., & Jayne,
K. M. (2015). Child-centered play therapy in the
schools: Review and meta-analysis. Psychology in
the Schools, 52, 107–123. http://dx.doi.org/10
.1002/pits.21798
Ray, D. C., Blanco, P. J., Sullivan, J. M., & Holli-
man, R. (2009). An exploratory study of child-
centered play therapy with aggressive children.
International Journal of Play Therapy, 18, 162–
175. http://dx.doi.org/10.1037/a0014742
Ray, D. C., Schottelkorb, A., & Tsai, M. H. (2007).
Play therapy with children exhibiting symptoms of
attention deficit hyperactivity disorder. Interna-
tional Journal of Play Therapy, 16, 95–111. http://
dx.doi.org/10.1037/1555-6824.16.2.95
Reddy, L. A. (2012). Group play interventions for
children: Strategies for teaching prosocial skills.
Washington, DC: American Psychological Associ-
ation. http://dx.doi.org/10.1037/13093-000
Roundtable, L. D. (2002). Specific learning disabili-
ties: Finding common ground. Washington DC:
U.S. Department of Education, Office of Special
Education Programs, Office of Innovation and De-
velopment.
Schaefer, C. E., & Drewes, A. A. (2012). The ther-
apeutic powers of play and play therapy. In A. A.
Drewes & C. E. Schafer (Eds.), School-based play
therapy (2nd ed., pp. 3–16). Hoboken, NJ: Wiley.
http://dx.doi.org/10.1002/9781118269701.ch1
Speece, D. L., Case, L. P., & Molloy, D. W. (2003).
Responsiveness to general education instruction as
the first gate to learning disabilities identification.
Learning Disabilities Research & Practice, 18,
147–156. http://dx.doi.org/10.1111/1540-5826
.00071
Stecker, P. (2007). Tertiary intervention: Using prog-
ress monitoring with intensive services. Teaching
Exceptional Children, 39, 50 –57. http://dx.doi
.org/10.1177/004005990703900507
Swan, K. C., & Ray, D. (2014). Effects of child-
centered play therapy on irritability and hyperac-
tivity
behaviors
of children with intellectual dis-
abilities. Journal of Humanistic Counseling, 53,
120 –133. http://dx.doi.org/10.1002/j.2161-1939
.2014.00053.x
Swanson, H. L., Hoskyn, M., & Lee, C. (1999).
Interventions for students with learning disabili-
ties: A meta-analysis of treatment outcomes. New
York, NY: Guilford Press.
U.S. Department of Education. (2005). The guidance
counselor’s role in ensuring equal educational op-
portunity. Retrieved from www.ed.gov/about/
offices/list/docs/hq43ef.html
Vaughn, S., Fuchs, L., & Fuchs, D. (2008). Response
to intervention: A framework for reading educa-
tors. Newark, DE: International Reading Associa-
tion.
Vaughn, S., & Roberts, G. (2007). Secondary interven-
tion in reading: Providing additional instruction for
students at risk. Exceptional Children, 39, 40 46.
http://dx.doi.org/10.1177/004005990703900506
Vellutino, F. R. (2003). Individual differences as
sources of variability in reading comprehension in
elementary school children. In A. Polselli Sweet &
C. E. Snow (Eds.), Rethinking reading comprehen-
sion (pp. 51– 81). New York, NY: Guilford.
Vitaro, F., Boivin, M., Brendgen, M., Girard, A., &
Dionne, G. (2012). Social experiences in kinder-
garten and academic achievement in grade 1: A
monozygotic twin difference study. Journal of Ed-
ucational Psychology, 104, 366–380. http://dx.doi
.org/10.1037/a0026879
Voogd, C. (2014). Helping children with ADHD
reach their full potential. British Journal of School
Nursing, 9, 126 –130. http://dx.doi.org/10.12968/
bjsn.2014.9.3.126
Ysseldyke, J. E., Algozzine, B., & Thurlow, M.
(1998). Critical issues in special education. Delhi,
India: Kanishka Publishers.
Received December 9, 2015
Revision received September 6, 2016
Accepted September 12, 2016
11TREATING THE TIERS
This document is copyrighted by the American Psychological Association or one of its allied publishers.
This article is intended solely for the personal use of the individual user and is not to be disseminated broadly.