5x SPED model makes state implementations more difficult

Looking at the newest ed-fi model, there is a new domain for SPED eligibility. I think this is a good idea, but the problem that I have is that it introduces several more dates, and what I am seeing in the field is that a lot of states have very specific sorts of events that they track that partially line up with what is in the new SPED eligibility resource and what has traditionally been on student SPED association.
What we have put together for Georgia and New Mexico is an extension that tracks all of the special education events as a collection with a descriptor that identifies what the event is. This allows us to table-drive that list of events that is different for every state and even from year to year. This however gets ambiguous and inconsistent, should they be using the extension for fields that are explictly defined in the resource so everything is in one place and is similar to the legacy data flows or should we only use the extension for dates that are not in the resource? ANd how close to the semantics have to match between what the state is asking for and what the Ed-Fi model is? SPED language has to be very precise.
I would advocate that all dates other then those that are inherited from general student program association be removed and instead there should be a collection like the Georgia and New Mexico extensions. That way the modeling team is not trying to guess what everyone's sped eligibility process is.
Here are the event types that New Mexico captures:

• Special Education Exit or Known to be Continuing
• One-time Written Parental Consent for Medicaid and/or Private Insurance.
• Annual Written Notification to Parent/Guardian regarding Medicaid and/or Private Insurance
• The student received a conditional certificate of conditional transition and plans to return for a Free and Appropriate Public Education (FAPE). To be used for students with disabilities that have been awarded a Modified Diploma or Ability Diploma and are continuing to work toward a Standard Diploma and/or IEP goals. Plans to return for a Free and Appropriate Public Education (FAPE).
• Graduation – Student with a disability graduated with a diploma on the ability or modified option and will not be returning for a Free and Appropriate Public Education (FAPE).
• Completion – Student with a disability earned a conditional certificate of transition and will not be returning for a Free and Appropriate Public Education (FAPE).
• Part C to B (Indicator 12) - Date referral received from Part C (Item a of equation a-b-d-e ÷ c)
• Parental Notification of the transfer of rights has occurred
• Part C to B (Indicator 12) - 90 day transition conference date
• Part C to B (Indicator 12)- Eligibility Determination- YES
• Part C to B (Indicator 12)- Initial Placement IEP date or date when IEP was developed prior to third birthday (Item c of equation a-b-d-e ÷ c)
• Part C to B (Indicator 12)- IEP Implementation (when student started receiving special education services under Part B prior to third birthday) (Item c of equation a-b-d-e ÷ c)
• Part C to B (Indicator 12)- Eligibility Determination – NO must be determined prior to third birthday. (Item b of equation a-b-d-e ÷ c)
• Part C to B (Indicator 12) - Determined to be eligible for early intervention services under * Part C less than 90 days before third birthday. (Item e of equation a-b-d-e ÷ c)
• Part C to B (Indicator 12) - Parent refused to provide consent for evaluation or initial services. (Item d of equation a-b-d-e ÷ c)
• Parental consent revoked for Special Education & Related Services (34 CFR §300.300 (b)(4))
• Part B (Indicator 11) - Parental Consent Initial Evaluation Only
• Part B (Indicator 11) - Initial Evaluation Only
• Part B (Indicator 11) - Initial EDT Eligibility Determination - YES
• Part B (Indicator 11) - Initial EDT Eligibility Determination - NO
• Part B - Initial IEP Date
• Part B (Indicator 11) - A child enrolls in a school or another public agency after the timeframe for initial evaluations has begun, and prior to a determination by the child’s previous public agency as to whether the child is a child with a disability.
• Part B (Indicator 11) - Parent fails or refuses to produce the child for evaluation (at least three documented attempts)
• LEA missed timeline (Indicators 11 and 12)
• A Communication Needs Consideration Form was completed at the IEP for student who is deaf or hard of hearing, or Blind or Visually Impaired, regardless of the disability regardless of the disability.
• The LEA assures that compliance has been met for the following Post-secondary Transition Goals. Now Required for 14 and older.
• A Communication Needs Considered at the IEP for student who is. Note: When Developing IEPs for students who are blind or have a visual impairment the IEP team must consider instruction in Braille unless the team determines after an evaluation that Braille is not needed.
• CEIS - Date of referral for special education
• Parental consent revoked for Medicaid and/or Private Insurance (34 CFR §300.154 (d)(2)
  Here is what Georgia captures:
• Babies Can?t Wait Notification
• Parent Consent to Evaluation
• Initial Evaluation
• Initial Eligibility Determination
• Initial IEP Meeting
• Initiation of IEP Services/Transition Service
• IEP Annual Review
• Reevaluation
• Special Education Exit
• Parent Revoked Consent
• Student Not Eligible for Initial Provision of Services
• Parent Refused Initial Provision of Services
• District Verified student was incorrectly reported as SWD in a prior year
• Signed Parental Consent for the Provision of Services
• Reevaluation Waiver
  I have also attached the New Jersey special education template instructions that has their dates.