Does In-School Suspension Count as a Day of Suspension Toward the 11th Day Rule?

I just received a copy of "Parent Rights in Special Education (Procedural Safeguards)" from the Office of Exceptional Children at the SC State Department of Education. The word DRAFT is clearly written on each page in addition to the following statement, "It is a 'living' document and will change and grow as resources and information become available."
One thing I love about the format of our new state policies and procedures for special education, is the Q and A section at the end of each chapter...here is an example:
So, does in-school suspension count as a day of suspension toward the 11th day rule?

Whether school days of in-school suspension count as school days of suspension for determining if a change of placement has occurred depends on the nature of the in-school suspension environment. Many schools already use in-school suspension for code of conduct violations. Because children frequently are unsupervised and undirected by school personnel if placed on out-of-school suspension, many school districts prefer to use in-school suspension, at least for first-time offenders or less serious offenses. Comments following the Federal regulations indicate that school districts have authoirity to utilize in-school suspension as a disciplinary tool (Federal Register, August 6, 2006, p. 46715).

Additionally, a school day of in-school suspension should not count as a school day of suspension for services or change of placement purposes if, during the in-school suspension, the child is afforded an opportunity to:

• continue to appropriately progress in the general curriculum;
• continue to receive the services specified on his or her IEP; and
• continue to participate with children without disabilities to the extent they would have in their current placement.

The assumption is that school districts may use in-school suspension for children with disabilties just as they would for children without disabilities. The issue is really whether the school day(s) count toward accumulating the 11th school day of suspension which would require the beginning of educational services or toward the 10 consecutive school days for change of placement or provision of services. The Comments indicate that for children with disabilities, if the in-school suspension approximates the current placement in the areas outlined above, it does not count toward the 10 school days needed for a change of placement or provision of services. On he other hand, if in-school suspension is a place where children are held without opportunities to progress in the general curriculum, receive IEP services, and participate with children without disabilties to the same extent they would have in the current placement, the days do count as school days of suspension for change of placement and provision of services purposes.