Results Driven Accountability Effort – Question Three

OSEP appreciates the comments and suggestions posted in response to the RDA questions one and two. OSEP will accept comments on question 3 until September 14.

RDA Question #3:

“The Individuals with Disabilities Education Act (IDEA) requires the U.S. Department of Education and states to focus on improving educational results and functional outcomes for infants, toddlers, children and youth with disabilities, as well as to ensure that programs meet IDEA requirements. As the department refocuses its accountability efforts, which IDEA requirements do you see as being most closely related to improved educational results and functional outcomes for infants, toddlers, children and youth with disabilities?”


  1. You need to measure a student’s progress against a their own baseline. That’s really the only fair way to measure their progress because often their progress is miniscule over a full year. We do NOT need more attorneys in our IEP meetings demanding more services for students who clearly do not meet eligibility criteria. Example: we have students who may be 7 years old but who are functioning at an 18 mo. level, and attorneys are demanding speech services for sounds that are not typically produced until many normally developing children are 7 or 8. It’s insane. So then we have to work on later developing sounds for YEARS and these kids show NO progress because it’s like giving articulation therapy to a baby. It should be against the law. And attorneys should not demand articulation therapy for an 8 year old nonverbal severely autistic child!! Attorneys know NOTHING about speech and language development. If we could get rid of attorneys in IEP meetings making ludicrous and unrealistic demands, then the states and fed would save billions!

  2. In order to have true educational outcomes, school personnel need to be well trained on how to ensure students have full and meaningful access to the general education curriculum, including a high rigor tier one level of reading instruction. I worry that the department is moving away from the state specific Deafblind Grant Projects, who spend considerable time ensuring these students have meaningful access and specialized instruction to address their very unique learning needs.

  3. The IDEA requirement is only effective when the IEP is a comprehensive, detailed portrait of the child, his/her disability, his/her strengths and challenges and the appropriate interventions to meet their needs.
    It needs to be specific. There are so many general, cookie-cutter IEP’s that allow districts room for interpretation. Parents need to be educated on the fact that the district obligation is to identify the need and meet it appropriately – appropriately.

  4. Development of the IEP and the IEP meeting are essential to providing promising educational outcomes for our children. IEPs must include a PLAAFP with Data, not just a narrative. Goals and objectives must be identified from the weaknesses, and written so they are measurable. I am aware this is what IDEA states now, but this is not what occurs. This is the reason that a focus must continue to be placed on compliance. When districts fail to comply with IDEA requirements, parents must have additional resources beyond what is currently given to them. Districts can blatantly ignore timelines, not follow laws, not follow IEPs, etc. and at most they are told they must be in compliance. This process often takes years to occur. Recently in one New Jersey district it took 4 years for special education students to obtain the right to take a language other than Spanish because there were no aides in other classes. The students that initiated due process had graduated before the case was settled. There was no compensation for these students. The district now must be in compliance, yet these students and their parents have spent thousands of dollars for a right which is given to all other students.

    IEP meetings are crucial to ensuring parents are part of the IEP process. Timelines must be followed. Two teachers, a general education and a special education teacher, must be present at the IEP meeting. All data must be presented prior to the meeting so parents have the opportunity to review it and understand it. If teachers are not at the meeting, as was done to me, then there should be consequences. Keeping teachers out of meetings so that parents cannot obtain information regarding their child’s educational program should never be acceptable. However, there is no accountability. What recourse is there when teachers are not present at an IEP meeting. IDEA states they should be present at IEP meetings. It is a vital component of the legislation. But what happens when districts fail to follow IDEA?

    • I also wanted to add the need to use evidence based instruction whenever it is appropriate. When districts do not use an evidence based program, then students are not offered there best opportunity at successful outcomes.

      For example, teachers cannot use reading comprehension questions as a writing program for a student with a writing disability when the reading program is not an evidenced based program for writing. Students need to be taught specific strategies in writing. IEPs then are constructed to cover up the fact that an effective writing program was not used. The student is blamed for lack of progress, not the teacher or the program. Programs should be stated in the IEP and objective data included to document progress. Then when an IEP meeting is scheduled, teachers should attend the IEP meeting so parents have the opportunity to discuss the program used and their child’s progress.

  5. As a result of Part C, the parents should be able to participate as true partners in their PPTs P-20 with the confidence of someone who knows their child and knows how Part B works. They will know their Part B rights, know how to communicate about their child and they’ll be connected with the state PTI.
    The parents of children who do not go on to Part B should know what to expect with regard to typical development for their child and how to make a referral to their LEA or back into EI as soon as they develop any concerns. They will also know their Part C and B rights.
    Most children aren’t in EI long enough for us to say that EI should result in changes in their developmental trajectory. EI is about families!

  6. I strongly support the movement to shift the focus away from compliance and focus on educational outcomes. As a special education teacher and more importantly, parent of a son with a specific learning disability, I have become frustrated by a system that has failed to provide my son with the education he needs to lead an independent life. Compliance without consequences has proven ineffective in making school districts meet the requirements of IDEA.

    Over the past 2 years I have spent $30,000 for an educational advocate to perform assessments & observations and attend IEP meetings. She attended my son’s most recently scheduled “IEP” meeting last May and attempted to convince the district of his need for ESY. No teachers were present at the “IEP” meeting although they were never excused (2 teacher signatures were later found on the IEP cover page). I was asked to sign the IEP cover page stating I had attended this IEP meeting in which no teacher entered the room and goals and objectives were never discussed. I refused. The CST supervisor told me there was “no real definition of what makes an IEP meeting”, so an IEP meeting had been held. The draft IEP blames my son for lack of progress, when actually I know that the teacher failed to use an evidence-based writing program. Rather than use the agreed upon program, she used the reading text to give a reading comprehension question once a week. The draft IEP I was given prior to the meeting lacked the data the was agreed upon to measure progress. It was stated in the previous IEP that informal reading inventories would be given every marking period. That was not done. It was necessary for my advocate, a doctor of educational psychology, to arrive 3 hours before the meeting, to assess my son at my expense in order to have data. Unfortunately the IEP meeting was never held. I paid my advocate $1,600 to complete assessments which should have been completed by the district and attend a meeting which was never held. There is no recourse for me to recover this money. If another IEP meeting is held, I will pay her again. If I file a complaint, the district is merely found out of compliance.

    Under the present system there is no consequence to the district when they have blatantly ignored IDEA by not allowing my son to have his annual IEP meeting with teachers present. Writing samples as well as weekly lesson plans mailed to me prove an evidence-based writing program was not used for my son with a significant weakness in writing. But I have learned there is no accountability for the supervisor of special education or the superintendent who supported the practice of keeping teachers out of an “IEP” meeting. Now my son is attending high school. It has been over a year and he still has not had an IEP meeting. I no longer trust that the system will act in the best interests of my son to see that he is given an appropriate education. At present it only acts to ensure there is compliance with IDEA. When districts are not in compliance, blatantly ignoring student’s rights, there is no accountability. However, I have found that as I advocate for my child, teachers and administrators retaliate against him, making it difficult for me to voice my concerns without him experiencing the consequences. That is the system that I know.

    My concern as you focus toward educational outcomes:
    Although I am in full support of OSEPs realization that the focus on compliance has done little to improve the educational outcomes of our children, I have concerns regarding how I have witnessed teachers manipulate scores to give the illusion my son was making progress, when in fact he was not. For example, my son has modifications that provide study guides, advance notice for tests. and additional time The tests are not to be modified or read to him. My desire is for him to learn all the information and have a valid score. Over the past year I have had teachers, backed with the support of administrators, refuse to show me my son’s completed tests. They would only give me his scores. When I was finally able to see his tests (by a FERPA reminder) I found they had been modified to make them easier. For example, 2 of 4 possible responses would be blanked out on a multiple choice test. In a past writing class, he scored 9 out of 10 for editing and revising essays when he never completed the rough draft to even reach the editing and revising stages. My concern is that teachers can write whatever score they choose. Educational outcomes must be based on objective assessments, not subjectives teacher scores. Baseline data and benchmark assessments are important components of this process.

    Based on my experiences, the IDEA requirements that would improve educational outcomes would be:

    – teachers (gen ed & spec ed) must be present at IEP meetings – no teachers attended my son’s IEP meeting, yet signed the IEP cover page. It has now been over a year since his last IEP meeting. He does not have valid goals and objectives or an appropriate program as he begins high school. The IEP PLAAFP must have a narrative containing the programs used (evidence based) and data to document progress. Objectives based on the PLAAFP that are measurable (SMART goals)

    – use evidence-based programs in the classroom – teacher used a reading program for writing, although no evidence to support it’s use. A teacher wrote in my son’s IEP that “he presented as reading on grade level” when he was in 7th grade reading at a 2nd grade reading level. We did not know that he was this far below grade level until obtaining an independent evaluation. He clearly was not reading on grade level if he was 5 years below grade level. My son informed me the teacher had not read with him once during the year. Luckily, we obtained a tutor who used a research-based program that summer, and he gained 2 grade levels in 7 weeks. This demonstrates the importance of a research based program.

    – measurable goals and objectives – my son’s objectives were not measured each marking period using the IRI. Also give same assessments as given in the general ed classroom. He was not given assessments because he was in LRC, so I cannot compare his progress to that of gen ed students. He should participate in district wide assessments and take benchmark assessments with other students. The district does use curriculum based measurements to measure progress, however these are at assigned levels, not at the levels students are functioning.

    -IEPs must include data to accurate reflect current levels and measure progress. The data must be in the same form. For example, the district gave a grade level score for oral reading fluency mid year, then a Gray Silent Reading Quotient at the end of the year. The IEP state an IRI would be given every marking period.

    -allow parents a parent-teacher conference even when 30 day review is close to school conferences. Last year I was denied a parent teacher conference with my son’s LRC teacher because she had participated in the 30 day review meeting. This discriminates against the parents of special education students.

    -allow parents to attend assistive technology meetings when an evaluation has been requested. I was not informed when meetings occurred or when AT evaluation ended. I was denied an AT IEP meeting to include assistive technology in my son’s IEP. As a result he was suspended from school for using a cell phone to record homework, which the specialist had told him to do. He eventually missed his graduation due to this suspension.

    -One additional concern, in seeking educational outcomes for students. I have found that my son has been given a special education teacher for his reading program when a reading specialist has been designated by the program as the appropriate instructor. As a special education teacher, I have taken only 1 class in reading instruction to obtain a special education certification in my state. I do not have the skills and strategies needed to teach a child with my son’s disability. My son made great progress during his 7 weeks with the reading specialist, but very little over the years with the special education teacher. I strongly believe that there are times when a reading specialist is required to admister programs to students with reading disabilities, even though this is not guaranteed. To put him in a classroom where the special education teacher puts in CD roms and he listens to books does nothing to improve his reading comprehension, yet there is nothing I can do to voice my concerns to this district. Instead I pay for tutors after school and through the summer to compensate for what is not taught by the special education teacher. When I voice my concerns, I am told to “take us to due process” because the district knows IDEA does not provide a reading specialist and it is futile for me to try to obtain a reading program for my son that will benefit him. The IEP does not provide data or objectives that are measurable. Even if they were measurable, when there is an IEP meeting scheduled, the teachers do not attend and the meeting is never held. IEPs blame my son for lack of progress when teachers don’t use evidence-based programs. There is no accountability so my son now does not have an IEP as he starts the new year.

    In conclusion, from my experience, please make certain to maintain a focus on compliance. However, consequences must be added when student’s rights are ignored. Monetary damages should be available to parents and students who have spent considerable sums of money to obtain programs for their children. $30,000 later and I feel we have achieved very little for my son – he doesn’t even have an IEP as he enters high school. Thank you for this opportunity to voice my opinion.

  7. This is in response to question #3, but also responsive to question #2.

    Frankly, the question itself reveals the answer.

    “The Individuals with Disabilities Education Act (IDEA) requires the U.S. Department of Education and states to focus on improving educational results and functional outcomes for infants, toddlers, children and youth with disabilities, as well as to ensure that programs meet IDEA requirements.”

    IDEA requires that all students receive FAPE, yet that is not happening in the U.S. today. Almost every single state in the United States is out of compliance with both the procedure and substance of the law. It has been this way for years. What is U.S. DOE doing about it? Continuing to fund SEAs and their LEAs who year in and year out continue such noncompliance. How does this meet the plain language of the IDEA which requires that noncompliant SEAs and LEAs are held accountable? The reality is that without “compliance” and a focus on procedural aspects, including the proper implementation of procedural safeguards and the validity of the complaint processes under IDEA, which U.S. DOE claims to have been focusing on, we can’t really get to the substantive.

    The notion that U.S. DOE is “refocusing” its accountability efforts itself seems something of a disingenuous dodge, not to mention avoidance of its own failure of accountability with regard to its duties and obligations to children with disabilities under the IDEA in overseeing states and ensuring compliance. It has often been stated that IDEA 2004 brought more focus on outcomes rather than the focus on compliance in prior reauthorizations. If U.S. DOE is just now “refocusing” on outcomes, I can’t help but wonder what it is the agency has been doing over the eight years since IDEA 2004 was enacted?

    The most important thing U.S. DOE can do to improve outcomes is to do its job, i.e., enforce the law according to its plain language against noncompliant state education agencies, including looking at the continued failure to students to make academic and social progress, particularly in the areas of access to literacy and reading, the failure of students to have access to and make progress in state standards that they can demonstrate through valid assessment, and the failure to graduate and go on to become what IDEA contemplates, i.e., productive members of society. I would submit that all of these substantive issues are underlain by procedural and compliance failures at both the state and local level.

    I can’t speak for other states, but California has been out of compliance for years. It has passed legislation that allows it to opt out students with disabilities from its high school exit exam without coming up with an appropriate alternative assessment, despite California law that says that ALL students must pass in order to graduate from high school. As such, California is actively discriminating against students with disabilities, U.S. DOE knows it on the annual reports California dutifully files with CDE, but U.S. DOE annually accepts the reports California provides claiming that students with disabilities are graduating, ignoring that they do not meet the standards their typical peers must in order to do so.

    U.S. DOE does nothing about California’s failing complaint resolution process and the continued noncompliance that is endemic throughout the state. U.S. DOE does nothing about the fact that California routinely allows districts to fail to comply with corrective actions it issues in response to noncompliance found through its complaint resolution process and then claims such noncompliance is a “dispute” that can only be resolved in the due process system where school districts routinely use legal counsel and engage in scorched earth litigation against unrepresented families. U.S DOE ignores the inequity of California’s so-called due process system with administrative law judges who routinely side with school districts and their legal counsel and against parents and families who for the most part are unrepresented and who even sanction parents who happen to be attorneys for asserting their student’s due process rights as the law requires. I won’t even go into the school district legal counsel issue which has become a cottage industry in California where education dollars are paid by LEAs to law firms to avoid providing services to students at the same time LEAs assert that they are providing FAPE to students in order to receive federal funds.

    When U.S. DOE is going to do something truly meaningful for students with disabilities, so that their outcomes truly improve, it will be a new day. Parents in California are not holding their breath.

    • EXCELLENT COMMENT! If OSEP would do their current job of enforcing compliance, then these questions would not need to be asked.

  8. National Center for Learning Disabilities

    Comments on The Office of Special Education, U.S. Department of Education
    Results Driven Accountability Initiative – Question #3

    The National Center for Learning Disabilities (NCLD) works to ensure that the nation’s 15 million children, adolescents and adults with learning disabilities have every opportunity to succeed in school, work and life. Since 1977, NCLD has been led by devoted parents and professionals committed to creating better outcomes for children, adolescents and adults with learning disabilities. Over 40,000 parents and teachers rely on NCLD for information and resources on learning disabilities.

    NCLD is keenly interested in the work of the Office of Special Education (OSEP) particularly related to the Results Driven Accountability initiative. The initiative clearly intends to respond to the urgent need to update the compliance and monitoring system so that states can better deploy technical assistance, training and support aimed at ensuring the successful outcomes of K-12 students. Students with learning disabilities (LD) represent 42 percent of all special education students – numbering 2.4 million in our nation’s schools and continue to lag behind their peers in nearly every way. While we know that these students can achieve right along with their peers, it is critical that the outcomes of these students help drive instructional delivery and special education services in the most effective ways. We know that when provided evidence based instruction, interventions and services, they can achieve proficiency on grade level standards and graduate from high school with a regular diploma.

    NCLD appreciates the opportunity to respond to the RDA Question #3 which states:

    “The Individuals with Disabilities Education Act (IDEA) requires the U.S. Department of Education and states to focus on improving educational results and functional outcomes for infants, toddlers, children and youth with disabilities, as well as to ensure that programs meet IDEA requirements. As the department refocuses its accountability efforts, which IDEA requirements do you see as being most closely related to improved educational results and functional outcomes for infants, toddlers, children and youth with disabilities?”

    Participation of all IDEA-eligible students with disabilities in district and state assessments.
    Participation in assessments is necessary for accountability and to determine whether students with disabilities are participating in and making progress in the general education curriculum. Monitoring the states’ participation data regarding the percentage of students with disabilities who are participating in the general assessment (with or without accommodations) is also critical to ensuring that schools and districts are not overusing alternate assessment(s) and, therefore, taking students off track to graduate with a regular diploma.

    Performance of IDEA-eligible students on Statewide Assessments
    Including the performance of students with disabilities on state assessments (i.e., percent proficient/non-proficient) is critical to improving academic achievement. Expectations should be weighed on both the achievement of students regarding the target (AMO) set for the students with disabilities subgroup in the state’s accountability system [as required under the Elementary and Secondary Education Act/ESEA] as well as against the percent proficient in other states. Such measures will become particularly important when most states have agreed to implement both the Common Core State Standards (CCSS) and the assessments aligned to the CCSS. Improvement year-over-year (growth) should also be considered when there is a clear definition of growth that includes a specified timeframe in which proficiency will be achieved. In other words, OSEP should not give credit for growth to nowhere.

    Graduation with a Regular High School Diploma
    Monitoring of graduation rates for students with disabilities in the context of OSEP monitoring must be aligned with the ESEA regulation regarding graduation calculations, subgroup accountability and aggressive targets for improvement. Graduation rates for students with disabilities must also be disaggregated by race/ethnicity, income, ELL status in order to determine underperforming groups of students and provide interventions. Improvement year-over-year should also be considered, but should not overshadow graduation rates.

    Drop-out rates
    Monitoring of drop-out rates for students with disabilities in the context of OSEP monitoring must be disaggregated by race/ethnicity, income, ELL status in order to determine underperforming groups of students and provide interventions. Improvement year-over-year should also be considered, but should not overshadow drop-out rates.

    Disproportionality in Rates of Suspension and Expulsion and Disproportionate Representation in Special Education
    A common methodology for calculating disproportionality should be developed and applied across all states. The current patchwork approach that allows every state to define disproportionality renders any monitoring of disciplinary actions and representation as useless as documented in a report funded by OSEP via Project Forum State Definitions of Significant Disproportionality, 2007.

    Secondary Transition
    Monitoring of transition planning must progress beyond current factors (checking boxes) and become aligned to the student’s post-school outcomes. Transition planning must reflect the states’ larger agenda regarding college and career readiness and expect students with disabilities to be equally as prepared as their non-disabled counterparts.

    State Monitoring of LEAs
    OSEP’s refocused accountability efforts with regard to monitoring of State Educational Agencies (SEAs) will provoke improvement in the educational results and functional outcomes of children only if that same refocusing is required of the SEAs in their monitoring of the Local Educational Agencies (LEAs) within their state. Therefore, OSEP’s guidance to SEAs regarding LEA monitoring must be reformulated and reformatted to ensure a focus on outcomes at the LEA level. Currently there is too much variability across SEAs in how they monitor LEAs, the level of detail and the improvement activities LEAs are directed to carry out.

    Thank you for this opportunity to comment.

  9. As the parent of a high school student who has received special education since birth, an advocate who has served for years on my state’s ICC and a family leader who continues to support other family leaders I am glad that OSEP is moving beyond compliance. Compliance is important, however we know that far too many of our citizens with disabilities remain unemployed or underemployed, what we want and need are Results.

    Part C:
    Indicators 3 and 4 (Child and Family Outcomes) are a beginning. They help us to see the trajectory of growth and development of children enrolled in early intervention. The family outcomes data can begin to help to paint a picture of how families are experiencing early intervention. I wonder how many states are using the compliance and results data in concert to look at the issues that most confound families–connecting their various “teams”–educational, developmental and medical, including their young child with a disability in their home and community and receiving supports that are relevant to the whole family not simply the child with a disability. In my own state we have begun to use a more comprehensive approach to technical assistance and monitoring. One that reviews the data, samples IFSPs to review how the narrative and the functional outcomes work together (whether the items recorded as being a concern, priority or resource are really informing and driving the development of functional outcomes). And one that interviews not only providers but families as well to inform the monitoring process. This process also takes the time to look at both those programs and municipalities that are encountering challenges as well as those experiencing success.

    Workforce Development
    I believe that more emphasis needs to be placed on assisting our workforce to understand what it means to develop a strong, trusting relationship with families that assists them to feel confident and competent about caring for their child with a disability. More practitioners in the field need to be aware of and incorporate the important work of folks like Robin McWilliams and Carl Dunst into there everyday practices to insure that they are helping families to do for themselves and that their help-giving practices assume competence and foster confidence.

    ICCS and SEAPS

    I am glad that OSEP is using their website to expand their reach and to utilize social media to collect comments. However, Interagency Coordinating Councils under Part C (ICCs) , State Educational Advisory Panels under Part B (SEAPs) and Parent Training and Information centers (PTIs) from each state need to be more involved in this process as statutorily required components of IDEA. Many ICCs and SEAPs have a more formal schedule than the blog. Unfortunately, this means that ICCs and SEAPs don’t have the opportunity to reflect and respond to the blog questions. I would encourage OSEP to create a special opportunity to engage these important stakeholders who have experience in analyzing both the data and the implementation of the system in their respective states.

    Part B
    If more and more children with IEPs are spending more than 80% of their time in General Education classrooms as has been oft reported, than OSEP needs to work with Districts, Universities and the education department to insure that families are no longer faced with general education teachers who have no idea how to implement an IEP. Each year I hear that refrain from a teacher, a teacher who has been in the workforce for less than five years. When IDEA is older than these teachers! It is frustrating. Either the team resorts to the “canned” IEP goals from their online program, or nod their heads in agreement only to say weeks later that they have no idea how to support one’s child. If we wish to see real results we must work together to insure that all members of a school community are ready, willing and able to meet the demands of the diverse student body that inhabit our nation’s public schools.

    I get that we are all doing more with less, but we must redouble our efforts when it comes to children with disabilities. Together we can insure that children with disabilities become happy and productive adults!

  10. The 20 indicators, which are empirical proxies for IDEA requirements, measure the extent to which SEAs and LEAs are meeting their statutory obligations. While the indicators are not an exhaustive set of measures, they represent hypothetical and anecdotal connections between procedural compliance, educational results, and functional outcomes for children and students with disabilities. Results Driven Accountability is an opportunity to move from hypothetical and anecdotal connections between IDEA requirements and indicators, to those connections that are supported by evidence, data analysis, and research. For example, there is a strong hypothetical connection between indicators 13 and 14, which operationalize 20 U.S.C. 1416(a)(3)(B); but is there empirical evidence, either at the state or national level, to suggest that compliance with all elements included in the measurement of indicator 13 actually leads to better post-high school outcomes? Similarly, are there elements within the widely used NCSEAM Parent Involvement Survey, an instrument used to measure compliance with indicator 8 and 20 U.S.C. 1416(a)(3)(A), that relate to other indicators such as 3c, or 4b? OSEP’s role in providing research and analysis related to such connections using data from all 50 states and territories, as well as guidance to SEAs about leveraging the indicators to drive improved functional and educational results for children and students, is crucial.

    We agree with OSEP’s position that the “Results” Driven Accountability system should not be based on a single indicator or “Result”, and that OSEP’s work with states should not take on a top-down, one-size-fits-all approach. The connections between fiscal monitoring, and compliance and results outcomes are complex and multifaceted, likely varying widely from State to State. SEAs, in partnership with OSEP, must study these connections to determine which indicators, as well as legal requirements, have a positive impact on reading and math achievement, as well as other outcomes such as graduation and post-high school education, training, and employment. An RDA system that includes a study of these connections will lead to data-based and data-driven State Performance Plans, and provide a solid framework for continuous state improvement in advancing functional and educational outcomes for students.

  11. The term “special needs” and the corresponding provision of “special education” services has become so broad that it is difficult to believe that all teachers can be everything to all children with special needs. Yet, that is exactly what they profess to do. The only way to in fact really be able to do that is to have better training, mentoring, more leveling in classrooms and the teachers that are assigned to them, more resources and an educator having the abiity to say “I don’t know” but let’s figure it out together. What would it take to hear an educator say that?

    There needs to be more than Due Process as the system of checks and balances on School Districts. Fiscal cost to parents alone makes it an inefficient and insufficient check on School Districts so essentially leaves schools to police themselves.

    I have to second the well thought out email and it’s contents from Stephanie of CPSD in that it covers many, if not all, of the concerns raised by the prior posters. All of which are very valid and real. I add that I firmly agree that despite NCLB placing literacy and math standards for ALL students, same is either being outwardly ignored or there is minimal compliance for those students with more substantial disabilities in particular. Even in “good districts” “with money” the students who are more involved than learning disabilities continue to be placed in “life skills” classrooms run by teachers who do not believe that NCLB applies to them. While reading and math skills are very functional skills, the teaching of those skills are simply not a priority in these classrooms. If they are taught it is as splinter skills not as a part of any developmental or grade level curriculum. Instead, the priority is given to inclusion, even though the inclusion is not actual, as opposed to intensive reading remediation or other 1:1 instruction. This is a travesty. From personal experience, I know when those students are provided with appropriate access and modifications to academics that accomodate for their disabilities they can, and do, learn. So to not provide these children with the same opportunities for learning as their peers to which they are clearly entitled is beyond an injustice.

    Schools must fear recourse in order to change their status quo, othewise why would they?

    • So true. Due process is the only recourse. I have had case managers laugh at me and say “take it to due process if you don’t agree” knowing that my child will only be given the “ford” which has been proven not to benefit him when he needs a more expensive program. I have spent thousands of dollars for an advocate and learned the district never intended to follow even the agreed upon programs. They flatly denied anything that required a specialist. It was more cost effective to pay for specialists to tutor outside of school than to go to due process. District would not care if I took them to court for not following IEP, they just need to be in compliance. Where else in life do you do the crime and instead of do the time, simply say we won’t do that anymore with no compensation for the victim.

      • Exactly! Districts have no reason to follow through with whats written in the IEPs, because nobody (state or federal level) will force them to comply. How about “out of compliance, goodbye funding”? That would change the system, and then maybe our kids would have a chance.

  12. Let’s start with full funding and go from there. Having appropriate staffing is the first line of consideration.
    Seriously, the funding issue is where it all begins. Quit putting it off on Medicaid with their “medical necessity” rules which are the other end of the spectrum of educational impact and best practice in LRE.

  13. The Collaboration to Promote Self Determination (CPSD) is a coalition dedicated to advancing economic opportunities for citizens with significant disabilities. The undersigned members of CPSD submit the following comments in response to OSEP question #3.

    Association of People Supporting EmploymentFirst
    Autistic Self Advocacy Network
    Council of Parent Attorneys and Advocates, Inc.
    National Down Syndrome Congress
    National Down Syndrome Society
    Physician-Parent Caregivers
    The Advocacy Institute

    We have identified the IDEA requirements listed below as those most closely related to improved educational results and functional outcomes for infants, toddlers, children and youth with disabilities. However, the foundation that makes it possible for these requirements to be met is the full implementation of IDEA.

    • The natural environment provisions under Part C: In order to prepare children with disabilities to live and learn in the real world, it is important to start them out as early as possible in the same environment they would be in if they did not have a disability.

    •The Least Restrictive Environment provisions that apply from pre-school to age 21 (or older in certain states): This includes the application of LRE to work settings and transition programs (in high school, community and college settings) that a student participates in prior to exiting special education. In addition, the LRE requirement must be combined with the next bullet to ensure that each student gets a Free Appropriate Public Education (FAPE) in the LRE, not just a seat in the classroom.

    • The requirement that students with disabilities participate and make progress in the general education curriculum for the grade in which the student is enrolled: The goals of special education under IDEA, to ensure that students with disabilities are prepared for further education, employment, and independent living, cannot be met without this requirement. In order to ensure that educators have the curricula goals, instructional materials, professional development and assessments they need to enable all students, including those with disabilities, to participate and make progress in the general education curriculum for the grade in which they are enrolled, CPSD supports the implementation of Universal Design for Learning.

    • The participation of all students with disabilities in district and state assessments. Participation in assessments is necessary for accountability and to determine whether student with disabilities are participating in and making progress in the general education curriculum.

    • The provision of services and supports for communication competence. A recent paper published by the National Alternate Assessment Center describes the tragic consequences that occur when school systems fail to provide the services and supports that students need for communication competence. Kleinert, J., Holman, A., McSheehan, M., Kearns, J.F. (2010). The Importance of Developing Communicative Competence ( PDF : 138 Kb) This paper can be found at

    • Transition services and goals to facilitate the student’s movement to post K-12 activities: CPSD wants to emphasize that the focus of these services and goals must be post-secondary education and/or integrated paid employment, as well as independent living and community participation. During the transition years, school systems should be held accountable for providing students with integrated employment and and/or postsecondary education opportunities and the necessary linkages to other agencies, to ensure that the transition to adult life is seamless.

    We must never forget that IDEA is a civil rights statute. OSEP oversight with respect to procedural compliance, as well as outcomes, is necessary to ensure that each child’s rights are respected and that each child has the opportunity to succeed. Some key procedural requirements are:

    • Timely implementation of annual IEPs that are developed with all required team members, including parents as informed and equal partners in the IEP process.

    • Adherence to due process and procedural safeguards requirements, including meaningful efforts to contact and provide information to parents, taking into account their native language and educational level.

    • Timeliness of steps in the special education process and due process, including evaluations and resolutions of complaints.

    • Well stated. Students make progress in the curriculum. This must be documented in the IEP through measurable objectives and objective data, not narratives that place blame upon a student. Parents are equal partners and included in all meetings. Timelines followed. When IDEA reguirements are not met, there must be accountability beyond compliance. LEAs deny students programs and placements because they know parents a) do not have the knowledge to challenge them, or b) given the knowledge, do not have the monetary resources to legally take on a publicly financed school system denying them their request. LEAs, including teachers, CST members, CST supervisors, and school superintendents break the law, not following modifications, timelines, or following other rights under IDEA, because there is no personal responsibility. They must be accountable when students’ futures are depending upon them.

  14. The New Mexico Parent Training and Information Center believes that term “Methodology” and the measurement of implementation should be a priority to look at results for children with disabilities.
    The goals and objectives section of the IEP will become more of a instrumental portion of the IEP document thus including a transparent conversaton about “Methology”. This has been and will continue to be an instrumental part of the IEP to get a sense of how the outcomes, both academic and functional, for children with disabilities will be a determined

    Infortunately, Local Education Agencies have not embraced the “Methodology” discussion during the IEP meeting, which has made monitoring progress a moving target and difficult to discern whether or not the student is set up for success. Most often, the communication to parents is that “we can’t do that” or “we will not put that in the IEP”.

    Methodology should be noted clearly in the IEP and considered a “roadmap” of what is going to happen for the student, how strategies will be measured and what research based or scientific based practices will be used for the student’s growth. Too many times the strategies documented in this part of the IEP is repeated year after year, and children are not seeing much progress or improvement.

  15. FBAs and BIPs for students with challenging behavior.

    Would be helpful if minimum standards and guidelines were established for both, now that we have many year of research available.

  16. -Functional Behavior Assessments and BIPs to encourage positive behavior supports(non-existant in some districts)
    – LRE with support and training(needs to be enforced)
    -Child Find- needs to be monitored
    -Parental involvement in the IEP process
    – Transition planning

  17. 1- LRE provisions
    2- Develop more consistency among states in the implementation of IDEA (complete funding) Full Federal Funding of IDEA
    3-Embed IDEA in ESEA

  18. 1. LRE
    2. True Parent Participation in the IEP process
    3. School Districts Truly Implementing the IEP and all accommodations for every student
    4. Enforce School Districts to Comply with the Law

  19. The national Tourette Syndrome Association recognizes two IDEA requirements as being critical to improving educational results and functional outcomes.
    1. The addition of Tourette Syndrome under the definition of Other Health Impairment has resulted in a major change in attitudes regarding children with Tourette Syndrome by school personnel across the country. This has resulted in a shift from viewing students with TS as having emotional and behavioral disorders to one of having neurological disorders. This has had a positive impact on the manner in which children with highly misunderstood symptoms are treated and supported.
    2. The other IDEA requirement we believe to be critical to positive results for all students is the inclusion of the phrase “positive behavioral interventions.” IDEA requires that appropriate positive behavior interventions and supports be determined during the development of an IEP. IDEA also requires that “In the case of a child whose behavior impedes the child’s learning or that of others, consider the use of positive behavioral interventions and supports, and other strategies, to address that behavior.” We support the U.S. DEPARTMENT OF EDUCATION RESOURCE DOCUMENT THAT DISCOURAGES RESTRAINT AND SECLUSION which states that positive behavior interventions have been demonstrated repeatedly to be effective for all students.

  20. The adversarial nature of the system in place magnifies the incentive gap between schools (trying to prove that they cannot provide a service) and parents (trying to prove that the child needs a service). Often the trio of parent-teacher-child initially hae the best interests of the child in mind – that’s why people go into teaching. That best interest is often very hard to put into words and the outcomes may not be measurable on tests. In cases where education is working well, everyone knows it is working well, because everyone is learning and experiencing rewarding relationships, and there is no need to escalate the situation. This can be true even if the child is not progressing “normally” or not at grade level. It is only when the situation is perceived to be failing that the concept of the best interest warps into things that are supposedly measurable, and accountability starts to be about tests and hours and minutes and other numbers. Under conditions where parents are fighting schools, we tend to lose that more nuanced view of what is a successful day, which ideally is based in nurturing from the heart (the reason we went into teaching, right?) Therefore all questions about state and federal requirements on teaching should preserve the ability of the parent-teacher-child trio to solve problems. Following more externally imposed rules will never, in itself, fix any perceived problem, but those rules can give the people involved the ability to improve a situation from their creative spirit or by changing the people involved. One can never enforce education. Consequently, the factors that the department should evaluate are:

    – Adequate choice – Can parents move their child to another placement? Can they afford to? Can teachers do what they do best? Can teachers try different things? Can students direct their own IEP? Can everyone make exceptions or are they stuck? Are the district regulations so restrictive that problem solving is impossible? Are teachers so afraid of discipline that no creative risks are taken?

    – Adequate transparency – Can parents find out what is really going on?

    – Adequate resources – Is any move to a more restrictive environment accompanied by a commensurate increase in the professional skill applied? Are those teachers more experienced, higher paid, and have fewer students? Do those students with greater temporary needs get those needs fulfilled by the IEP and then return to general ed successfully, or is special ed a trap door to the basement?

  21. 1. Are the right children identified as students with disabilities?
    2. Are the right services being provided to those students?
    3. Are parents able to engage in the process in a meaningful way?

  22. I think some measure of growth across a year with a correlation towards progress in grade level content standards would be helpful. Yes, there are student’s for whom this may be less appropriate, but we can’t keep letting perfection be the enemy of good. There are a lot of students in special education who can come a lot closer to performing on grade level with instruction, compensatory strategies, and accommodations.

    I like the systems thinking that is also voiced in earlier comments teacher training and coaching with performance measures showing improvement in performance with groups of students would also be an indicator. I’d like to see a feedback loop or connection between ESEA subgroup performance and the special education program improvement plans. We have some districts who are creating special education data teams. their role will be to analyze the performance of students on IEP’s for their progress towards ELA and math standards (note this is instructional improvement that goes on outside the IEP process). Is it a good thing to have teams using data to make instructional improvements outside the constraints of the IEP? Monitoring should be able to think about checking for coherence within and across systems for ensuring compliance.

  23. More attention to the programs/services for infants and toddlers is essential. Research shows this is the most important time in a child’s life for learning. It is a time when delays can often be either eliminated or reduced. I would suggest more oversight and required high standards for personnel. The message from OSEP needs to be very clear about these standards. There is too much room for interpretion and some states are not providing appropropriately trained staff for all infants and toddlers. Please remember that if you don’t put enough funding and attention into programs/services for infants and toddlers you will have to put 7 times the funding into attempts to manage or remediate later. Patterns of behavior and brain development primarily happen during the first 3 years. This should be a high priority in terms of attention to quality and funding.

  24. The IDEA requirements most closely related to improved educational results and functional outcomes for infants, toddlers, children and youth with disabilities are:
    Full Funding
    Educational Environments (LRE) Access to instruction to close the Achievement Gap
    Change forumula for MOE – Maintain FAPE, honor innovation and changing practices
    Embed IDEA in ESEA
    Remove RtI from IDEA, put prevention in ESEA

  25. The American Speech-Language-Hearing Association (ASHA) is pleased to have the opportunity to comment on the U.S. Department of Education, Office of Special Education Program’s Results Driven Accountability outreach efforts on this new strategy to shift the balance from a system focused primarily on compliance to one that puts more emphasis on results for children with disabilities. ASHA is the professional, scientific, and credentialing association for more than 150,000 members and affiliates who are audiologists, speech-language pathologists and speech, language, and hearing scientists. More than half of our members work in public schools and have an integral and active role in the school community. Therefore, education is a priority area for the Association. ASHA members who work in a school-based setting provide primary services to over 1.5 million students with speech-language and hearing disabilities (2010, Data Accountability Center). The high incidence of speech-language impairments requires a large and highly qualified pool of speech-language pathologists (SLPs) to meet these students’ needs.

    ASHA is pleased to submit the following comments to be considered in the reframing of OSEP’s accountability system:

    • The original intent of the IEP was to monitor/reflect the outcomes of the child and not to be a compliance tool, which it has also become. Consideration should be given to the separation of the compliance information out of the IEP so its focus remains an outcomes document for the child.

    • IDEA compliance monitoring should involve more than ensuring timelines, forms, and documentation mandates are followed. The following issues should be considered:
    a. Schedules. Specifically, whether schedules reflect time for collaboration among professionals; include adequate planning time; and allow for a variation in service delivery models.
    b. Workload. Ensure reasonable workloads for all staff, both classroom teachers and specialized instructional support (SISPs) staff. A reasonable workload would not only allow professionals to work face-to-face with students, but it would also allow for collaboration, consultation, and time to complete mandated processes.
    c. Intervention models. Determine whether intervention models applied will facilitate student success.
    d. Collaboration. There should be collaboration among all professionals working with students. To what extent it exists? Do general education personnel understand the needs and progress of students with IEPs? Do special educators and SISPs understand the demands of the classroom?
    e. Professional development. Ensure that all staff has been provided with specific and appropriate professional development related to their unique roles and responsibilities.

    • Explore the feasibility of requiring states to develop an electronic educational record, which could include the IEP (not as a compliance tool), similar to what is required in the medical setting with the Health Insurance Portability and Accountability Act of 1996. This electronic educational record would provide:
    – Portability
    – Increased accuracy of data
    – Potentially decrease the paperwork burden experienced by providers in school settings

    • Ensure reasonable workloads for all staff, both classroom teachers and specialized instructional support (SIPPS) staff. Reasonable workloads which take into account all of the various activities and services that educational professionals engage in order to meet the needs of the child and family. These may include collaborating with teachers, parents and staff, developing goals to meet student’s needs, attending IEP and IFSP meetings and completing paperwork to ensure that the child’s program is appropriate. A reasonable workload would not only allow professionals to work face-to-face with students, but it would also allow for collaboration, consultation, and time to complete mandated processes.

    • Recruiting and retaining high quality teaching, administrative, and specialized instructional support staff. Retention is often dependent upon:
    a. Suitability of the work environment
    b. Effective and supportive mentoring
    c. Appropriate professional development opportunities
    d. Reasonable workload
    e. Problem solving systems within the school community that engage all members of the faculty

    • Provide adequate, evidenced-based assessment and teaching materials. All materials need to be related to the common core state standards, be current and applicable to the specific teaching assignment, and easily accessible. There should also be ample opportunity to share resources among staff.

    • When designing systems to assess teacher/ SISPs, ensure multiple measures are employed and results are used to design professional development plans.

    • Systems designed to evaluate student progress also need to include multiple measures, and to account for the variation in the trajectories of student growth, especially students with special needs.

    • A centralized and unified data collection system would be fundamental to ensure accountability as well as reduce redundancy in segmented systems. This support will facilitate enhanced data tracking and further the development of systems that will have the capacity to share key information components both intra- and interstate.

    • The premise of professional development is to provide high quality, discipline specific training to school-wide personnel in their respective fields. In order to safeguard the success of all children, ensure that SISPs are included in the Department’s overall efforts related to preparation, equitable distribution, recruitment, professional development, support, and recognition. We underscore the importance of professional development for teachers and SISPs, especially speech-language pathologists, who instruct children with disabilities as well as provide effective resources to support learning for those children. Specific and targeted professional development opportunities should be provided for the wide variety of school personnel.

    • We encourage the Department to work with Congress to increase funding for education laws and other initiatives, particularly IDEA and ESEA. The expectation that state and local education agencies and their employees can continue to deliver the same or better quality and intensity of services over time without additional funds is unrealistic. Sufficient funding should be allocated for effective and efficient delivery of professional development and personnel preparation, which is an important priority that will produce positive outcomes for children with disabilities. Therefore, we recommend full funding of IDEA and increased funding of ESEA, particularly for engaging special education staff and SISPs in prevention programs such as Response to Intervention.

  26. Education in the Least Restrictive Environment with supports and services for every student first. This is Inclusion with Universal Design and differentiated instruction/assignments to ensure access to the curriculum. The State compliance offices need to be held accountable and in turn need to hold the districts accountable. They should work with the OCR to end the discrimination and bullying of students with disabilities by teachers and other staff. Districts must be accountable for having highly qualified staff working with students.

  27. Making sure states comply with the law. Delaware has run rampant in not providing education for special ed need students. And when they do it is always the same IEP “Chunk assignments, preferred seating, allow longer time to complete work….” they do not individualize the student or even care, and as states above, their ultimate goal is to move the student to an “alternative school” where the expelled students are sent. In addition, parents should be notified 504s and IEPs are available, make the schools publicize that, most parents don’t even know they exist and they are kept hidden in Delaware. A special ED administrator should be required at every meeting because I have found the IEP teams are made up of people with no special education training. Require mandated hours of teacher training so they can recognize a disability instead of just labelling it laziness. Put penalties in place for not complying with Child Find and monetary penalties for not complying with IEPs and not writing appropriate IEPs. You have hard work ahead of you beause shools are taught to say no to IEPs and no teach is allowed to vote against what the principal votes. We should not be forced to secure attorneys and file lawsuits in order to get our children, the future of our country, adequate education. Just FYI, my son is 17 and doesn’t know his times tables and the school response is the math teacher says he does so he does, end of conversation. My passion has actually become advocating for these kids that have learning disabilities and the schools label as bad and just want then out. If you can help me in Delaware, I would welcome you contacting me.

    • I have to agree with you Chris. I am from Delaware also and if it were not for the parents fighting with the school to get out children, alot of our children would not get the help they need or what we can get. I know myself personally, I have to fight with the school because they automatically want to “write” my son up for anything instead of trying to find out what the problem is. My son has Asperger’s Syndrome and Sensory Problems and they think because he can talk, then he is fine. They think he is just be lazy or only wants to do what he wants to do. They are always telling me that they don’t have the “time” to do this because they have other students. When he was in elementary school, he was in a self-contained class with 10 students at the most and at least 3 teachers in there at all times. I believe they all teachers (inlcuding general teachers), administrators, principals, school staff, etc. needs training at least 2 times a year on all disabilities so they can spot and help students. Alot of the ideas that I have given them can be used for typical students and they could incorporate the ideas for everyone. Even though this is a federal mandate, the schools act as if they can do what ever they want. That is bad.

  28. From an APR Reporting perspective, I think that a focus on Graduation, Dropout, Discipline, Statewide Assessments, and Secondary Transition should be the primary foci for all students with IEPs (and those without IEPs). If these Indicators are showing positive results for students with IEPs, I think those are the over-arching markers of effective schools and practices.

    I also think there should be a more intentional connection with District and School Improvement Teams and Plans. In my experience, special eduators are often not represented on these Teams and, therefore, inputs from these educators are not considered (much less incorporated) into these Plans. To affect real and lasting change (read: IMPROVEMENT) in schools and districts and, subsequently, on ALL student achievement, we need to have a greater, more inclusive perspective on District and School Improvement Teams and Plans.

  29. As an educator in Special Education for over 40 years, I was excited with IDEA (2004) requirements to have some type of intervention before a child is considered
    for Special Education placement. My career was in the state of Pennsylvania and
    I am most disappointed that this State doesn’t enforce this requirement. There
    are too many minorities placed in Special Education because they haven’t been
    taught. Reponse to Intervention would have been a tremendous help to curtail
    these numbers. In honesty, I don’t feel that OSEP has done a good job in monitoring
    the State in which I spent 40 years working. The number of class action lawsuits against the Pennsylvnia Department of Education gives credence to this statement. You have allowed this State to do its own thing. Better monitoring of States could be a good start for refocusing on the new IDEA Guidelines.

  30. The number one priority from my perspective would be the provision of technical assistance in order to:
    -Help states simplify and make more practical the performance plan data reporting requirements
    -Help states simplify and make more practical IEP and other procedural documentation requirements
    -Develop more consistency among states in the implementation of IDEA

    Number 2, Increase funds for and improve dissemination of peer reviewed research and professional development opportunities under Part D.

    Number 3, Enhance and enforce requirements for other state agencies to participate in the provision of services while a student is school age and when a student transitions out of the school aged environment.

  31. 1- Using evidence based research with frequent progress monitoring.
    2- LRE- get rid of the continuum. We know what 30 years of research says. As long as there is someplace to send “those kids”, you can be certain administrators will find some way to justify it. Any “time away” from general education classroom needs to be 100% direct 1:1 instruction.
    3- Enforce actual compliance with the law. Whether you have a beautiful IEP that the school refuses to implement or the school has no regard for the law or for writing an acceptable IEP, you can write 1000 complaints, have the school found noncompliant, and what happens? The school has to submit a written assurance to not do it again. Gasp- a written assurance, will that change anything? Will my kid get back what she missed out on? The only lesson the current compliance procedures teaches is for parents to not waste your time writing complaints. Even if you win, you win nothing. It has to be monetary and there has to be compensatory services for every violation.

    • I agree with you on the enforcement of the laws and rules in place. Since the schools know there really is no enforcement of the laws through the complaint process the schools really have no incentive to comply with the laws and they get away with non-compliance. Until the laws are enforced and ACTUAL consequences put into place schools will not comply.

    • 1. EBR with frequent monitoring within the districts by outside federal or state agencies that fund said districts.
      2.Of course districts will find ways of justification for not providing a FAPE, because they can-they do. Usually there is no recourse for accountability against such instances where its the students “performance” levels that are the supposed indication and weighed standards of state performance levels in said districts/schools.
      3. Very well said and profound in accuracy for the reality of what it means to attempt to get implementation according to Special Education Disability related “laws” for such students. IEPS sound good, look good, but when recommendations are even partially implemented or not necessarily carried out accordingly, the students are the ones whose educational needs are not met. To find a school non compliant, and or to attempt mediation or obtain outside legal assistance no matter how much correspondance with school, teachers, etc; or even complaints filed by parents …the IDEA, the NCLB, and other related laws mean zilch to the families who cannot pursue any actions due to lack of financial or other resource. What does that mean for the students? What does it mean for the parents? It means that the No Fear Act or fear of retaliation when up against a school or district, overshadows the necessity of providing, obtaining and receiving an education with or without so called compliance. Schools are supposed to also provide alternatives with lateral educational provisions in or out of district. That costs them $$$ and its money they either don’t have or don’t want to pay. Parents often have to pull students out and place them elsewhere on their own dime.
      Your right, complaining does nothing and the schools and districts know it so they drag it along until those students are aged out of the school system, and the districts repeat the substandard methods of lack in differential, inclusion, or any IEP implentations and the performance levels are what matters so they can get funded. Sigh Sigh gasp.

  32. While perhaps not a direct IDEA requirement, I see RtI and PBIS initiatives that are implemented with fidelity as yielding data that indicates improved educational results and functional outcomes for all students with learning/behavior needs.

  33. Use of evidence-based practices in the IEP
    Implementation of the IEP
    Time spent accessing the general education curriculum (not just in the lunchroom, music and gym either)
    Gains in reading and math for students with disabilities each year being equal to or greater than students without disabilities
    Parent involvement in activities that strengthen their child’s performance at school, not just attending school functions but reading to their child, practicing spelling etc.

  34. Having the school or district prove it is implementing RTI with fidelity and therefore has acceptable data to show positive academic achievement of students with a disability.

  35. 1) LRE provisions
    2) 3 is 3 (services beginning at 3rd birthday)
    3) services required while in disciplinary settings over 10 days
    4) parent participation in IEP process
    5) inclusion in state and federal accountability systems as a student (sub) group

  36. 300.43 Transition Services
    The requirements in this section require a “coordinated set of activities…designed to be within a results oriented process.” If we are to consider both educational results and functional outcomes for our youth, then we must look at how we are preparing them for the world outside of school. For students with disabilities, it will require a coordinated set of activities and effort among many entities: student, teacher, parents, social worker, physician, community service providers, etc. to make the transition in to the adult world. All parties must work together to support the student as he/she navigates into the world that is not like the school environment they are comfortable in. In order to know which way to assist them, we have to take into account their individual strengths, academic abilities, functional achievement, and interests. The requirements in this section directly link to improved educational results and functional outcomes, especially for the transition aged youth.

  37. Colorado children with deafblindness age birth to 21 have been the beneficiary of federal funding directed toward the state deafblind project in numerous ways. Direct child and IEP team training, parent education seminars, one on one parent support and parent support group activities, parent matching, paraprofessional training and annual professional summer institutes attended by educators that work directly with deafblind students have had a huge impact on my child (now age 15) and other children with this diagnosis and that of severe disabilities. Though difficult to measure, the outcomes are significant and this extremely low incident disability would be lost among the many other disabilities IDEA impacts were it not for the targeted funding and services delivered through state DB projects. As a former employee of our state project, as a consultant with Anchor Center for Blind Children, but primarily as a mother of a young adult, the impact of funding through IDEA for children with deafblindness is significant and should be continued.

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