Learn Your Special Education Laws, Special Education Rights, and Share IEP Goal Ideas

Apr 12
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by Jess

In drafting the provisions of IDEA, our nation’s special education law, Congress clearly contemplated that, at times, there would be disagreements between parents of children with disabilities and the school districts providing special education and related services to their children.

While it is expected that parents and school personnel will work in partnership to ensure children with disabilities are provided appropriate services, there are times when the child’s parents and school officials cannot reach consensus on what constitutes a free appropriate public education (FAPE) for an individual child. When such disagreements occur, parents and school districts can turn to IDEA’s procedural safeguards and dispute resolution options. .

IEP Review

Under IDEA, the school system is responsible for determining when it is necessary to conduct an IEP meeting, and the child’s IEP team is responsible for reviewing the child’s IEP periodically, but not less than annually, and revising the child’s IEP, if appropriate. In addition, the parents of a child with a disability have the right to request an IEP meeting at any time.

What kinds of disputes might be resolved through an IEP review meeting? After the annual IEP review has taken place, if a parent has concerns about his or her child’s rate of progress, the appropriateness of the services provided to the child, or the child’s educational placement, it would be appropriate for the parents to request that the IEP team reconvene. At that meeting, the parent and public agency can discuss the parent’s concerns and, hopefully, as collaborative members of the IEP team, work toward a solution that is agreeable to all.

The solution doesn’t have to be permanent. It’s not uncommon for IEP teams to agree on a temporary compromise—for example, to try out a particular plan of instruction or classroom placement for a certain period of time that the child’s IEP is in effect. During (or at the end of) that period, the school can check the child’s progress. Team members can then meet again and discuss how the child is doing, how well the temporary compromise addressed the original concern, and what to do next. The trial period may help parents and the school come to a comfortable agreement on how to help the child.

Does the entire team have to be there? Not necessarily. A new provision in the 2004 Amendments to IDEA allows changes to be made to the child’s IEP, following the annual IEP team review, without convening the full IEP team [§300.324(a)(4)]. Simply stated, the parent and the public agency may agree not to convene an IEP team meeting for the purpose of making changes to the child’s IEP. We bring this up because, in some cases, the parties may be able to resolve a disagreement by conducting a review of the child’s IEP and amending it as appropriate, without convening the entire IEP team. For more information on the conditions that apply to using this option, please visit Meeting Without Meeting.

What are the benefits of resolving a dispute through an IEP review? Because parents and the public agency are partners in ensuring the child is provided an appropriate education, and sometimes will be working together for many years—in some cases, the child’s entire school career—it is in everyone’s best interest, especially the child’s, that the IEP team members communicate with one another, respectfully and honestly.

Facilitated IEP Meeting

Another informal approach to resolving disputes between parents and schools is IEP facilitation.

IEP facilitation is not mentioned in IDEA and is not one of the dispute resolution options described in the law’s procedural safeguards. However, it is being used to help IEP teams reach agreements in special education decision-making. There are probably others as well, but IEP facilitation is an approach on the rise.

Some SEAs provide parents and school districts with the option of facilitated IEP meetings. When relationships between parents and schools are strained, facilitated meetings may be beneficial. It’s important to remember, though, that this approach is not required or addressed under IDEA and may not be available in your school district.

What is a facilitated IEP team meeting? A facilitated IEP team meeting is one that includes an impartial facilitator. The facilitator is not a member of the IEP team but, rather, is there to keep the IEP team focused on developing the child’s program while addressing conflicts as they arise.

The facilitator can help promote communication among IEP team members and work toward resolving differences of opinion that may occur concerning the provision of a free appropriate public education to a child. The facilitator helps keep the IEP team on task so that the meeting purposes can be accomplished within the time allotted for the meeting.

What are the benefits of having a facilitator for an IEP team meeting? The IEP facilitator can help support the full participation of all parties. The facilitator does not impose a decision on the group; the facilitator clarifies points of agreement and disagreement and can model effective communication and listening for the IEP team members. When disagreements arise, the facilitator can help encourage the members to identify new options. Most importantly, the impartial facilitator ensures that the meeting remains focused on the child.

Do all school districts have to offer facilitated IEP team meetings? No. IDEA does not address IEP facilitation. This means that there is no requirement in IDEA for school systems to provide an impartial facilitator for IEP team meetings. While the use of IEP facilitation has become more popular, facilitators may not be available in all school districts and are not required.

The State Complaint Process, Summarized

A state complaint is very much what it sounds like: a letter written to a official state agency to report a violation or problem. Within special education, it’s one of several procedural safeguards available under IDEA to resolve disputes between parents of children with disabilities and the school systems responsible for educating those children.

To whom does a person write? Why would a person write? What must he or she include in the complaint? What happens then? The answers to these questions are the heart and soul of the state complaint procedure–and they are largely determined by the requirements of IDEA. States must follow IDEA’s regulations when they develop and implement the state complaint procedures in the state.

While many details exist in the process and are important to know, a quick summary of the state complaint requirements as a dispute resolution option would include these major points:

Any individual or organization may file a complaint alleging that the State or other participating agency has violated a requirement of the IDEA.

An individual wishing to file a complaint must provide a copy of the complaint to the school district or public agency serving the child at the same time the complaint is filed with the SEA. In some states, the SEA provides for the filing of a complaint with a public agency and retains the right to have the SEA review the public agency’s decision on the complaint.

Complaints must be written and signed and must contain a statement that a public agency has violated a requirement of Part B of IDEA or its implementing regulations and the facts upon which the statement is based.

The complaint must allege a violation that occurred not more than one year prior to the date that the complaint is received.

The SEA is obligated to resolve such a complaint within 60 calendar days from the date of receipt, unless exceptional circumstances exist with respect to the complaint.

The complainant (the individual or organization filing the complaint) must be given the opportunity to submit additional information, either orally or in writing, about the allegations in the complaint.

The SEA must conduct an on-site investigation, if it determines such an investigation to be necessary.

The SEA must review all relevant information and make an independent determination as to whether the school system has violated or is violating a requirement of the law.

The SEA must then issue a written decision that addresses each of the allegations in the complaint and contains the findings of fact and conclusions, as well as the reasons for the SEA’s final decision.

Your State’s Complaint Procedures

As was mentioned above, working from IDEA’s requirements, states develop and implement their own state complaint procedures (which still must address the IDEA requirements at 34 CFR §§300.151-153). Therefore, it’s helpful to know what state complaint procedures exist in your state.

You can find out by contacting the Director of Special Education at your SEA and requesting information about these procedures. Additional clarification may also be available about how mediation, the due process procedure, and the State complaint process operate as distinct and separate remedies. Visit the website of your SEA (or call, or email) to find out more about your state’s complaint procedures.

You may also want to seek advice from the Parent Training and Information Center (PTI) or the Protection and Advocacy (P&A) Agency in your state.

 

Mediation, Summarized

Mediation is a process conducted by a qualified and impartial mediator to resolve a disagreement between a parent and a public agency regarding any matter arising under Part B of IDEA, including matters arising prior to the filing of a due process complaint. The law requires that the mediation process meet certain, specific conditions, as follows:

Mediation must be voluntary on the part of both parties.

Mediation may not be used to deny or delay a parent’s right to a due process hearing or to deny any other right under Part B of IDEA.

The state must bear the cost of the mediation process.

Each session in the mediation process must be scheduled in a timely manner and held in a location convenient to the parties in the dispute.

Mediation must be conducted by a qualified and impartial mediator who is trained in effective mediation techniques.

The state must maintain a list of individuals who are qualified mediators and knowledgeable in laws and regulations relating to the provision of special education and related services.

Mediators must be selected on a random, rotational, or other impartial basis. [§300.506(b)(3)]

The mediator must not be an employee of the SEA or the school district involved in the education or care of the child and cannot have a personal or professional interest that conflicts with his or her objectivity [§300.506(c)]. IDEA is very clear that the mediator is not an employee of the LEA or SEA solely because he or she is paid by the agency to serve as a mediator.

The public agency must make sure that its representative participating in mediation has the authority to enter into a binding agreement on its behalf [§300.506(b)(6)(ii)].

If the parties resolve the dispute through the mediation process, they must execute a legally binding agreement that states the resolution and is signed by both the parent and a representative of the agency who has authority to bind the agency [§300.506(b)(6)]. A written, signed mediation agreement is enforceable in any state court of competent jurisdiction (a court that has the authority under state law to hear this type of case) or in a district court of the United States.

 

Due Process Complaints, Summarized

A due process complaint is a filing by a parent or a public agency on matters related to the:

  • identification;
  • evaluation; or
  • educational placement of a child; or
  • provision of FAPE to the child.

Such a complaint must meet the content requirements in §300.508(b) (listed below).

Whenever a due process complaint is received, the parents and local educational agency (LEA) involved in the dispute must have an opportunity for an impartial a due process hearing [§300.511(a)]. That’s why filing a due process complaint is the first step in the process that may lead to a hearing, a formal proceeding held to resolve conflicts between parents and schools.

Some basic things to know about due process complaints include:

Complaints must be written, signed, and include a statement that a public agency has violated a requirement of Part B of IDEA, as well as the facts upon which the statement is based.

Complaints must include specific information. A party may not have a hearing until the party (or the attorney representing the party) files a due process complaint that includes this information [300.508(c)].

The party filing a due process complaint must provide a copy to the other party and forward a copy to the state educational agency (SEA) [§300.508(a)(2)].

The information contained in the due process complaint must be kept confidential [§300.508(a)].

There’s a time limit for filing a due process complaint.

Information the Complaint Must Include

As spelled out by IDEA at §300.508(b), the due process complaint must contain specific information in order to be considered “sufficient.” This information is:

  • the child’s name;
  • the address of the child’s residence;
  • the name of the school the child is attending;
  • a description of the nature of the child’s problem relating to the proposed action or refusal that’s causing the conflict, and facts upon which the complaint is based, and
  • a proposed resolution of the problem to the extent known and available to the person filing the complaint.

If the child is homeless, as defined in the McKinney-Vento Homeless Assistance Act, the complaint must include available contact information for the child—instead of the address of the child’s residence—and the name of the school the child is attending. [§300.508(b)]

Who determines that the complaint contains all the required information?

A due process complaint is deemed “sufficient” unless the party receiving the due process complaint notifies the hearing officer and the other party in writing, within 15 days of receiving the due process complaint, that the notice does not meet the requirements [§300.508(d)(1)].

Within five days, the hearing officer must then make a decision based on the face of the due process complaint whether it is legally sufficient and immediately notify the parties in writing of the determination. If the hearing officer rules that the due process complaint is not sufficient, the decision will identify how the notice is insufficient so that the filing party can amend the notice, if appropriate.

If the due process complaint is determined to be insufficient and is not amended, the due process complaint could be dismissed (71 Fed. Reg. 46698).

Time Limits on Filing a Complaint

Due process complaints must allege a violation that occurred not more than two years before the date the parent or public agency knew or should have known about the alleged action that forms the basis of the due process complaint. However, if the state has an explicit time limitation for requesting a due process hearing under Part B, the complaint must be filed in the time allowed by the state’s law.

 

The Resolution Process, Summarized

The resolution process is new in IDEA, so not much is known about it yet, except how it is described within the law and its implementing regulations. States are busy implementing this newest addition to IDEA’s dispute resolution options; as time goes by, we’ll learn more about state policies and local implementation. It’s important to know that, unlike mediation, the resolution process is not voluntary. IDEA requires it, as described at §300.510. This summary will take a look at the basic details of how the resolution process is expected to work.

Timelines

The LEA must convene the meeting within 15 days of receiving a parent’s due process complaint, and before convening a due process hearing. There are only two circumstances in which the resolution meeting may be skipped:

  • if both parties agree in writing to waive the meeting, or
  • if both agree to use the mediation process instead.

Interestingly, convening a resolution meeting is not required if the public agency files the due process complaint.

Participants

IDEA states that the parents and relevant member or members of the IEP team who have specific knowledge of the facts identified in the parent’s due process complaint. The group must include a representative of the public agency who has decision-making authority on behalf of that agency [§300.510(a)(1)].

And who decides which IEP team member(s) are “relevant?” IDEA is very clear about this: The parent and the LEA together determine the relevant member or members of the IEP team that will attend the resolution meeting.  Furthermore, “relevant” members will be those with “specific knowledge of the facts identified in the parent’s due process complaint” [§300.510(a)(1)].

Wondering if attorneys may be involved in the resolution meeting? Simple answer: The LEA’s attorney may not be included in the meeting unless an attorney accompanies the parent [§300.510(a)(1)(ii)].

Wondering if participants must keep the information shared in a resolution meeting confidential? The answer is: No. IDEA regulations for the resolution process do not mention confidentiality at all.

Failure to Participate

What happens if one of the disputing parties (parent or LEA) fails to show up for, and participate in, the resolution meeting? Or if the LEA doesn’t follow through on its obligation to schedule the meeting?

Provided that the parents and LEA haven’t agreed in writing to waive the resolution meeting, what happens when either fails to participate in the meeting will depend on which party we’re talking about.

  • When parents fail to participate: The LEA can ask the hearing officer to dismiss the parents’ due process complaint.
  • When the LEA fails to schedule the meeting or participate in it: Parents may seek the intervention of the hearing officer to begin the timeline for a due process hearing [§300.510(b)(5)].

Results of the Meeting

If a resolution to the dispute is reached at the resolution meeting, the parent and the LEA must enter into a legally binding, written agreement [§300.510(d) and (e)]. That agreement:

  • must be signed by the parent and a public agency representative with “the authority to bind the agency”;
  • is enforceable in any state court of competent jurisdiction (a state court that has authority to hear this type of case) or in a district court of the United States; and
  • may be voided by either party (the parent or the LEA) within three business days of the date the agreement was signed.

If the parents and the LEA fail to reach an agreement during the resolution process (or agree to waive the process altogether), the next step will be the due process hearing, a more formal, often costly legal proceeding.

The Next Set of Timelines: Due Process Hearings

A different timeline attaches to due process hearings: 45 days to reach a decision in the hearing. This timeline starts ticking the day after one of the following events occurs:

  • Both parties agree in writing to waive the resolution meeting;
  • Both parties agree in writing that no agreement is possible; or
  • Both parties agree in writing to continue mediation at the end of the 30-day resolution period, but later, the parent or public agency withdraws from the mediation process. [§300.510(c)(3)]

 

The Due Process Hearing, Summarized

There are times when the parties have been unable or unwilling to resolve the dispute themselves, and so they proceed to a due process hearing. There, an impartial, trained hearing officer hears the evidence and  issues a hearing decision. During a due process hearing, each party has the opportunity to present their views in a formal legal setting, using witnesses, testimony, documents, and legal arguments that each believes is important for the hearing officer to consider in order to decide the issues in the hearing. Since the due process hearing is a legal proceeding, a party will often choose to be represented by an attorney.

Due process is a longstanding approach within IDEA to resolving disputes. Filing a due process complaint is the first step in the process that may lead to a due process hearing. A due process hearing, like many legal proceedings, involves multiple steps that must be followed in order for a party to have his or her case heard before a hearing officer.

What rights does each party have in a due process hearing?

IDEA gives the disputing parties specific rights in a due process hearing. These rights are found at §300.512 and include the right to:

Be accompanied and advised by counsel and by individuals with special knowledge or training with respect to the problems of children with disabilities, except that whether parties have the right to be represented by non-attorneys at due process hearings is determined under State law.

Present evidence and confront, cross-examine, and compel the attendance of witnesses.

Stop any evidence from being introduced at the hearing that has not been disclosed to that party at least five business days before the hearing.

Get a written (or, at the option of the parents, electronic) verbatim record of the hearing.

Get a written (or, at the option of the parents, electronic) findings of fact and decisions. [§300.512(a)]

Disclosure | At least five business days before a hearing conducted under §300.511(a), each party must disclose to all other parties all evaluations completed by that date and recommendations based on the offering party’s evaluations that the party intends to use at the hearing [§300.512(b)]. The hearing officer may prevent any party that fails to comply with this requirement from introducing the relevant evaluation or recommendation at the hearing without the consent of the other party.

Additional parent rights | IDEA gives parents additional rights in due process hearings. As identified at §300.512(c), these are the right to:

  • have the child who is the subject of the hearing present,
  • open the hearing to the public, and
  • have the record of the hearing, and the findings of fact and decisions, provided to them at no cost. [§300.512(c)]

The Role of the Hearing Officer

It’s the hearing officer’s job to weigh the merits of each party’s argument, evidence, and witnesses, in light of what IDEA and state law require, also bearing in mind relevant federal and state regulations pertaining to the Act and legal interpretations of the Act by federal and state courts.

The hearing officer must possess the knowledge and ability to conduct hearings in accordance with appropriate, standard legal practice. IDEA includes provisions at §300.511(c) that describe the minimum qualifications that a hearing officer must have.

What is the timeline for reaching a decision in the due process hearing?

The State Education Agency (SEA) or the public agency directly responsible for the child’s education (whichever agency is responsible for conducting the hearing in your State) must ensure that, not later than 45 days after the 30-day resolution period expires (or any of the adjustments made to that period), a final decision is reached in the hearing and a copy of the decision is mailed to each of the parties. The hearing officer may grant specific extensions of this time period at the request of either party.

 

Can the hearing officer’s decision be appealed?

Yes, it can be. But, as stated above, if it’s not appealed, the decision made by the hearing officer is final.

The specific actions required to appeal the hearing officer’s decision depend on what type of due process system (one-tier or two-tier) an SEA has, as described below.

Appealing in a one-tier system | In states using a one-tier system for due process hearings, the SEA is the entity that conducted the initial due process hearing and issued the decision. This means that, in a one-tier system, a state-level review of a hearing decision is not available. If one of the parties disagrees with the decision, the only “appeal” will be for the party to bring a civil action in an appropriate state or federal court. This will be discussed more fully after we take a look at appealing in a two-tier system.

Appealing in a two-tier system In states that have a two-tier system, a state-level appeal to the SEA is available. This is because the initial due process hearing was conducted by the public agency directly responsible for the child’s education, so appeal to the SEA exists as an option. This is a longstanding provision of IDEA.

In such cases, the SEA must conduct an impartial review of the findings and decision in the hearing, as specified at §300.514(b). According to these provisions, the review conducted by the SEA:

  • is based on examining the entire hearing record;
  • must ensure that the procedures used in the original due process hearing were consistent with due process requirements; and
  • may involve the SEA asking for additional evidence, if necessary, and holding a hearing to receive it.

If a hearing is held to receive additional evidence, the rights in §300.512 apply. These were discussed earlier and include the right to be accompanied and advised by counsel; the right to confront, cross-examine, and compel the attendance of witnesses; and so on.

IDEA uses slightly different language in referring to where and when hearings and reviews that involve oral arguments must be conducted. With respect to scheduling IEP meetings, the phrase IDEA uses is “mutually agreed on time and place.” The phrase IDEA uses with respect to scheduling hearings and reviews involving oral arguments is “reasonably convenient to the parents and child involved” [§300.515(d].

Why the difference? Why is there no requirement that the parties mutually agree to the hearing time and place?

In the Analysis of Comments and Changes, the Department responded to a public comment seeking clarification about the standard for determining the time and place for conducting hearings, stating:

The Department believes that every effort should be made to schedule hearings at times and locations that are convenient for the parties involved. However, given the multiple individuals that may be involved in a hearing, it is likely that hearings would be delayed for long periods of time if the times and locations must be ‘‘mutually convenient’’ for all parties involved. (71 Fed. Reg. 46707)

Okay, then, all the evidence is in. What happens next? As might be expected, the reviewing official must make an independent decision and issue findings of fact and decisions, providing a copy to both parties. Under §300.512(c)(3), the parent has the right to a copy of the findings of fact and decision on appeal in written or electronic form, at the parent’s option, at no cost.

Are there timelines for issuing a final decision in the review?

Yes. The SEA must ensure that, not later than 30 days after receiving a request for review, a final decision is reached in the review and a copy of the decision is mailed to the parties. This requirement is stated at §300.515(b). The 30-day timeline may be extended by the reviewing officer at the request of either party, as specified at §300.515(c).

Can the SEA’s decision be appealed?

Suppose that one of the parties is still not satisfied with the decision? Can the SEA’s decision be appealed? Yes, by bringing a civil action.

This is the same dispute resolution process mentioned just a bit ago when we were talking about one-tier due process systems where there is no right to appeal to the SEA for any party aggrieved by the decision in the initial hearing.

Who can bring a civil action, and what’s involved?

First, let us re-state, for clarity, who may bring a civil action. Under §300.516(a), a civil action may be brought by:

  • any party aggrieved by the decision in a initial due process hearing in a one-tier State (where there is no right to appeal to the SEA); and
  • any party aggrieved by the decision in the SEA-level review in a two-tier State (where an appeal of the initial hearing decision can be made to the SEA).

The civil action may be brought in a State court of competent jurisdiction (a State court that has authority to hear this type of case) or in a district court of the United States without regard to the amount in controversy.

Under a new provision in the statute and regulations, there is now a timeline for filing a civil action. Under §300.516(b), in a one-tier system, the party must bring the civil action within 90 days of the date of the hearing officer’s decision (or, if the state has established a different timeframe, within the time allowed under the state’s law). In a two-tier due process system, the civil action must be brought within 90 days from the date of the state review official’s decision (or, if the state has established a different timeframe, within the time allowed under the State’s law). It’s important to note that the public agency must, through the procedural safeguards notice, notify parents of the time period to file a civil action [§300.504(c)(12)].

In any civil action, the court receives the records of the administrative proceedings and hears additional evidence at the request of either party [§300.516(c)].

The court bases its decision on the preponderance of the evidence and grants the relief that the court determines to be appropriate [§300.516(c)(3)]. IDEA provides that the district courts of the United States have the authority to rule on actions brought under Part B of the IDEA without regard to the amount in controversy [§300.516(d)].

It’s also important to note that IDEA sets forth a “rule of construction” at §300.516(e) that pertains to civil actions. Under this rule of construction, a dissatisfied party may have remedies available under other laws that overlap with those available under the IDEA. However, in general, to obtain relief under those other laws, the dissatisfied party must first use the available administrative remedies under the IDEA (i.e., the due process complaint, resolution meeting, and impartial due process hearing procedures) before going directly into court (U.S. Department of Education, 2009, pp. 34-35).

Do parents have the right to represent themselves in an IDEA case in federal court?

Yes. Generally, federal law allows any person to represent themselves in federal court to protect their own federal rights.   In Winkelman v. Parma City Sch. Dist. (2007), the U.S. Supreme Court held that non-lawyer parents of a child with a disability may represent themselves pro se (i.e., without an attorney) in federal court, because IDEA grants parents independent, enforceable rights that include the entitlement to a free appropriate public education (FAPE) for their child.  Because parents have these rights under IDEA, they can bring and defend IDEA claims on their own and without an attorney in federal court.

May other individuals who are not attorneys help parents in a due process hearing and recover fees for their services?

The question naturally arises as to whether parents are entitled to recover fees for expert services. The straight answer: No.

The details: The U.S. Supreme Court decided this matter in Arlington Cent. Sch. Dist. Bd. of Educ. V. Murphy(2006). In that case, the court held that section 1415(i)(3)(B) of the statute, which authorizes courts to award reasonable attorneys’ fees to parents who are prevailing parties in actions or proceedings brought under the IDEA, does not authorize recovery of fees for experts’ service.

References

Arlington Cent. Sch. Dist. Bd. Of Educ. v. Murphy, 548 U.S., 126 S.Ct. 2455 (2006). (The decision is available online at: http://www.law.cornell.edu/supct/html/05-18.ZO.html)

Harnett County, North Carolina. (n.d.) Legal glossary: A guide to commonly used legal terms. Retrieved on June 15, 2007, at http://www.harnett.org/clerk/legal-glossary.asp

Kerr, S. (2000, September). Special education due process hearings. Retrieved June 15, 2007, at www.harborhouselaw.com/articles/dp.kerr.htm

National Center for State Courts. (2001). English legal glossary. Retrieved on June 15, 2007, but is currently being revised. Visit the NCSC at: http://www.ncsc.org/

O’Reilly, F. (2003, April). Dispute resolution: Year 1 survey findings and Year 1 and 2 focus study findings. Paper presented at the annual meeting of the IDEA Part B Data Managers, Arlington, Virginia.

Shaffer v. Weast, 546 U.S. 49 (2005). (The decision is available online at: http://www.law.cornell.edu/supct/html/04-698.ZO.html)

U.S. Department of Education. (2009, June). Model form: Procedural safeguards notice. Washington, DC: Author. (Quote from pp. 34-35. Available online at: http://idea.ed.gov/download/modelform_Procedural_Safeguards_June_2009.pdf)

Winkelman v. Parma City Sch. Dist., 127 S.Ct. 1994 (2007). (Read all about it at: http://www.abanet.org/publiced/preview/briefs/pdfs/06-07/05-983_Petitioner.pdf)

Visit CADRE!

We also highly recommend visiting CADRE, the National Center on Dispute Resolution in Special Education, where you’ll find a wide range of materials in English and Spanish to help you understand how to resolve disputes in special education.

Find CADRE at: http://www.directionservice.org/cadre/

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