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From http://www.ldadvocates.com/Parent_Counseling_and_Training_Services_Guide.htm .
Parent Counseling and Training Services Guide
Produced in Partnership with LRP Publications, and The Mountain Plains Regional Resource Center, A program funded by the Office of Special Education Programs (OSEP), U.S. Department of Education 2005
Parent Counseling and Training Services Guide
The Parent Counseling and Training Services Guide was produced in partnership among the following:
The Mountain Plains Regional Resource Center (MPRRC) at Utah State University, a U.S. Department of Education, Office of Special Education funded project. The MPRRC provides technical assistance in special education to 10 States and the Bureau of Indian Affairs. The MPRRC Web site is www.usu.edu/mprrc
LRP Publications (www.lrp.com), of Palm Beach Gardens, Florida, is the national leader in special education legal case reports, newsletters, pamphlets, books, videos, and more. LRP?s hallmark publications include the Individuals with Disabilities Education
Law Report® and The Special Educator®. On the Internet, LRP?s Special Education Connection Web site (www.specialedconnection.com) is a one-stop source for news, practical advice, best practices, tips, case decisions, chat rooms, e-mail bulletins, and much more. LRP also provides top-quality training and educational development seminars, conferences, and symposiums through its Conference Group, including the National Institute on Legal Issues of Educating Individuals with Disabilities, attended by thousands of special education directors, administrators, school psychologists, attorneys, and others each year.
Steven E. Lake, Esq., is Editorial Director of Special Education Products at LRP Publications. He is the author of the Top 10 IEP Errors: How to Avoid Them, How to Fix Them; Separating Church and State: The Challenges of Special Education in Parochial Schools; IEP Procedural Errors: Lessons Learned, Mistakes to Avoid; and Alternative Schools: Legal Guidance for Serving Special Education Students. Mr. Lake has a B.A. from the University of Connecticut and a J.D. from California Western School of Law, where he served on the editorial board of the Law Review. He is admitted to the California and Massachusetts bars. Parent Counseling and Training Services Guide
John W. Norlin, Esq., is LRP Publications? legal editor for education ancillary products. He is the author of Identify, Locate and Evaluate: Child Find under the IDEA and Section 504; Courts Divided: The Debate Over Section 1983 Claims for IDEA Violations; Beyond FERPA: A Guide to Student Records Under the IDEA; The No Child Left Behind Act: Your Guide to Key Components; Aversives in the Classroom: What Are the Legal Limits; and The Special Educator Desk Book. He is also the editor of What Do I Do When . . . The Answer Book on the Family Educational Rights and Privacy Act. Prior to joining LRP Publications, Mr. Norlin practiced law in Palm Beach County, Florida. He has a J.D. from the University of Michigan Law School.
John Copenhaver is the Director of Mountain Plains Regional Resource Center, a U.S. Department of Education, Office of Special Education funded project, providing technical assistance in special education to the following States: Arizona, the BIA, Colorado, Kansas, Montana, Nebraska, New Mexico, North Dakota, South Dakota, Utah, and Wyoming.
Jack L. Rudio, Ed.D., is a Program Consultant for Mountain Plains Regional Resource Center; formerly an MPRRC Program Specialist and Assistant to the Director of MPRRC; Director of Special Services, Missoula, Montana; and Montana?s State Director of Special Education.
The Parent Training and Information Centers in the MPRRC region that suggested the development of this document include the following: Parent Information Network, Pilot Parents of Southern Arizona, Navajo Nation Growing in Beauty, Raising Special Kids, Native American Families, PEAK Parent Center, Families Together, Inc., Parent?s Let?s Unite for Kids, Nebraska Parents? Center, EPICS Project, Parents Reaching Out, Pathfinder Family Center, Black Hills Parent Resource Network, South Dakota Parent Connection, Jakata Ho Tiwahe Parent Training, Utah Parent Center, and Wyoming picture. Parent Counseling and Training Services Guide Copyright © 2005 LRP Publications, Inc.
Table of Contents
I Introduction????????????????????????????? ......5
II Legal Authority, Regulatory Provisions, and Case Law??????????. .......6
III Benefits and Determining the Need for
Parent Counseling and Training????.????????????????.......11
IV Appendix??????????????????????????????..15
A. Full-text Letters of Opinion??????????????????. .................15B.
List of Relevant Citations???????????????????....................... 20
I. Introduction
As a parent of a child with a disability, you have probably been confused regarding your role in the special education process and by the terminology used at IEP meetings for your child. Most parents want to know as much as possible regarding their child?s disability and how they can be part of implementing some of the IEP goals and objectives. The related services of parent counseling and training are intended to address those issues.
Suddenly, what you once knew to be a parent/teacher conference among two or three persons, has become an Individualized Education Program (IEP) meeting with a cast of as many as five or 10 individuals, referred to as a ?team,? who will each assess some dimension of your child?s behavior or performance and make recommendations to put in the form of a document called an IEP. The school did not give you information on your role at the IEP Team. Parents want to play an active role in their child?s special education program and should be provided information to be an equal team member.
Fortunately, legislators, professionals, parents, and other advocates responsible for creating the Individuals with Disabilities Education Act (IDEA) anticipated that many parents would be caught in the position of not having adequate knowledge for the many problems children with disabilities present at school and at home. Congress wrote into the law a process for parents to have an opportunity to learn their roles and involvement in the IEP process. The related services of parent counseling and parent training are intended to provide parents information and make them an active part of the IEP process. However, the related services of parent training and parent counseling have been largely overlooked by many IEP teams.
This primer has been designed to explain the purpose and advantages of parent counseling and training services. It is hoped that these related services, if used effectively, will create a strong partnership between the school and the parents.
II. Legal Authority, Regulatory
Provisions, and Case Law
Under the IDEA, ?related services? are supportive services provided to a student with disabilities to assist the student in benefiting from special education. 20 USC 1401(22) (20 USC 1401 (26) under the newly reauthorized IDEA). They are, therefore, an integral element of an appropriate education.
Examples of related services available to students with disabilities under 34 CFR 300.24 include the following:
? Transportation
? Speech-language pathology and audiology services
? Psychological services
? Physical and occupational therapy
? Recreation
? Counseling services
? Orientation and mobility services
? Medical services for diagnostic or evaluation purposes
? School health services
? Social work services in schools
Additionally, the law specifically authorizes several types of related services that may be provided directly to the parents of students with disabilities. These include the following:
? Counseling of and guidance for parents regarding hearing loss (34 CFR 300.24(b)(1)(v)) and the related service of audiology
? Planning and managing a program of psychological counseling for children and parents (34 CFR 300.24 (b)(9)(v))
? Counseling of parents regarding speech and language impairments and the related services of speech pathology (34 CFR 300.24(b)(14)(v))
? Group and individual counseling with the child and family (34 CFR 300.24(b)(13)(ii))
? Parent counseling and training (34 CFR 300.24(b)(7)).
According to the Office of Special Education Programs, in a letter issued prior to the 1997 IDEA reauthorization, ?any related service provided for parents must assist the child in developing skills needed to benefit from special education or correct conditions that interfere with his or her progress toward the goals and objectives in his IEP.? Letter to Dagley, 17 IDELR 1107 (17 EHLR 1107) (OSEP 1991). The general term ?counseling services? is defined in the IDEA regulations at 34 CFR 300.24(b)(2) to mean ?services provided by qualified social workers, psychologists, guidance counselors, or other qualified personnel.? The regulations identify ?group and individual counseling with the child and his family? as a component of social work services in schools. 34 CFR 300.24(b)(3)(ii).
In discussions accompanying the publication of the final IDEA regulations, the Department of Education stated that ?school social workers work in partnership with parents and others on those problems in a child?s living situation (home, school, and community) that affect the child?s adjustment in school.? 64 Fed. Reg. 12406, 12550 (1999).
Note, however, that the school district?s obligation probably does not extend to the provision of an in-home behavior management program. Burke County Bd. of Educ. v. Denton, 16 IDELR 432 (16 EHLR 432) (4th Cir. 1990); In re: Child with a Disability, 21 IDELR 753 (SEA CT 1994).
While no further definitions are provided in the regulations and very little guidance has come from OSEP, it should be noted that in a Letter of Finding interpreting Section 504 of the Rehabilitation Act, the Office for Civil Rights has stated that family counseling may be provided informally, when needed as well as more systematically. Provision of services by telephone is permitted. Township High Sch. (IL) Dist. #211, 353 IDELR 289 (ELHR 352:289) (OCR 1986).
As defined in the 1999 IDEA regulations at 34 CFR 300.24(b)(7), parent counseling and training consists of the following:
? Assisting parents in understanding the special needs of their child
? Providing parents with information about child development
? Helping parents acquire the necessary skills that will allow them to support the implementation of their child?s IEP or IFSP.
Commenting on the revisions made in the 1999 Regulations, the Department of Education had this to say: The definition of ?parent counseling and training? should be changed to recognize the more active role acknowledged for parents as participants in the education of their children. Parents of children with disabilities are very important participants in the education process for their children. Helping them gain the skills that will enable them to help their children meet the goals and objectives of their IEP or IFSP will be a positive change for parents, will assist in furthering the education of their children, and will aid the schools as it will create opportunities to build reinforcing relationships between each child?s educational program and out-of-school learning.
For these reasons, the definition of ?parent counseling and training? should be changed to include helping parents to acquire the necessary skills that will allow them to support the implementation of their child?s IEP or IFSP. This change is in no way intended to diminish the services that were available to parents under the prior definition in these regulations. 64 Fed. Reg. 12405, 12549 (1999).
Judicial and administrative decisions interpreting the rules for parent counseling and training have been quite sparse. As a precursor to the general guidance from OSEP?s Letter to Dagley, above, an impartial hearing officer found that parent counseling and training was a related service for the parents of a student whose inappropriate behavior outside of school was adversely affecting her ability to benefit from special education. The purpose of the training was to counsel the parents about how to respond at home to such behavior in a manner consistent with the in-school behavior management program that was part of the student?s IEP. Stanislaus County Office of Educ., 507 IDELR 364 (EHLR 507:364) (SEA CA 1985).
In Letter to Dole, 211 IDELR 399 (EHLR 211:399) (OSEP 1978), OSEP noted that parent counseling and training could be included in the IEP of a deaf child in order to train parents to use the same mode of communication the child would be using at school. Some 20 years later, an Iowa hearing officer cited that policy letter in concluding that parental instruction in the same type of sign language that their five-year-old child with a hearing impairment would receive was a related service. Ankeny Community Sch. Dist., 30 IDELR 451 (SEA IA 1999). The district was ordered to arrange for sign language classes for the parents and to reimburse them for the costs of classes in which they had already participated.
One recent judicial decision is worthy of mention. In Aaron M. by Glenn M. and Lindy M. v. Yomtoob, 38 IDELR 122 (N.D. Ill. 2003), a federal court in Illinois affirmed a hearing officer?s ruling that the district could reduce from 12 to six the number of reimbursable parental training trips to the out-of-State residential placement of a 14-year-old student with autism. The court cited several factors listed in the underlying due process decision, stressing that the parents had never taken the allotted 12 trips to the facility for purposes of receiving training. The parents had made significant progress with their son when he returned home for visits, and they had developed skills to generalize the child?s improved behavior from his residential placement to his home.
The parents admitted to the IHO that they had achieved the necessary skills for successful at-home visits. Additionally, the residential facility did not include parental training as a goal in the student?s IEP. The court also noted the parents took other trips to the facility to enable the student to attend family events. Those trips did not coincide with study meetings or the training sessions offered at the residential placement.
Although infrequent, parent counseling and training has made its way into a few State due process decisions. In Mount Prospect School District No. 571, 4 ECLPR 404 (SEA IL 2002), although the district met its FAPE obligation to a child with a hearing impairment, the impartial hearing officer ordered the IEP team to reconvene for the limited purpose of offering the parents training and counseling. The services were to include (1) assisting them in understanding their child?s special needs; (2) providing them with information about child development, as it related to their son?s specific diagnosis; and (3) helping them acquire necessary skills that would allow them to support the implementation of the student?s IEP.
A Hawaii hearing officer ordered the State education department to reimburse the parents of an eight-year-old for testing and evaluations of performed by a private evaluator. Hawaii Department of Educ., 102 LRP 3706 (SEA HI 2000). Noting that parent counseling and training means ?helping parents to acquire the necessary skills that will allow them to support the implementation of their child?s IEP or IFSP,? the hearing officer found no indication that ?anyone ever advised the parent about the hazard of getting an independent evaluation.?
Finally, a New York hearing officer determined that the IEP developed for an eight-year-old with autism was inadequate because it omitted parent training. In re: Student with a Disability, 102 LRP 8600 (SEA NY 2000). The IHO cited a State regulation mandating that ?provision be made for parent counseling and education for the purpose of enabling parents to perform appropriate follow-up intervention activities at home for children who are classified as autistic.? He concluded that the evidence overwhelmingly pointed to the need for training to enable the parent to perform follow-up ABA therapy in their home. The child needed such therapy to develop a bathroom schedule, as well as other areas of development, including dressing and eating. The IHO disagreed with the district?s apparent position that simply informing the parent that she could come to school and observe ABA instruction was sufficient to satisfy its IDEA requirements. He also disagreed with the district?s view that parent training could not take place at a student?s home.
III. Benefits and Determining the Need for Parent Training and Counseling
One purpose of parent counseling is to provide support and information to the parent(s) regarding the disability. If the parents receive this information, they will be better equipped to participate in IEP team meetings, assist their child, and plan for the future as well as be better informed regarding their child?s disability.
It is critical for IEP teams to consider parent counseling at the initial placement meeting. This is usually the first time a parent is made aware of their child?s disability and what this means for their child. Most parents report a period of grieving after the initial eligibility of their child in special education. It would be analogous to being diagnosed by a doctor and being labeled with a serious medical condition. Most doctors take the time to ?counsel? and provide literature to the patient regarding his/her condition. All parents of students with disabilities need to be empowered with relevant information about the disability and what they can do to assist their children in benefiting from their education.
The IEP team should always consider the parent to be the expert on their child. Whenever possible, the parent should be included as part of the services listed on the IEP. This is especially important for preschool children eligible for special education services. The individualized family service program (IFSP) or IEP, as the case may be, might contain a component for parents to implement at home.
If the parents are is involved with the IFSP or IEP, they might require training to provide the service. Parent training would then become a related service. Some possible examples are given below:
? The student has behavior problems and is on a behavior intervention program. The parent(s) would need to be trained in behavior management strategies to implement the program in the home environment.
? The student has severe fine and gross motor difficulties and requires assistive technology devices to complete schoolwork and homework. The parent might require training on how to operate the equipment at home.
? A student is deaf and can only benefit from his/her education by using sign language. If no other resources are available, the school district might be required to provide sign language training for the parent(s). Obviously, if the parents do not sign, they will be unable to assist their child with homework and communicate about other school activities. Parent counseling and/or training yields multiple benefits for students with disabilities, their parents, and school personnel. Following is a brief list of what some of these benefits are:
? The parent gains an understanding of their child?s disability.
? The parents are better informed to be an equal team member with school staff.
? The parents will have a better understanding of future ramifications for their child.
? The parents will be better equipped to discuss the disability with their child.
? The student will be better informed to advocate for himself/herself.
? The parents can be trained to implement certain parts of the IEP.
? Parents can assist and support other parents who have children with the same disability.
? Knowledge and understanding of the disability and special education process will replace fear and anger.
? If the parent is informed and involved in the process, it is less likely conflicts will arise between the parent(s) and school. The majority of parent counseling and training can be provided during the school day by the special education staff and, most importantly, IEP team members who work closely with the student. Other school personnel that have an important role in parent counseling and training are school counselors, school psychologists, school nurses, and school social workers.
Other parent counseling and/or training sources are parent support groups with the school, the State Parent Information Center, other parents, and disability organizations representing students who have specific disabilities. As a related service under IDEA, parent counseling and/or training is not automatically provided for every family. The IEP or IFSP team must determine that these services are required to assist the student in benefiting from special education. If the determination is made by the IEP team that such parent counseling and/or training must be provided in order for the student to receive a free and appropriate public education, the related service must be described in the student?s IEP and provided by the school. Further, the amount of time for the service must be specified on the IEP (for example, five one-half hour sessions per week) as well as when the service is to commence (September 1, 2005) and the duration of the service (through November 2005).
Note: There has been confusion with the word ?counseling.? The definition in the regulations refers to providing information, not counseling the parent because of an emotional or behavior problem.
There are several questions the IEP team should answer to make the decision of including the related service of parent counseling and training in the IEP:
1. Does the parent need information about their child?s disability and their role in the IEP process?
2. Can a problem be solved by providing parents with information specific to their child?s disability or by making referral to relevant school or community resources?
3. Is it necessary for the parent to implement a portion of the child?s IEP?
4. Is the service necessary to provide the parents with specific skills that will allow them to support the implementation of the child?s IEP?
5. Does the parent need to be trained to implement a portion of the IEP goals/objectives at home?
Examples include behavior management techniques or using assistive technology.
IV. Appendix
A. Full-text Letters of Opinion 17 IDELR 1107 (17 EHLR 1107) Dagley, Letter to (Parent Training)
Office of Special Education Programs
Mr. Myron T. Dagley
Executive Director
DuPage/West Cook Regional
Special Education Association
420 North Eisenhower Lane
Lombard, IL 60148
Digest of Inquiry
March 26, 1991
? Is sign language instruction for parents of children with hearing impairments considered a related service under the IDEA?
Digest of Response
June 3, 1991
Parental Instruction in Sign Language May Be Require If an IEP team determines that sign language instruction for the parent of a child with a hearing impairment is necessary in order for the child to benefit from his educational program, then such instruction must be provided as a related service under the aegis of ?parent counseling and training? and must be included in the child?s IEP, in accordance with Regs. 300.346(c) and 300.13(b)(6).
Text of Inquiry
I have recently been requested to direct an inquiry to your attention as a means of gathering information which may be used to help our special education association frame a policy statement. Specifically, we respectfully request that you respond to the following question. ?Does the U.S. Department of Education view the provision of sign language instruction to the parents of the hearing impaired population as a matter of entitlement to a related service under the aegis of I.D.E.A.??
We have already received copies of the various policy briefings available to us through EHLR with respect to this matter. Our reading of those, however, suggests that each is positioned in a specific context and not necessarily applicable to all individuals with hearing impairments of educational significance. We would greatly appreciate your prompt response to this inquiry. We thank you in advance for giving this matter careful consideration.
Text of Response
This is in response to your letter to the Office of Special Education Programs (OSEP), in which you request policy clarification on requirements of Part B of the Individuals with Disabilities Education Act (Part B).
Specifically, your letter asks the following question:
Does the U.S. Department of Education view the provision of sign language instruction to the parents of the hearing impaired population as a matter of entitlement to a related service under the aegis of I.D.E.A.? Under Part B, States and local school districts have an ongoing responsibility to provide a free appropriate public education (FAPE) to all eligible children with disabilities in the State and to extend the rights and protections in Part B to those children and their parents. 34 CFR §§ 300.121 and 300.2. FAPE, among other factors, includes the provision of special education and related services, under public supervision and direction, at no cost to parents, in conformity with an individualized education program (IEP). 34 CFR § 300.4.
The term, ?related services? is defined to include ?transportation, and such developmental, corrective, and other supportive services as are required to assist a [child with a disability] to benefit from special education. . . .? 34 CFR § 300.13(a); see also 20 U.S.C. 1401(a)(17). The specific related service relevant to your inquiry is ?parent counseling and training,? which is defined at 34 CFR § 300.13(b)(6) to mean ?assisting parents in understanding the special needs of their child and providing parents with information about child development.? In previous policy guidance addressing the question of ?what type and extent of services the school district is required to provide for the parents of a deaf child,? the Department has stated:
Under the definition of ?parent counseling and training,? for example, a IEP for a deaf child could include training parents to use the mode of communication that their child uses as part of an educational program. In order to determine whether services for a child?s parents, such as training or counseling, should be included in a child?s IEP, the team developing the IEP must determine that the service is needed in order for the child to receive an appropriate special education or other required related services in the least restrictive environment. Any related services provided for parents must assist the child in developing skills needed to benefit from special education or correct conditions which interfere with the child?s progress toward the goals and objectives listed in the IEP. The service could precede the initiation of specially designed instruction to make the child ready for instruction, or the service and the special education could proceed concurrently.
See letter dated July 25, 1986 to Senator Robert Dole from Ms. Madeleine Will, former Assistant Secretary for the Office of Special Education and Rehabilitative Services (copy enclosed), published at EHLR 211:399.
This remains the Department?s position. Part B does not require that parents of all children with hearing impairments automatically must be provided with sign language instruction as a related service in all instances. However, public agencies are responsible for ensuring that the unique communication needs of children with disabilities are addressed so that they receive an appropriate educational program in the least restrictive environment. Therefore, if a parent of a child with a hearing impairment or a school district believes that sign language instruction for the parent is needed in order for the child to benefit from the special education and related services included in the child?s IEP, then the parent?s need for such instruction must be considered by the participants on the IEP team. If the participants on the IEP team determine that this service is needed, sign language instruction must be provided to the parent as a related service in the form of ?parent counseling and training? and must be included in the child?s IEP. 34 CFR §§ 300.346(c) and 300.13(b)(6). In all instances, decisions as to whether a child with a disability requires a particular related service must be made on an individual basis through applicable IEP and placement procedures. 34 CFR §§ 300.340-300.349 and 300.550-300.553. I hope the above information has been helpful. If we can provide further assistance, please let me know.
Judy A. Schrag, Ed.D.
Director, Office of Special Education Programs
19 IDELR 58 1 ECLPR 269 Anonymous, Letter to (Related Serv.)
Office of Special Education Programs
[Inquirer?s Name Not Provided]
Digest of Inquiry
September 19, 1992
Is sign language training for the parents of a child who is deaf included within the Part B definition of related services?
Digest of Response
December 8, 1992
Issue of Sign Language Training for Parents Was Previously Addressed The question of whether sign language training for the parent of a child who is deaf is covered by the Part B definition of related services was addressed in a previous OSEP policy letter. See Letter to Dagley, 17 EHLR 1107 (1991), in which OSEP noted that sign language training for parents may be provided under the aegis of ?parent counseling and training? in accordance with 34 CFR 300.346(c) and 300.13(b)(6).
Text of Inquiry
I am writing to you to ask for an official copy of your definition of related services under code of federal regulations 300.13 a?specifically as it relates to parent training?does this include sign language training for the parents of a deaf child? If so please send a copy of your policy on this to [ ] and [ ] (coordinators) of the committee on special education in the [ ] N.Y. school district.
At my annual review on [ ], I asked that sign language training for my husband and I be put in the IEP under related services. They have refused to do this saying that parent training does not mean sign language training. Please send an official copy of your department?s policy on this to [ ] and [ ] at [ ] Committee on Special Education.
Please send me a copy of your policy also and any [ ] instruction you may have for us to get sign language training put in the IEP.
Thank-you for your time.
Text of Response
This is in response to your letters concerning the definition of ?related services? under Part B of the Individuals with Disabilities Education Act (Part B) at 34 CFR § 300.13.
Specifically, you want to know if sign language training for the parents of a child who is deaf is included within the Part B definition of ?related services.? You indicate that you recently asked to have sign language training for your husband and yourself included in your son?s individualized education program under related services. You state that you were informed by school officials that the parent training referenced at 34 CFR § 300.13(b)(6) does not include sign language training.
The issue you raise was addressed in some detail in a letter, dated June 3, 1991, that I wrote to Mr. Myron T. Dagley, Executive Director of the DuPage/West Cook Regional Special Education Association in Lombard, Illinois. A copy of this letter is enclosed for your information. You may want to share the contents of this correspondence with appropriate school district officials. I hope that the information contained in this letter is helpful. If this Office can be of further assistance, please let me know.
Judy A. Schrag
Director, Office of Special Education Programs
B. List of Relevant Citations
1. IDEA statute and regulations
20 USC 1401(22)
34 CFR 300.24
34 CFR 300.24(b)(1)(v)
34 CFR 300.24(b)(2)
34 CFR 300.24(b)(3)(ii)
34 CFR 300.24(b)(7)
34 CFR 300.24(b)(9)(v)
34 CFR 300.24(b)(13)(ii)
34 CFR 300.24(b)(14(v)
2. Federal Register
64 Fed. Reg. 12405, 12549 (1999)
64 Fed. Reg. 12406, 12550 (1999)
3. Case citations
Aaron M. by Glenn M. and Lindy M. v. Yomtoob, 38 IDELR 122 (N.D. Ill. 2003)
Ankeny Community Sch. Dist., 30 IDELR 451 (SEA IA 1999)
Burke County Bd. of Educ. v. Denton, 16 IDELR 432 (16 EHLR 432) (4th Cir. 1990)
Hawaii Department of Educ., 102 LRP 3706 (SEA HI 2000)
In re: Child with a Disability, 21 IDELR 753 (SEA CT 1994)
In re: Student with a Disability, 102 LRP 8600 (SEA NY 2000)
Letter to Anonymous, 19 IDELR 586 (OSEP 1992)
Letter to Dagley, 17 IDELR 1107 (17 EHLR 1107) (OSEP 1991)
Letter to Dole, 211 IDELR 399 (EHLR 211:399) (OSEP 1978)
Mount Prospect School District No. 571, 4 ECLPR 404 (SEA IL 2002)
Stanislaus County Office of Educ., 507 IDELR 364 (EHLR 507:364) (SEA CA 1985)
Township High Sch. (IL) Dist. #211, 353 IDELR 289 (ELHR 352:289) (OCR 1986)
G:\Library\Handouts\parent counseling project\parcounselingproject.doctor
Copyright © 2005 LRP Publications, Inc.
Parent Counseling and Training Services Guide
Produced in Partnership with LRP Publications, and The Mountain Plains Regional Resource Center, A program funded by the Office of Special Education Programs (OSEP), U.S. Department of Education 2005
Parent Counseling and Training Services Guide
The Parent Counseling and Training Services Guide was produced in partnership among the following:
The Mountain Plains Regional Resource Center (MPRRC) at Utah State University, a U.S. Department of Education, Office of Special Education funded project. The MPRRC provides technical assistance in special education to 10 States and the Bureau of Indian Affairs. The MPRRC Web site is www.usu.edu/mprrc
LRP Publications (www.lrp.com), of Palm Beach Gardens, Florida, is the national leader in special education legal case reports, newsletters, pamphlets, books, videos, and more. LRP?s hallmark publications include the Individuals with Disabilities Education
Law Report® and The Special Educator®. On the Internet, LRP?s Special Education Connection Web site (www.specialedconnection.com) is a one-stop source for news, practical advice, best practices, tips, case decisions, chat rooms, e-mail bulletins, and much more. LRP also provides top-quality training and educational development seminars, conferences, and symposiums through its Conference Group, including the National Institute on Legal Issues of Educating Individuals with Disabilities, attended by thousands of special education directors, administrators, school psychologists, attorneys, and others each year.
Steven E. Lake, Esq., is Editorial Director of Special Education Products at LRP Publications. He is the author of the Top 10 IEP Errors: How to Avoid Them, How to Fix Them; Separating Church and State: The Challenges of Special Education in Parochial Schools; IEP Procedural Errors: Lessons Learned, Mistakes to Avoid; and Alternative Schools: Legal Guidance for Serving Special Education Students. Mr. Lake has a B.A. from the University of Connecticut and a J.D. from California Western School of Law, where he served on the editorial board of the Law Review. He is admitted to the California and Massachusetts bars. Parent Counseling and Training Services Guide
John W. Norlin, Esq., is LRP Publications? legal editor for education ancillary products. He is the author of Identify, Locate and Evaluate: Child Find under the IDEA and Section 504; Courts Divided: The Debate Over Section 1983 Claims for IDEA Violations; Beyond FERPA: A Guide to Student Records Under the IDEA; The No Child Left Behind Act: Your Guide to Key Components; Aversives in the Classroom: What Are the Legal Limits; and The Special Educator Desk Book. He is also the editor of What Do I Do When . . . The Answer Book on the Family Educational Rights and Privacy Act. Prior to joining LRP Publications, Mr. Norlin practiced law in Palm Beach County, Florida. He has a J.D. from the University of Michigan Law School.
John Copenhaver is the Director of Mountain Plains Regional Resource Center, a U.S. Department of Education, Office of Special Education funded project, providing technical assistance in special education to the following States: Arizona, the BIA, Colorado, Kansas, Montana, Nebraska, New Mexico, North Dakota, South Dakota, Utah, and Wyoming.
Jack L. Rudio, Ed.D., is a Program Consultant for Mountain Plains Regional Resource Center; formerly an MPRRC Program Specialist and Assistant to the Director of MPRRC; Director of Special Services, Missoula, Montana; and Montana?s State Director of Special Education.
The Parent Training and Information Centers in the MPRRC region that suggested the development of this document include the following: Parent Information Network, Pilot Parents of Southern Arizona, Navajo Nation Growing in Beauty, Raising Special Kids, Native American Families, PEAK Parent Center, Families Together, Inc., Parent?s Let?s Unite for Kids, Nebraska Parents? Center, EPICS Project, Parents Reaching Out, Pathfinder Family Center, Black Hills Parent Resource Network, South Dakota Parent Connection, Jakata Ho Tiwahe Parent Training, Utah Parent Center, and Wyoming picture. Parent Counseling and Training Services Guide Copyright © 2005 LRP Publications, Inc.
Table of Contents
I Introduction????????????????????????????? ......5
II Legal Authority, Regulatory Provisions, and Case Law??????????. .......6
III Benefits and Determining the Need for
Parent Counseling and Training????.????????????????.......11
IV Appendix??????????????????????????????..15
A. Full-text Letters of Opinion??????????????????. .................15B.
List of Relevant Citations???????????????????....................... 20
I. Introduction
As a parent of a child with a disability, you have probably been confused regarding your role in the special education process and by the terminology used at IEP meetings for your child. Most parents want to know as much as possible regarding their child?s disability and how they can be part of implementing some of the IEP goals and objectives. The related services of parent counseling and training are intended to address those issues.
Suddenly, what you once knew to be a parent/teacher conference among two or three persons, has become an Individualized Education Program (IEP) meeting with a cast of as many as five or 10 individuals, referred to as a ?team,? who will each assess some dimension of your child?s behavior or performance and make recommendations to put in the form of a document called an IEP. The school did not give you information on your role at the IEP Team. Parents want to play an active role in their child?s special education program and should be provided information to be an equal team member.
Fortunately, legislators, professionals, parents, and other advocates responsible for creating the Individuals with Disabilities Education Act (IDEA) anticipated that many parents would be caught in the position of not having adequate knowledge for the many problems children with disabilities present at school and at home. Congress wrote into the law a process for parents to have an opportunity to learn their roles and involvement in the IEP process. The related services of parent counseling and parent training are intended to provide parents information and make them an active part of the IEP process. However, the related services of parent training and parent counseling have been largely overlooked by many IEP teams.
This primer has been designed to explain the purpose and advantages of parent counseling and training services. It is hoped that these related services, if used effectively, will create a strong partnership between the school and the parents.
II. Legal Authority, Regulatory
Provisions, and Case Law
Under the IDEA, ?related services? are supportive services provided to a student with disabilities to assist the student in benefiting from special education. 20 USC 1401(22) (20 USC 1401 (26) under the newly reauthorized IDEA). They are, therefore, an integral element of an appropriate education.
Examples of related services available to students with disabilities under 34 CFR 300.24 include the following:
? Transportation
? Speech-language pathology and audiology services
? Psychological services
? Physical and occupational therapy
? Recreation
? Counseling services
? Orientation and mobility services
? Medical services for diagnostic or evaluation purposes
? School health services
? Social work services in schools
Additionally, the law specifically authorizes several types of related services that may be provided directly to the parents of students with disabilities. These include the following:
? Counseling of and guidance for parents regarding hearing loss (34 CFR 300.24(b)(1)(v)) and the related service of audiology
? Planning and managing a program of psychological counseling for children and parents (34 CFR 300.24 (b)(9)(v))
? Counseling of parents regarding speech and language impairments and the related services of speech pathology (34 CFR 300.24(b)(14)(v))
? Group and individual counseling with the child and family (34 CFR 300.24(b)(13)(ii))
? Parent counseling and training (34 CFR 300.24(b)(7)).
According to the Office of Special Education Programs, in a letter issued prior to the 1997 IDEA reauthorization, ?any related service provided for parents must assist the child in developing skills needed to benefit from special education or correct conditions that interfere with his or her progress toward the goals and objectives in his IEP.? Letter to Dagley, 17 IDELR 1107 (17 EHLR 1107) (OSEP 1991). The general term ?counseling services? is defined in the IDEA regulations at 34 CFR 300.24(b)(2) to mean ?services provided by qualified social workers, psychologists, guidance counselors, or other qualified personnel.? The regulations identify ?group and individual counseling with the child and his family? as a component of social work services in schools. 34 CFR 300.24(b)(3)(ii).
In discussions accompanying the publication of the final IDEA regulations, the Department of Education stated that ?school social workers work in partnership with parents and others on those problems in a child?s living situation (home, school, and community) that affect the child?s adjustment in school.? 64 Fed. Reg. 12406, 12550 (1999).
Note, however, that the school district?s obligation probably does not extend to the provision of an in-home behavior management program. Burke County Bd. of Educ. v. Denton, 16 IDELR 432 (16 EHLR 432) (4th Cir. 1990); In re: Child with a Disability, 21 IDELR 753 (SEA CT 1994).
While no further definitions are provided in the regulations and very little guidance has come from OSEP, it should be noted that in a Letter of Finding interpreting Section 504 of the Rehabilitation Act, the Office for Civil Rights has stated that family counseling may be provided informally, when needed as well as more systematically. Provision of services by telephone is permitted. Township High Sch. (IL) Dist. #211, 353 IDELR 289 (ELHR 352:289) (OCR 1986).
As defined in the 1999 IDEA regulations at 34 CFR 300.24(b)(7), parent counseling and training consists of the following:
? Assisting parents in understanding the special needs of their child
? Providing parents with information about child development
? Helping parents acquire the necessary skills that will allow them to support the implementation of their child?s IEP or IFSP.
Commenting on the revisions made in the 1999 Regulations, the Department of Education had this to say: The definition of ?parent counseling and training? should be changed to recognize the more active role acknowledged for parents as participants in the education of their children. Parents of children with disabilities are very important participants in the education process for their children. Helping them gain the skills that will enable them to help their children meet the goals and objectives of their IEP or IFSP will be a positive change for parents, will assist in furthering the education of their children, and will aid the schools as it will create opportunities to build reinforcing relationships between each child?s educational program and out-of-school learning.
For these reasons, the definition of ?parent counseling and training? should be changed to include helping parents to acquire the necessary skills that will allow them to support the implementation of their child?s IEP or IFSP. This change is in no way intended to diminish the services that were available to parents under the prior definition in these regulations. 64 Fed. Reg. 12405, 12549 (1999).
Judicial and administrative decisions interpreting the rules for parent counseling and training have been quite sparse. As a precursor to the general guidance from OSEP?s Letter to Dagley, above, an impartial hearing officer found that parent counseling and training was a related service for the parents of a student whose inappropriate behavior outside of school was adversely affecting her ability to benefit from special education. The purpose of the training was to counsel the parents about how to respond at home to such behavior in a manner consistent with the in-school behavior management program that was part of the student?s IEP. Stanislaus County Office of Educ., 507 IDELR 364 (EHLR 507:364) (SEA CA 1985).
In Letter to Dole, 211 IDELR 399 (EHLR 211:399) (OSEP 1978), OSEP noted that parent counseling and training could be included in the IEP of a deaf child in order to train parents to use the same mode of communication the child would be using at school. Some 20 years later, an Iowa hearing officer cited that policy letter in concluding that parental instruction in the same type of sign language that their five-year-old child with a hearing impairment would receive was a related service. Ankeny Community Sch. Dist., 30 IDELR 451 (SEA IA 1999). The district was ordered to arrange for sign language classes for the parents and to reimburse them for the costs of classes in which they had already participated.
One recent judicial decision is worthy of mention. In Aaron M. by Glenn M. and Lindy M. v. Yomtoob, 38 IDELR 122 (N.D. Ill. 2003), a federal court in Illinois affirmed a hearing officer?s ruling that the district could reduce from 12 to six the number of reimbursable parental training trips to the out-of-State residential placement of a 14-year-old student with autism. The court cited several factors listed in the underlying due process decision, stressing that the parents had never taken the allotted 12 trips to the facility for purposes of receiving training. The parents had made significant progress with their son when he returned home for visits, and they had developed skills to generalize the child?s improved behavior from his residential placement to his home.
The parents admitted to the IHO that they had achieved the necessary skills for successful at-home visits. Additionally, the residential facility did not include parental training as a goal in the student?s IEP. The court also noted the parents took other trips to the facility to enable the student to attend family events. Those trips did not coincide with study meetings or the training sessions offered at the residential placement.
Although infrequent, parent counseling and training has made its way into a few State due process decisions. In Mount Prospect School District No. 571, 4 ECLPR 404 (SEA IL 2002), although the district met its FAPE obligation to a child with a hearing impairment, the impartial hearing officer ordered the IEP team to reconvene for the limited purpose of offering the parents training and counseling. The services were to include (1) assisting them in understanding their child?s special needs; (2) providing them with information about child development, as it related to their son?s specific diagnosis; and (3) helping them acquire necessary skills that would allow them to support the implementation of the student?s IEP.
A Hawaii hearing officer ordered the State education department to reimburse the parents of an eight-year-old for testing and evaluations of performed by a private evaluator. Hawaii Department of Educ., 102 LRP 3706 (SEA HI 2000). Noting that parent counseling and training means ?helping parents to acquire the necessary skills that will allow them to support the implementation of their child?s IEP or IFSP,? the hearing officer found no indication that ?anyone ever advised the parent about the hazard of getting an independent evaluation.?
Finally, a New York hearing officer determined that the IEP developed for an eight-year-old with autism was inadequate because it omitted parent training. In re: Student with a Disability, 102 LRP 8600 (SEA NY 2000). The IHO cited a State regulation mandating that ?provision be made for parent counseling and education for the purpose of enabling parents to perform appropriate follow-up intervention activities at home for children who are classified as autistic.? He concluded that the evidence overwhelmingly pointed to the need for training to enable the parent to perform follow-up ABA therapy in their home. The child needed such therapy to develop a bathroom schedule, as well as other areas of development, including dressing and eating. The IHO disagreed with the district?s apparent position that simply informing the parent that she could come to school and observe ABA instruction was sufficient to satisfy its IDEA requirements. He also disagreed with the district?s view that parent training could not take place at a student?s home.
III. Benefits and Determining the Need for Parent Training and Counseling
One purpose of parent counseling is to provide support and information to the parent(s) regarding the disability. If the parents receive this information, they will be better equipped to participate in IEP team meetings, assist their child, and plan for the future as well as be better informed regarding their child?s disability.
It is critical for IEP teams to consider parent counseling at the initial placement meeting. This is usually the first time a parent is made aware of their child?s disability and what this means for their child. Most parents report a period of grieving after the initial eligibility of their child in special education. It would be analogous to being diagnosed by a doctor and being labeled with a serious medical condition. Most doctors take the time to ?counsel? and provide literature to the patient regarding his/her condition. All parents of students with disabilities need to be empowered with relevant information about the disability and what they can do to assist their children in benefiting from their education.
The IEP team should always consider the parent to be the expert on their child. Whenever possible, the parent should be included as part of the services listed on the IEP. This is especially important for preschool children eligible for special education services. The individualized family service program (IFSP) or IEP, as the case may be, might contain a component for parents to implement at home.
If the parents are is involved with the IFSP or IEP, they might require training to provide the service. Parent training would then become a related service. Some possible examples are given below:
? The student has behavior problems and is on a behavior intervention program. The parent(s) would need to be trained in behavior management strategies to implement the program in the home environment.
? The student has severe fine and gross motor difficulties and requires assistive technology devices to complete schoolwork and homework. The parent might require training on how to operate the equipment at home.
? A student is deaf and can only benefit from his/her education by using sign language. If no other resources are available, the school district might be required to provide sign language training for the parent(s). Obviously, if the parents do not sign, they will be unable to assist their child with homework and communicate about other school activities. Parent counseling and/or training yields multiple benefits for students with disabilities, their parents, and school personnel. Following is a brief list of what some of these benefits are:
? The parent gains an understanding of their child?s disability.
? The parents are better informed to be an equal team member with school staff.
? The parents will have a better understanding of future ramifications for their child.
? The parents will be better equipped to discuss the disability with their child.
? The student will be better informed to advocate for himself/herself.
? The parents can be trained to implement certain parts of the IEP.
? Parents can assist and support other parents who have children with the same disability.
? Knowledge and understanding of the disability and special education process will replace fear and anger.
? If the parent is informed and involved in the process, it is less likely conflicts will arise between the parent(s) and school. The majority of parent counseling and training can be provided during the school day by the special education staff and, most importantly, IEP team members who work closely with the student. Other school personnel that have an important role in parent counseling and training are school counselors, school psychologists, school nurses, and school social workers.
Other parent counseling and/or training sources are parent support groups with the school, the State Parent Information Center, other parents, and disability organizations representing students who have specific disabilities. As a related service under IDEA, parent counseling and/or training is not automatically provided for every family. The IEP or IFSP team must determine that these services are required to assist the student in benefiting from special education. If the determination is made by the IEP team that such parent counseling and/or training must be provided in order for the student to receive a free and appropriate public education, the related service must be described in the student?s IEP and provided by the school. Further, the amount of time for the service must be specified on the IEP (for example, five one-half hour sessions per week) as well as when the service is to commence (September 1, 2005) and the duration of the service (through November 2005).
Note: There has been confusion with the word ?counseling.? The definition in the regulations refers to providing information, not counseling the parent because of an emotional or behavior problem.
There are several questions the IEP team should answer to make the decision of including the related service of parent counseling and training in the IEP:
1. Does the parent need information about their child?s disability and their role in the IEP process?
2. Can a problem be solved by providing parents with information specific to their child?s disability or by making referral to relevant school or community resources?
3. Is it necessary for the parent to implement a portion of the child?s IEP?
4. Is the service necessary to provide the parents with specific skills that will allow them to support the implementation of the child?s IEP?
5. Does the parent need to be trained to implement a portion of the IEP goals/objectives at home?
Examples include behavior management techniques or using assistive technology.
IV. Appendix
A. Full-text Letters of Opinion 17 IDELR 1107 (17 EHLR 1107) Dagley, Letter to (Parent Training)
Office of Special Education Programs
Mr. Myron T. Dagley
Executive Director
DuPage/West Cook Regional
Special Education Association
420 North Eisenhower Lane
Lombard, IL 60148
Digest of Inquiry
March 26, 1991
? Is sign language instruction for parents of children with hearing impairments considered a related service under the IDEA?
Digest of Response
June 3, 1991
Parental Instruction in Sign Language May Be Require If an IEP team determines that sign language instruction for the parent of a child with a hearing impairment is necessary in order for the child to benefit from his educational program, then such instruction must be provided as a related service under the aegis of ?parent counseling and training? and must be included in the child?s IEP, in accordance with Regs. 300.346(c) and 300.13(b)(6).
Text of Inquiry
I have recently been requested to direct an inquiry to your attention as a means of gathering information which may be used to help our special education association frame a policy statement. Specifically, we respectfully request that you respond to the following question. ?Does the U.S. Department of Education view the provision of sign language instruction to the parents of the hearing impaired population as a matter of entitlement to a related service under the aegis of I.D.E.A.??
We have already received copies of the various policy briefings available to us through EHLR with respect to this matter. Our reading of those, however, suggests that each is positioned in a specific context and not necessarily applicable to all individuals with hearing impairments of educational significance. We would greatly appreciate your prompt response to this inquiry. We thank you in advance for giving this matter careful consideration.
Text of Response
This is in response to your letter to the Office of Special Education Programs (OSEP), in which you request policy clarification on requirements of Part B of the Individuals with Disabilities Education Act (Part B).
Specifically, your letter asks the following question:
Does the U.S. Department of Education view the provision of sign language instruction to the parents of the hearing impaired population as a matter of entitlement to a related service under the aegis of I.D.E.A.? Under Part B, States and local school districts have an ongoing responsibility to provide a free appropriate public education (FAPE) to all eligible children with disabilities in the State and to extend the rights and protections in Part B to those children and their parents. 34 CFR §§ 300.121 and 300.2. FAPE, among other factors, includes the provision of special education and related services, under public supervision and direction, at no cost to parents, in conformity with an individualized education program (IEP). 34 CFR § 300.4.
The term, ?related services? is defined to include ?transportation, and such developmental, corrective, and other supportive services as are required to assist a [child with a disability] to benefit from special education. . . .? 34 CFR § 300.13(a); see also 20 U.S.C. 1401(a)(17). The specific related service relevant to your inquiry is ?parent counseling and training,? which is defined at 34 CFR § 300.13(b)(6) to mean ?assisting parents in understanding the special needs of their child and providing parents with information about child development.? In previous policy guidance addressing the question of ?what type and extent of services the school district is required to provide for the parents of a deaf child,? the Department has stated:
Under the definition of ?parent counseling and training,? for example, a IEP for a deaf child could include training parents to use the mode of communication that their child uses as part of an educational program. In order to determine whether services for a child?s parents, such as training or counseling, should be included in a child?s IEP, the team developing the IEP must determine that the service is needed in order for the child to receive an appropriate special education or other required related services in the least restrictive environment. Any related services provided for parents must assist the child in developing skills needed to benefit from special education or correct conditions which interfere with the child?s progress toward the goals and objectives listed in the IEP. The service could precede the initiation of specially designed instruction to make the child ready for instruction, or the service and the special education could proceed concurrently.
See letter dated July 25, 1986 to Senator Robert Dole from Ms. Madeleine Will, former Assistant Secretary for the Office of Special Education and Rehabilitative Services (copy enclosed), published at EHLR 211:399.
This remains the Department?s position. Part B does not require that parents of all children with hearing impairments automatically must be provided with sign language instruction as a related service in all instances. However, public agencies are responsible for ensuring that the unique communication needs of children with disabilities are addressed so that they receive an appropriate educational program in the least restrictive environment. Therefore, if a parent of a child with a hearing impairment or a school district believes that sign language instruction for the parent is needed in order for the child to benefit from the special education and related services included in the child?s IEP, then the parent?s need for such instruction must be considered by the participants on the IEP team. If the participants on the IEP team determine that this service is needed, sign language instruction must be provided to the parent as a related service in the form of ?parent counseling and training? and must be included in the child?s IEP. 34 CFR §§ 300.346(c) and 300.13(b)(6). In all instances, decisions as to whether a child with a disability requires a particular related service must be made on an individual basis through applicable IEP and placement procedures. 34 CFR §§ 300.340-300.349 and 300.550-300.553. I hope the above information has been helpful. If we can provide further assistance, please let me know.
Judy A. Schrag, Ed.D.
Director, Office of Special Education Programs
19 IDELR 58 1 ECLPR 269 Anonymous, Letter to (Related Serv.)
Office of Special Education Programs
[Inquirer?s Name Not Provided]
Digest of Inquiry
September 19, 1992
Is sign language training for the parents of a child who is deaf included within the Part B definition of related services?
Digest of Response
December 8, 1992
Issue of Sign Language Training for Parents Was Previously Addressed The question of whether sign language training for the parent of a child who is deaf is covered by the Part B definition of related services was addressed in a previous OSEP policy letter. See Letter to Dagley, 17 EHLR 1107 (1991), in which OSEP noted that sign language training for parents may be provided under the aegis of ?parent counseling and training? in accordance with 34 CFR 300.346(c) and 300.13(b)(6).
Text of Inquiry
I am writing to you to ask for an official copy of your definition of related services under code of federal regulations 300.13 a?specifically as it relates to parent training?does this include sign language training for the parents of a deaf child? If so please send a copy of your policy on this to [ ] and [ ] (coordinators) of the committee on special education in the [ ] N.Y. school district.
At my annual review on [ ], I asked that sign language training for my husband and I be put in the IEP under related services. They have refused to do this saying that parent training does not mean sign language training. Please send an official copy of your department?s policy on this to [ ] and [ ] at [ ] Committee on Special Education.
Please send me a copy of your policy also and any [ ] instruction you may have for us to get sign language training put in the IEP.
Thank-you for your time.
Text of Response
This is in response to your letters concerning the definition of ?related services? under Part B of the Individuals with Disabilities Education Act (Part B) at 34 CFR § 300.13.
Specifically, you want to know if sign language training for the parents of a child who is deaf is included within the Part B definition of ?related services.? You indicate that you recently asked to have sign language training for your husband and yourself included in your son?s individualized education program under related services. You state that you were informed by school officials that the parent training referenced at 34 CFR § 300.13(b)(6) does not include sign language training.
The issue you raise was addressed in some detail in a letter, dated June 3, 1991, that I wrote to Mr. Myron T. Dagley, Executive Director of the DuPage/West Cook Regional Special Education Association in Lombard, Illinois. A copy of this letter is enclosed for your information. You may want to share the contents of this correspondence with appropriate school district officials. I hope that the information contained in this letter is helpful. If this Office can be of further assistance, please let me know.
Judy A. Schrag
Director, Office of Special Education Programs
B. List of Relevant Citations
1. IDEA statute and regulations
20 USC 1401(22)
34 CFR 300.24
34 CFR 300.24(b)(1)(v)
34 CFR 300.24(b)(2)
34 CFR 300.24(b)(3)(ii)
34 CFR 300.24(b)(7)
34 CFR 300.24(b)(9)(v)
34 CFR 300.24(b)(13)(ii)
34 CFR 300.24(b)(14(v)
2. Federal Register
64 Fed. Reg. 12405, 12549 (1999)
64 Fed. Reg. 12406, 12550 (1999)
3. Case citations
Aaron M. by Glenn M. and Lindy M. v. Yomtoob, 38 IDELR 122 (N.D. Ill. 2003)
Ankeny Community Sch. Dist., 30 IDELR 451 (SEA IA 1999)
Burke County Bd. of Educ. v. Denton, 16 IDELR 432 (16 EHLR 432) (4th Cir. 1990)
Hawaii Department of Educ., 102 LRP 3706 (SEA HI 2000)
In re: Child with a Disability, 21 IDELR 753 (SEA CT 1994)
In re: Student with a Disability, 102 LRP 8600 (SEA NY 2000)
Letter to Anonymous, 19 IDELR 586 (OSEP 1992)
Letter to Dagley, 17 IDELR 1107 (17 EHLR 1107) (OSEP 1991)
Letter to Dole, 211 IDELR 399 (EHLR 211:399) (OSEP 1978)
Mount Prospect School District No. 571, 4 ECLPR 404 (SEA IL 2002)
Stanislaus County Office of Educ., 507 IDELR 364 (EHLR 507:364) (SEA CA 1985)
Township High Sch. (IL) Dist. #211, 353 IDELR 289 (ELHR 352:289) (OCR 1986)
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