DC Is Seeking Mediators; Caution!

"Plan of the City of Washington," Ma...
"Plan of the City of Washington," March 1792, Engraving on paper, see Library of Congress record (Photo credit: Wikipedia)











Washington, DC is seeking special ed mediators!!!  

(Please NOTE: I am NOT recommending these jobs.  This post is for informational reasons only.  Please study the rfp very closely, and apply at your own peril and only if you so desire.)

Horrible pay, intolerable working conditions...otherwise sweet gig!

You can read the rfp here.




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Memorial Day

Memorial Day Commemoration 2008
Memorial Day Commemoration 2008 (Photo credit: davidyuweb)
 
 
 
 
 
 
 
 
On this Memorial Day, 2012, we thank all those who have served our country. We have no shortage of heroes.

Those who were killed in service of our country, we salute you today. To those who were injured, today we urge our representatives to ensure that you get all the medical and other care you need. This blog focuses on kids with disabilities, but adults are also often disabled, sometimes as a result of war.  We owe it to our wounded warriors to ensure that we take care of them.  It really is the least that we can do.

Happy Memorial Day.
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Where do Obama & Romney Stand On Special Education Law?

Deutsch: Garten des Weißen Hauses in Washingto...
: Lawn in front of the White House, Washington, DC.  (Photo credit: Wikipedia)





As this blog's readership grows, so does our clout,  Let's use it!

In presidential elections the candidates rarely address special education issues.  They all have positions on education (guess what, the are for it!), but they do not go near the tough questions.  Here at the special education law blog, however, we feel that our readers should know the detailed special education positions of the candidates, and so we are going to ask them. This seems like a very good use of the blogosphere doesn't it?

OK so we are going to ask the campaigns of the presumptive nominees of the major parties, Barack Obama and Mitt Romney, how they stand on special education law issues. We'll ask about full funding of IDEA.We'll ask about Reauthorization of NCLB and IDEA. We'll ask about whether they might change Rowley standard. We'll ask about whether they will propose changes to the law in light of Supreme Court decisions like Murphy (expert W fees); Weast (burden of persuasion); Winkleman (pro se parents in court); and Buckhannon (attorney's fees).We will ask how they feel about inclusion.  We will ask whether there should be a federal law concerning bullying of students at school.  We'll ask whether seclusion and restraints should be regulated by the federal government.   

We're also open to suggestions. We need your help. What would you ask the candidates about special education, and especially changes in the law you'd like to see. We will put together the requests and send them to the campaigns around July 1st. If we get responses, we'll publish them here and try to get others to publicize them. If we don't get responses, we'll publish that fact and publicize it as well.
Please submit your suggestions as early as possible. We look forward to hearing from you!
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Procedural Safeguards - The Series Part X

WASHINGTON - MARCH 02:  The U.S. Supreme Court...
WASHINGTON - MARCH 02: The U.S. Supreme Court Building is seen on March 2, 2010 in Washington, DC. Today the high court is hearing arguments in the case of McDonald v the City of Chicago case that questions whether the Second Amendment is incorporated into the due process clause or the privileges or immunities clause of the fourteenth amendment, thus invalidating the city's handgun ban. (Image credit: Getty Images via @daylife)






This is the tenth installment in a multi-part series on procedural safeguards under the federal special education law, the Individuals With Disabilities Education Act. I work a lot in this area, so it is near and dear to my heart. Despite the importance of procedural safeguards. however, many issues in this area are misunderstood. I hope that the special education stakeholders who read this blog find the information in this series helpful.


Due Process Hearings


A due process hearing resembles a court trial. Increasingly, parties are represented by lawyers. Opening statements are made. Testimony is provided by parents, teachers, related service providers, administrators, and many others- often by expert witnesses. Although the formal rules of evidence are generally not applied, exhibits, or documentary evidence, are offered and admitted. The tone is increasingly adversarial. Either closing arguments are made or written briefs are submitted. Hearing officer decisions are generally lengthy and legalistic in tone. The decision of the hearing officer may be appealed to one or more courts.

Parents and local education agencies may file a due process complaint for any matter related to the identification, evaluation, educational placement or the provision of a free and appropriate public education to a child with a disability. IDEA §§ 615(f);615(b)(6).

IDEA imposes a two-year statute of limitations on due process complaints. Unless state law imposes a contrary limitations period, a party must request a due process hearing within two years of the date that the party knew or reasonably should have known about the alleged action that forms the basis of the complaint. § 615 (f)(3)(C). The statute of limitations recognizes two exceptions – cases in which the parent was prevented from requesting the hearing due either to specific misrepresentations by the LEA that it had resolved the problem or to the LEA’s withholding of information that the IDEA requires it to provide. § 615 (f)(3)(D). OSEP has clarified that a state may adopt a statute of limitations either shorter or longer than two years by statute or regulation, but not by common law, subject to the notification provisions of IDEA. 71 Fed. Register No. 156 at pages 46696-97 (August 14, 2006). It is the province of the hearing officer to determine whether a specific complaint has been filed within the statute of limitations and whether an amended complaint relates to a previous complaint. 71 Fed. Register No. 156 at pages 46698 (August 14, 2006).

In addition to the requirement that a hearing officer not have a personal or professional interest that would conflict with objectivity, three more qualifications for due process hearing officers were added in 2004. The following new qualities are required in a hearing officer: the knowledge and ability to conduct hearings in accordance with standard legal practice; the knowledge and ability to write decisions in accordance with standard legal practice; knowledge of and ability to understand special education law. § 615 (f)(3)(A)(ii)-(iv). The changes in the qualifications for hearing officers are significant. The fact that the Congress amended this section signals at least some concern about hearing officers. SEA personnel who train and select hearing officers need to be mindful of these changes to the law. Those who train hearing officers should be people with experience in conducting due process hearings and in writing decisions thereafter. New hearing officers should be able to cite prior experience concerning these qualifications. OSEP has noted that pursuant to its general supervisory responsibility, each SEA must ensure that its hearing officers are sufficiently trained to meet the new qualifications established by IDEA. 71 Fed. Register No. 156 at page 46705 (August 14, 2006).

IDEA provides that the party requesting the due process hearing “…shall not be allowed to raise issues at the due process hearing that were not raised in the (due process hearing) notice…,” unless the other party agrees. § 615 (f)(3)(B). see, 34 CFR §300.511(d); 71 Fed. Register No. 156 at pages 46705 -06 (August 14, 2006). However, note that IDEA § 615 (o) provides that nothing in § 615 “… shall be construed to preclude a parent from filing a separate due process complaint on an issue separate from a due process complaint already filed.”

OSEP noted that states have considerable latitude in developing procedural rules for due process hearings and that determinations upon procedural matters not specifically addressed by IDEA are within the sound discretion of the hearing officer so long as the parties’ right to a timely hearing is not denied. 71 Fed. Register No. 156 at page 46704 (August 14, 2006). Other items left to the discretion of the hearing officer include the following: decisions concerning appropriate expert witness testimony. 71 Fed. Register No. 156 at page 46691 (August 14, 2006); ruling upon compliance with timelines and the statute of limitations. 71 Fed. Register No. 156 at page 46705 (August 14, 2006); determining when dismissals are appropriate. 71 Fed. Register No. 156 at page 46699 (August 14, 2006); whether the non-complaining party may raise other issues at the hearing that were not raised in the due process complaint. 71 Fed. Register No. 156 at page 46706 (August 14, 2006); the meaning of the word “misrepresentation” for purposes of the exception to the statute of limitations for filing a due process complaint. 71 Fed. Register No. 156 at page 46706 (August 14, 2006); and providing proper latitude for pro se parties. 71 Fed. Register No. 156 at page 46699 (August 14, 2006).

Concerning the five business day rule for disclosure of evidence prior to a due process hearing, OSEP commented that nothing prevents parties from agreeing to a shorter period of time. 71 Fed. Register No. 156 at page 46706 (August 14, 2006).

As to the location and time of due process hearings, OSEP resisted the suggestion that they be conducted in a “mutually convenient” time and place, fearing that the large number of participants to a hearing would necessitate long delays if mutually convenient times and locations were required. The regulations retain the requirement that hearings be conducted at a time and place that is reasonably convenient to the parents and student. 34 CFR § 300.515(d); 71 Fed. Register No. 156 at page 46707 (August 14, 2006).

Representation by Non-Attorneys in Due Process Hearings

Changes to the federal IDEA regulations effective on December 31, 2008 made an important change to the policy interpretation by OSEP regarding the representation of parties (primarily parents) by non-lawyers in due process hearings. Prior to the change, it had been the long-standing interpretation of OSEP that a non-lawyer could represent parents at a due process hearing in much the same way that a lawyer could represent a party. After certain lower courts declared such a practice to be a violation of “unauthorized practice” statutes, OSEP changed 34 C.F.R. Section 300.512 (a)(1) to specify that whether a party has the right to be represented by a non-lawyer at a due process hearing shall be determined by state law.

Some commenters, including this author, asked OSEP to clarify whether it was sufficient for a state by rule or regulation to specify that parties could be represented by non-lawyers or whether the ability of a lay advocate to represent parents is instead controlled by state law regarding the unauthorized practice of law. OSEP’s “response” was as follows:

Discussion: Whether an SEA may have a State regulation or procedural rule permitting non-attorney advocates to represent parties at due process hearings or whether that issue is controlled by State attorney practice laws is determined by State law. If State law is silent on the question of whether non-attorney advocates can represent parties in due process hearings, there is no prohibition under the Act or its implementing regulations on nonattorney advocates assuming a representational role in due process hearings. 73 Fed Register No. 231 at page 73018 (12/1/2008)

Here is the OSEP Topic Brief on Due Process Hearings:

 Here is the OSEP Questions and Answers On Procedural Safeguards and Due Process Procedures For Parents and Children With Disabilities:



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Bullying of Children with Disabilities - Part X

In My Room from the Bully Series
In My Room from the Bully Series (Photo credit: Wikipedia)
 
 
 
 
Bullying remains the hottest of hot button issues in special education law. 
 
In the first installment of this series, I explained the early cases laying the conceptual groundwork for the proposition that failure to react to bullying can constitute a denial of FAPE under IDEA.  In later installments, I have discussed the seminal decision of TK & SK ex rel LK v. New York City Dept of Educ 779 F.Supp.2d 289, 56 IDELR 228 (E.D.N.Y. 4/25/2011).  This case is important not just because it analyzes special education law principles involving bullying, but also because it provides a thorough review of the social science literature on bullying. You should read this case and you can do so here.
Here is more from the court...these are not my words:
 

F. Effects on Children

If nothing is done to rectify the situation, a bully is likely to continue bullying and victimization continues. Olweus, supra, at 27. Thus, without a change in the dynamic, a child who suffers at the hands of a tormentor, is unlikely to be able to escape. And the effects of bullying are likely to continue unabated. Id. at 28. Each child can be bully, victim, or bystander. And with each of those labels comes different, but often related consequences.

1. Victim

The typical victim of bullying is more anxious and insecure than her peers. Olweus, supra, at 32. She is more likely to be quiet, sensitive, and have low self-esteem. Id. It is important to note, however, that not all victims react in the same way. Macklem, supra, at 63.
"Students who are bullied in schools have no escape from bullying other than feigning illness and staying home which is a very temporary reprieve." Id. at 61. Not surprisingly, being a victim is most strongly associated with a feeling that one did not belong at school and an increase in the classroom days missed. Id. at 70; Glew, supra, at 1030. "Feeling as though one did not belong at school was most strongly associated with being the victim; the odds of members of this group being a victim were 4.1 times higher than those who felt they belonged at school" Glew, supra, at 1030. "For students who felt sad most days, their odds of being a victim were 1.8 times higher than the odds of being a victim among those who did not feel sad most days." Id. Being sad most days is known to be a precursor to diagnoses of major depression. Id.
"The take-home message is that elementary school-aged children ... who struggle academically are more likely to be victims or bully-victims." Id. (defining a "bully-victim" as one who both is the victim of bullying and the bully at different times). Bullying brings with it a whole host of other issues. It impairs concentration and leads to poorer academic performance. Id. Additionally, victims are more likely to engage in antisocial behavior, have increased health problems, and struggle to adjust emotionally. See Macklem, supra, at 68 ("Being the victim of bullying is related to sliding grades, absenteeism, poor academic achievement, being lonely, exhibiting withdrawal behaviors, difficulty acting assertively, or being aggressive."); Snyder, supra, at 1881, 1887; Nansel, supra, at 733-34 ("Youth involved in bullying —as bully, victim, or both—consistently reported significantly higher levels of health problems, poorer emotional adjustment, and poorer school adjustment than non-involved youth. Victims and bully victims also consistently reported significantly poorer relationships with classmates than uninvolved youth.")
[ 779 F.Supp.2d 305 ]

Victims who are friends of a non-victim peer are less likely to internalize problems such as feelings of depression and sadness. Rodkin, supra, at 36. Even children as young as those in first grade who have one friend and do not suffer in isolation, have fewer problems than children who have no peer to rely upon. Id. "The victims are lonely and abandoned at school. As a rule, they do not have a single good friend in their class." Olweus, supra, at 32. This solitude perpetuates feelings of shame and unattractiveness, and a belief that the victim is stupid. Id.
Children with feelings of rejection and loneliness, withdraw and have trouble making new friends. Macklem, supra, at 68. "Withdrawal because a child is rejected by peers places the child at a greater risk [of isolation] than is the case for children who prefer to play alone or who are socially anxious." Id. Victims have lower self-esteem and begin blaming themselves for what is happening. Id. at 69 ("Self-esteem drops once a child becomes a victim.... They blame themselves for being victimized, and give in quickly or respond in a disorganized manner when they are teased or bullied."). "Self-views are unlikely to change for the better, unless the child who has been victimized becomes more accepted in the group." Id.
The end of school does not bring an end to the damage done by years of harassment. As a result of this trapped setting, where harassment is a repeated occurrence, victims carry lasting emotional and psychological scars into adulthood. Id. at 68 (citing Olweus study that found those who were bullied for at least three years in grades six through nine had higher rates of depressive symptoms and lower self-esteem when they were twenty-three years old.)
 
 
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Feds Issue Principles on Seclusion and Restraint

Seal of the United States Department of Education
Seal of the United States Department of Education (Photo credit: Wikipedia)











Today, the United States Department of Eucation  issued 15 principles concerning seclusion and restraint. The document amount to suggestions to states and school districts in formulating their own policies on seclusion and restraint. NOTE: these principles are not a law or regulation, or even policy guidance, they are instead merely suggestions.  But I am already wondering what impact these principles may have in practice.  Parent advocates and lawyers may cite them as authority when they are not followed.  Similarly school lawyers may cite them as a shield when a district's policy is similar or more protective.  Often in this area of law the usual rules regarding precedent and hornbook rules get a little fuzzy.  Also I am wondering if seclusion and restraint cases, like the bullying cases, might have horrendous fact patterns.  Following my previous train of thought in previous posts these cases might water down the Rowley "some benefit" standard.  Thoughts?

The accompanying press release states, "{t}he 15 principles that frame the document ultimately highlight how schoolwide behavioral interventions can significantly reduce or eliminate the use of restraint or seclusion. These guiding principles offer states, districts and other education leaders a framework for developing appropriate policies related to restraint and seclusion to ensure the safety of adults and children.

'Ultimately, the standard for educators should be the same standard that parents use for their own children,” Duncan added. “There is a difference between a brief time out in the corner of a classroom to help a child calm down and locking a child in an isolated room for hours. This really comes down to common sense.' ”

Here are the 15 principles:
1. Every effort should be made to prevent the need for the use of restraint and for the use of seclusion.
2. Schools should never use mechanical restraints to restrict a child’s freedom of movement, and
schools should never use a drug or medication to control behavior or restrict freedom of
movement (except as authorized by a licensed physician or other qualified health professional).
3. Physical restraint or seclusion should not be used except in situations where the child’s behavior poses imminent danger of serious physical harm to self or others and other interventions are ineffective and should be discontinued as soon as imminent danger of serious physical harm to self or others has dissipated.
4. Policies restricting the use of restraint and seclusion should apply to all children, not just children with disabilities.
5. Any behavioral intervention must be consistent with the child’s rights to be treated with dignity
and to be free from abuse.
6. Restraint or seclusion should never be used as punishment or discipline (e.g., placing in
seclusion for out-of-seat behavior), as a means of coercion or retaliation, or as a convenience.
7. Restraint or seclusion should never be used in a manner that restricts a child’s breathing or
harms the child.
8. The use of restraint or seclusion, particularly when there is repeated use for an individual
child, multiple uses within the same classroom, or multiple uses by the same individual, should
trigger a review and, if appropriate, revision of strategies currently in place to address
dangerous behavior;8 if positive behavioral strategies are not in place, staff should
consider developing them.
9. Behavioral strategies to address dangerous behavior that results in the use of restraint or
seclusion should address the underlying cause or purpose of the dangerous behavior.
10. Teachers and other personnel should be trained regularly on the appropriate use of effective
alternatives to physical restraint and seclusion, such as positive behavioral interventions and
supports and, only for cases involving imminent danger of serious physical harm, on the safe use
of physical restraint and seclusion.  Every effort should be made to prevent the need for the use
of restraint and for the use of seclusion.
11. Every instance in which restraint or seclusion is used should be carefully and continuously and visually monitored to ensure the appropriateness of its use and safety of the child, other children, teachers, and other personnel.
12. Parents should be informed of the policies on restraint and seclusion at their child’s school or other educational setting, as well as applicable Federal, State, or local laws.
13. Parents should be notified as soon as possible following each instance in which restraint or seclusion is used with their child.
14. Policies regarding the use of restraint and seclusion should be reviewed regularly and updated as appropriate.
15. Policies regarding the use of restraint and seclusion should provide that each incident involving the use of restraint or seclusion should be documented in writing and provide for the collection of specific data that would enable teachers, staff, and other personnel to understand and implement the preceding principles.


You can read the entire document here.
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Happy Birthday to Us; Tech Update


Today is the fifth anniversary of this blog.  It is hard to believe that we have been around for that long.  Thank you to all of our loyal and enthusiastic readers.

This blog is responsible for dragging me kicking and screaming into the world of modern technology.  In the words of the troubled public defender in the classic movie "My Cousin Vinny," I'm getting better."

One of the ways that we have tried to share information about special education law is through the new social media avenues. Many people read our posts on Facebook.  Others get our headline tweets on twitter.  The best way to be sure you get our posts is still to take one of the free subscriptions on the lefthand side of the blog.

We have added a few new wrinkles.  You can now get our post headlines on our Microblog on Tumblr here.  If you are into Pinterest, we have added a button on the left hand side of the blog you can use to pin our site to a board. (I'm not quite sure how this works yet.)  We also have added an Evernote site memory button if you use Evernote, that really cool site that remembers everything for you. And we have added a google plus button for google plus users.

The corporate overlords at Facebook have "archived" our special education law group.  We had 900+ members, but now you have to join again to participate.  Apparently we only exchanged information rather than  obsessively chattering about inane matters.  The good news is that the LinkedIn Special Education Law Group now has over 3000 members and the discussions there are very lively. You can check it out here.

As always, we are open to suggestions as to other "new" ways to provide information about special education law.  As an impartial, either a mediator, hearing officer or consultant, I don't have an advocacy position.  Our goal here is to ensure that all stakeholders have as much good information as possible and a forum to discuss issues in this rapidly growing body of law.  Let us hear from you.
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OSEP Wants You! Results Driven Accountability

Uncle Sam recruiting poster.
Uncle Sam recruiting poster. (Photo credit: Wikipedia)







You may recall that in a recent post, I mentioned the press release by the federal Office of Special Education Programs stating that they were suspending their verification visits and contemplating a system driven more by results than compliance.  Here is the old post.

On the OSERS website you can find the press release and a Questions & Answers document as well as a summary of the new acronym RDA (results driven approach.)

Also the OSEP director, Melody Musgrove, has announced a new email address where you can submit your opinion as to what should be included in the new monitoring approach. You can put in your two cents at OSEP-RDA-input@ed.gov OSEP wants your opinion; give it to them!

Also please let me know what you think of this new approach.
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Procedural Safeguards - The Series Part IX

Confidential
Confidential (Photo credit: highersights)




This is the ninth installment in a multi-part series on procedural safeguards under the federal special education law, the Individuals With Disabilities Education Act. I work a lot in this area, so it is near and dear to my heart. Despite the importance of procedural safeguards. however, many issues in this area are misunderstood. I hope that all of the different types of special education stakeholders who read this blog find the information in this series helpful.




Resolution Session Meetings


A mandatory resolution session was added to the special education dispute resolution process in 2004. IDEA § 615 (f)(1)(B). Within 15 days of receipt of a due process hearing complaint from a parent, the school district must convene a meeting with the parents, a representative of the LEA with “decision making authority,” and relevant member(s) of the IEP team who have “specific knowledge of the facts identified in the complaint.” The purpose of the resolution session is to permit the parents to discuss their complaint and the underlying facts and to provide the LEA the opportunity to resolve the complaint. The LEA may not bring their lawyer unless the parent has a lawyer. The parties may avoid the resolution session only by waiving the meeting in writing or by participating in mediation. § 615(f)(1)(B)(i). If the LEA has not resolved the complaint to the satisfaction of the parents within 30 days after receipt of the complaint, the hearing may occur and “all applicable timelines for a due process hearing” shall commence. § 615(f)(1)(B)(ii). If the resolution session results in a written settlement agreement, the agreement is legally binding and enforceable in court, except that if either party suffers from “buyer’s remorse,” they may void the agreement within three business days after it is executed. § 615(f)(1)(B)(iii) and (iv).

Attorneys who represent parents are barred from seeking attorney’s fees and costs if they decide to participate in the resolution session. § 615 (i)(3)(D)(ii)and(iii).

Unless one of the exceptions apply, the 45 day deadline for the hearing officer decision begins after the resolution period ends. 34 C.F.R. §300.510(b)(2).

Unlike the mediation provisions of the Act, which contain a specific guarantee of confidentiality for any discussions during a mediation session, §615 (e)(2)(G), there is no confidentiality protection for discussions that take place during a resolution session. OSEP specifically rejected the request of several commenters on the proposed 2006 federal regulations to clarify whether discussions at resolution meetings are confidential because the Act is silent regarding confidentiality. 71 Fed. Register No. 156 at page 46704 (8/14/06). OSEP went on to say that although the parties could negotiate a confidentiality agreement as a part of their written resolution agreement, a state could not require the parties to a resolution meeting to keep the discussions confidential. 71 Fed. Register No. 156 at page 46704 (8/14/06)(emphasis not in original).

The federal regulations provide that where a parent does not participate in the resolution meeting, the timelines for both the resolution process and the hearing will be delayed. 34 C.F.R. § 300.510(b)(3). To avoid the potential perpetual stay-put problem caused by the proposed regulations, the final federal regulations added a provision that if the LEA is unable to obtain the participation of the parent after reasonable efforts (which now must be documented in the same manner as IEP Team meeting participation), the LEA may, at the conclusion of the 30 day period, request that the hearing officer dismiss the due process complaint. 34 C.F.R. § 300.510(b)(4).

34 C.F.R. § 300.510(b)(5), that provides that where an LEA fails to schedule the resolution meeting within fifteen days, or the LEA delays the due process hearing by scheduling the resolution session at times or places that are inconvenient for the parent, or the LEA otherwise fails to participate in good faith in the resolution process, the parent may seek the intervention of the hearing officer to begin the due process hearing. 71 Fed. Register No. 156 at page 46702 (8/14/06). Although OSEP stated that it believes that such occurrences would be very rare, it agreed with commenters that parents should be able to request that the hearing officer begin the hearing process timelines in such cases. 71 Fed. Register No. 156 at page 46702 (8/14/06).

Although the resolution meeting includes “relevant” members of the IEP Team, it is clear that the resolution meting is not an IEP Team meeting. The purpose of the resolution meeting is for parents to discuss their complaint and the underlying facts and for the LEA to have an opportunity to resolve the dispute. § 615(f)(1)(B)(i)(IV); 71 Fed. Register No. 156 at page 46701 (8/14/06). In response to a commenter who questioned whether a resolution meeting agreement supersedes decisions made by the IEP Team, OSEP stated that nothing in the Act or regulations requires an IEP Team to reconvene following a resolution agreement that includes IEP-related matters. 71 Fed. Register No. 156 at page 46703 (8/14/06).

The purpose underlying the resolution meeting is described in a portion of the conference committee report that discusses the resolution session states that these changes address “unscrupulous lawyers and an overly complex system” that has “led to an abundance of costly and unnecessary lawsuits.” The conference report goes on to explain that the resolution sessions are needed because “...(t)oo often, schools are unaware of parental complaints and concerns until an official complaint is filed and the legal process is already underway.” H.R. 1350 Conference Report, (November 17, 2004).

Here is an analysis by CADRE of Resolution Meetings- State Supports and Practices.

Here is a now somewhat dated (2006) presentation by me concerning the resolution session at a CADRE National Conference.


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