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Education professionals and parents need to be able to understand federal requirements for individualized educa- tion program (IEP) meetings, both to ensure compliance and also so that they are able to recognize potential violations. Part of this understanding should include knowledge of certain “core principles” of the Individuals With Disabilities Education Act (IDEA; 2006): zero reject, nondiscriminatory evaluation, individualized and appro- priate education, least restrictive envi- ronment, procedural due process, and parent participation (H. R. Turnbull, Stowe, & Huerta, 2007). Although many schools have made

significant strides in providing special education services to students with disabilities, recent studies indicate that many barriers still exist to fully imple- menting IDEA. For example, although some general and special educators and school administrators support inclusive services for students with

disabilities, others do not (Pugach, 2005; Wolery & Odom, 2000; Young, 2008), citing lack of resources, class size, and inadequate training for teachers (Carlson, Brauen, Klein, Shroll, & Willig, 2002). Similarly, schools may provide families with little helpful information regarding IDEA (Lake & Billingsley, 2000)—or provide them with information that’s not easy to understand (Fitzgerald & Watkins, 2006; Mandic, Rudd, Hehir, & Acevedo-Garcia, 2010). Thus, many families may face challenges in their pursuit of an IDEA-mandated equitable education for their children with dis- abilities (Harry, 2008; Hess, Molina, & Kozleski, 2006); these struggles are evidenced by the frequency of adjudi- cated due process hearings nationwide (i.e., approximately 2,800 per year; Zirkel & Gischlar, 2008)—which likely represents only a proportion of fami- ly–school disputes.

Current research on parental reports of their experiences during the IEP process suggests that favorable percep- tions are the exception rather than the norm. In their review of 10 studies on parental views of the IEP process pub- lished since 2004, Reiman, Beck, Coppola, and Engiles (2010) found only one study reporting that the majority of parent participants indicat- ed overall positive experiences (i.e., Fish, 2008). The remaining studies indicated that parents felt high levels of dissatisfaction during IEP meetings, with parents citing difficulty process- ing the information (Stoner et al., 2005), being intimidated by educators and blamed for their children’s aca- demic and behavioral difficulties (Fish, 2006), and being relegated to roles in which their participation was limited to listening to information about their child’s education, answering ques- tions, and signing preset forms on stu- dents’ goals (Childre & Chambers,

50 COUNCIL FOR EXCEPTIONAL CHILDREN

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Teachers + Families = Success for All Students

2005). These findings underscore the importance of supporting educators with research-based recommendations for enlisting parents as collaborators during the IEP process. When educators and parents collab-

orate to confront and resolve disputes, parent satisfaction with special educa- tion services can increase (Mueller, Singer, & Draper, 2008). The Council for Exceptional Children’s (CEC) best practice recommendations for collabo- ration (2009) provides guidance for parents and educators to work together in the best interest of the student. Some first steps towards productively addressing conflicts that may arise dur- ing the IEP process include IEP team members understanding the IDEA requirements, including the core princi- ples of IDEA (H. R. Turnbull & Turn- bull, 1998; H. R. Turnbull, Stowe, & Huerta, 2007) listed below:

• Zero reject: All students with disabil- ities are entitled to a free appropri- ate public education (34 C.F.R. §§ 300.121 and 300.122; Timothy W. v. Rochester School District, 1989).

• Nondiscriminatory evaluation: Assessment of students with or sus- pected of having a disability must be fair (34 C.F.R. § 303.323).

• Individualized and appropriate edu- cation: Students with disabilities must receive individualized services to provide a beneficial education (34 C.F.R. §§ 300.320–300.324).

• Least restrictive environment (LRE): To the greatest extent beneficial, students with disabilities should be educated in a typical setting with students who do not have disabili- ties (34 C.F.R. § 300.550[b][1] and [2]).

• Procedural due process (safeguards): Schools and parents hold each other

mutually accountable; these safe- guards also provide dispute resolu- tion procedures (34 C.F.R. § 300.507[a] and 300.508[a]–[c]).

• Parent participation: Parents and students with disabilities are part- ners with educators in decision making about students’ education (34 C.F.R. § 300.345).

IEP team members must also have the confidence to speak up when its man- dates are not being followed. In this way, special educators can speak up in response to things that should not be said during IEP meetings. Following are six illustrative case

vignettes, which include statements that parents and professionals should not hear at IEP meetings, a commen- tary about each case vignette, and sug- gested responses for educational pro- fessionals should they encounter situa- tions similar to those in the vignette.

TEACHING EXCEPTIONAL CHILDREN � JAN/FEB 2012 51

1. The Time Saver

Special education professionals are seemingly always pressed for time. Any strategy that can save time is valuable. This vignette involves two principles of IDEA that are relevant to Jonas’s math goals: individualized/appropriate edu- cation and parent participation. First, to meet IDEA requirements for an indi- vidualized appropriate education, spe- cial education teachers must support students’ access to the general educa- tion curriculum and meet state stan- dards (U.S. Department of Education, 2010). Goals and objectives should be developed as a team, on the basis of formal and informal assessment data regarding the child’s current strengths and weaknesses gathered through a nondiscriminatory evaluation (A. Turnbull, Turnbull, & Wehmeyer, 2010; 34 CFR § 303.322). Although a “bank” of IEP goals can be a productive place to start the process of identifying stu- dent goals (and many school districts provide them), these resources may not be appropriate as goals to meet an individual student’s needs. IDEA requires teachers to gather assessment data to determine the student’s present

level of academic achievement and functional performance (34 C.F.R. § 320[a]), which leads to collaborative development of IEP goals during the IEP meeting. The IEP team determines which goals are most appropriate and most likely to meet the individual needs of the student. This individual- ization and personalization means that the team must adapt any “off-the- shelf” goals to meet the individual stu- dent’s needs. Moreover, IDEA requires that par-

ents must be provided opportunities for meaningful participation in any dis- cussion of their children’s education (34 CFR § 300.322). Clearly, Jonas’s mother was excluded from collaborat- ing with the other IEP team members regarding Jonas’s goals. Simply reading a list of predetermined goals and ask- ing for a parent signature does not engage parents in collaborative deci- sion making; instead, it relegates them to recipients of the school profes- sionals’ decisions (A. Turnbull, Turn- bull, Erwin, Soodak, & Shogren, 2010). School personnel can enhance parent participation by allowing sufficient time for meetings, refraining from com- pleting forms in advance of parental input, and perhaps even providing par- ents with a copy of draft IEP goals and objectives a few weeks before the meeting. All of these actions are part of a democratic process that enhances parental sense of ownership as team members (Blue-Banning, Summers, Frankland, Nelson, & Beegle, 2004; Fish, 2006, 2008). Instead of a directive to sign an IEP absent meaningful parental input, what IEP team mem- bers should hear is the friendly buzz of voices as educators and parents work together toward understanding and agreement about the students’ strengths and areas for improvement, which naturally leads to individualized goals and objectives.

�� The Right Response

Instead of “I have already prepared the goals; please sign here,” educators should emphasize, “I think we can all agree how important it is to work as a team for Jonas. Other IEP team mem- bers have important things to share

about Jonas and, like you, we’d like to work together to develop the best IEP goals for Jonas that we can.”

2. The LRE Plea

Many educators are apprehensive about inclusive settings. Some believe that students with disabilities need specialized settings outside of the gen- eral education classroom to best access individualized instruction (Kavale & Forness, 2000). Others may not believe students with disabilities should be held to the same academic standards as students without disabilities (Agran, Alper, & Wehmeyer, 2002), which can lead to recommendations like that of the educators on Marissa’s team. However, the IDEA principles of

least restrictive environment (LRE) and appropriate education apply here. LRE guarantees a student’s right to be edu- cated in the setting most like that for peers without disabilities wherein the student can be successful with appro- priate supports and services (Palley, 2006; 34 C.F.R. § 300.550[b][1] and

52 COUNCIL FOR EXCEPTIONAL CHILDREN

At a recent IEP meeting, Jonas’s mother entered the conference room and enjoyed a friendly chat with the general education teacher, special education teacher, and the school principal. The group began the for- mal part of the meeting by sharing their concerns for 15-year-old Jonas at school. Jonas’s mother said that she had been worried about Jonas’s math skills for years. At the time of the IEP meeting, he continued to lag behind his peers, but had made progress. The teachers confirmed that Jonas continued to have difficul- ty with math problem solving, in both science and math class, despite the help of his special and general education teachers. The special edu- cation teacher said, “Good news! We have a new book with tons of IEP goals. We picked a few and entered them on the IEP. So the IEP’s all done. I’ll read the goals and then you can sign here.”

Marissa is an energetic 5-year-old with communication and cognitive delays, previously served successful- ly in an inclusive preschool setting. At the start of Marissa’s IEP meet- ing, Marissa’s parents were happy to learn that the professionals at their daughter’s new elementary school seemed to have collaborated effec- tively with her previous preschool teachers. However, when discussing the setting for her special education services, the educators were reluc- tant to place Marissa in a general education kindergarten setting. “Because she’s new to kindergarten and to the school,” one teacher said, “let’s see how well Marissa does in a resource room or self-con- tained classroom before we place her in a more inclusive setting where she may be overwhelmed.” Marissa’s parents were disappoint- ed, because they strongly believed Marissa benefited from being edu- cated with her typical peers and pre- viously had been successful in this type of setting.

[2]). The result is a presumption of educating students with disabilities in general education settings; this pre- sumption may be set aside by the team (which includes the parents) only after intensive supports, supplementary aides, and services have been provided in the general education classroom without success (Friend & Bursuck, 2009). Therefore, the discussion of Marissa’s placement must begin with consideration of the general education setting before moving to a discussion of more restrictive settings—instead of the reverse. The IEP team should also outline the continuum of services avail- able to Marissa and meet the IDEA requirement for appropriate education by tailoring a program to meet her individual needs.

Universal design for learning is a research-based strategy that promotes inclusion of students with disabilities (A. Turnbull, Turnbull, & Wehmeyer, 2010) and can result in academic and social benefits for all students (Cole, Waldron, & Majd 2004; Idol, 2006; McGregor & Vogelsberg, 1998; Salend & Duhaney, 1999; see www.cast.org/udl). The IEP team meeting should include a discussion of the specific techniques and adaptations that address Marissa’s presenting areas of need and how these can be integrated as part of the teacher’s instructional delivery natural- ly and throughout the course of the school day.

�� The Right Response

The IEP meeting should include a fruit- ful discussion about the availability of strategies for supporting the student in the least restrictive environment. A teacher can say, “I can appreciate your concerns for Marissa’s success given the new challenges she and all of the other new students will experience in the kindergarten classroom. I have no doubt that if we put our heads together

about ideas for strategies to support her, we’ll feel confident in providing Marissa the opportunity to start off in the kindergarten classroom.”

3. Who’s in Charge?

The salient IDEA principle in this situation is the assurance of proce- dural safeguards (i.e., due process rights; 34 C.F.R. § 300.507[a] and 300.508[a]–[c]). Procedural due pro cess ensures that schools carry out IDEA principles. IDEA mandates that the IEP team include a representative of the school system who is qualified to pro- vide or supervise special education and is also knowledgeable about the general education curriculum and school

resources (34 C.F.R. § 300.321[a]). During IEP meetings, the LEA repre- sentative has the responsibility to (a) make sure the appropriate special edu- cation services are provided to the stu- dent and (b) supervise and commit resources for those services listed on the IEP. It is the responsibility of the LEA representative and the other mem- bers of the IEP team to ensure that these decisions and responsibilities are met and that procedural safeguards regarding the participation of appropri- ate team members are followed. The IEP team should be appropriately con- vened (i.e., all required members pres- ent) before proceeding. This means that the team members include the special education teacher, the general education teacher, a representative of the district/school who has the author- ity to release the resources of both time and personnel, the parent, and any other required member necessary to conduct the IEP meeting.

�� The Right Response

In planning the IEP meeting, educators should ensure that everyone who is required to be at the meeting attends. At the beginning of the meeting, the team should be able to answer the question “Which IEP team member is ultimately responsible to supervise and ensure that appropriate educational services will be provided for this child?”

4. The Search Ain’t Over Until It’s Over

TEACHING EXCEPTIONAL CHILDREN � JAN/FEB 2012 53

Suzie is a third grader who loves science. She has a specific learning disability in reading decoding and comprehension. The IEP meeting included the special education teacher, the general education teacher, the speech/language pathol- ogist, and Suzie’s mother, and was going very well. After developing the IEP goals based on the state standards (as required by IDEA, 34 C.F.R. § 200.1[f][2][ii][B]), they determined Suzie should receive 2 hours a week of speech/language services to meet her academic goals. However, no local education agency (LEA) representative, such as the principal or special education direc- tor, was present (or designated) at the meeting, as required by IDEA. As the meeting was winding down, the special education teacher said, “I need to check with the special education director before determin- ing the recommended level of speech/language services for Suzie” and left the meeting room to get the LEA’s signature.

School personnel can enhance parent participation by allowing sufficient time for meetings, refraining from completing forms in

advance of parental input, and perhaps even providing parents with a copy of draft IEP goals and objectives a few weeks before the meeting.

Johnny is a fifth-grade student whose IEP meeting started off congenially until it came to addressing IEP goals—when Johnny’s parents noticed that his proposed reading goals were nearly the same as those in his IEP from the previous school year. When his father asked why, the special education teacher explained, “I don’t know what else to try with him. He has not improved this year even after I’ve tried every strategy to help him attain his goals and nothing works.”

The IDEA principle of an individual- ized/appropriate education (34 CFR §§ 300.121 and 300.122) is important here. The key word in the vignette is everything. At times, teachers continue to implement familiar strategies rather than investigating different research- based interventions or discussing ideas for strategies with parents and other professionals. After an IEP is written for a student, it is the respon- sibility of the special education teacher to continually measure progress against the IEP goals. This can be accomplished through system- atic progress monitoring—when teach- ers assess student performance on a regular basis to determine whether children are benefiting from instruc- tion, implement research-based strate- gies, and then monitor students’ progress or lack thereof (Fuchs & Fuchs, 2003). The special education teacher’s role is similar to that of a detective: to research instructional strategies while also collecting data to determine if the strategy is effective, and to discard those strategies that are ineffective (i.e., strategies that do not help students make progress on their IEP goals). School districts must provide ongo-

ing training for teachers regarding research-based instructional strategies to meet the needs of individual stu- dents with disabilities. The parent can also be a resource for ideas regarding the child’s learning style, which may help in researching appropriate strate- gies. Discussing interventions with other professionals (e.g., administra- tors, school social workers, psycholo- gist, curriculum specialists, and/or other teachers) is also a way to discov- er ideas to implement with the student. The U.S. Department of Education refers states and districts to some Internet web sites, which supply quali- ty information regarding research- based strategies (e.g., http://nichcy. org/research/basics/disabilities, http:// www.nectac.org/topics/evbased /evbased.asp).

�� The Right Response

After reviewing the list of strategies that have been implemented with the

student, how long each strategy was used, and evidence illustrating the effectiveness of use, the team might instead ask the teacher, “Have you discussed this challenge with other professionals to see if they have any other research-based teaching sugges- tions?” or “What kinds of professional development could benefit the IEP team’s decisions about instructing Johnny?”

5. Pass The Buck

Two principles of IDEA apply here: LRE and parent participation. Teachers in content-area classes may not have received adequate preparation for inclusive practices (DeSimone & Parmar, 2006). As frustration grows, particularly because the other students in the class seem to grasp concepts quickly, teachers may assume that the home environment is to blame. Consequently, they may recommend alternative placements for the student’s “own good,” placing the student in a more restrictive environment with

other students who have similar chal- lenges. Student outcomes can suffer; according to Kerr and Nelson (2010), parents may avoid interactions with school personnel because of perceived blaming by teachers. It is incumbent upon the school staff to invite parents’ suggestions and their participation in their student’s education. Friend (2011) admonished teachers to be aware of parents’ diverse understandings of their children’s special needs and empha- sized that the teacher’s responsibility is to overcome negative perceptions, to offer help to families, and to provide services that are exemplary and appro- priate to the individual student. In this case, a mutual sharing of information regarding Nick’s specific math chal- lenges should have set the agenda for the discussion.

54 COUNCIL FOR EXCEPTIONAL CHILDREN

Nick is an 11th-grade student with learning disabilities who is in an inclusive class for mathematics for the first time this year. At the IEP meeting, the mathematics teacher shared some positive comments about Nick’s behavior in class but struggled when describing Nick’s mathematics performance: It seemed to him that Nick viewed high school as more about socializ- ing than academics. In frustration, the mathematics teacher blurted out, “Look, honestly, Nick, you are just not interested in mathematics like the other students. I prepare for the class each day. I have asked you a million times how you learn best and you always reply, ‘I don’t know.’ Perhaps if he spent an hour or two at home each night on math- ematics and you [his parents] encouraged him to do better at school, we wouldn’t have this prob- lem. Or if not, we could refer him to a separate class that caters to stu- dents who are not motivated where he can be more successful.”

Parents’ participation in decisions regarding the education of their stu- dent with special needs is emphasized in IDEA. Viewing parents as a support for mutual academic and behavioral goals rather than the source of the school problems should underlie col- laborative efforts (Duchnowski, 2007; Eber & Keenan, 2004). Helping families support academic and behavior improvements made at school is an effective collaborative approach to addressing inconsistency between home and school behaviors. Moreover, parents need to have input about inter- ventions if they are expected to support learning goals (Kerr & Nelson, 2010). Nick’s parents needed the opportunity to communicate his successes at home and to use those as a springboard to

address the challenges Nick faced in class. Nick himself should also be a criti-

cal participant in the development of his IEP. Mason, McGahee-Kovac, and Johnson (2004) found that students who led their IEP meetings meaning- fully contributed to them, demon - strated an understanding of their dis- ability rights and accommodations, increased in their self-confidence, were able to self-advocate, interacted more positively with adults, assumed more responsibility for themselves, and were more aware of their limitations as well as the resources available to them; moreover, parental participation increased. Students in Hawbaker’s (2007) study consistently reported that leading their IEP meeting was one of the most memorable learning experi-

ences of the school year. Further, stu- dents who were involved with the stu- dent-led IEP process felt greater empowerment when they were actively involved in their decision-making process (Barrie & McDonald, 2002).

�� The Right Response

During the IEP meeting, teachers should stress the common goal of meeting the student’s needs (e.g., “We are all concerned about Nick’s suc- cess.”). Asking IEP team participants to highlight the student’s strengths can help identify ways to enhance progress toward goals. For instance, the math teacher could say to the parent, “I remember you said that Nick uses a computer assisted design program at home—he loves to construct buildings and produce blueprints. You also said that he rarely declines a math chal- lenge. How do you think we could incorporate some of Nick’s interests into classroom activities and his learn- ing goals?”

6. The Old Standby

TEACHING EXCEPTIONAL CHILDREN � JAN/FEB 2012 55

Jacob is a friendly 13-year-old boy with retinitis pigmentosa, a heredi- tary eye disorder characterized by progressive vision loss. Although he has participated actively in school programs (including general educa- tion classes) over the course of his childhood, Jacob has experienced persistent visual loss, resulting in significant low vision, and receives special education services via an IEP. Jacob’s family recently moved to a new school district in another state just at the start of the school year. At the IEP team meeting, the educators told his parents that their school did not serve students with significant vision problems or stu- dents who are blind, stating “We don’t have the personnel to serve students with vision impairments. We always refer these students to the school for the blind, which has excellent programming for students like Jacob and can better cater to his unique needs.”

Many educators may have concerns about serving students with relatively low-incidence disabilities with which they may not be familiar. At the sec- ondary level, many teachers still believe students with severe disabilities cannot be appropriately served in gen-

eral education classes or even in their neighborhood schools (Smith, 2000). The IDEA principle of zero reject applies in this case: special education services must be available wherever there are students who qualify for its benefits (A. Turnbull, Turnbull, & Weh - meyer, 2010; Timothy W. v. Roches ter

School District, 1989). Although the team members may not believe that they are refusing Jacob an appropriate education—because they are offering an alternative that they believe is a more appropriate placement—the team is still subtly violating the zero reject principle. Regardless of the nature or severity of the disability, the school district has the responsibility to provide a free and appropriate education by implementing the existing IEP or start- ing the assessment process to develop a new one. Schools must document efforts to provide an appropriate edu- cation at the student’s home school and in the least restrictive environment before determining an alternative set- ting is more suitable to address the stu- dent’s needs.

�� The Right Response

Jacob’s school personnel showed a lack of effort to provide appropriate services, instead relying on “the old standby”; their recommendations were based on the way things had always been done. A more appropriate response to a situation like this would be for the teachers and parents to emphasize the child’s strengths and previous services as outlined in his IEP. For example, an educator could say, “Because Jacob’s parents knew that he was slowly losing his sight, he has developed, with the help of his teach- ers, the necessary mobility skills to move safely from class to class and other skills to compensate for his low vision. He has always been placed with

his same-age peers and we should con- tinue that level of service. Let’s consult with the state school for resources and support to help us with Jacob here.”

Final Thoughts

Families and schools face many chal- lenges as they work toward following

the letter and spirit of IDEA. Although educators are typically well meaning in their efforts to educate students with disabilities, some things should never be said or heard during IEP meetings. When education professionals know the six principles of IDEA and words to respond to potential violations of the principles, IEP teams can better meet the needs of students with disabilities.

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Gregory A. Cheatham (Kansas CEC), Assistant Professor, Special Education Department, University of Kansas, Lawrence. Juliet E. Hart (Arizona CEC), Assistant Professor; and Ida Malian (Arizona CEC), Professor, Division of Teacher Preparation, Arizona State University, Phoenix. Joan McDonald (Arizona CEC), Deputy Associate Superintendent, Arizona Department of Education, Phoenix.

Address correspondence concerning this article to Gregory A. Cheatham, 1122 W. Campus Rd., University of Kansas, Lawrence, Kansas 66045-3101 (e-mail: [email protected]).

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