Association (LDA) Comments on the
Report of the President’s Commission on
Excellence in Special Education
August 2002, LDA of America
Visit LDA of America online at:
The Learning Disabilities of America (LDA)
applauds the formation of the President’s Commission on
Excellence in Special in Special Education (the Commission) and
the vision of encouraging “every child to learn to his or her
full potential” that it seeks to advance. The Report is the
result of nine months of listening, reading, questioning,
discussion, and writing that resulted in nine Findings and three
Major Recommendations accompanied by seven sections containing
additional recommendations and narrative. The Report addresses a
variety of topics related to the education of children with
disabilities and designed to guide the Re-authorization of
LDA is a non-profit organization of over 40,000 volunteers
across the country including individuals with learning
disabilities, their families, and the professionals who work
with them. LDA is dedicated to identifying causes and promoting
prevention of learning disabilities and enhancing the quality of
life for all individuals with learning disabilities by:
encouraging effective identification and intervention,
fostering research, and
protecting their rights under the law.
LDA’s comments and response are based on review of the Report,
along with direct involvement by several dozen LDA members over
the past nine months. At least one LDA member attended each of
the 13 Task Force meetings held across the country to listen to
the invited panelists, provide oral comments and submit eleven
more extensive written comments on the specific meeting topics.
LDA extends its thanks to these volunteers for the time, energy,
and financial commitment they made during the public comment
process, as well as to those on the LDA Public Policy Committee,
all of whom contributed to this report.
A. Overall Strengths of the Report
LDA supports Major Recommendation 1 to the extent that IDEA’s
focus on results should increase and become more balanced with
attention to process. At the same time, LDA reiterates the need
for continued federal monitoring for compliance with processes
that must be in place if improved educational results are to
occur. To ignore process is to jeopardize positive results.
LDA recognizes and values Major Recommendation 3, urging that
“children with disabilities” should be considered as “general
education children first,” because it could foster a feeling of
joint responsibility between general and special education
personnel. Concerns remain, however, about the effects of
policies, practical implementation, and procedural protections,
as well as funding costs and flexibility, that might result from
such an approach.
LDA strongly supports the Report Recommendations that address
the need for recruiting, training, and publicly reporting the
performance of teachers. Highly qualified teachers, along with
similarly high quality administrators and related services
personnel are critically necessary. LDA notes, however, that
adequate resources and a supportive administrative environment
are also vital for the continued progress toward improved
educational outcomes of our students with disabilities.
LDA strongly supports the value of early screening,
identification, and research-based instruction in early reading
as an important foundation for reading and lifelong learning.
LDA strongly opposes any suggestion that such efforts will
prevent learning disabilities or that currently proposed
alternative assessment/identification approaches will guarantee
elimination of “wait-to-fail.” However, LDA has consistently
expressed support for carefully structured and evaluated
research into a variety of alternative assessment/identification
models in order to determine whether any of them offer improved
results over currently used models.
LDA supports the Report’s Recommendation that data be gathered
and analyzed to assist in determining the true excess costs of
special education across states.
LDA strongly supports Report Recommendations in the area of
dispute prevention and resolution through parent empowerment and
availability of a range of avenues to foster amicable
LDA recognizes the potential value of simplified transition
requirements, interagency cooperation, and higher education
involvement to smooth and improve the transition to
post-secondary education and work. Thus, LDA strongly supports
the Report Recommendations related to Post-Secondary results,
with the hope that practical details of implementation can be
put in place.
LDA supports Report Recommendations concerning paperwork
reduction that encourage the use of clerical support,
technology, and targeted technical assistance, as well as
carefully defined, time-limited waivers for selected states to
determine appropriateness and effectiveness prior to approval of
LDA supports the Report Recommendations providing direction for
needed research-based information about assessment,
identification, intervention, teacher training, minority
over-identification, and a host of other questions raised in
various areas of the Report. A strong research base is required
prior to mandated changes in IDEA and its implementation.
B. Overall Areas of Great Concern
LDA was disappointed to find gross oversimplification and
over-generalization in the Report’s proposed solutions to very
complex and human problems. Some of these generalizations ignore
or inaccurately reflect the testimony of expert witnesses. A
related problem was the tendency to use terms without sufficient
definitions, which made it impossible to understand proposals
and react logically to them.
LDA is greatly troubled by Major Recommendation 2, which focused
on the narrow and poorly documented area of promoting a model of
prevention to replace the current model of failure. LDA is very
supportive of new models and approaches offering improved
educational outcomes for the nation’s students with
disabilities. However, the proposed reform depends on early
identification and quick scientifically based intervention to
prevent failure, although there is not yet research evidence
that such a model improves educational outcomes when implemented
in large-scale, diverse settings. Equally of concern is the
suggestion that massive reforms in K-12 schools, teacher
education, and program supports would also be based on such an
untested and unproven model.
Unfortunately, LDA also found that the Commission appears naïve
about how government agencies function. This is particularly
evident in the many structural and relationship changes that are
implied in the Recommendations and narrative throughout the
Report. These include those between general and special
education, within OSEP, and among the many agencies involved in
providing comprehensive services for children birth through 5
and individuals with disabilities beyond age 21. There is also a
failure to recognize the difference between federal and state
level requirements and their practical implications, or even
whether the requirements are to be set at the national or state
level. For example, state to state comparisons are of little
value when federal standards for compliance, performance and
state to state comparisons are established, but each state uses
its own standards and accountability measures.
LDA also notes with considerable alarm, that both the Report
narrative and recommendations often reveal a lack of knowledge
about the details of what IDEA-97 and NCLB actually do or do not
require and an unfamiliarity with what OSEP and OSERS have
actually initiated since 1997. The result is fuzzy
generalizations that do not reflect reality. In a similar way,
many Commission Recommendations are based on perceived problems
with IDEA, but no specific statute or regulations are cited as
the source of the difficulty, nor is any alternative language
recommended to correct them.
When LDA compared the six facts used by the Commission to
justify “an urgency for reform that few can deny” (Introduction)
with the Report content, none addressed decreasing dropouts,
increasing graduation rates, meeting grades 3-12 needs, or
ensuring a smooth transition. Instead, there was a consistent
focus on early identification and intervention in reading—an
area already addressed through NCLB. LDA also noted with concern
the major focus on what are termed “high incidence” disabilities
while the needs of “low-incidence” disabilities were largely
ignored except to suggest “risk pool” financing, support
safety-net funding and advocate targeting through full funding
LDA views with alarm the lack of financial sophistication in the
Commission’s Report. For example, the Commission suggested that
full funding be available for the severely handicapped, while
reduced or “projected” funding was seen as adequate for children
with so-called high-incidence disabilities who are mildly
handicapped. At various points, poorly defined proposals
recommended that funds for birth through 5, for general and
special education, and for birth through 21 be pooled; and that
90 percent of state funds be “passed through” to localities.
Never mentioned, however, was how IDEA protections would be
preserved, compliance would be ensured, or needed services would
be maintained or improved.
LDA found both the Report Recommendations and narrative to be
disconnected, disorganized, and repetitive as they are
reiterated throughout the document. This was especially evident
for SLD identification processes, early reading intervention,
excessive regulation and paperwork, scientifically-based
information and general/special education collaboration. In
contrast universal design in accountability and unified services
for birth through 21 received brief discussion and
recommendations without any reference in the Report’s formal
LDA identified numerous inconsistencies within the Report. For
example, the Commission makes frequent negative comments about
local variation in identifying and serving students with special
needs across states. Yet Commission support is offered for
“state flexibility to use IDEA funds” and universal screening
that is “locally driven…is associated with better outcomes…for
all children” (p.20).
From LDA’s perspective, there is little understanding on the
part of the Commission that time is required for the
scientifically-based research and careful planning that will
lead to successful change in national policy and practice. LDA
knows from experience how disastrous quick fixes that seem so
obviously right, can in fact, become disastrous for a generation
or more of children. Time is a critical factor in the careful,
considered, and thoughtful steps that must be taken to ensure
that promised positive change will actually enlarge educational
opportunities for America’s students with disabilities.
While LDA agrees that the Re-Authorization provides an important
opportunity to review past progress, evaluate current status,
and move toward continued improvements. However, LDA also agrees
with the recent testimony of former Congressman William
Goodling, under whose stewardship the 1997 reathorization was
accomplished. In his testimony before the House Education and
the Workforce Committee, Mr. Goodling stated that the focus of
this re-authorization should be on minor refinements in
implementation through the regulations, rather than on “creating
additional federal mandates in the statute.
LDA reviewed the Reports’ seven sections, including
Recommendations and narrative which accompanied those sections.
LDA’s comments on each section are provided below.
A. FEDERAL REGULATIONS, MONITORING, PAPERWORK, and FLEXIBILITY
1. Change monitoring from technical assistance (TA) and process
to a focus on performance and results
LDA supports the use of the focused monitoring process adopted
by OSEP to allow stakeholders to give advice on priorities that
include both process and results, along with continued use of
the existing Continuous Improvement Monitoring system.
LDA opposes replacement of or major changes in current
monitoring and technical assistance until all states have had
the opportunity to complete at least one cycle under the
continuous improvement monitoring model.
LDA notes the following concerns and suggestions related to the
Recommendation and narrative:
Consideration should be given to providing for graduated
sanctions that may be employed by OSEP to encourage compliance.
If the case outlined by a New York official is accurate, a
difference between state regulation wording and OSEP’s suggested
wording illustrates the frustrations of focus on process.
However, it also suggests why the monitoring of New York state
required more than three years.
The suggestion to replace current monitoring of state policies
and procedures to ensure that conditions of the statute are met,
with a requirement “that states provide assurance that they are
in place” (footnote, p 13), would not ensure that states
actually meet IDEA requirements. The Report seems ambivalent
about the appropriate relationship between OSEP monitoring and
technical assistance functions (p. 15). Additional
data-collection and input from stakeholders, including SEAs,
LEAs, local administrators, and parents must be studied
carefully prior to decisions about separation, partnering, or
combining these two functions.
The Commission recommendation seems to be at odds with a basic
tenet of NCLB that no state can improve teaching or produce
positive results until a technically sound, high quality process
for assessing students and holding schools accountable is in
place. Further, NCLB provides for non-compliance agreements,
withholding, sanctions, and limitations on waivers. In the same
way, ensuring parent involvement, legal IEPs, competent
teachers, quality supports, access to related services and
similar process elements must remain basic tenets of IDEA.
Technical assistance is critical to both effective processes and
successful results. Rather than additional funds, adjustments in
the format and content; expansion of the audience; and use of
formative/summative evaluation may be more important. Without
practical, accurate technical assistance, a kind of folklore and
fear of litigation can lead to denial of appropriate services,
as well as the addition of requirements at the district and
state levels that are far beyond federal requirements. Many
complaints about excessive paperwork, meeting time, and
assessment sessions could be lessened through effective
2. Reduce and simplify regulatory and paperwork requirements;
LDA recognizes that federal requirements are often cited as the
cause of paperwork burdens. However, LDA strongly believes that
currently required IEP components and timelines form a vital
cornerstone of the parent/teacher/administrator partnership that
leads to improved educational outcomes. While many parents and
professionals initiate ongoing contact, others need specific
requirements to ensure awareness of changes in settings and
LDA believes that there are several ways in which regulatory and
paperwork burdens can be reduced, including the following:
Parents, educators, and administrators need to be made much more
aware of the simplicity of federal IDEA paperwork requirements.
Teachers need more thorough training in how to write IEPs. Wider
dissemination of existing federal guidelines and materials like
A Guide to the Individualized Education Program (OSERS, 2000)
that clearly outline a simplified legal IEP would also reduce
unnecessary effort and paperwork.
A major factor in the increased regulatory and paperwork burden
on teachers is the escalating caseload. Each piece of paper from
every meeting is multiplied by the ever larger numbers of
students for whom a teacher is responsible. Increasingly, that
responsibility includes students in collaborative, inclusionary,
resource, and intensive instructional settings. In contrast, the
Reading First Initiative often reported caseloads as one staff
person per three students per day, with a maximum of eight
students per year.
The use of clerical support staff to assist with record keeping,
data collection, scheduling meetings, assuring notifications,
distributing required forms, and circulating copies is a very
appropriate and practical way to increase teacher instructional
time, while reducing paperwork burdens. Interns, community
volunteers, and retirees who can meet confidentiality and
privacy requirements could serve in such a capacity.
Specific IDEA funds should be earmarked for the purchase of
hardware and software to support electronic IEP case management
that (1) reduces teacher time, effort, and paper, and (2)
encourages individualization and updating.
States should be encouraged to develop IEP processes that use
secure websites and to consider the use of PDAs to record,
analyze, and report real-time student performance data for early
reading assessment and instruction.
The recommendation that up to 10 states waive federal paperwork
requirements based on their proposed paperwork reduction
strategies shows promise, but is too broad. Clearly defined
pilot small-scale projects, undertaken in a defined time period,
should be undertaken first. Close monitoring and evaluation of
these pilot efforts by stakeholders, including parents, must
precede either statewide waivers or adoption.
3. Improve OSEP use of staff and resources to implement Federal
law and improve Technical Assistance.
LDA supports ongoing efforts designed to use OSEP staff and
resources effectively. LDA notes that both IDEA-97 and
subsequent reorganization of OSEP in 1999 were directed toward
improving technical assistance, increasing staffing, and using
Monitoring and State Improvement Planning (MSIP) to focus on
collaborative rather than adversarial aspects of compliance and
technical assistance. These changes should be allowed sufficient
time to become fully operational before major changes are
mandated. Specific recommendations and concerns identified by
The Annual Report to Congress should be expanded to include
reports of state performance compared to their own performance
standards, as well as those of other states.
OSEP data documenting the time elapsed between monitoring exit
meetings and issuance of the monitoring report should be made
Development of a coordinated intra-agency and inter-agency
accountability system across educational programs should be
implemented. The goal would be to reduce multiple data reports,
site visits and other duplicative efforts, while maintaining the
functional integrity of agency programs and responsibilities.
4. Expedite implementation in 12 months with timetable for each
section of re-authorization
LDA is extremely concerned that the implementation timetable be
directly related to the complexity of changes in statute and
regulations. In view of the recognized complexity of IDEA and
the many changes that were only recently introduced through
IDEA-97, continuing the trend toward improved educational
outcomes must not be sacrificed to a perceived need for speed.
Speed must never become the measure of success.
LDA identified the following specific recommendations and
Professional training to ensure needed competence in such areas
as general/special education collaboration, universal screening,
early intervention in scientifically-based reading, measurement
of response-to-intervention, intensive multi-sensory
interventions, and transition support must be developed and
implemented. Time for needs assessment, trainer and resource
development, actual training, and the integration of
competencies into the culture of a specific setting will also be
Developing, conducting, analyzing, and evaluating possible
alternative approaches to SLD assessment and identification will
require considerable time as small-scale, clinical efforts are
undertaken; piloted in large, diverse settings; and again
evaluated across many factors, including educational outcomes.
Many structural and relationship changes are incorporated as
recommendations throughout the Report, such as those between
general and special education, within OSEP and among numerous
agencies outside of the Department of Education. Time will be
required, if implementation of such changes are to truly enlarge
educational opportunities and life success for students with
Early Childhood Programs
LDA supports, in principle, the concept of a seamless system for
children with disabilities from birth through-21 suggested in
the Commission narrative (p 19). However, LDA believes many
important questions must be answered before major changes are
LDA notes the following specific suggestions and concerns:
LDA strongly recommends that a GAO study be initiated to
carefully review the widely varying goals, eligibility,
comprehensiveness , services, revenue sources, service
providers, and advisory groups among the agencies involved, as
well as other administrative, programmatic and accountability
issues associated with development of a practical seamless
system. Only after such information is obtained could the
planning begin that might lead to eventual legislative action.
LDA is concerned that increased state flexibility in use of Part
C, Section 619, and Part B funds would require study of existing
expenditures, development of financial provisions, and piloting
of models in which the needs of ALL students are appropriately
met, well in advance of any implementation.
LDA notes with great concern the necessity for any unified
system to include provisions ensuring the identification that
triggers IDEA protections, effective assessment prior to
services, positive outcomes at all ages and smooth transitions
States should be permitted to retain the existing lead agency if
programs have been demonstrated to work well, with changes
occurring only when data indicates a lack of success.
Monitoring and evaluation of early childhood programs should be
data driven to ensure compliance in both process and results.
Careful study must also be given to which agency should be
responsible for the monitoring and data-collection processes.
B. ASSESSMENT AND IDENTIFICATION
1. Identify and intervene early using research-based programs.
LDA strongly supports the value of early screening,
identification and intervention in order “to better serve
children with learning and behavioral difficulties (p. 20).” LDA
firmly believes that early intervention, including the use of
research-based instruction, is critical to building a strong
foundation in reading, whether in general or special education,
for improved lifelong learning. However, the Report is vague
about how such early intervention would actually be implemented.
LDA’s specific comments include the following:
As discussed in the Report, the concepts of assessment and
services are misunderstood, overly simplified, and generalized.
Neither assessment nor service is a unitary concept describing a
single activity. Assessment includes a range of activities such
as: (1) changes in lesson plans and instructional groupings
based on teacher observation and evaluative tasks in regular
classrooms; (2) scores on standardized tests of development,
ability, or academic achievement interpreted by diagnosticians
or other specialists; (3) qualitative and clinical
interpretation of performance on standardized, diagnostic, and
informal instruments conducted by competent professionals; (4)
classroom observation, interviews, and portfolio reviews
integrated with other data; (5) parent interviews and
observations; and (6) trial teaching, curriculum based
measurement, and response to intervention carried out by
personnel with competencies in those areas. Possible services
include a similar range, referred to in IDEA as a continuum of
services, such as: general education class without or with
accommodations, general education class with varying degrees of
added intensive help, highly intensive instruction with some
general education attendance, and continuous intensive
instruction throughout the school day. Without appropriate
assessment activity, the choice of instructional interventions
and services cannot be expected to improve educational outcomes.
Suggesting that a mantra of “services first, assessment later”
will improve educational outcomes for students with LD, shows a
lack of understanding of students with disabilities. Children
with severe disabilities, including some with learning
disabilities, must be referred, assessed, and identified through
Child Find, early childhood programs, or kindergarten programs,
so that appropriate individualized specialized services,
including research-based interventions can be initiated prior to
to first grade. For children with suspected disabilities,
well-intentioned, but inadequate and inappropriate services
will, unfortunately, precede the assessment and appropriate
intervention services needed for educational progress. These
children will still be victims of a “wait to fail” process.
While access to the best in early screening, referral,
assessment, and intervention can minimize some effects of
learning disabilities, it cannot prevent learning disabilities,
which are lifelong and neurologically based (e.g., just as
blindness and mental retardation cannot be prevented through
1. Simplify and clarify identification, especially of [early
reading problems in students with] high-incidence disorders.
LDA supports the Commission’s overall recommendation to “orient
assessment toward the provision of services,” but is concerned
that any changes intended to simplify assessment and
identification be carefully researched and piloted, prior to any
changes in law or regulations. Any changes must also clearly
demonstrate improved educational outcomes and reduce mis-identification.
LDA’s specific comments in this section include the following:
The suggestion to reduce categories from 13 to three, while
seeming to be an easy simplification of “the eligibility
determination process” which “bears little relation to
intervention” (p. 20), actually has nothing to recommend it.
While general education instruction can often benefit most
students with disabilities, most will also require specific
individualized services at various times during their school
years. Additional accommodations; intensive interventions;
specialized supports, assistive technology; and programmatic
guidance from professionals with very specific competencies must
not only be available, but must be matched to each student’s
special needs. The disability categories ensure a practical
focus on a reasonable range of interventions and services, as
well as the specific professional competence enabling each child
to truly learn to his or her potential. Thus, the “complexity of
IDEA” noted by the Commission (p. 20) has actually emerged from
both the highly unique nature of human differences and the
recognized necessity of the resultant categorical
The proposed three categories are confusing. Deaf-blindness is
placed under sensory disabilities, but multiple disabilities
under physical and neurological disabilities. SLD, which is
recognized as neurologically-based, and BD are both categorized
as developmental disabilities. What was intended to simplify the
eligibility process actually provides new complexities which are
acknowledged as “not perfect” (p 21)
LDA finds it difficult to understand how the Commission can
state that it “found compelling evidence supporting the
existence of …[SLD, ED, mild MR, SLI] and ADHD,” yet it also
“could not identify firm practical or scientific reasons
supporting the current classification in IDEA” (page 21).
LDA considers the effort to define the three proposed categories
as “high incidence” versus “low incidence” as unworkable, since
some students classified as in high incidence categories, have
Whether disabilities are based on “objective” or “subjective”
criteria, LDA strongly believes that assessment and
identification must be a prerequisite for the appropriately
specialized services that keep the “individual” in IDEA. For
example, the sensory disability of visual impairment (VI) may
seem clearly identifiable “on the basis of vision tests” (p.
21). Actually it is “a matter of degree on several dimensions,”
since some VI children simply need access to large print
materials as services, while others require specialized mobility
and Braille training.
LDA strongly believes that SLD students require assessment and
identification as a prerequisite for appropriate services if
they are to profit from educational opportunities. Without
appropriate assessment, SLD students, who are marked by varying
patterns of skills (1) within each individual, (2) across
academic subjects of reading, mathematics, language, written
expression, and spelling, and (3) among indirect areas such as
behavioral, social, and organizational areas, cannot logically
have their highly individual instructional needs met. IDEA-97
recognized the importance of sharing information about how a
child learns by requiring that a member of the IEP team be “an
individual who can interpret the instructional implications of
evaluation results” (20USC 1414 (d)(1)(B)(y).
While early reading intervention may assist the 80% of SLD
students that the National Institute of Mental Health (NIMH)
identifies as having reading problems, the intervention may not
be of the intensity, fidelity, and timing needed to develop
reading skills. Indeed, in NIMH studies of early intervention
5-6% remain “treatment resisters” even after early intervention
in reading. For some SLD students, even high quality reading
instruction will not provide intervention for emerging math,
spelling, or writing difficulties. As too many parents know,
some SLD students have learning disabilities that create major
and recurring interference in the later acquisition of the
academic, social, and vocational skills needed for adult
independence. Early math computation difficulties reappear in
mathematics reasoning and still later as problems in maintaining
budgets, keeping checkbooks, and paying bills on time.
To deny the need for assessment as a precursor and guide to
appropriate identification and instruction is tantamount to
declaring that someone complaining of chest pains be provided
with digitalis, a pacemaker, and quadruple bypass surgery.
Following these services, the patient would receive an EKG and
other tests to assess whether additional services were needed.
LDA notes that the discussion on increases in OHI, OI, and SLD
categories presents interesting, but selective information that
distorts the conclusions. SLD is the category with the least
growth of the three (36%), yet is targeted as needing the most
drastic change in “the current methods of assessing the presence
of SLD(p. 24).” Questions arise about the basis upon which SLD
is selected as the area in need of change, especially when
several factors other than assessment methods (as noted below)
have contributed to growth in the SLD category.
The Commission attributes the 10-year growth in OHI (319%) to
increases in identification of ADHD, which a physician’s
signature is “sufficient to trigger” based on “clinical judgment
using very specific criteria” (p. 23). The Report then adds that
many [ADHD] children are “not adequately evaluated” and schools
“cannot establish eligibility” (p.24). Therefore, it is
difficult to see how changing SLD assessment to use “clinical
judgment using very specific criteria” can be expected to
improve identification and reduce mis-identification.
The increase in SLD (36%) is suggested to be the result of
prematurity without “neurological anomalies”, which has caused a
three-fold increase. However, there is no acknowledgement of two
other important factors: (1) the change in MR IQ criteria, which
created a lower threshold for “normal” ability and resulted in a
concomitant increase in the SLD population; and (2) the increase
in secondary school SLD students whichclosely mirrors the
decrease in SLI high school students.
LDA supports the alignment of NCLB and IDEA with respect to
intervention collaboration between general and special
education, but is concerned about the implications of joint
responsibility only for early intervention.
LDA strongly supports better training for regular education
teachers, but opposes the open ended use of IDEA funds for
non-special education services. Under IDEA-97, LEAs already can
use up to 20 % of excess IDEA funding for non-special education
1. Adopt Response to Intervention and Progress Monitoring Models
and Use Data to Assess Special Education Progress
LDA has consistently expressed support for continued exploration
of alternative eligibility and identification models, including
problem-solving and response-to-intervention, for students with
disabilities, including those with SLD. This support, however,
includes several concerns, some of which seem to be supported by
LDA strongly supports the recognition and continued use of
on-going classroom assessment and diagnosis as a guide for
adjustments in intervention. For more than thirty years,
diagnostic teaching, direct instruction, curriculum based
measurement, and behavior analysis have been components of
general and special education instruction. More recently, newer
approaches, such as computerized progress measurement have
become common classroom assessment tools.
LDA strongly opposes hasty and ill-considered changes in IDEA’s
SLD identification and eligibility criteria. LDA opposes the
adoption of processes that do not demonstrate the hoped for
improvement and actually produce unintended consequences that
serve as a setback to student outcomes. Carefully designed
research and pilot projects must prove any alternative to be
more valid, prompt and accurate in identifying all students who
are truly LD as distinguished from those underachieving for
other reasons. Acceptable alternatives must also be demonstrated
as effective in large-scale, diverse settings; less expensive;
reducing paperwork and litigation; providing guidance for
instruction; and improving educational outcomes.
LDA supports the use of Part D funds to research and pilot
alternative identification and assessment models. LDA supports
research into scientifically-based interventions to ensure
genuine improvement in outcomes and to meet other criteria as
outlined in LDA’s response to Recommendation 3, above.
In light of reported widespread school district use of an
IQ/achievement discrepancy formula as the sole criterion for SLD
eligibility and identification, LDA strongly supports improved
technical assistance and monitoringto ensure that parents, LEAs
and SEAs understand that IDEA-97 prohibits the use of any single
assessment criterion, including an IQ/achievement discrepancy
formula. Further, IDEA requires that “observation of academic
performance in the regular classroom (§300.542)” be considered
in such decisions. In addition, the current regulations
encourage the use of problem-solving and other pre-referral
approaches that could maximize learning, and minimize mis-identification.
1. Incorporate universal design through accommodations and
modifications, into accountability tools.
LDA supports the Commission’s concern about the continued
exclusion of students with disabilities, including SLD, and/or
their scores from statewide testing programs and therefore, from
accountability data. LDA also has the following specific
comments related to the Recommendation:
LDA believes that the appropriate use of accommodations
incorporated into the IEP on an individualized basis, coupled
with test instruments that adhere to universal design principles
are useful approaches to solving the exclusion problem.
LDA is concerned that there is some confusion about the use of
modifications, which generally refer to curricular adjustments,
and would raise questions about test validity if they were
permitted on statewide accountability instruments.
LDA strongly supports the expectation that the accountability
testing incorporated into NCLB would apply to all students,
whether disabled or not and whether in general or special
education, but questions whether an amendment is necessary.
1. Increase Part B funding up to a threshold percent of “excess
LDA appreciates the efforts of the Commission to clarify the
actual costs of providing special education to children with
disabilities. LDA supports efforts to determine true excess
costs, rather than relying on expenditure data that may not be
comparable from state to state. Other concerns are as follows:
When LEAs allocate the cost of all services for students with
disabilities to special education, the special education costs
are not true costs (e.g. all students with disabilities are
transported on special buses, even though students in regular
education are also provided this service).
LDA recommends that the Department of Education develop and
implement clear guidelines for the allocation of costs of
educating students with disabilities in regular education,
special education, and other federally funded education
1. Link future funding increases above the threshold percent to
state accountability plans
LDA’s support of the concept of rewarding SEAs and LEAs for
improved student results (which is similar to a proposal by
Representative Pete Stark, R-CA) is tempered by concern about
possible unintended consequences. Some of LDA’s concerns are
How will such funding plans affect the performance outcomes for
students with disabilities in states or localities that do not
show the required improvement?
Although the Commission suggests that data to justify such
increases should “replace, not add to existing data
requirements,” there is a high probability that increased
paperwork would be required at several levels.
1. Target funds for direct services, with 90 % of IDEA
flow-through going to LEAs
LDA is very concerned about the effects of the recommendation to
mandate 90% of IDEA state set-aside as flow-through directly to
states and that the remaining funds be used to supplement risk
management pools and for “discretionary, administrative and
high-need student reimbursement purposes” (p. 35). Some of LDA’s
additional concerns are outlined below:
Each state would be very limited in its ability to provide
in-service and parent training.
Opportunities to implement innovative model programs suited to
state needs would be limited.
Very limited financial support would be available to meet
critical needs important to a given state.
1. Increase Part C and Section 619 funding
LDA supports increased funding for Part C and Section 619, but
strongly opposes open-ended flexibility in the use of IDEA
funds. In addition, LDA strongly urges increases in Part D of
As written, this recommendation (p. 28) does not incorporate the
earlier narrative which recommends that “states be given
flexibility to use IDEA funds to support early intervention
programs and to combine IDEA funds with other sources of federal
support for these programs" (p. 22).
Increased Part D funds are needed to provide the research and
dissemination, personnel preparation, and parent training
centers essential for implementing the long-term commitment to
using research-based and scientifically-validated practices at
all levels of the education system, including educating students
Current law allows LEAs to (1) combine IDEA and ESEA funds for
school wide programs and supplementary services and aides to
students without disabilities when also providing for a child
with a disability, and (2) use up to 20% of increases in IDEA
funding for programs other than IDEA. This level of flexibility
would seem to be sufficient.
5. and 6. Increase state and local flexibility and focus on high
LDA supports the recommendation to provide for high cost
students through safety net funding and risk management pools.
Provisions for safety net funding are preferable, but it is
recommended that model programs such as the Washington State
Safety Net Committee/Audit Team, be piloted in large scale prior
to widespread application of such funding patterns.
D. ACCOUNTABILITY, FLEXIBILITY and PARENTAL EMPOWERMENT
LDA supports the four Commission major recommendations in this
area, but with additional specific suggestions and/or concerns
in each of the areas.
1. Set high expectations for special education
LDA also strongly supports high expectations for teacher
Data should be collected on participation in Advanced Placement,
upper level high school core courses, and parent reports of post
graduation outcomes with disaggregation of the data for students
with and without disabilities. Both aggregated and disaggregated
data should be collected and made public.
As implementation of IDEA-97 continues, LDA expects that an
increasing number of secondary school students will have had
extended access to the general curriculum and intensive
remediation. For students with learning disabilities, the result
should be a continued increase in the graduation rate and
decrease in the dropout rate. LDA believes that both general and
special education must take responsibility for continuing this
The Report suggests that IDEA should define “Adequate Yearly
Progress” (AYP) in the same way that NCLB expects AYP for
students with disabilities. But it is unclear how progress
toward both NCLB’s state reading/mathematics assessments and
IDEA’s “ambitious additional…goals…using… graduation rates,
post-graduation outcomes, and parent satisfactions surveys“ (p.
36) could be consistent with NCLB’s requirement that students
without disabilities only show AYP on reading/mathematics
assessments. LDA is concerned that the result would be dual AYP
expectations for those with disabilities, but only one set of
expectations for other students, instead of the same learning
standards for ALL students.
LDA believes that careful study must be made of current diploma
requirements and options among the states and their impact on
students with disabilities. As noted by the Commission, the
choice of “either diploma or graduation certification” (p. 39);
leaves many students with learning disabilities without accurate
documentation of their abilities. Entrance into competitive
employment and apprentice-based occupations can be permanently
closed when students fail to meet all standards-based state-wide
test requirements. Ways must be found to strongly encourage
completion of a standard high school diploma, while recognizing
the value of an official document that verifies mastery of basic
academic and performance skills sufficient for competitive
employment and post-secondary skill training.
1. Hold LEAs accountable for results
LDA strongly supports the recommendation that LEA’s should be
accountable for the performance results of all students with
disabilities and included in state accountability data. However,
LDA’s concerns about practical details include the following:
Specifics are lacking in the recommendation, so it is unclear
what “IDEA goals” are to be reported for each school and LEA. Is
performance on IEP Annual Goals, performance on state-wide
standardized tests, or performance on NCLB mandated reading and
mathematics assessments in grades 3-8 to be reported, or some
combination of these?
Every child should be included in state-wide assessments, unless
reported as a “non-participant” with an appropriate rationale.
Students with disabilities should be included in district
assessment data ONLY when appropriate accommodations are applied
on an individual basis, determined in advance with
parent/student involvement, and practiced in the general
Performance data should be provided in both aggregated and
disaggregated form, as currently required in both NCLB and
As with NCLB, LEA’s should report to parents whether or not a
child’s teacher holds a certificate for the field in which they
1. Increase parental empowerment and school choice
LDA strongly agrees that, as provided in IDEA-97, parents should
continue to have meaningful information about their child’s
progress, based on assessment results from educators and other
service providers, at least as frequently as students without
disabilities. LDA is very concerned, however, about how some of
the additional recommendations would apply in practice.
The term “educational options” is not specifically defined. It
could simply mean access to added needed related services or to
other placements on a continuum of settings or it could suggest
a broader range of options.
LDA is concerned that the Report suggests that IDEA should be
consistent with NCLB by providing funds to parents who choose
other services or schools [particularly] when a school has not
made AYP under IDEA for three consecutive years. The word
“particularly” is bracketed in the previous sentence, because it
seems to indicate that a “school in improvement” is not an
actual requirement for access to other options. Doesn’t NCLB
already provide a school choice option for ALL parents when an
NCLB school is “in improvement” for three years?
Of greater concern to LDA are general statements declaring that
a “majority of special education students will continue …in the
regular public school system,” and “IDEA should allow state use
of federal funds to enable students…to attend schools or access
services of their families choosing, provided states measure and
report outcomes.…” Such statements, raise important questions
including whether the protections of IDEA would continue, the
implications for IDEA funds, and the possibility of availability
to students with disabilities but not to all students.
1. Prevent disputes and improve dispute resolution
LDA is highly supportive of parent empowerment and processes
that minimize or avoid conflict and promote agreement about
instructional goals and services. Effective selection and
training of mediators, arbitrators and hearing officers must
ensure knowledge of applicable laws and regulations, as well as
impartiality in decision-making.
Additional LDA concerns and suggestions include the following:
In view of the fact that IDEA-97 requires that mediation be made
available, at least when a hearing is requested, the
recommendation concerning mediation is not necessary.
Specific required steps must be in place to ensure that parents
are fully informed about the range of options available to
minimize or avoid conflict, foster amicable agreement, and
encourage genuine parent/professional partnerships.
Access to binding arbitration, while a possibility, continues to
be an unlikely option for either parents or schools from a
practical standpoint. However, it should be available when a
quicker resolution is determined to be worth waiving further due
The suggestion concerning “IEP Facilitators,” who would be
trained to guide IEP meetings toward positive solutions for both
parents and school staffs, is a promising idea that should be
explored further. One caution is that such a facilitator would
further increase the number attending an IEP meeting, when
simplified processes are being sought.
5. POST-SECONDARY RESULTS and EFFECTIVE TRANSITION SERVICES
LDA strongly supports the Commission’s recognition that
“academic achievement alone will not lead to successful results
for students with disabilities…[but they also] need educational
supports and services…throughout their school lives…[which] may
intensify during the transition years.’ (p.50). Additional LDA
comments and suggestions concerning the recommendations include
1. Simplify federal transition requirements
LDA supports the recommendation that IDEA transition
requirements should be simplified. Too many LD students move
through the transition years without the knowledge or supports
to facilitate a smooth and productive transition from high
school to post-secondary educational opportunities or successful
LDA notes the following additional suggestions and concerns:
For students with learning disabilities, it is especially
important that attention to self-determination, self-advocacy,
social, and organizational skills is begun before high school
and not omitted as schools focus on academics.
Transition requirements in IDEA must be clearly described so
that what is required and when it is required is not only
understandable to educators, parents, and students, but also to
others such as vocational rehabilitation counselors,
occupational therapists, and college support personnel.
Differences between the transition tasks at age 14 and 16 and
between transition service needs and needed transition service
must also be clarified, along with the possible impact of age of
Strong reading, mathematics, and study skills are important keys
to high school and transition success. Students, especially
those with learning disabilities, must have access to intensive
remedial instruction from highly qualified teachers so they will
be fully prepared academically for appropriate post-secondary
As students mature and their educational needs and career goals
change, there are also changes in the role of accommodations.
Thus, at different times, accommodations may have to be provided
to students in ways that will maximize academic performance,
assure accurate state-wide test achievement, and smooth
transition to post-secondary education and high-end employment
Schools must do a better job of working with parents and
students to develop and implement an IEP that clearly specifies
needed transition services and develops goals appropriate to the
post-secondary expectations of high school students.
Consideration should also be given to specifically addressing
these needs in IDEA by extending the Individualized Transition
Plan with a Secondary School Plan.
All secondary teachers should be trained in the basics of
linking academics to future employment, encouraging
self-advocacy, supporting self-determination, and fostering
learning and behavioral independence, all of which enhance the
possibility of post-secondary success. The secondary curriculum
should also be sufficiently aligned with graduation requirements
to foster successful transitions into post-secondary education
Every secondary school must have an identified “LD transition
specialist” who has specific added skills in addition to their
professional training in teaching, counseling, vocational
rehabilitation, or another related area. They should attend
appropriate IEP/ITP meetings, share practical information about
post-secondary educational and employment options, and guide
course and experience selections to enable students to achieve
Clear, accurate and timely information must be provided to
parents and students about possible linkages that exist to
support a student who drops out of school and refuses to return.
In order to ensure comparable dropout data among states, a
federal definition and guidelines for its implementation should
be put in place.
1. Mandate federal interagency cooperation
LDA strongly supports the recommendation to strengthen the
connections between federal and state special education and
rehabilitation policy, and to improve cooperation among the many
federal and state agencies housing programs relating to
transition, training, higher education, and employment
opportunities for students with disabilities. LDA is not only
concerned that too many students drop out of high school without
a diploma, but also that they are unable to access or navigate
the maze of various programs that have the potential to provide
assistance. The framework for success is available, but
typically agencies do not work together to ensure effective and
Additional comments by LDA concerning interagency cooperation
Agencies and programs must work together to take a practical
look at why students drop out of school and what is needed to
ensure completion of the education that will lead to securing
Ways must be found to ensure that agencies develop coordinated
approaches for youth who will not return to school and
therefore, will lack access to the IDEA protections that
otherwise continue to age 21. Of particular concern are students
who have left school, but because of their age, cannot access
WIA programs, especially the GED, the academic tutoring of the
Youth Services Program, and the pre-college vocational training
programs that are currently available.
Existing OSERS Interagency Agreements between SEAs and state
Vocational Rehabilitation agencies must be strengthened, with
increased time limits so that students who are just beginning to
show progress are not left without a support system as they
Agency personnel need training to ensure a basic understanding
of learning disabilities, how it is often misunderstood and
typical accommodations, as well as the characteristics and
frustrations that often continue into adulthood. For example, it
is important to understand that clients with learning
disabilities often have quite different needs, skills, and
aspirations than those who are physically or mentally
State flexibility to coordinating funds from federal agencies
appears to be needed in order to create transition services that
most effectively serve the students in each state. LDA is
concerned, however, that critical practical specifics, such as
oversight responsibility, service priorities, monitoring and
performance outcome data remain to be developed. As is often the
case with funding flexibility, the best intentions may falter
and fail if effective guidelines and monitoring processes are
not also in place.
3. Create a Rehabilitation Act Re-Authorization Advisory
LDA strongly supports the recommendation that an
Advisory Committee be formed to provide guidance for the
upcoming re-authorization of the Vocational Rehabilitation Act.
LDA suggests that parents of students with disabilities,
including learning disabilities, be included on such an Advisory
4. Help Higher Education faculty and administration ensure
completed, quality Post-Secondary
LDA strongly supports the recommendation that higher education
faculty, administrators and auxiliary service providers find
ways to provide the effective supports needed for completion of
post-secondary education by students with disabilities. Many
post-secondary institutions describe effective model support
systems on paper, but when students are “experiencing” the
program, they often do not truly offer the range of supports
necessary for success. In addition, the existing student grants
to fund post-secondary education are not effective if such funds
are used for GED and remedial work in community colleges, so
that mounting debt and depleted grant funds prevent students
from entering four-year institutions.
1. TEACHER and ADMINISTRATOR PREPARATION, TRAINING, and
1. Recruit and Train Highly Qualified General and Special
LDA supports the recommendation that new strategies must be
devised to recruit teachers that are highly qualified to educate
students with disabilities, supplemented by career-long
professional development systems that are based on professional
standards. LDA also recognizes that it is critical that licenses
and endorsements for all teachers and administrators require
training in meeting the needs of students with disabilities and
in including parents as partners in improving educational
LDA’s specific concerns and suggestions follow:
Current state licensure requirements vary widely in their
criteria and level of expectation.
State license and endorsement requirements for principals must
include experiences and competencies in understanding
disabilities and special education. In each school the degree of
knowledge, understanding and support for students with
disabilities depends, in large part, on the building principal’s
knowledge, understanding and support. When principals view all
students as their responsibility, they see to it that teachers
and support personnel receive the training and resources to
improve learning outcomes for all students attending the school.
For students with learning disabilities, it is especially
important that teachers are competent to help students develop
such skills as self-determination, self-advocacy, social, and
organization. Since these skills need to be established before
high school and not omitted as schools increase the focus on
academics, competencies in these areas are equally important for
elementary, middle, and secondary school educators.
When new instructional initiatives are developed by SEAs or IHEs,
coordination should be a pre-requisite to funding.
1. Create research and data-driven training systems
LDA strongly agrees that teacher education should incorporate
existing research on student learning and teacher
characteristics that produce improved student achievement.
Equally important, however, is funding for additional research
data and analysis, to guide factors such as certification
routes, the selection of training components, competencies, exit
assessment criteria, likelihood of continuing as a teacher and
other criteria to improve systems for teacher education.
1. Ensure Ongoing Field Experiences
LDA agrees that quality field experiences are an important
component of teacher education and must incorporate supervised
experiences that provide a comprehensive view of the full
continuum of service delivery models, in both general and
special education settings.
It is very important that field placements provide positive
experiences with teachers who are excellent role models and work
in supportive settings recognized for positive educational
results for students.
Field experiences should be supplemented with frequent
supervisor feedback, reflective logs, reality-based case
studies, videotaped micro-teaching, and similar experiences.
1. Require rigorous reading training
LDA strongly supports the recommendation that training of both
general and special education teachers must be trained to
implement appropriate research-based practices in reading,
including systematic instruction in phonemic awareness,
decoding, fluency, vocabulary and comprehension. At the same
time, LDA notes with concern that these skills are necessary,
but not sufficient to ensure that students with learning
disabilities are able to continue to progress during their
school experience, graduate and become successful in life.
In addition, LDA notes the following specific concerns:
Competence in teaching early reading is critical for elementary
teachers. In addition, teachers at the middle and secondary
levels, teachers must understand the relationship of reading
skill to content acquisition and special education teachers must
be able to teach basic reading skills to older students.
In addition to strong training in early reading, LDA believes
that elementary level general and special education teachers
also need to understand learning and language development and be
highly qualified to teach in content areas such as science, and
the social sciences.
LDA strongly believes that training at the elementary level
should ensure strong training in all seven domains included in
the IDEA definition of learning disabilities (listen, think,
speak, read, write, spell, and do mathematical calculations),
since many students with learning disabilities experience
difficulty in areas other than or in addition to basic reading.
Middle and secondary level teachers must be able to integrate
strategy instruction, content enhancement routines and similar
methods into the general education curriculum (as noted in the
testimony by Dr. Deshler at the Nashville Commission hearing).
Learning disabilities teachers must be able to provide age
appropriate intensive academic skill instruction to older
Learning disability specialists must possess competence in a
range of instructional approaches, including intensive,
specialized reading interventions supported by clinical or
promising practices and/or data-based research, as well as
instructional methods in the other six learning domains defined
in IDEA. In addition, the collaborative skills needed to guide
and assist general education teachers in implementing
individualized interventions needed to master the general
curriculum are especially important for successful learning in
students with learning disabilities.
1. Require public reporting of performance of graduates
LDA strongly supports the recommendation that institutions
training teachers, administrators, and related services
personnel be required to collect and publicly report data from
consumers that indicate the success of program graduates in
educating students with disabilities.
Performance data of teachers, administrators, and related
services personnel who graduate from IHE and private programs,
should indicate the level of success in educating both students
with and without disabilities.
Data from graduates of higher education programs concerning the
degree of resources and other supports provided in their
employment setting should be collected, analyzed and publicly
1. Increase faculty in special education and related services
LDA supports the need for recruitment and
training of additional highly qualified faculty to educate our
nation’s future teachers and other professionals and prepare
them to achieve improved results for diverse learners.
Additional concerns include the following:
Faculty must possess the knowledge and experience to plan and
implement pre-service and in-service programs that develop the
specific, but differentiated competencies required by teachers
in general education, secondary content areas, special
education, and learning disabilities.
Faculty who will provide training in learning disabilities must
possess advanced, in-depth knowledge of intensive, specialized
interventions. Faculty who will provide training in general
education must possess the knowledge and attitudes to transmit
to intending and practicing teachers the ability to recognize
emerging difficulties in students and to work collaboratively
with a learning disability specialist to provide or supplement
LDA is concerned that both teachers and related service
providers must be better prepared to effectively assist high
school students in meeting the requirements of post-secondary
institutions. Faculty must work collaboratively to ensure that
general and special education teachers, guidance counselors,
speech/language pathologists, and other professionals possess
the knowledge and skills to help prepare students for transition
out of secondary school programs.
1. Conduct research on critical factors in training that improve
LDA views this recommendation as essentially the same as the
second recommendation, which is addressed above.
7. RESEARCH AND DISSEMINATION OF SPECIAL EDUCATION RESEARCH
LDA supports the basic concepts in the four recommendations in
this section, noting especially the critical importance of
research efforts that must provide guidance on several areas
within the Report. These include, but are not limited to:
efficacy of alternative assessment/identification models,
determination of scientifically-based interventions, teacher
characteristics that improve educational outcomes, extension of
valid intervention approaches beyond early reading to other
academic areas across grades K-12, approaches to reducing school
dropouts and non-graduation, special education costs,
consequences of various funding patterns and determining
interagency coordination policies that improve transition
However, LDA has specific concerns and questions about the
practical aspects and possible impact of several
recommendations, as indicated in sections below.
1. Change to a more scientifically rigorous grant review
The Report outlines eight proposed changes to the existing grant
review process, primarily related to Part D programs. Some of
the proposals are very specific, but others lack clarity about
the nature of the changes and how those changes might contribute
significantly to a more rigorous grant review process.
While the close and continuing involvement of qualified
researchers must be a part of all proposal reviews, proposals
focusing on implementation should include experienced
practitioners in the review process.
Although it is noted that current statute requires that review
panels include researchers, consumers, and practitioners, the
Report goes on to caution that “non-researchers may not be able
to address technical aspects of the proposal” (p. 64). Yet the
proposed “national advisory committee” would include
“practitioners, researchers, parents, and people with
disabilities” to be responsible for establishing priorities and
agendas, as well as review research for relevance to people with
disabilities” (p. 65). Would this group be more capable of
making such decisions? How would the panel’s activities fit into
the overall review process and timetable for proposal review? If
practitioners are unable to address the technical aspects during
proposal review, how will they be expected to implement them in
The lack of definitions, interrelationships among components,
and practical details results in an uncertain picture of how a
more rigorous grant review process would be established. For
example, it is difficult to understand how numerous standing
panels will be established, each chaired by “a senior
researcher” that is independent of OSEP, and at the same time be
similar to “internal review groups” used by NIH as a “separate
institute for review” (p. 65). LDA wonders who would be defined
as a senior researcher and how an internal review group would be
independent of OSEP?
1. Improve coordination of special education research.
LDA agrees that special education research should not only be
coordinated among the three OSERS offices, but efforts should be
continued that foster and reward coordination with HHS and NIH
and similar agencies with respect to developing priorities,
requesting and funding proposals, and dissemination of results
at both scientific and practical levels.
1. Support long term research priorities
LDA strongly agrees that many important research questions
emerging from the Report demand longitudinal studies and will
require sustained research priorities to achieve meaningful
results that can guide practice.
1. Improve the impact of research findings
LDA strongly supports dissemination of research findings to meet
a range of needs. These needs include an understanding of basic
science, guidance for program and service implementation, and
practical information. Such dissemination should provide
direction, simplified information, and hands-on approaches for
improving the abilities of teachers and families to maximize
educational outcomes for all the nation’s children, both with
and without disabilities.
LDA’s believes it is critically important that research and
piloting of alternative models for assessment and identification
be carefully designed and described, with data on educational
outcomes made available for peer review. In short, the same
scientific research standards must be met that are the basis for
questioning the processes currently used and permitted.
LDA is particularly concerned that discussion of research needs
in the Report seems to assume that research will focus on
“bringing to scale practices that are identified as effective”
(p 69). A more defensible approach is to move effective clinical
research into a pilot phase in diverse settings that are
gradually scaled-up to test continued effectiveness prior to
large scale models that, if also effective, are ready for
dissemination, adoption, and adaptation.
LDA notes with great concern that the Commission uses terms such
as “evidence-based,” “research-based,” and
“scientifically-based” instruction throughout the Report without
defining the terms. While LDA advocates for instruction that is
supported by quantitative research, LDA also recognizes the
value of promising practices supported by experiential evidence,
anecdotal reports, qualitative research, empirical data and
similar research methods. Teachers need a repertoire of
instructional methods available to individualize intervention,
meet student needs and improving learning. Such an instructional
repertoire should include both scientifically validated and
LDA is concerned that the Report attempts to narrow
dissemination efforts “largely…to scientifically based
practices”(p. 69), “to disseminate scientifically-based
information on research-based practices to parents and schools”
(p. 70), and to “dissemination programs in OSERS that focus on
the adoption of scientifically-based practices in the
preparation of and continuing education for teachers (p.63). In
contrast, dissemination of user-friendly materials to inform and
up-date parents and teachers are dismissed with the statement
that there should be “less emphasis on distributing information
about the law and how to comply with it, and more emphasis on
“what works” and “outcomes” (p.69).
To LDA it is vitally important that parents and educators
understand the law and regulations in order to advocate for and
obtain the practical services that IDEA promises. Often, ERIC is
the only known source of answers to practical questions. ERIC
material is not “largely redundant (p. 69), but rather is a
relevant database of resources that others draw from. Funding
for ERIC must continue, so that information so necessary for
both parents and teachers continues to be accessible.