Each IEP must be developed with careful consideration of the individual child’s capabilities, strengths, needs, and interests. The IEP should direct the child toward high expectations and toward becoming a member of his or her community and the workforce. It should function as the tool that directs and guides the development of meaningful educational experiences, thereby helping the child learn skills that will help them achieve his or her goals. In short, it should assist the child in meeting the goals and challenging standards of our educational system as well as identified postsecondary goals.
A child who has multiple diagnoses, including Down Syndrome and Autism. The school district identified the student as Other Health Impaired, but the IEP did not make sufficient mention of the student’s Autism diagnosis, in the parents’ opinion. The IEP did, however, describe the student’s strengths and weaknesses, current functioning, and an educational program that provided educational benefit for the student. Nevertheless, the parents sought due process, alleging that the IEP was deficient because it did not adequately describe the student’s autism. The parents argued that the IEP was necessarily deficient because appropriate planning was impossible without fully and adequately acknowledging the student’s Autism. In turn, the school district argued that, although the IEP did not emphasize the student’s Autism, the services described in the IEP were appropriate for the student, given her unique needs.
A federal appellate court agreed with the school district. The court noted that the IEP, totaling 31 pages with a two-page behavior intervention plan, accurately described the student’s needs and provided a “tremendous” amount of resources and support for her. Moreover, the school district was able to show that the student had made progress through the educational plan. Finally, the court noted that, no matter what label the student had received, there was no evidence that his actual educational programming would have been affected. The case is Fort Osage R-1 School District v. Sims, 641 F.3d 996 (8th Cir. 2011).
This case serves as a useful reminder about the essential purpose of an IEP: crafting an educational plan that will benefit a disabled student. Often, IEP teams can become focused on labels. But no two children are alike, and no two children will manifest a disability in exactly the same way. Instead, focus on the individual child and her unique needs so you can craft an IEP based on substance, not labels.
This article ties into key IDEA regulation – evaluations are to be “sufficiently comprehensive to identify all of the child’s special education and related services needs, whether or not commonly linked to the disability category in which the child has been classified.” 300.304(c)(6)