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Start with these folks:

Children's Education Law Clinic

Duke University School of Law

P.O. Box 90360

Durham, NC 27708-0360

(919) 613-7169; (919) 613-7262 (fax)

Email: pettiford@...

Web: http://www.childedlaw.org

A legal advocacy project of Duke Law School focused on protecting the

rights of low-income children in public school. Service area includes

Durham and 10 surrounding counties.

And here are other resources:

The Children's Law Center

Education Law Project

601 E. 5th Street, Suite 480

Charlotte, NC 28202

(704) 331-9474 ext. 1090

Family Support Network of North Carolina

Central Directory of Resources

CB #7340

University of NC at Chapel Hill

Chapel Hill, NC 27599-7340

(919) 966-2841; (800) 852-0042

Email: cdr@...

Web: fsnnc.med.unc.edu

F.I.R.S.T. Inc

Janet Price-Ferrell

PO Box 802

Asheville, NC 28802

(828) 277-1315; (828) 216-7745; (828) 277-1321 (fax)

Email: janet@...

Web: http://www.FIRSTwnc.org

F.I.R.S.T., parent-driven resource center for families of children with

disabilities, providing parent training, effective IEP writing and

advocacy to help families become the best advocate.

North Carolina Congress of Parents and Teachers

3501 Glenwood Avenue

Raleigh, NC 27612-4934

(919) 787-0534; (800) 255-0417

Email: office@...

Web: http://www.ncpta.org/

The Youth's Lighthouse

Curtis

1826 Birmingham Avenue

Durham, NC 27704

(919) 479-9338

Email: mdenisec32@...

Our services are available for persons seeking help/resolutions with

situations that involve children/adolescents with or without

disabilities. Certified Mediation services available.

>

> Hey guys, I need help already. We are having problems with our

school,

> again, not wanting to give Zachary, 10 SMA II in 5th grade,his own

one

> on one, or more time or supply him with a computer(lap top or table

> top)or making the school handicap accesible. He isnt able to open any

> of the doors in the school, going in or getting out. We have asked

> since the middle of last year and they still havent attempted a

thing.

> So for safety reasons Im starting to push!!!And he is having to wait

> for the assistant when he needs something or needs to go out of the

> room. Because the assistant is out of the room with another

> handicapped child. Who can I call for major, immediate results?? We

> are in NC, McDowell Co! Anything will be helpful. Thanks a bunch

> Gardner

>

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Why can't Zachary simply ask a school mate to please open the door? Why can't

they do the " Buddy " system for the easy stuff like opening doors, getting

books, help with desk or anything not related to personal care or feeding?

Why have adult assistance push Zachary beyond his peers and isolate him making

him feel " different? " Mind you, if it is because he is physically unable to

write or manipulate his own hands then its understandable. I would think kids

hate having " adults " flutter around them when they are among school mates who

may want to become friends but are intimidated by the assistants presence.

Mainstream as much as possible and try to encourage more student involvement

at some level. What does Zachary want or say? How does he feel about what you

would want him to have? I know its tough being a parent, be protective but

try not too smother him or control every aspect of his public life. Hopefully

Zachary is letting you know his concerns and that they get addressed.

The least your school could do is put automatic door openers/closers on the

main entrances and get a bathroom aid on staff then encourage a " Buddy "

system.

Good luck. It's been 18 years since I left college, so my ideas are dated. I

would imagine they'd have better ones by now.

Angie

On Wednesday 06 September 2006 12:10, agardner0477 wrote:

> Hey guys, I need help already. We are having problems with our school,

> again, not wanting to give Zachary, 10 SMA II in 5th grade,his own one

> on one, or more time or supply him with a computer(lap top or table

> top)or making the school handicap accesible. He isnt able to open any

> of the doors in the school, going in or getting out. We have asked

> since the middle of last year and they still havent attempted a thing.

> So for safety reasons Im starting to push!!!And he is having to wait

> for the assistant when he needs something or needs to go out of the

> room. Because the assistant is out of the room with another

> handicapped child. Who can I call for major, immediate results?? We

> are in NC, McDowell Co! Anything will be helpful. Thanks a bunch

> Gardner

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The NC State Dept of Education has an " Exceptional Children Division " that

includes disabled as well as gifted children. At the bottom, there is a link

entitled " Handbook on Parents Rights " and one called " Special Education

Reference for Regulations, Policies and Procedures. " Seems like that would

be the first place to start.

http://www.ncpublicschools.org/ec/

:)

>

> Hey guys, I need help already. We are having problems with our school,

> again, not wanting to give Zachary, 10 SMA II in 5th grade,his own one

> on one, or more time or supply him with a computer(lap top or table

> top)or making the school handicap accesible. He isnt able to open any

> of the doors in the school, going in or getting out. We have asked

> since the middle of last year and they still havent attempted a thing.

> So for safety reasons Im starting to push!!!And he is having to wait

> for the assistant when he needs something or needs to go out of the

> room. Because the assistant is out of the room with another

> handicapped child. Who can I call for major, immediate results?? We

> are in NC, McDowell Co! Anything will be helpful. Thanks a bunch

> Gardner

>

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I would say the buddy system would be nice but it doesn't always work well.

They had that with me a lot in grade school and what always ended up happening

was the " buddy " that was helping me would always end up getting annoyed and

hostile. Which ended up with me not wanting to ask them for help because of it.

I do think it is great to have him working with peers, but I don't think it

always works well. Just giving info from personal experience.

Angie <angie@...> wrote:

Why can't Zachary simply ask a school mate to please open the door? Why can't

they do the " Buddy " system for the easy stuff like opening doors, getting

books, help with desk or anything not related to personal care or feeding?

Why have adult assistance push Zachary beyond his peers and isolate him making

him feel " different? " Mind you, if it is because he is physically unable to

write or manipulate his own hands then its understandable. I would think kids

hate having " adults " flutter around them when they are among school mates who

may want to become friends but are intimidated by the assistants presence.

Mainstream as much as possible and try to encourage more student involvement

at some level. What does Zachary want or say? How does he feel about what you

would want him to have? I know its tough being a parent, be protective but

try not too smother him or control every aspect of his public life. Hopefully

Zachary is letting you know his concerns and that they get addressed.

The least your school could do is put automatic door openers/closers on the

main entrances and get a bathroom aid on staff then encourage a " Buddy "

system.

Good luck. It's been 18 years since I left college, so my ideas are dated. I

would imagine they'd have better ones by now.

Angie

On Wednesday 06 September 2006 12:10, agardner0477 wrote:

> Hey guys, I need help already. We are having problems with our school,

> again, not wanting to give Zachary, 10 SMA II in 5th grade,his own one

> on one, or more time or supply him with a computer(lap top or table

> top)or making the school handicap accesible. He isnt able to open any

> of the doors in the school, going in or getting out. We have asked

> since the middle of last year and they still havent attempted a thing.

> So for safety reasons Im starting to push!!!And he is having to wait

> for the assistant when he needs something or needs to go out of the

> room. Because the assistant is out of the room with another

> handicapped child. Who can I call for major, immediate results?? We

> are in NC, McDowell Co! Anything will be helpful. Thanks a bunch

> Gardner

---------------------------------

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Gosh, I had the totally opposite experience in school. Classmates

practically fell all over themselves to get a turn to help me out.

Jenn

>

> I would say the buddy system would be nice but it doesn't always work well.

They had

that with me a lot in grade school and what always ended up happening was the

" buddy "

that was helping me would always end up getting annoyed and hostile. Which

ended up

with me not wanting to ask them for help because of it. I do think it is great

to have him

working with peers, but I don't think it always works well. Just giving info

from personal

experience.

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When I was in the younger grades (< 3rd grade) I had this experience.

Classmates would argue who got to help me - which included help with

lifting things, playing games, walking to/from classrooms when I was

ambulatory, getting things in/out of my locker, etc. It got to the

point that my teachers would make an assignment chart of about 5

classmates per day who would be " assigned " to help me that day. It

helped to teach kids how to share, get along, and communicate. My

teachers loved it. I also thought it was kind of neat that I got to

talk to and interact with every kid in my class one-on-one at some

point during the month. It helped me be more social in settings I

couldn't participate (such as gym or recess). I could sit on the side

lines or only partake in one stationary game but I was able to learn

how to interact with others verbally, and it was encouraged.

As I got older and my disability progressed, I was assigned a

one-on-one attendant who would remain in the classroom to help me with

anything, but was not always there for me. She was a teacher's

assistant in whichever class I had so it allowed me to have some

freedom. When I was in middle school and the only mainstreamed student

with a disability, this was fine. However, in high school, more and

more students with disabilities (mostly learning disabilities) were

mainstreamed and my attendant was then spread out among us. I often

experienced long waits between classes until she could come, causing

me to be late for classes or miss some all together. Once I found ways

of managing h.s. on my own (asking friends to help, only needing one

notebook for many periods in a row) I would go to my next class on my

own. I was often reprimanded for this because the aide thought she

" lost " me. I immediately spoke up and explained that when I don't need

help, I don't need her and that if I would miss out on classes because

she was needed elsewhere, then we needed to make a schedule together

reagrding when she could be on time and when she couldnt. From there,

we met up only a certain times of the day rather than after every class.

<3 Kendra

> >

> > I would say the buddy system would be nice but it doesn't always

work well. They had

> that with me a lot in grade school and what always ended up

happening was the " buddy "

> that was helping me would always end up getting annoyed and

hostile. Which ended up

> with me not wanting to ask them for help because of it. I do think

it is great to have him

> working with peers, but I don't think it always works well. Just

giving info from personal

> experience.

>

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My son is 24 year old, and he had the same type of experience you had,

e. He never had an aide at all. He, like you, had kids fussing

about who'd get to help him while in elementary school. By middle

school, he had a large group of friends and made new friends that were

always glad to help. Danny used a power chair all through school, so

was independently mobile, but couldn't open doors, get books or lunch

out, etc. Later, his friends even helped him with eating/drinks as he

got too weak to lift stuff up. He did get a laptop from school from

5th grade on and a custom desk in each class, and those are things

that every school should supply if needed. For the restroom, he went

to the nurse after lunch (and more if needed) and she'd help him in

the clinic's large restroom up until high school. He mostly went

shortened days in high school, so he'd wait til he got home, or call

me to meet him in the clinic. I'd guess that most nurses might not do

this anymore, but I assume some type of similar arrangement could be

made nowadays.

I remember asking Danny at some point in elementary if he needed an

aide, and he said " No way! " He didn't want some adult doing things for

him that other kids could do, and he didn't want someone hovering

around the classroom at his beck and call. I'm actually glad we did it

this way. Now, at 24, when he's at home or out with friends, it's just

Danny and them...and he's comfortable with asking friends or other

people for help when he needs it.

As a side note...my 14 year old who has severe adhd has always hated

getting any extra or special treatment (such as less work or extra

time). She says she doesn't want to be considered different or special

by the other kids. I'd guess that Danny felt the same way in school

about an aide.

>

> Wow, I'm really shocked by how many SMA kids have one-on-one

assistance at school. This is actually common practice now? I'm only

22, it hasn't been long at ALL since I graduated, and I definitely

never had nor wanted that kind of help as a kid. I had an aid to help

me in the bathroom at a scheduled time, but that was all. The other

kids would help me open doors and get books out of my backpack. I

don't think I needed much help beyond that. And I never had an

assigned buddy system, it was always just whoever was around at the

time. My friends, the people I sat by, whatever. The kids never minded

helping, usually they thought it was fun. And I learned how to ask for

things politely and show appropriate appreciation. I wouldn't have had

it any other way. I was such a painfully shy child; asking peers for

help and explaining my needs helped me to develop some badly needed

assertiveness. Besides, I eventually was able to leave home and go to

college, where there definitely isn't anybody following me around all

day at my beck and call. I'm glad I learned early on to rely on myself

and the kindness of whoever happens to be around.

>

> If this is the trend for SMA kids now, I have to wonder where the

funding and staffing are coming from. I've just started my student

teaching in the special ed department of a local high school, and all

I ever hear about is all the cuts they've made to save money. The

resource rooms don't have any para eds, the self contained unit is

full so kids get placed inappropriately, the secretaries who used to

handle paperwork are gone, the classes don't have textbooks, the

teachers have way more students in their classes than state law

allows... I just hear nonstop stories about kids and teachers that

aren't having their needs met because of fundingcuts, it surprises me

that there are so many stories of SMA kids with the opposite experience.

>

> Just interesting is all. :)

>

> e

>

> Re: (unknown)

>

> I just wanted to add that my son does have a one on one aide

and he is in 1st grade- I wouldn't have it any other way. He gets his

space but he also has the help right there when he needs it. I

personally would rather her assist than another child who may or may

not have a cold. I think with some of the kids, limiting the exposure

to more germs is important- at least with my son I feel that it is. It

has also helped him transition into school- he is used to having me

near and he didn't want to go to school until I told him there would

be someone helping him when he needed it. He was homebound for

Kindergarten. Hopefully, the need of her being so close can dissipate

and Brett can rely more on friends. His school has been phenomenal

with all of our requests and gone the extra mile in every way

possible- I feel very lucky!

>

> Kristal

> Mom to Brett- SMA II- 6-1/2 years old

> Visit Brett's website at: http://www.our-sma-angels.com/brett/index.htm

> Learn more about SMA:

> www.fsma.org

> www.smasupport.com

> (unknown)

>

> Thanks to all who gave info on my earlier post. I will get busy with

> calling and letters. This isnt a problem that has just started. I

> have fought with this school since PreK. I do know that If we were in

> a different county we wouldnt be having these problems. But we arent

> looking to move, and its the county and the schools responsiblility to

> accomodate to Zack and the other children. The buddy system gets old.

> He has tons of friends, but most ten year old children dont get the

> responsibility thing like they should. So even with them helping, the

> class is still waiting on him. Zack does speak his mind to us and

> tells us what he thinks and wants. He is so very much main streamed in

> every way possible. And there have been times where the friend was

> with him opening doors for him, but take off and decide they are done

> so thats leaves him where? I have looked at this from all different

> ways. Im not asking for someone to sit on top of him, just be there

> when he needs them. Its just our school system here. Didnt have this

> problem with the school when we moved away for a short time. Once

> again thanks a bunch and anything helps.

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  • 3 years later...

Hi ,

We are new to this (my DS just Dx'd two weeks ago) and we are awaiting the

formal written report from Children's. It is my understanding, though, that the

report from Children's is supposed to include all kinds of recommended supports

in the school system (15 minute time limit on home work, aide in classroom,

preferred seating, small lunch group). Just thinking that maybe you can go back

to Children's & let them know about the problems you are having. Maybe they can

identify some things your DD should be receiving. It is always a stronger

arguement if you can say experts in the field recommend x,y, & z, than trying to

argue it on your own.

Just a thought.

Good luck & best wishes.

>

> Hi, my 10 year old dd was recently diagnosed with AS...finally. We

> received this diagnose at our local Children's Hospital. We have

> requested that her school perform an evaluation on her to assess if she

> needs any services. She does suffer from anxiety, but controls it at

> school. Her grades are excellent. The school is refusing to initiate

> an evaluation b/c they say that academically, she is fine. I am ready

> to rip my hair out. We just want the evaluation and they won't do it.

> At this point, we are paying an advocate and we are handing in the NOREP

> stating we want mediation. Any advice at all about this. I really am

> so frustrated!

> Thanks, from PA

>

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You are doing a great job so far in getting a diagnosis and in getting an

advocate to help you at the IEP meetings. My son fell through the cracks at

first - It was obvious to me that he was struggling in school, but the school

district gave me the line that everything was fine since he was getting passing

grades - never mind that the grades were steadily going down and that he spent

some classes with his head on his desk...SO ask if a behavior psychologist from

the school district could quietly observe her in the classroom, at recess, and

over the lunch hour. The report I got was an eye opener for me as it made me

realize that things were much worse than I thought. The report also helped

establish that my son was having problems in the classroom because of his

disability.

You mentioned that your child suffers from anxiety, but controls it at school.

Let the school know about her meltdowns at home and her attitude about going to

school in the morning.

Are you helping her with homework? Is it taking her a long, long time to

complete some assignments? Any problems following instructions or planning

projects? Does she try to do a complex project the night before it is due? My

advice to you is to step back and truly let her do the homework on her own and

remember to turn in the homework on her own. Let her work on her own for about

an hour and then stop since that is about how long it should take the other kids

in her class. It may be painful to see what happens to her grades, but at this

point, the grades don't count for much. In the long run, it will certainly get

the teacher's attention and so the teacher may step up to help you get an IEP,

plus an assessment from the district.

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  • 1 year later...
Guest guest

My son will turn 3 at the end of May and as such, his Early Intervention

services will end. Had my informational meeting with the school district

yesterday. During the meeting, I advised that my major concern was

therapies/services would be available for my son during the summer months before

school started. They advised there was no summer program available and that we

could use our insurance to do provide services. Of course, we will still be

using our private insurance to get him therapy, but isn't the school district

legally responsible to provide him services once he turns 3? Any help would be

greatly appreciated.

Thanks,

Kim

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Guest guest

Our school district only provides summer school or services if a child is

shown to regress over summer or on winter break, etc.

On Wed, Mar 2, 2011 at 11:46 AM, kiddietalk <kiddietalk@...> wrote:

>

>

> Not sure if you read my book The Late Talker but if you didn't I highly

> recommend you at least take a look at the aeakdvocacy chapter as my co

> author is a neurodevelopmental pediatrician who advocates for her patients

> in the schools, and we had the advise as well from special education

> attorneys and an award winning teacher advocate (our VP of Cherab :) Cheryl

> Bennet SLP included)

>

> Whenever a school professional says something that sounds wrong just say

> nicely " That's interesting, would you mind putting in writing for me why

> there are no summer programs available at all for my son even if extended

> school year is found appropriate for him? "

>

> Trust me -nothing will be put in writing that is against your child's

> rights. And if they don't put it in writing- you should. Keep a paper trail

> -use tape recorders at the IEP meetings. Not that you have to be aggressive

> and nasty -you can do all in a very nice way and explain that you would like

> to share the information with your child's private doctor (or therapist) as

> this is all new to you etc. You can come up with a zillion reasons why you

> bring a tape recorder- but just do.

>

> Here are some archives

>

> Re: denied speech for summer... advice?

>

> There's much in the archives about this -here's just a bit:

>

> Actually this is from The Late Talker book but rest from the archives

>

> " Many children with severe speech impairments regress without continued

> therapy,

> so make sure your child gets enrolled in the Extended School Year (ESY)

> program,

> especially for the long summer break. ESY services must be considered at

> the

> annual IEP meeting and documented in the IEP. The ESY also has to be the

> same as

> what your child receives during the regular school year. For example, if he

> normally has a ten hour a week schedule, his ESY should also be for ten

> hours a

> week. "

>

> The Late Talker book 2003 Agin, Geng, Nicholl

>

> Re: [ ] ESY Services

> As with any special education school service, please remember one thing.

> Special education is funded by the state. The school district may want to

> provide many things. But if state funding is not provided, it is probably

> not going to happen.

>

>

> FYI - It's getting time to schedule those meetings with your schools to

> discuss

> ESY. Do not let the schools jump past the ESY portion in your IEP meeting

> and

> merely tell you your child doesn't qualify (no regression), so no need for

> ESY.

> Regression is NOT the only requirement for ESY, I've bolded important

> information below.

>

> Also, don't let the school tell you ESY is traditional summer school, it is

> not,

> although it can be if it is appropriate to meet the child's IEP goals.

>

> I often use ESY services to negotiate additional services for children

> where the

> school has " Failed to Identify " , appropriately remediate a child's learning

> problem, and/or failed to provide identified spec. ed. support or related

> services. I've used it to give the school one more chance to teach a child

> to

> read or to teach a child appropriate social skills, before pulling out and

> privately placing the child at public expense. The school system can pay

> for

> traditional summer school classes as ESY services for instance, if a school

> failed to identify a child with a disability, and the child failed the

> first

> semester of High School, and now needs to make up courses during Summer

> School.

>

> Extended School Year can look at many things. Don't let the schools tell

> you no

> automatically, and don't let them tell you it is only for the severely

> disabled.

> NOT TRUE! Talk with an advocate, attorney, or disability organization to

> find

> out more information.

>

> Carol Sadler

> Special Education Consultant/Advocate

> GA Advocacy Office PLSP I Graduate

> 770-442-8357

> 1105 Rock Pointe Look

> Woodstock, GA 30188

> CarolSadler@...

> www.IEPadvocate4You.com <http://www.iepadvocate4you.com/>

> http://iepadvocate4you.blogspot.com/

>

> CONFIDENTIAL AND PRIVILEGED

> Information contained in this communication is confidential and privileged.

> It

> is not meant to represent legal or medical advice, but rather advice given

> based

> on my knowledge as a trained Parent Advocate by the GA Advocacy Office,

> Council

> of Parent Advocates & Attorneys, CHADD, LDA, and the GA DOE Parent Mentor

> program as an invited guest. Please do not forward without my permission.

>

> Extended School Year (ESY)

>

> The Individuals with Disabilities Education Act (IDEA) regulations

> requirethat

> ESY services be considered annually for every child with a disability.An

> ESY

> Program of services in the summer or weekends, must be provided if needed

> to

> make a student's education program appropriate. " Under the law, aschool

> district

> may not limit ESY services for children with particular categories of

> disabilities, and may not limit the type, amount or duration of ESY. " (Ed

> Law

> Center - PA)

>

> A school system cannot use a " lack ofavailable funds " argument to deny ESY

> services to a child with a disability.School districts must look at issues

> beyond regression or recoupment whendetermining ESY eligibility.

>

> ESY is NOT traditional summer school, but rather an extension of an

> individual

> child's education plan!

>

> The following is taken

> from:http://www.ppmd.org/publications/extended_school_year.html It is a

> summary

> of judicial decisions regarding ESY.

>

> Extended School Year

> by Rose Kraft

>

> Since the precedent for extended school year programming was set in the

> Armstrong v. Kline case in Philadelphia, in a large number of instances the

> courts have been asked to determine the eligibility of individual children

> for

> extended school year services. This summary looks at the judicial decisions

> that

> have been rendered regarding this issue.

>

> Judges and lawmakers have made significant decisions during the last 20

> years,

> which define extended school year (ESY) services for childen with

> disabilities.

> Several district court cases, beginning with Armstrong v. Kline (1979) and

> culminating with Reusch v. Fountain (1994), shaped thecurrent federal

> regulations. For the first time in the history of the Individuals with

> Disabilities Education Act (IDEA), these regulations require that ESY

> services

> be considered annually for every child with a disability. Each team that

> develops an individual education plan (IEP) for achild must decide if ESY

> services are necessary so that the child can avoid regression, a lengthy

> recoupment of lost skills, or other difficulties that could interfere with

> the

> education plan.

>

> The first significant case in this arena was the Armstrong case, in which

> the

> judge ruled that a mandated 180-day school year violated a child's right to

> a

> free appropriate public education (FAPE), specifically in reference to

> children

> with severe and profound impairments or severe emotional disturbances. The

> court

> stated that, " By its terms, the Act (meaning the Education for All

> Handicapped

> Children Act) appears to demand that the state supply instruction designed

> to

> meet all of the handicapped child's " unique needs " without limitation. " The

> court also required state and local school districts " to provide an

> education to

> handicapped children in excess of 180 days, " as determined by each child's

> needs.

>

> This case defined that a school system's goal for these severely affected

> children should be self-sufficiency, which could require providing more

> thanthe

> same 180 days to disabled children that is provided to non disabled

> children.

> This case was upheld on appeal by the circuit court, which agreed that,

> " For

> some, but not all, SPI and SED children, standing in the way of the

> attainment

> of some of these objectives (for self-sufficiency) is the effect of breaks

> in

> the educational program which are created, at least inpart, by the 180 day

> rule. " The court also noted that recoupment time for lost skills is

> " usually

> much greater " for children with disabilities.

>

> Once the courts ordered state and local school systems to provide more than

> 180

> days of school per year to some children with disabilities, families across

> the

> nation began taking their school systems to court. In Stacey G.v. Pasadena

> Independent School District (1982), a 12-month program without major breaks

> was

> ruled necessary for a child with autism and severe mental retardation. In

> Georgia Association for Retarded Citizens v. Mc (1983), the court

> ruled

> that a school system cannot use a " lack of available funds " argument to

> deny ESY

> services to a child with a disability. A school system must look at the

> child's

> needs, rather than at its budget, when determining summer services for a

> child.

> The judge in Alamo Heights Independent School District v. State Board of

> Education (1986) noted that transportation services must be part of the ESY

> package for a child, even if the bus must get that child from a

> babysitter's

> out-of-district home.

>

> The case of Bucks County Public Schools v. Commonwealth of Pennsylvania

> (1987)

> showed that academic regression isn't the only qualification for ESY

> eligibility. The judge in the Bucks County case stated that regression in

> emotional development for severely emotionally disturbed children is often

> " caused by interruptions in the educational programming, " and ordered that

> prediction of regression in emotional development qualifies as a need for

> ESY.

> Holmes v. Sobol (1988) was a significant case because it found that

> physical

> therapy was a related service that could be provided for ESY, and further

> ruled

> that a related service can be a sole special education program. This case

> stated

> that without the maintenance of physical strength through therapy, the

> child

> would not be able to benefit from his general education. In v.

> Gering

> Public Schools (1990), the parents of a child with multiple disabilities

> believed that a 12-month program could only be provided for their child in

> a

> residential placement. This court agreed that the child needed a 12-month

> school

> program in order to receive a free appropriate public education, but did

> not

> require that it be provided in a residential facility. The court ordered

> the

> school district to provide the12-month program at a local facility for

> multi

> handicapped children, specifying that an interruption from one school to

> another

> just for a summer program would provide an unacceptable level of regression

> for

> the child.

>

> Reusch v. Fountain (1994) blasted a land school district for deceptive

> and

> purposeful policies which sought to deprive children of ESY services.The

> school

> district had (a) refused to notify parents of a child's eligibility for ESY

> services, (B) written misleading letters recommending asummer program that

> required tuition from the parents, © told schooladministrators to refer

> parents to central administration when they asked for ESY services, (d)

> purposely didn't mention ESY services until it was too late to deliver

> them, and

> (e) never told parents they had a right to request ESY services. The judge

> used

> strong language as he set the parameters for ESY policies for children with

> disabilities. " The MCPS practice of inadequate and untimely ESY notice must

> cease. Notice of ESY designed to fully explain such services must be

> provided to

> parents of disabled childrenin a timely fashion before annual review

> meetings.

> The notice must not disguise or downplay the true nature of ESY or attempt

> to

> confuse parents between free extended year services and tuition-charging

> summer

> enrichmentprograms. " The court went further and required that additional

> criteria be considered in addition to regression and recoupment time when

> considering achild for ESY services. The court decided that " emerging

> skills "

> and " breakthrough opportunities " (as when a child is on the brink of

> learning to

> read) -- can and should be incorporated into the eligibility analysis. " A

> fixed-length program was also ruled illegal by this court, which ordered

> the

> school district to " make individualized determinations of the number of

> weeks,

> days per week, and hours per day that each student receiving ESYshould be

> provided.

>

> " While litigation continued in courtrooms across the country, the Office of

> Special Education Programs and the Office of Special Education and

> Rehabilitative Services wrote policy letters, which provided interpretation

> of

> the federal regulations for school districts. The Office of Civil Rights

> wrote

> letters of finding which defined when the denial of ESY services violated a

> person's civil rights. Together these letters provided parallel support for

> the

> court decisions by (a) defining ESY criteria and related services in an ESY

> program, (B) requiring school districts to look at issues beyond regression

> or

> recoupment when determining ESY eligibility, ©emphasizing the need to set

> higher ESY standards than simply working toward self-sufficiency, (d)

> refusing

> to allow school districts to offer ESYprograms that were available only to

> the

> most severely disabled children,and (e) requiring that integration with

> nondisabled peers be provided in ESYprograms if required by the IEP.

>

> The result of the court cases and substantive letters has led to the

> written

> federal regulations, which describe how ESY services are to be implemented

> according to IDEA. The regulations define ESY as " special education and

> related

> services " which (a) go beyond the normal school year, (B) are addressed and

> mandated by the IEP, and © are free to the parents. The regulations also

> require that ESY services are available to each child with a disability

> and,

> " The determination of whether a child with a disability needs extended

> school

> year services must be made on an individual basis by the child's IEP team. "

> 34

> CFR ? 300.309 (1997).

>

> The regulations also add two notes clarifying these definitions. The first

> note

> states that school districts cannot limit ESY services to " particular

> categories

> of disability or unilaterally limit the duration of services. " The second

> note

> gives states the authority to set standards for use in determining ESY

> eligibility " on an individual basis, " suggesting the consideration of

> factors

> such as the " likelihood of regression, slow recoupment, and predictive data

> based on the opinion of professionals.

>

> " References:

> Alamo Heights Independent School District v. State Board of Education,

> Education for the Handicapped Law Report 554:315 (5th Cir. 1986).

> Armstrong v. Kline, Education for the Handicapped Law Report 551:195 (

> E.D.Pa <http://e.d.pa/>.

> 1979). Baltimore (MD) City Public Schools (1986).

> Office of Civil Rights Letter of Finding, Education for the Handicapped Law

> Review 352:185.Battle v. Commonwealth,

> Education for the Handicapped Law Report 551:647(3rd Cir. 1980).

> Bucks County Public Schools v. Commonwealth of Pennsylvania, Education

> forthe

> Handicapped Law Report 559:153 (Commonwealth Ct. of Pa. 1987).

> Davila, R. R. (1990, Nov.).

> Office of Special Education and RehabilitativeServices Policy Letter, 17

> Education for the Handicapped Law Review 419.

> Georgia Association for Retarted Citizens v. Mc, Education for

> theHandicapped Law Report 555:251 (11th Cir. 1983).

> Holmes v. Sobol, Education of the Handicapped Law Report 559:463 (W.D.

> Ny.1988).

> Mesa (AZ) Public Schools (1989).

> Office of Civil Rights Letter of Finding,16 Education for the Handicapped

> Law

> Review 316.

> Reusch v. Fountain, 21 Individuals with Disabilities Education Law

> Report1107

> (D. Md. 1994).

> Schrag, J. A. (1989, Aug.). Office of Special Education Programs

> PolicyLetter,

> Education for the Handicapped Law Review 213:255.

> Stacey G. v. Pasadena Indep endent School District, Education for

> theHandicapped

> Law Report 554:206 (S.D. Tx. 1982).

> Turnbull, H.R. III, & Turnbull, A.P. (1998).

> Free appropriate public education: The law and children with disabilities

> (5th

> ed.).

> Denver, CO:Love Publishing Company.Will, M. (1987, Aug.).

> Office of Special Education and Rehabilitative Services Policy Letter,

> Education

> for the Handicapped Law Review 211:481.

> v. Gering Public Schools, 17 Education ofthe Handicapped Law

> Report427

> (Ne. S. Ct. 1990).

>

> Extended School Year Services (ESY) - Info from

www.slaw.com<http://www.wrightslaw.com/>

> http://www.wrightslaw.com/info/esy.index.htm

>

> Many parents have questions about extended school year services. If you

> have

> questions about a legal issue, you should do your own legal research. Do

> not

> accept legal advice from school personnel. While they may tell you what

> they

> believe is true, in many cases, they have not read the law and regulations

> for

> themselves. You need to know what the law and regulations say!

>

> Read what the IDEA statute says about your issue. Next read the federal

> regulations and your state special ed regulations about your issue. (the

> IDEA

> statute and regulations are in slaw: Special Education Law and in the

> Statute and Regs section of the slaw site)

>

> Next read a case or two about your issue (check the Caselaw Library). If

> you

> take these steps, you will have a clear understanding of the issues and

> variables.

>

> You will find that extended school year (ESY) is not mentioned in the IDEA

> statute, but is in the IDEA regulations. Read the IDEA regulation about

> ESYat 34

> CFR Section 300.309 (page 165, slaw: Special Education Law).

>

> We selected two cases about ESY to help you understand these issues:

> Lawyer v. Chesterfield and Reusch v. Fountain. For more information, check

> the

> Topics Pages - especially the FAPE and IEP pages.

>

> " Windows of Opportunity " : Lawyer v. Chesterfield School Board (1993)Danny

> Lawyer

> is a young child with autism. At age six, he had expressive language and

> phonological processing problems. The experts who evaluated and treated

> Danny

> advised his parents that his ability to beself-sufficient and independent

> later

> in life would depend on his ability tocommunicate. During the summer, Danny

> regressed in his ability to communicate. His behavior deteriorated. His

> school

> district refused to provide any speech language therapy during the summer

> months

> - and refused to reimburse his parents for the services they purchased for

> their

> son. The parents requested a special education due process hearing and

> prevailed. The school district appealed. The Review Officer overturned the

> Hearing Officer's decision. The case was appealed to Federal Court.

>

> After reviewing the record and hearing new testimony, Judge Spencer

> concluded,

> " Regression is not the only factor " in deciding if a child needs ESY

> services.

> The judge listed several additional factors that IEP teams should consider

> in

> making ESY decisions:

> Recoupment in the Fall;

> Child's rate of progress;

> Child's behavioral or physical problems;

> Availability of alternative resources;

> Areas of the child's curriculum that need continuous attention;

> Child's vocational needs.

>

> In " Lawyer, " Judge Spencer discussed regression and recoupment. He also

> discussed the need to take advantage of " windows of opportunity " in

> educating

> children with disabilities: " Danny's regression in the summer, coupled with

> nominal recoupment, severely limits the educational benefits he receives

> from

> instruction during the school year. His rate of progress isminimized by the

> interplay of continuous regression and recoupment. " " Moreover, Danny's

> behavioral

> problems are compounded by his severe language deficit. His inability to

> effectively communicate triggers unacceptable behavior. Therefore, it is

> critical that Danny be provided with continuous speech and communication

> services. " " Finally, the evidence provided by expert witnesses indicates

> that

> for children who suffer from moderate to severe childhood autism, there is

> a

> small, but vital, window of opportunityin which they can effectively learn.

> Such

> period is generally between theages of five and eight years old....The

> Court

> concludes that it is extremely important that at this critical stage of

> development, Danny receive uninterrupted speech language therapy.

>

> " Read the decision in Lawyer v. Chesterfield.

>

> Hostility to Providing ESY: Reusch v. Fountain (1994) In Reusch v.

> Fountain, 872

> F.Supp. 1421 (D. MD 1994), a federal court addressed the school districts

> " hostility to providing ESY. " In this case,the court found that parents

> were

> prevented from advocating for their children by the districts refusal to

> provide

> parents with notice about their right to request these services. The

> district

> also engaged in delaying tactics by requiring parents to attend futile

> meetings.

> The court found that, in this district, administrative convenience took

> precedence over providing FAPE to children with disabilities. Educational

> decisions were not individualized according to the needs of the child.

>

> Six Factors for IEP Teams to Consider

>

> In Reusch v. Fountain, the court listed six factors that the IEP team

> shouldconsider in deciding if the child is eligible for ESY as a related

> service:

>

> 1. Regression and recoupment - is the child likely to lose critical skills

> or

> fail to recover these skills within in a reasonable time;

> 2. Degree of progress toward IEP goals and objectives;

> 3. Emerging skills/breakthrough opportunities - Will a lengthy summer break

> cause significant problems for a child who is learning a key skill,

> likereading;

> 4. Interfering Behavior - does the childs behavior interfere with his or

> her

> ability to benefit from special education;

> 5. Nature and/or severity of disability;

> 6. Special circumstances that interfere with childs ability to benefit from

> special education.

>

> Citing Pete's case, Florence County School District Four v. ,

> the

> District Court found that: " In any contest between systematic efficiency

> and the

> provision of FAPE to a disabled child, Congress and the Supreme Court have

> made

> it clear that the child must prevail. "

>

> Other findings:

>

> Notice and Timing - The importance of making a decision about ESY early

> enough

> in the school year to allow the parents adequate time to exercisetheir

> rights

> administrative review or appeal in a timely fashion. That the explanation

> about

> ESY contained in a brochure distributed to all studentswas not sufficient

> and

> ordered that the student's eligibility for ESY be considered at each annual

> review meeting, and the parents sign a form acknowledging their receipt of

> this

> information. The district must documentthe discussion and the decision

> reached

> after consideration of ESYeligibilty at each annual review meeting.

>

> Content and Duration - The content of child's ESY program must be

> determined on

> an individual basis. The duration is also based on individualized

> determinations

> of the number of weeks, days per week,and hours per day that each student

> receiving ESY should be provided.

>

> Copyright 1999-2002, W. D. and Pamela Darr .

> All rightsreserved. www.wrightlaw.com

>

> --

> Posted by Carol Sadler to IEPadvocate4You at 3/14/2005 05:59:00 AM

>

> =====

>

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Guest guest

Hi Kim,

You don't say what school distict you are in,but i know there are services out

there that will help. Look into Provider 50. My daughter has been recieving

services from them since she was three.(now 10)We recieve services from

Behavioral Health Associates in Weissport,Pa. There is also Holcolm.There are

more,but I can't remember off hand. You may also want to look into Pinebrook

Services.They have offices in town and Easton.

One other place to look is Good Shepherd Pediatrics in town. They provide

OT,PT,speech and physical therapies.

GOOD LUCK!

Dawn

>

> My son will turn 3 at the end of May and as such, his Early Intervention

services will end. Had my informational meeting with the school district

yesterday. During the meeting, I advised that my major concern was

therapies/services would be available for my son during the summer months before

school started. They advised there was no summer program available and that we

could use our insurance to do provide services. Of course, we will still be

using our private insurance to get him therapy, but isn't the school district

legally responsible to provide him services once he turns 3? Any help would be

greatly appreciated.

>

> Thanks,

> Kim

>

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Guest guest

So glad to read this post! I think my son's IEP update will be in May and this

will be his 1st one since starting preschool services. Want to make sure he gets

summer speech sessions too.

Thanks-

Sent from my Verizon Wireless BlackBerry

[ ] Re: Help with school

Not sure if you read my book The Late Talker but if you didn't I highly

recommend you at least take a look at the advocacy chapter as my co author is a

neurodevelopmental pediatrician who advocates for her patients in the schools,

and we had the advise as well from special education attorneys and an award

winning teacher advocate (our VP of Cherab :) Cheryl Bennet SLP

included)

Whenever a school professional says something that sounds wrong just say nicely

" That's interesting, would you mind putting in writing for me why there are no

summer programs available at all for my son even if extended school year is

found appropriate for him? "

Trust me -nothing will be put in writing that is against your child's rights.

And if they don't put it in writing- you should. Keep a paper trail -use tape

recorders at the IEP meetings. Not that you have to be aggressive and nasty

-you can do all in a very nice way and explain that you would like to share the

information with your child's private doctor (or therapist) as this is all new

to you etc. You can come up with a zillion reasons why you bring a tape

recorder- but just do.

Here are some archives

Re: denied speech for summer... advice?

There's much in the archives about this -here's just a bit:

Actually this is from The Late Talker book but rest from the archives

" Many children with severe speech impairments regress without continued therapy,

so make sure your child gets enrolled in the Extended School Year (ESY) program,

especially for the long summer break. ESY services must be considered at the

annual IEP meeting and documented in the IEP. The ESY also has to be the same as

what your child receives during the regular school year. For example, if he

normally has a ten hour a week schedule, his ESY should also be for ten hours a

week. "

The Late Talker book 2003 Agin, Geng, Nicholl

Re: [ ] ESY Services

As with any special education school service, please remember one thing.

Special education is funded by the state. The school district may want to

provide many things. But if state funding is not provided, it is probably

not going to happen.

FYI - It's getting time to schedule those meetings with your schools to discuss

ESY. Do not let the schools jump past the ESY portion in your IEP meeting and

merely tell you your child doesn't qualify (no regression), so no need for ESY.

Regression is NOT the only requirement for ESY, I've bolded important

information below.

Also, don't let the school tell you ESY is traditional summer school, it is not,

although it can be if it is appropriate to meet the child's IEP goals.

I often use ESY services to negotiate additional services for children where the

school has " Failed to Identify " , appropriately remediate a child's learning

problem, and/or failed to provide identified spec. ed. support or related

services. I've used it to give the school one more chance to teach a child to

read or to teach a child appropriate social skills, before pulling out and

privately placing the child at public expense. The school system can pay for

traditional summer school classes as ESY services for instance, if a school

failed to identify a child with a disability, and the child failed the first

semester of High School, and now needs to make up courses during Summer School.

Extended School Year can look at many things. Don't let the schools tell you no

automatically, and don't let them tell you it is only for the severely disabled.

NOT TRUE! Talk with an advocate, attorney, or disability organization to find

out more information.

Carol Sadler

Special Education Consultant/Advocate

GA Advocacy Office PLSP I Graduate

770-442-8357

1105 Rock Pointe Look

Woodstock, GA 30188

CarolSadler@...

www.IEPadvocate4You.com

http://iepadvocate4you.blogspot.com/

CONFIDENTIAL AND PRIVILEGED

Information contained in this communication is confidential and privileged. It

is not meant to represent legal or medical advice, but rather advice given based

on my knowledge as a trained Parent Advocate by the GA Advocacy Office, Council

of Parent Advocates & Attorneys, CHADD, LDA, and the GA DOE Parent Mentor

program as an invited guest. Please do not forward without my permission.

Extended School Year (ESY)

The Individuals with Disabilities Education Act (IDEA) regulations requirethat

ESY services be considered annually for every child with a disability.An ESY

Program of services in the summer or weekends, must be provided if needed to

make a student's education program appropriate. " Under the law, aschool district

may not limit ESY services for children with particular categories of

disabilities, and may not limit the type, amount or duration of ESY. " (Ed Law

Center - PA)

A school system cannot use a " lack ofavailable funds " argument to deny ESY

services to a child with a disability.School districts must look at issues

beyond regression or recoupment whendetermining ESY eligibility.

ESY is NOT traditional summer school, but rather an extension of an individual

child's education plan!

The following is taken

from:http://www.ppmd.org/publications/extended_school_year.html It is a summary

of judicial decisions regarding ESY.

Extended School Year

by Rose Kraft

Since the precedent for extended school year programming was set in the

Armstrong v. Kline case in Philadelphia, in a large number of instances the

courts have been asked to determine the eligibility of individual children for

extended school year services. This summary looks at the judicial decisions that

have been rendered regarding this issue.

Judges and lawmakers have made significant decisions during the last 20 years,

which define extended school year (ESY) services for childen with disabilities.

Several district court cases, beginning with Armstrong v. Kline (1979) and

culminating with Reusch v. Fountain (1994), shaped thecurrent federal

regulations. For the first time in the history of the Individuals with

Disabilities Education Act (IDEA), these regulations require that ESY services

be considered annually for every child with a disability. Each team that

develops an individual education plan (IEP) for achild must decide if ESY

services are necessary so that the child can avoid regression, a lengthy

recoupment of lost skills, or other difficulties that could interfere with the

education plan.

The first significant case in this arena was the Armstrong case, in which the

judge ruled that a mandated 180-day school year violated a child's right to a

free appropriate public education (FAPE), specifically in reference to children

with severe and profound impairments or severe emotional disturbances. The court

stated that, " By its terms, the Act (meaning the Education for All Handicapped

Children Act) appears to demand that the state supply instruction designed to

meet all of the handicapped child's " unique needs " without limitation. " The

court also required state and local school districts " to provide an education to

handicapped children in excess of 180 days, " as determined by each child's

needs.

This case defined that a school system's goal for these severely affected

children should be self-sufficiency, which could require providing more thanthe

same 180 days to disabled children that is provided to non disabled children.

This case was upheld on appeal by the circuit court, which agreed that, " For

some, but not all, SPI and SED children, standing in the way of the attainment

of some of these objectives (for self-sufficiency) is the effect of breaks in

the educational program which are created, at least inpart, by the 180 day

rule. " The court also noted that recoupment time for lost skills is " usually

much greater " for children with disabilities.

Once the courts ordered state and local school systems to provide more than 180

days of school per year to some children with disabilities, families across the

nation began taking their school systems to court. In Stacey G.v. Pasadena

Independent School District (1982), a 12-month program without major breaks was

ruled necessary for a child with autism and severe mental retardation. In

Georgia Association for Retarded Citizens v. Mc (1983), the court ruled

that a school system cannot use a " lack of available funds " argument to deny ESY

services to a child with a disability. A school system must look at the child's

needs, rather than at its budget, when determining summer services for a child.

The judge in Alamo Heights Independent School District v. State Board of

Education (1986) noted that transportation services must be part of the ESY

package for a child, even if the bus must get that child from a babysitter's

out-of-district home.

The case of Bucks County Public Schools v. Commonwealth of Pennsylvania (1987)

showed that academic regression isn't the only qualification for ESY

eligibility. The judge in the Bucks County case stated that regression in

emotional development for severely emotionally disturbed children is often

" caused by interruptions in the educational programming, " and ordered that

prediction of regression in emotional development qualifies as a need for ESY.

Holmes v. Sobol (1988) was a significant case because it found that physical

therapy was a related service that could be provided for ESY, and further ruled

that a related service can be a sole special education program. This case stated

that without the maintenance of physical strength through therapy, the child

would not be able to benefit from his general education. In v. Gering

Public Schools (1990), the parents of a child with multiple disabilities

believed that a 12-month program could only be provided for their child in a

residential placement. This court agreed that the child needed a 12-month school

program in order to receive a free appropriate public education, but did not

require that it be provided in a residential facility. The court ordered the

school district to provide the12-month program at a local facility for multi

handicapped children, specifying that an interruption from one school to another

just for a summer program would provide an unacceptable level of regression for

the child.

Reusch v. Fountain (1994) blasted a land school district for deceptive and

purposeful policies which sought to deprive children of ESY services.The school

district had (a) refused to notify parents of a child's eligibility for ESY

services, (B) written misleading letters recommending asummer program that

required tuition from the parents, © told schooladministrators to refer

parents to central administration when they asked for ESY services, (d)

purposely didn't mention ESY services until it was too late to deliver them, and

(e) never told parents they had a right to request ESY services. The judge used

strong language as he set the parameters for ESY policies for children with

disabilities. " The MCPS practice of inadequate and untimely ESY notice must

cease. Notice of ESY designed to fully explain such services must be provided to

parents of disabled childrenin a timely fashion before annual review meetings.

The notice must not disguise or downplay the true nature of ESY or attempt to

confuse parents between free extended year services and tuition-charging summer

enrichmentprograms. " The court went further and required that additional

criteria be considered in addition to regression and recoupment time when

considering achild for ESY services. The court decided that " emerging skills "

and " breakthrough opportunities " (as when a child is on the brink of learning to

read) -- can and should be incorporated into the eligibility analysis. " A

fixed-length program was also ruled illegal by this court, which ordered the

school district to " make individualized determinations of the number of weeks,

days per week, and hours per day that each student receiving ESYshould be

provided.

" While litigation continued in courtrooms across the country, the Office of

Special Education Programs and the Office of Special Education and

Rehabilitative Services wrote policy letters, which provided interpretation of

the federal regulations for school districts. The Office of Civil Rights wrote

letters of finding which defined when the denial of ESY services violated a

person's civil rights. Together these letters provided parallel support for the

court decisions by (a) defining ESY criteria and related services in an ESY

program, (B) requiring school districts to look at issues beyond regression or

recoupment when determining ESY eligibility, ©emphasizing the need to set

higher ESY standards than simply working toward self-sufficiency, (d) refusing

to allow school districts to offer ESYprograms that were available only to the

most severely disabled children,and (e) requiring that integration with

nondisabled peers be provided in ESYprograms if required by the IEP.

The result of the court cases and substantive letters has led to the written

federal regulations, which describe how ESY services are to be implemented

according to IDEA. The regulations define ESY as " special education and related

services " which (a) go beyond the normal school year, (B) are addressed and

mandated by the IEP, and © are free to the parents. The regulations also

require that ESY services are available to each child with a disability and,

" The determination of whether a child with a disability needs extended school

year services must be made on an individual basis by the child's IEP team. " 34

CFR ? 300.309 (1997).

The regulations also add two notes clarifying these definitions. The first note

states that school districts cannot limit ESY services to " particular categories

of disability or unilaterally limit the duration of services. " The second note

gives states the authority to set standards for use in determining ESY

eligibility " on an individual basis, " suggesting the consideration of factors

such as the " likelihood of regression, slow recoupment, and predictive data

based on the opinion of professionals.

" References:

Alamo Heights Independent School District v. State Board of Education,

Education for the Handicapped Law Report 554:315 (5th Cir. 1986).

Armstrong v. Kline, Education for the Handicapped Law Report 551:195 (E.D.Pa.

1979). Baltimore (MD) City Public Schools (1986).

Office of Civil Rights Letter of Finding, Education for the Handicapped Law

Review 352:185.Battle v. Commonwealth,

Education for the Handicapped Law Report 551:647(3rd Cir. 1980).

Bucks County Public Schools v. Commonwealth of Pennsylvania, Education forthe

Handicapped Law Report 559:153 (Commonwealth Ct. of Pa. 1987).

Davila, R. R. (1990, Nov.).

Office of Special Education and RehabilitativeServices Policy Letter, 17

Education for the Handicapped Law Review 419.

Georgia Association for Retarted Citizens v. Mc, Education for

theHandicapped Law Report 555:251 (11th Cir. 1983).

Holmes v. Sobol, Education of the Handicapped Law Report 559:463 (W.D. Ny.1988).

Mesa (AZ) Public Schools (1989).

Office of Civil Rights Letter of Finding,16 Education for the Handicapped Law

Review 316.

Reusch v. Fountain, 21 Individuals with Disabilities Education Law Report1107

(D. Md. 1994).

Schrag, J. A. (1989, Aug.). Office of Special Education Programs PolicyLetter,

Education for the Handicapped Law Review 213:255.

Stacey G. v. Pasadena Indep endent School District, Education for theHandicapped

Law Report 554:206 (S.D. Tx. 1982).

Turnbull, H.R. III, & Turnbull, A.P. (1998).

Free appropriate public education: The law and children with disabilities (5th

ed.).

Denver, CO:Love Publishing Company.Will, M. (1987, Aug.).

Office of Special Education and Rehabilitative Services Policy Letter, Education

for the Handicapped Law Review 211:481.

v. Gering Public Schools, 17 Education ofthe Handicapped Law Report427

(Ne. S. Ct. 1990).

Extended School Year Services (ESY) - Info from www.slaw.com

http://www.wrightslaw.com/info/esy.index.htm

Many parents have questions about extended school year services. If you have

questions about a legal issue, you should do your own legal research. Do not

accept legal advice from school personnel. While they may tell you what they

believe is true, in many cases, they have not read the law and regulations for

themselves. You need to know what the law and regulations say!

Read what the IDEA statute says about your issue. Next read the federal

regulations and your state special ed regulations about your issue. (the IDEA

statute and regulations are in slaw: Special Education Law and in the

Statute and Regs section of the slaw site)

Next read a case or two about your issue (check the Caselaw Library). If you

take these steps, you will have a clear understanding of the issues and

variables.

You will find that extended school year (ESY) is not mentioned in the IDEA

statute, but is in the IDEA regulations. Read the IDEA regulation about ESYat 34

CFR Section 300.309 (page 165, slaw: Special Education Law).

We selected two cases about ESY to help you understand these issues:

Lawyer v. Chesterfield and Reusch v. Fountain. For more information, check the

Topics Pages - especially the FAPE and IEP pages.

" Windows of Opportunity " : Lawyer v. Chesterfield School Board (1993)Danny Lawyer

is a young child with autism. At age six, he had expressive language and

phonological processing problems. The experts who evaluated and treated Danny

advised his parents that his ability to beself-sufficient and independent later

in life would depend on his ability tocommunicate. During the summer, Danny

regressed in his ability to communicate. His behavior deteriorated. His school

district refused to provide any speech language therapy during the summer months

- and refused to reimburse his parents for the services they purchased for their

son. The parents requested a special education due process hearing and

prevailed. The school district appealed. The Review Officer overturned the

Hearing Officer's decision. The case was appealed to Federal Court.

After reviewing the record and hearing new testimony, Judge Spencer concluded,

" Regression is not the only factor " in deciding if a child needs ESY services.

The judge listed several additional factors that IEP teams should consider in

making ESY decisions:

Recoupment in the Fall;

Child's rate of progress;

Child's behavioral or physical problems;

Availability of alternative resources;

Areas of the child's curriculum that need continuous attention;

Child's vocational needs.

In " Lawyer, " Judge Spencer discussed regression and recoupment. He also

discussed the need to take advantage of " windows of opportunity " in educating

children with disabilities: " Danny's regression in the summer, coupled with

nominal recoupment, severely limits the educational benefits he receives from

instruction during the school year. His rate of progress isminimized by the

interplay of continuous regression and recoupment. " " Moreover, Danny's behavioral

problems are compounded by his severe language deficit. His inability to

effectively communicate triggers unacceptable behavior. Therefore, it is

critical that Danny be provided with continuous speech and communication

services. " " Finally, the evidence provided by expert witnesses indicates that

for children who suffer from moderate to severe childhood autism, there is a

small, but vital, window of opportunityin which they can effectively learn. Such

period is generally between theages of five and eight years old....The Court

concludes that it is extremely important that at this critical stage of

development, Danny receive uninterrupted speech language therapy.

" Read the decision in Lawyer v. Chesterfield.

Hostility to Providing ESY: Reusch v. Fountain (1994) In Reusch v. Fountain, 872

F.Supp. 1421 (D. MD 1994), a federal court addressed the school districts

" hostility to providing ESY. " In this case,the court found that parents were

prevented from advocating for their children by the districts refusal to provide

parents with notice about their right to request these services. The district

also engaged in delaying tactics by requiring parents to attend futile meetings.

The court found that, in this district, administrative convenience took

precedence over providing FAPE to children with disabilities. Educational

decisions were not individualized according to the needs of the child.

Six Factors for IEP Teams to Consider

In Reusch v. Fountain, the court listed six factors that the IEP team

shouldconsider in deciding if the child is eligible for ESY as a related

service:

1. Regression and recoupment - is the child likely to lose critical skills or

fail to recover these skills within in a reasonable time;

2. Degree of progress toward IEP goals and objectives;

3. Emerging skills/breakthrough opportunities - Will a lengthy summer break

cause significant problems for a child who is learning a key skill, likereading;

4. Interfering Behavior - does the childs behavior interfere with his or her

ability to benefit from special education;

5. Nature and/or severity of disability;

6. Special circumstances that interfere with childs ability to benefit from

special education.

Citing Pete's case, Florence County School District Four v. , the

District Court found that: " In any contest between systematic efficiency and the

provision of FAPE to a disabled child, Congress and the Supreme Court have made

it clear that the child must prevail. "

Other findings:

Notice and Timing - The importance of making a decision about ESY early enough

in the school year to allow the parents adequate time to exercisetheir rights

administrative review or appeal in a timely fashion. That the explanation about

ESY contained in a brochure distributed to all studentswas not sufficient and

ordered that the student's eligibility for ESY be considered at each annual

review meeting, and the parents sign a form acknowledging their receipt of this

information. The district must documentthe discussion and the decision reached

after consideration of ESYeligibilty at each annual review meeting.

Content and Duration - The content of child's ESY program must be determined on

an individual basis. The duration is also based on individualized determinations

of the number of weeks, days per week,and hours per day that each student

receiving ESY should be provided.

Copyright 1999-2002, W. D. and Pamela Darr .

All rightsreserved. www.wrightlaw.com

--

Posted by Carol Sadler to IEPadvocate4You at 3/14/2005 05:59:00 AM

=====

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Guest guest

This is one of those moments where I want to praise our school. We have

our daughter at Logan-ville, in Missouri. We are a tiny

community, and yet every year they amaze me with the level of commitment

to her education. Occupational and speech therapy have both been

provided year round since starting the program three years ago. She is

currently testing for Kindergarten placement. When I read these posts I

am reminded of how lucky I am to now have to fight for her rights.

Meyer

From:

[mailto: ] On Behalf Of

Stilwell

Sent: Wednesday, March 02, 2011 12:00 PM

Subject: Re: [ ] Re: Help with school

Our school district only provides summer school or services if a child

is

shown to regress over summer or on winter break, etc.

On Wed, Mar 2, 2011 at 11:46 AM, kiddietalk <kiddietalk@...

<mailto:kiddietalk%40> > wrote:

>

>

> Not sure if you read my book The Late Talker but if you didn't I

highly

> recommend you at least take a look at the aeakdvocacy chapter as my co

> author is a neurodevelopmental pediatrician who advocates for her

patients

> in the schools, and we had the advise as well from special education

> attorneys and an award winning teacher advocate (our VP of Cherab :)

Cheryl

> Bennet SLP included)

>

> Whenever a school professional says something that sounds wrong just

say

> nicely " That's interesting, would you mind putting in writing for me

why

> there are no summer programs available at all for my son even if

extended

> school year is found appropriate for him? "

>

> Trust me -nothing will be put in writing that is against your child's

> rights. And if they don't put it in writing- you should. Keep a paper

trail

> -use tape recorders at the IEP meetings. Not that you have to be

aggressive

> and nasty -you can do all in a very nice way and explain that you

would like

> to share the information with your child's private doctor (or

therapist) as

> this is all new to you etc. You can come up with a zillion reasons why

you

> bring a tape recorder- but just do.

>

> Here are some archives

>

> Re: denied speech for summer... advice?

>

> There's much in the archives about this -here's just a bit:

>

> Actually this is from The Late Talker book but rest from the archives

>

> " Many children with severe speech impairments regress without

continued

> therapy,

> so make sure your child gets enrolled in the Extended School Year

(ESY)

> program,

> especially for the long summer break. ESY services must be considered

at

> the

> annual IEP meeting and documented in the IEP. The ESY also has to be

the

> same as

> what your child receives during the regular school year. For example,

if he

> normally has a ten hour a week schedule, his ESY should also be for

ten

> hours a

> week. "

>

> The Late Talker book 2003 Agin, Geng, Nicholl

>

> Re: [ ] ESY Services

> As with any special education school service, please remember one

thing.

> Special education is funded by the state. The school district may want

to

> provide many things. But if state funding is not provided, it is

probably

> not going to happen.

>

>

> FYI - It's getting time to schedule those meetings with your schools

to

> discuss

> ESY. Do not let the schools jump past the ESY portion in your IEP

meeting

> and

> merely tell you your child doesn't qualify (no regression), so no need

for

> ESY.

> Regression is NOT the only requirement for ESY, I've bolded important

> information below.

>

> Also, don't let the school tell you ESY is traditional summer school,

it is

> not,

> although it can be if it is appropriate to meet the child's IEP goals.

>

> I often use ESY services to negotiate additional services for children

> where the

> school has " Failed to Identify " , appropriately remediate a child's

learning

> problem, and/or failed to provide identified spec. ed. support or

related

> services. I've used it to give the school one more chance to teach a

child

> to

> read or to teach a child appropriate social skills, before pulling out

and

> privately placing the child at public expense. The school system can

pay

> for

> traditional summer school classes as ESY services for instance, if a

school

> failed to identify a child with a disability, and the child failed the

> first

> semester of High School, and now needs to make up courses during

Summer

> School.

>

> Extended School Year can look at many things. Don't let the schools

tell

> you no

> automatically, and don't let them tell you it is only for the severely

> disabled.

> NOT TRUE! Talk with an advocate, attorney, or disability organization

to

> find

> out more information.

>

> Carol Sadler

> Special Education Consultant/Advocate

> GA Advocacy Office PLSP I Graduate

> 770-442-8357

> 1105 Rock Pointe Look

> Woodstock, GA 30188

> CarolSadler@... <mailto:CarolSadler%40bellsouth.net>

> www.IEPadvocate4You.com <http://www.iepadvocate4you.com/>

> http://iepadvocate4you.blogspot.com/

>

> CONFIDENTIAL AND PRIVILEGED

> Information contained in this communication is confidential and

privileged.

> It

> is not meant to represent legal or medical advice, but rather advice

given

> based

> on my knowledge as a trained Parent Advocate by the GA Advocacy

Office,

> Council

> of Parent Advocates & Attorneys, CHADD, LDA, and the GA DOE Parent

Mentor

> program as an invited guest. Please do not forward without my

permission.

>

> Extended School Year (ESY)

>

> The Individuals with Disabilities Education Act (IDEA) regulations

> requirethat

> ESY services be considered annually for every child with a

disability.An

> ESY

> Program of services in the summer or weekends, must be provided if

needed

> to

> make a student's education program appropriate. " Under the law,

aschool

> district

> may not limit ESY services for children with particular categories of

> disabilities, and may not limit the type, amount or duration of ESY. "

(Ed

> Law

> Center - PA)

>

> A school system cannot use a " lack ofavailable funds " argument to deny

ESY

> services to a child with a disability.School districts must look at

issues

> beyond regression or recoupment whendetermining ESY eligibility.

>

> ESY is NOT traditional summer school, but rather an extension of an

> individual

> child's education plan!

>

> The following is taken

> from:http://www.ppmd.org/publications/extended_school_year.html It is

a

> summary

> of judicial decisions regarding ESY.

>

> Extended School Year

> by Rose Kraft

>

> Since the precedent for extended school year programming was set in

the

> Armstrong v. Kline case in Philadelphia, in a large number of

instances the

> courts have been asked to determine the eligibility of individual

children

> for

> extended school year services. This summary looks at the judicial

decisions

> that

> have been rendered regarding this issue.

>

> Judges and lawmakers have made significant decisions during the last

20

> years,

> which define extended school year (ESY) services for childen with

> disabilities.

> Several district court cases, beginning with Armstrong v. Kline (1979)

and

> culminating with Reusch v. Fountain (1994), shaped thecurrent federal

> regulations. For the first time in the history of the Individuals with

> Disabilities Education Act (IDEA), these regulations require that ESY

> services

> be considered annually for every child with a disability. Each team

that

> develops an individual education plan (IEP) for achild must decide if

ESY

> services are necessary so that the child can avoid regression, a

lengthy

> recoupment of lost skills, or other difficulties that could interfere

with

> the

> education plan.

>

> The first significant case in this arena was the Armstrong case, in

which

> the

> judge ruled that a mandated 180-day school year violated a child's

right to

> a

> free appropriate public education (FAPE), specifically in reference to

> children

> with severe and profound impairments or severe emotional disturbances.

The

> court

> stated that, " By its terms, the Act (meaning the Education for All

> Handicapped

> Children Act) appears to demand that the state supply instruction

designed

> to

> meet all of the handicapped child's " unique needs " without

limitation. " The

> court also required state and local school districts " to provide an

> education to

> handicapped children in excess of 180 days, " as determined by each

child's

> needs.

>

> This case defined that a school system's goal for these severely

affected

> children should be self-sufficiency, which could require providing

more

> thanthe

> same 180 days to disabled children that is provided to non disabled

> children.

> This case was upheld on appeal by the circuit court, which agreed

that,

> " For

> some, but not all, SPI and SED children, standing in the way of the

> attainment

> of some of these objectives (for self-sufficiency) is the effect of

breaks

> in

> the educational program which are created, at least inpart, by the 180

day

> rule. " The court also noted that recoupment time for lost skills is

> " usually

> much greater " for children with disabilities.

>

> Once the courts ordered state and local school systems to provide more

than

> 180

> days of school per year to some children with disabilities, families

across

> the

> nation began taking their school systems to court. In Stacey G.v.

Pasadena

> Independent School District (1982), a 12-month program without major

breaks

> was

> ruled necessary for a child with autism and severe mental retardation.

In

> Georgia Association for Retarded Citizens v. Mc (1983), the

court

> ruled

> that a school system cannot use a " lack of available funds " argument

to

> deny ESY

> services to a child with a disability. A school system must look at

the

> child's

> needs, rather than at its budget, when determining summer services for

a

> child.

> The judge in Alamo Heights Independent School District v. State Board

of

> Education (1986) noted that transportation services must be part of

the ESY

> package for a child, even if the bus must get that child from a

> babysitter's

> out-of-district home.

>

> The case of Bucks County Public Schools v. Commonwealth of

Pennsylvania

> (1987)

> showed that academic regression isn't the only qualification for ESY

> eligibility. The judge in the Bucks County case stated that regression

in

> emotional development for severely emotionally disturbed children is

often

> " caused by interruptions in the educational programming, " and ordered

that

> prediction of regression in emotional development qualifies as a need

for

> ESY.

> Holmes v. Sobol (1988) was a significant case because it found that

> physical

> therapy was a related service that could be provided for ESY, and

further

> ruled

> that a related service can be a sole special education program. This

case

> stated

> that without the maintenance of physical strength through therapy, the

> child

> would not be able to benefit from his general education. In

v.

> Gering

> Public Schools (1990), the parents of a child with multiple

disabilities

> believed that a 12-month program could only be provided for their

child in

> a

> residential placement. This court agreed that the child needed a

12-month

> school

> program in order to receive a free appropriate public education, but

did

> not

> require that it be provided in a residential facility. The court

ordered

> the

> school district to provide the12-month program at a local facility for

> multi

> handicapped children, specifying that an interruption from one school

to

> another

> just for a summer program would provide an unacceptable level of

regression

> for

> the child.

>

> Reusch v. Fountain (1994) blasted a land school district for

deceptive

> and

> purposeful policies which sought to deprive children of ESY

services.The

> school

> district had (a) refused to notify parents of a child's eligibility

for ESY

> services, (B) written misleading letters recommending asummer program

that

> required tuition from the parents, © told schooladministrators to

refer

> parents to central administration when they asked for ESY services,

(d)

> purposely didn't mention ESY services until it was too late to deliver

> them, and

> (e) never told parents they had a right to request ESY services. The

judge

> used

> strong language as he set the parameters for ESY policies for children

with

> disabilities. " The MCPS practice of inadequate and untimely ESY notice

must

> cease. Notice of ESY designed to fully explain such services must be

> provided to

> parents of disabled childrenin a timely fashion before annual review

> meetings.

> The notice must not disguise or downplay the true nature of ESY or

attempt

> to

> confuse parents between free extended year services and

tuition-charging

> summer

> enrichmentprograms. " The court went further and required that

additional

> criteria be considered in addition to regression and recoupment time

when

> considering achild for ESY services. The court decided that " emerging

> skills "

> and " breakthrough opportunities " (as when a child is on the brink of

> learning to

> read) -- can and should be incorporated into the eligibility

analysis. " A

> fixed-length program was also ruled illegal by this court, which

ordered

> the

> school district to " make individualized determinations of the number

of

> weeks,

> days per week, and hours per day that each student receiving ESYshould

be

> provided.

>

> " While litigation continued in courtrooms across the country, the

Office of

> Special Education Programs and the Office of Special Education and

> Rehabilitative Services wrote policy letters, which provided

interpretation

> of

> the federal regulations for school districts. The Office of Civil

Rights

> wrote

> letters of finding which defined when the denial of ESY services

violated a

> person's civil rights. Together these letters provided parallel

support for

> the

> court decisions by (a) defining ESY criteria and related services in

an ESY

> program, (B) requiring school districts to look at issues beyond

regression

> or

> recoupment when determining ESY eligibility, ©emphasizing the need

to set

> higher ESY standards than simply working toward self-sufficiency, (d)

> refusing

> to allow school districts to offer ESYprograms that were available

only to

> the

> most severely disabled children,and (e) requiring that integration

with

> nondisabled peers be provided in ESYprograms if required by the IEP.

>

> The result of the court cases and substantive letters has led to the

> written

> federal regulations, which describe how ESY services are to be

implemented

> according to IDEA. The regulations define ESY as " special education

and

> related

> services " which (a) go beyond the normal school year, (B) are

addressed and

> mandated by the IEP, and © are free to the parents. The regulations

also

> require that ESY services are available to each child with a

disability

> and,

> " The determination of whether a child with a disability needs extended

> school

> year services must be made on an individual basis by the child's IEP

team. "

> 34

> CFR ? 300.309 (1997).

>

> The regulations also add two notes clarifying these definitions. The

first

> note

> states that school districts cannot limit ESY services to " particular

> categories

> of disability or unilaterally limit the duration of services. " The

second

> note

> gives states the authority to set standards for use in determining ESY

> eligibility " on an individual basis, " suggesting the consideration of

> factors

> such as the " likelihood of regression, slow recoupment, and predictive

data

> based on the opinion of professionals.

>

> " References:

> Alamo Heights Independent School District v. State Board of Education,

> Education for the Handicapped Law Report 554:315 (5th Cir. 1986).

> Armstrong v. Kline, Education for the Handicapped Law Report 551:195 (

> E.D.Pa <http://e.d.pa/>.

> 1979). Baltimore (MD) City Public Schools (1986).

> Office of Civil Rights Letter of Finding, Education for the

Handicapped Law

> Review 352:185.Battle v. Commonwealth,

> Education for the Handicapped Law Report 551:647(3rd Cir. 1980).

> Bucks County Public Schools v. Commonwealth of Pennsylvania, Education

> forthe

> Handicapped Law Report 559:153 (Commonwealth Ct. of Pa. 1987).

> Davila, R. R. (1990, Nov.).

> Office of Special Education and RehabilitativeServices Policy Letter,

17

> Education for the Handicapped Law Review 419.

> Georgia Association for Retarted Citizens v. Mc, Education for

> theHandicapped Law Report 555:251 (11th Cir. 1983).

> Holmes v. Sobol, Education of the Handicapped Law Report 559:463 (W.D.

> Ny.1988).

> Mesa (AZ) Public Schools (1989).

> Office of Civil Rights Letter of Finding,16 Education for the

Handicapped

> Law

> Review 316.

> Reusch v. Fountain, 21 Individuals with Disabilities Education Law

> Report1107

> (D. Md. 1994).

> Schrag, J. A. (1989, Aug.). Office of Special Education Programs

> PolicyLetter,

> Education for the Handicapped Law Review 213:255.

> Stacey G. v. Pasadena Indep endent School District, Education for

> theHandicapped

> Law Report 554:206 (S.D. Tx. 1982).

> Turnbull, H.R. III, & Turnbull, A.P. (1998).

> Free appropriate public education: The law and children with

disabilities

> (5th

> ed.).

> Denver, CO:Love Publishing Company.Will, M. (1987, Aug.).

> Office of Special Education and Rehabilitative Services Policy Letter,

> Education

> for the Handicapped Law Review 211:481.

> v. Gering Public Schools, 17 Education ofthe Handicapped Law

> Report427

> (Ne. S. Ct. 1990).

>

> Extended School Year Services (ESY) - Info from

www.slaw.com<http://www.wrightslaw.com/>

> http://www.wrightslaw.com/info/esy.index.htm

>

> Many parents have questions about extended school year services. If

you

> have

> questions about a legal issue, you should do your own legal research.

Do

> not

> accept legal advice from school personnel. While they may tell you

what

> they

> believe is true, in many cases, they have not read the law and

regulations

> for

> themselves. You need to know what the law and regulations say!

>

> Read what the IDEA statute says about your issue. Next read the

federal

> regulations and your state special ed regulations about your issue.

(the

> IDEA

> statute and regulations are in slaw: Special Education Law and

in the

> Statute and Regs section of the slaw site)

>

> Next read a case or two about your issue (check the Caselaw Library).

If

> you

> take these steps, you will have a clear understanding of the issues

and

> variables.

>

> You will find that extended school year (ESY) is not mentioned in the

IDEA

> statute, but is in the IDEA regulations. Read the IDEA regulation

about

> ESYat 34

> CFR Section 300.309 (page 165, slaw: Special Education Law).

>

> We selected two cases about ESY to help you understand these issues:

> Lawyer v. Chesterfield and Reusch v. Fountain. For more information,

check

> the

> Topics Pages - especially the FAPE and IEP pages.

>

> " Windows of Opportunity " : Lawyer v. Chesterfield School Board

(1993)Danny

> Lawyer

> is a young child with autism. At age six, he had expressive language

and

> phonological processing problems. The experts who evaluated and

treated

> Danny

> advised his parents that his ability to beself-sufficient and

independent

> later

> in life would depend on his ability tocommunicate. During the summer,

Danny

> regressed in his ability to communicate. His behavior deteriorated.

His

> school

> district refused to provide any speech language therapy during the

summer

> months

> - and refused to reimburse his parents for the services they purchased

for

> their

> son. The parents requested a special education due process hearing and

> prevailed. The school district appealed. The Review Officer overturned

the

> Hearing Officer's decision. The case was appealed to Federal Court.

>

> After reviewing the record and hearing new testimony, Judge Spencer

> concluded,

> " Regression is not the only factor " in deciding if a child needs ESY

> services.

> The judge listed several additional factors that IEP teams should

consider

> in

> making ESY decisions:

> Recoupment in the Fall;

> Child's rate of progress;

> Child's behavioral or physical problems;

> Availability of alternative resources;

> Areas of the child's curriculum that need continuous attention;

> Child's vocational needs.

>

> In " Lawyer, " Judge Spencer discussed regression and recoupment. He

also

> discussed the need to take advantage of " windows of opportunity " in

> educating

> children with disabilities: " Danny's regression in the summer, coupled

with

> nominal recoupment, severely limits the educational benefits he

receives

> from

> instruction during the school year. His rate of progress isminimized

by the

> interplay of continuous regression and recoupment. " " Moreover, Danny's

> behavioral

> problems are compounded by his severe language deficit. His inability

to

> effectively communicate triggers unacceptable behavior. Therefore, it

is

> critical that Danny be provided with continuous speech and

communication

> services. " " Finally, the evidence provided by expert witnesses

indicates

> that

> for children who suffer from moderate to severe childhood autism,

there is

> a

> small, but vital, window of opportunityin which they can effectively

learn.

> Such

> period is generally between theages of five and eight years old....The

> Court

> concludes that it is extremely important that at this critical stage

of

> development, Danny receive uninterrupted speech language therapy.

>

> " Read the decision in Lawyer v. Chesterfield.

>

> Hostility to Providing ESY: Reusch v. Fountain (1994) In Reusch v.

> Fountain, 872

> F.Supp. 1421 (D. MD 1994), a federal court addressed the school

districts

> " hostility to providing ESY. " In this case,the court found that

parents

> were

> prevented from advocating for their children by the districts refusal

to

> provide

> parents with notice about their right to request these services. The

> district

> also engaged in delaying tactics by requiring parents to attend futile

> meetings.

> The court found that, in this district, administrative convenience

took

> precedence over providing FAPE to children with disabilities.

Educational

> decisions were not individualized according to the needs of the child.

>

> Six Factors for IEP Teams to Consider

>

> In Reusch v. Fountain, the court listed six factors that the IEP team

> shouldconsider in deciding if the child is eligible for ESY as a

related

> service:

>

> 1. Regression and recoupment - is the child likely to lose critical

skills

> or

> fail to recover these skills within in a reasonable time;

> 2. Degree of progress toward IEP goals and objectives;

> 3. Emerging skills/breakthrough opportunities - Will a lengthy summer

break

> cause significant problems for a child who is learning a key skill,

> likereading;

> 4. Interfering Behavior - does the childs behavior interfere with his

or

> her

> ability to benefit from special education;

> 5. Nature and/or severity of disability;

> 6. Special circumstances that interfere with childs ability to benefit

from

> special education.

>

> Citing Pete's case, Florence County School District Four v.

,

> the

> District Court found that: " In any contest between systematic

efficiency

> and the

> provision of FAPE to a disabled child, Congress and the Supreme Court

have

> made

> it clear that the child must prevail. "

>

> Other findings:

>

> Notice and Timing - The importance of making a decision about ESY

early

> enough

> in the school year to allow the parents adequate time to exercisetheir

> rights

> administrative review or appeal in a timely fashion. That the

explanation

> about

> ESY contained in a brochure distributed to all studentswas not

sufficient

> and

> ordered that the student's eligibility for ESY be considered at each

annual

> review meeting, and the parents sign a form acknowledging their

receipt of

> this

> information. The district must documentthe discussion and the decision

> reached

> after consideration of ESYeligibilty at each annual review meeting.

>

> Content and Duration - The content of child's ESY program must be

> determined on

> an individual basis. The duration is also based on individualized

> determinations

> of the number of weeks, days per week,and hours per day that each

student

> receiving ESY should be provided.

>

> Copyright 1999-2002, W. D. and Pamela Darr .

> All rightsreserved. www.wrightlaw.com

>

> --

> Posted by Carol Sadler to IEPadvocate4You at 3/14/2005 05:59:00 AM

>

> =====

>

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Guest guest

Sent from my iPhone

>

> So glad to read this post! I think my son's IEP update will be in May and this

will be his 1st one since starting preschool services. Want to make sure he gets

summer speech sessions too.

>

> Thanks-

>

> Sent from my Verizon Wireless BlackBerry

>

> [ ] Re: Help with school

>

> Not sure if you read my book The Late Talker but if you didn't I highly

recommend you at least take a look at the advocacy chapter as my co author is a

neurodevelopmental pediatrician who advocates for her patients in the schools,

and we had the advise as well from special education attorneys and an award

winning teacher advocate (our VP of Cherab :) Cheryl Bennet SLP

included)

>

> Whenever a school professional says something that sounds wrong just say

nicely " That's interesting, would you mind putting in writing for me why there

are no summer programs available at all for my son even if extended school year

is found appropriate for him? "

>

> Trust me -nothing will be put in writing that is against your child's rights.

And if they don't put it in writing- you should. Keep a paper trail -use tape

recorders at the IEP meetings. Not that you have to be aggressive and nasty

-you can do all in a very nice way and explain that you would like to share the

information with your child's private doctor (or therapist) as this is all new

to you etc. You can come up with a zillion reasons why you bring a tape

recorder- but just do.

>

> Here are some archives

>

> Re: denied speech for summer... advice?

>

> There's much in the archives about this -here's just a bit:

>

> Actually this is from The Late Talker book but rest from the archives

>

> " Many children with severe speech impairments regress without continued

therapy,

> so make sure your child gets enrolled in the Extended School Year (ESY)

program,

> especially for the long summer break. ESY services must be considered at the

> annual IEP meeting and documented in the IEP. The ESY also has to be the same

as

> what your child receives during the regular school year. For example, if he

> normally has a ten hour a week schedule, his ESY should also be for ten hours

a

> week. "

>

> The Late Talker book 2003 Agin, Geng, Nicholl

>

>

>

> Re: [ ] ESY Services

> As with any special education school service, please remember one thing.

> Special education is funded by the state. The school district may want to

> provide many things. But if state funding is not provided, it is probably

> not going to happen.

>

>

> FYI - It's getting time to schedule those meetings with your schools to

discuss

> ESY. Do not let the schools jump past the ESY portion in your IEP meeting and

> merely tell you your child doesn't qualify (no regression), so no need for

ESY.

> Regression is NOT the only requirement for ESY, I've bolded important

> information below.

>

> Also, don't let the school tell you ESY is traditional summer school, it is

not,

> although it can be if it is appropriate to meet the child's IEP goals.

>

> I often use ESY services to negotiate additional services for children where

the

> school has " Failed to Identify " , appropriately remediate a child's learning

> problem, and/or failed to provide identified spec. ed. support or related

> services. I've used it to give the school one more chance to teach a child to

> read or to teach a child appropriate social skills, before pulling out and

> privately placing the child at public expense. The school system can pay for

> traditional summer school classes as ESY services for instance, if a school

> failed to identify a child with a disability, and the child failed the first

> semester of High School, and now needs to make up courses during Summer

School.

>

> Extended School Year can look at many things. Don't let the schools tell you

no

> automatically, and don't let them tell you it is only for the severely

disabled.

> NOT TRUE! Talk with an advocate, attorney, or disability organization to find

> out more information.

>

>

> Carol Sadler

> Special Education Consultant/Advocate

> GA Advocacy Office PLSP I Graduate

> 770-442-8357

> 1105 Rock Pointe Look

> Woodstock, GA 30188

> CarolSadler@...

> www.IEPadvocate4You.com

> http://iepadvocate4you.blogspot.com/

>

>

> CONFIDENTIAL AND PRIVILEGED

> Information contained in this communication is confidential and privileged. It

> is not meant to represent legal or medical advice, but rather advice given

based

> on my knowledge as a trained Parent Advocate by the GA Advocacy Office,

Council

> of Parent Advocates & Attorneys, CHADD, LDA, and the GA DOE Parent Mentor

> program as an invited guest. Please do not forward without my permission.

>

>

> Extended School Year (ESY)

>

> The Individuals with Disabilities Education Act (IDEA) regulations requirethat

> ESY services be considered annually for every child with a disability.An ESY

> Program of services in the summer or weekends, must be provided if needed to

> make a student's education program appropriate. " Under the law, aschool

district

> may not limit ESY services for children with particular categories of

> disabilities, and may not limit the type, amount or duration of ESY. " (Ed Law

> Center - PA)

>

> A school system cannot use a " lack ofavailable funds " argument to deny ESY

> services to a child with a disability.School districts must look at issues

> beyond regression or recoupment whendetermining ESY eligibility.

>

> ESY is NOT traditional summer school, but rather an extension of an individual

> child's education plan!

>

> The following is taken

> from:http://www.ppmd.org/publications/extended_school_year.html It is a

summary

> of judicial decisions regarding ESY.

>

> Extended School Year

> by Rose Kraft

>

> Since the precedent for extended school year programming was set in the

> Armstrong v. Kline case in Philadelphia, in a large number of instances the

> courts have been asked to determine the eligibility of individual children for

> extended school year services. This summary looks at the judicial decisions

that

> have been rendered regarding this issue.

>

> Judges and lawmakers have made significant decisions during the last 20 years,

> which define extended school year (ESY) services for childen with

disabilities.

> Several district court cases, beginning with Armstrong v. Kline (1979) and

> culminating with Reusch v. Fountain (1994), shaped thecurrent federal

> regulations. For the first time in the history of the Individuals with

> Disabilities Education Act (IDEA), these regulations require that ESY services

> be considered annually for every child with a disability. Each team that

> develops an individual education plan (IEP) for achild must decide if ESY

> services are necessary so that the child can avoid regression, a lengthy

> recoupment of lost skills, or other difficulties that could interfere with the

> education plan.

>

> The first significant case in this arena was the Armstrong case, in which the

> judge ruled that a mandated 180-day school year violated a child's right to a

> free appropriate public education (FAPE), specifically in reference to

children

> with severe and profound impairments or severe emotional disturbances. The

court

> stated that, " By its terms, the Act (meaning the Education for All Handicapped

> Children Act) appears to demand that the state supply instruction designed to

> meet all of the handicapped child's " unique needs " without limitation. " The

> court also required state and local school districts " to provide an education

to

> handicapped children in excess of 180 days, " as determined by each child's

> needs.

>

> This case defined that a school system's goal for these severely affected

> children should be self-sufficiency, which could require providing more

thanthe

> same 180 days to disabled children that is provided to non disabled children.

> This case was upheld on appeal by the circuit court, which agreed that, " For

> some, but not all, SPI and SED children, standing in the way of the attainment

> of some of these objectives (for self-sufficiency) is the effect of breaks in

> the educational program which are created, at least inpart, by the 180 day

> rule. " The court also noted that recoupment time for lost skills is " usually

> much greater " for children with disabilities.

>

> Once the courts ordered state and local school systems to provide more than

180

> days of school per year to some children with disabilities, families across

the

> nation began taking their school systems to court. In Stacey G.v. Pasadena

> Independent School District (1982), a 12-month program without major breaks

was

> ruled necessary for a child with autism and severe mental retardation. In

> Georgia Association for Retarded Citizens v. Mc (1983), the court ruled

> that a school system cannot use a " lack of available funds " argument to deny

ESY

> services to a child with a disability. A school system must look at the

child's

> needs, rather than at its budget, when determining summer services for a

child.

> The judge in Alamo Heights Independent School District v. State Board of

> Education (1986) noted that transportation services must be part of the ESY

> package for a child, even if the bus must get that child from a babysitter's

> out-of-district home.

>

> The case of Bucks County Public Schools v. Commonwealth of Pennsylvania (1987)

> showed that academic regression isn't the only qualification for ESY

> eligibility. The judge in the Bucks County case stated that regression in

> emotional development for severely emotionally disturbed children is often

> " caused by interruptions in the educational programming, " and ordered that

> prediction of regression in emotional development qualifies as a need for ESY.

> Holmes v. Sobol (1988) was a significant case because it found that physical

> therapy was a related service that could be provided for ESY, and further

ruled

> that a related service can be a sole special education program. This case

stated

> that without the maintenance of physical strength through therapy, the child

> would not be able to benefit from his general education. In v. Gering

> Public Schools (1990), the parents of a child with multiple disabilities

> believed that a 12-month program could only be provided for their child in a

> residential placement. This court agreed that the child needed a 12-month

school

> program in order to receive a free appropriate public education, but did not

> require that it be provided in a residential facility. The court ordered the

> school district to provide the12-month program at a local facility for multi

> handicapped children, specifying that an interruption from one school to

another

> just for a summer program would provide an unacceptable level of regression

for

> the child.

>

> Reusch v. Fountain (1994) blasted a land school district for deceptive and

> purposeful policies which sought to deprive children of ESY services.The

school

> district had (a) refused to notify parents of a child's eligibility for ESY

> services, (B) written misleading letters recommending asummer program that

> required tuition from the parents, © told schooladministrators to refer

> parents to central administration when they asked for ESY services, (d)

> purposely didn't mention ESY services until it was too late to deliver them,

and

> (e) never told parents they had a right to request ESY services. The judge

used

> strong language as he set the parameters for ESY policies for children with

> disabilities. " The MCPS practice of inadequate and untimely ESY notice must

> cease. Notice of ESY designed to fully explain such services must be provided

to

> parents of disabled childrenin a timely fashion before annual review meetings.

> The notice must not disguise or downplay the true nature of ESY or attempt to

> confuse parents between free extended year services and tuition-charging

summer

> enrichmentprograms. " The court went further and required that additional

> criteria be considered in addition to regression and recoupment time when

> considering achild for ESY services. The court decided that " emerging skills "

> and " breakthrough opportunities " (as when a child is on the brink of learning

to

> read) -- can and should be incorporated into the eligibility analysis. " A

> fixed-length program was also ruled illegal by this court, which ordered the

> school district to " make individualized determinations of the number of weeks,

> days per week, and hours per day that each student receiving ESYshould be

> provided.

>

> " While litigation continued in courtrooms across the country, the Office of

> Special Education Programs and the Office of Special Education and

> Rehabilitative Services wrote policy letters, which provided interpretation of

> the federal regulations for school districts. The Office of Civil Rights wrote

> letters of finding which defined when the denial of ESY services violated a

> person's civil rights. Together these letters provided parallel support for

the

> court decisions by (a) defining ESY criteria and related services in an ESY

> program, (B) requiring school districts to look at issues beyond regression or

> recoupment when determining ESY eligibility, ©emphasizing the need to set

> higher ESY standards than simply working toward self-sufficiency, (d) refusing

> to allow school districts to offer ESYprograms that were available only to the

> most severely disabled children,and (e) requiring that integration with

> nondisabled peers be provided in ESYprograms if required by the IEP.

>

> The result of the court cases and substantive letters has led to the written

> federal regulations, which describe how ESY services are to be implemented

> according to IDEA. The regulations define ESY as " special education and

related

> services " which (a) go beyond the normal school year, (B) are addressed and

> mandated by the IEP, and © are free to the parents. The regulations also

> require that ESY services are available to each child with a disability and,

> " The determination of whether a child with a disability needs extended school

> year services must be made on an individual basis by the child's IEP team. " 34

> CFR ? 300.309 (1997).

>

> The regulations also add two notes clarifying these definitions. The first

note

> states that school districts cannot limit ESY services to " particular

categories

> of disability or unilaterally limit the duration of services. " The second note

> gives states the authority to set standards for use in determining ESY

> eligibility " on an individual basis, " suggesting the consideration of factors

> such as the " likelihood of regression, slow recoupment, and predictive data

> based on the opinion of professionals.

>

> " References:

> Alamo Heights Independent School District v. State Board of Education,

> Education for the Handicapped Law Report 554:315 (5th Cir. 1986).

> Armstrong v. Kline, Education for the Handicapped Law Report 551:195 (E.D.Pa.

> 1979). Baltimore (MD) City Public Schools (1986).

> Office of Civil Rights Letter of Finding, Education for the Handicapped Law

> Review 352:185.Battle v. Commonwealth,

> Education for the Handicapped Law Report 551:647(3rd Cir. 1980).

> Bucks County Public Schools v. Commonwealth of Pennsylvania, Education forthe

> Handicapped Law Report 559:153 (Commonwealth Ct. of Pa. 1987).

> Davila, R. R. (1990, Nov.).

> Office of Special Education and RehabilitativeServices Policy Letter, 17

> Education for the Handicapped Law Review 419.

> Georgia Association for Retarted Citizens v. Mc, Education for

> theHandicapped Law Report 555:251 (11th Cir. 1983).

> Holmes v. Sobol, Education of the Handicapped Law Report 559:463 (W.D.

Ny.1988).

> Mesa (AZ) Public Schools (1989).

> Office of Civil Rights Letter of Finding,16 Education for the Handicapped Law

> Review 316.

> Reusch v. Fountain, 21 Individuals with Disabilities Education Law Report1107

> (D. Md. 1994).

> Schrag, J. A. (1989, Aug.). Office of Special Education Programs PolicyLetter,

> Education for the Handicapped Law Review 213:255.

> Stacey G. v. Pasadena Indep endent School District, Education for

theHandicapped

> Law Report 554:206 (S.D. Tx. 1982).

> Turnbull, H.R. III, & Turnbull, A.P. (1998).

> Free appropriate public education: The law and children with disabilities (5th

> ed.).

> Denver, CO:Love Publishing Company.Will, M. (1987, Aug.).

> Office of Special Education and Rehabilitative Services Policy Letter,

Education

> for the Handicapped Law Review 211:481.

> v. Gering Public Schools, 17 Education ofthe Handicapped Law

Report427

> (Ne. S. Ct. 1990).

>

> Extended School Year Services (ESY) - Info from www.slaw.com

> http://www.wrightslaw.com/info/esy.index.htm

>

> Many parents have questions about extended school year services. If you have

> questions about a legal issue, you should do your own legal research. Do not

> accept legal advice from school personnel. While they may tell you what they

> believe is true, in many cases, they have not read the law and regulations for

> themselves. You need to know what the law and regulations say!

>

> Read what the IDEA statute says about your issue. Next read the federal

> regulations and your state special ed regulations about your issue. (the IDEA

> statute and regulations are in slaw: Special Education Law and in the

> Statute and Regs section of the slaw site)

>

> Next read a case or two about your issue (check the Caselaw Library). If you

> take these steps, you will have a clear understanding of the issues and

> variables.

>

> You will find that extended school year (ESY) is not mentioned in the IDEA

> statute, but is in the IDEA regulations. Read the IDEA regulation about ESYat

34

> CFR Section 300.309 (page 165, slaw: Special Education Law).

>

> We selected two cases about ESY to help you understand these issues:

> Lawyer v. Chesterfield and Reusch v. Fountain. For more information, check the

> Topics Pages - especially the FAPE and IEP pages.

>

> " Windows of Opportunity " : Lawyer v. Chesterfield School Board (1993)Danny

Lawyer

> is a young child with autism. At age six, he had expressive language and

> phonological processing problems. The experts who evaluated and treated Danny

> advised his parents that his ability to beself-sufficient and independent

later

> in life would depend on his ability tocommunicate. During the summer, Danny

> regressed in his ability to communicate. His behavior deteriorated. His school

> district refused to provide any speech language therapy during the summer

months

> - and refused to reimburse his parents for the services they purchased for

their

> son. The parents requested a special education due process hearing and

> prevailed. The school district appealed. The Review Officer overturned the

> Hearing Officer's decision. The case was appealed to Federal Court.

>

> After reviewing the record and hearing new testimony, Judge Spencer concluded,

> " Regression is not the only factor " in deciding if a child needs ESY services.

> The judge listed several additional factors that IEP teams should consider in

> making ESY decisions:

> Recoupment in the Fall;

> Child's rate of progress;

> Child's behavioral or physical problems;

> Availability of alternative resources;

> Areas of the child's curriculum that need continuous attention;

> Child's vocational needs.

>

> In " Lawyer, " Judge Spencer discussed regression and recoupment. He also

> discussed the need to take advantage of " windows of opportunity " in educating

> children with disabilities: " Danny's regression in the summer, coupled with

> nominal recoupment, severely limits the educational benefits he receives from

> instruction during the school year. His rate of progress isminimized by the

> interplay of continuous regression and recoupment. " " Moreover, Danny's

behavioral

> problems are compounded by his severe language deficit. His inability to

> effectively communicate triggers unacceptable behavior. Therefore, it is

> critical that Danny be provided with continuous speech and communication

> services. " " Finally, the evidence provided by expert witnesses indicates that

> for children who suffer from moderate to severe childhood autism, there is a

> small, but vital, window of opportunityin which they can effectively learn.

Such

> period is generally between theages of five and eight years old....The Court

> concludes that it is extremely important that at this critical stage of

> development, Danny receive uninterrupted speech language therapy.

>

> " Read the decision in Lawyer v. Chesterfield.

>

> Hostility to Providing ESY: Reusch v. Fountain (1994) In Reusch v. Fountain,

872

> F.Supp. 1421 (D. MD 1994), a federal court addressed the school districts

> " hostility to providing ESY. " In this case,the court found that parents were

> prevented from advocating for their children by the districts refusal to

provide

> parents with notice about their right to request these services. The district

> also engaged in delaying tactics by requiring parents to attend futile

meetings.

> The court found that, in this district, administrative convenience took

> precedence over providing FAPE to children with disabilities. Educational

> decisions were not individualized according to the needs of the child.

>

> Six Factors for IEP Teams to Consider

>

> In Reusch v. Fountain, the court listed six factors that the IEP team

> shouldconsider in deciding if the child is eligible for ESY as a related

> service:

>

> 1. Regression and recoupment - is the child likely to lose critical skills or

> fail to recover these skills within in a reasonable time;

> 2. Degree of progress toward IEP goals and objectives;

> 3. Emerging skills/breakthrough opportunities - Will a lengthy summer break

> cause significant problems for a child who is learning a key skill,

likereading;

> 4. Interfering Behavior - does the childs behavior interfere with his or her

> ability to benefit from special education;

> 5. Nature and/or severity of disability;

> 6. Special circumstances that interfere with childs ability to benefit from

> special education.

>

> Citing Pete's case, Florence County School District Four v. ,

the

> District Court found that: " In any contest between systematic efficiency and

the

> provision of FAPE to a disabled child, Congress and the Supreme Court have

made

> it clear that the child must prevail. "

>

> Other findings:

>

> Notice and Timing - The importance of making a decision about ESY early enough

> in the school year to allow the parents adequate time to exercisetheir rights

> administrative review or appeal in a timely fashion. That the explanation

about

> ESY contained in a brochure distributed to all studentswas not sufficient and

> ordered that the student's eligibility for ESY be considered at each annual

> review meeting, and the parents sign a form acknowledging their receipt of

this

> information. The district must documentthe discussion and the decision reached

> after consideration of ESYeligibilty at each annual review meeting.

>

> Content and Duration - The content of child's ESY program must be determined

on

> an individual basis. The duration is also based on individualized

determinations

> of the number of weeks, days per week,and hours per day that each student

> receiving ESY should be provided.

>

> Copyright 1999-2002, W. D. and Pamela Darr .

> All rightsreserved. www.wrightlaw.com

>

> --

> Posted by Carol Sadler to IEPadvocate4You at 3/14/2005 05:59:00 AM

>

>

> =====

>

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Guest guest

Hi Kim,

Did they give an option for summer school? My son just turned 3 in December &

during his IEP we inquired about summer school to insure that he would still

receive all his services. However, if he was not enrolled in summer school then

the district WILL NOT provide therapy services. Our coordinator even told me my

son wouldn't even have to show up to summer school on a regular basis, it is

just important the he is enrolled & services will continue. I'm not sure what

district you are in, but I believe summer school should be an option especially

if your son will regress with out services.

Hope that helps. Good Luck

________________________________

From: BRIAN <b.j.dewitt@...>

Sent: Wed, March 2, 2011 9:30:46 AM

Subject: [ ] Help with school

My son will turn 3 at the end of May and as such, his Early Intervention

services will end. Had my informational meeting with the school district

yesterday. During the meeting, I advised that my major concern was

therapies/services would be available for my son during the summer months before

school started. They advised there was no summer program available and that we

could use our insurance to do provide services. Of course, we will still be

using our private insurance to get him therapy, but isn't the school district

legally responsible to provide him services once he turns 3? Any help would be

greatly appreciated.

Thanks,

Kim

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Guest guest

This is soooo helpful! Thank you and thank you Kim for asking it. My son

is also turning 3 soon (2 weeks!) and we are moving prob by the beginning of

April. We have his IEP next week and I want to make sure he gets ESY cause

without it I know the progress he is making now will mostly likely slow down and

I don't even know about the insurance situation yet! My EI folks said that the

new school district will have to abide by the IEP rather than doing a new one

since it will be so recent that it was done. Thanks for all the pointers.

________________________________

From: kiddietalk <kiddietalk@...>

Sent: Wed, March 2, 2011 11:46:34 AM

Subject: [ ] Re: Help with school

Not sure if you read my book The Late Talker but if you didn't I highly

recommend you at least take a look at the advocacy chapter as my co author is a

neurodevelopmental pediatrician who advocates for her patients in the schools,

and we had the advise as well from special education attorneys and an award

winning teacher advocate (our VP of Cherab :) Cheryl Bennet SLP

included)

Whenever a school professional says something that sounds wrong just say nicely

" That's interesting, would you mind putting in writing for me why there are no

summer programs available at all for my son even if extended school year is

found appropriate for him? "

Trust me -nothing will be put in writing that is against your child's rights.

And if they don't put it in writing- you should. Keep a paper trail -use tape

recorders at the IEP meetings. Not that you have to be aggressive and nasty

-you can do all in a very nice way and explain that you would like to share the

information with your child's private doctor (or therapist) as this is all new

to you etc. You can come up with a zillion reasons why you bring a tape

recorder- but just do.

Here are some archives

Re: denied speech for summer... advice?

There's much in the archives about this -here's just a bit:

Actually this is from The Late Talker book but rest from the archives

" Many children with severe speech impairments regress without continued therapy,

so make sure your child gets enrolled in the Extended School Year (ESY) program,

especially for the long summer break. ESY services must be considered at the

annual IEP meeting and documented in the IEP. The ESY also has to be the same as

what your child receives during the regular school year. For example, if he

normally has a ten hour a week schedule, his ESY should also be for ten hours a

week. "

The Late Talker book 2003 Agin, Geng, Nicholl

Re: [ ] ESY Services

As with any special education school service, please remember one thing.

Special education is funded by the state. The school district may want to

provide many things. But if state funding is not provided, it is probably

not going to happen.

FYI - It's getting time to schedule those meetings with your schools to discuss

ESY. Do not let the schools jump past the ESY portion in your IEP meeting and

merely tell you your child doesn't qualify (no regression), so no need for ESY.

Regression is NOT the only requirement for ESY, I've bolded important

information below.

Also, don't let the school tell you ESY is traditional summer school, it is not,

although it can be if it is appropriate to meet the child's IEP goals.

I often use ESY services to negotiate additional services for children where the

school has " Failed to Identify " , appropriately remediate a child's learning

problem, and/or failed to provide identified spec. ed. support or related

services. I've used it to give the school one more chance to teach a child to

read or to teach a child appropriate social skills, before pulling out and

privately placing the child at public expense. The school system can pay for

traditional summer school classes as ESY services for instance, if a school

failed to identify a child with a disability, and the child failed the first

semester of High School, and now needs to make up courses during Summer School.

Extended School Year can look at many things. Don't let the schools tell you no

automatically, and don't let them tell you it is only for the severely disabled.

NOT TRUE! Talk with an advocate, attorney, or disability organization to find

out more information.

Carol Sadler

Special Education Consultant/Advocate

GA Advocacy Office PLSP I Graduate

770-442-8357

1105 Rock Pointe Look

Woodstock, GA 30188

CarolSadler@...

www.IEPadvocate4You.com

http://iepadvocate4you.blogspot.com/

CONFIDENTIAL AND PRIVILEGED

Information contained in this communication is confidential and privileged. It

is not meant to represent legal or medical advice, but rather advice given based

on my knowledge as a trained Parent Advocate by the GA Advocacy Office, Council

of Parent Advocates & Attorneys, CHADD, LDA, and the GA DOE Parent Mentor

program as an invited guest. Please do not forward without my permission.

Extended School Year (ESY)

The Individuals with Disabilities Education Act (IDEA) regulations requirethat

ESY services be considered annually for every child with a disability.An ESY

Program of services in the summer or weekends, must be provided if needed to

make a student's education program appropriate. " Under the law, aschool district

may not limit ESY services for children with particular categories of

disabilities, and may not limit the type, amount or duration of ESY. " (Ed Law

Center - PA)

A school system cannot use a " lack ofavailable funds " argument to deny ESY

services to a child with a disability.School districts must look at issues

beyond regression or recoupment whendetermining ESY eligibility.

ESY is NOT traditional summer school, but rather an extension of an individual

child's education plan!

The following is taken

from:http://www.ppmd.org/publications/extended_school_year.html It is a summary

of judicial decisions regarding ESY.

Extended School Year

by Rose Kraft

Since the precedent for extended school year programming was set in the

Armstrong v. Kline case in Philadelphia, in a large number of instances the

courts have been asked to determine the eligibility of individual children for

extended school year services. This summary looks at the judicial decisions that

have been rendered regarding this issue.

Judges and lawmakers have made significant decisions during the last 20 years,

which define extended school year (ESY) services for childen with disabilities.

Several district court cases, beginning with Armstrong v. Kline (1979) and

culminating with Reusch v. Fountain (1994), shaped thecurrent federal

regulations. For the first time in the history of the Individuals with

Disabilities Education Act (IDEA), these regulations require that ESY services

be considered annually for every child with a disability. Each team that

develops an individual education plan (IEP) for achild must decide if ESY

services are necessary so that the child can avoid regression, a lengthy

recoupment of lost skills, or other difficulties that could interfere with the

education plan.

The first significant case in this arena was the Armstrong case, in which the

judge ruled that a mandated 180-day school year violated a child's right to a

free appropriate public education (FAPE), specifically in reference to children

with severe and profound impairments or severe emotional disturbances. The court

stated that, " By its terms, the Act (meaning the Education for All Handicapped

Children Act) appears to demand that the state supply instruction designed to

meet all of the handicapped child's " unique needs " without limitation. " The

court also required state and local school districts " to provide an education to

handicapped children in excess of 180 days, " as determined by each child's

needs.

This case defined that a school system's goal for these severely affected

children should be self-sufficiency, which could require providing more thanthe

same 180 days to disabled children that is provided to non disabled children.

This case was upheld on appeal by the circuit court, which agreed that, " For

some, but not all, SPI and SED children, standing in the way of the attainment

of some of these objectives (for self-sufficiency) is the effect of breaks in

the educational program which are created, at least inpart, by the 180 day

rule. " The court also noted that recoupment time for lost skills is " usually

much greater " for children with disabilities.

Once the courts ordered state and local school systems to provide more than 180

days of school per year to some children with disabilities, families across the

nation began taking their school systems to court. In Stacey G.v. Pasadena

Independent School District (1982), a 12-month program without major breaks was

ruled necessary for a child with autism and severe mental retardation. In

Georgia Association for Retarded Citizens v. Mc (1983), the court ruled

that a school system cannot use a " lack of available funds " argument to deny ESY

services to a child with a disability. A school system must look at the child's

needs, rather than at its budget, when determining summer services for a child.

The judge in Alamo Heights Independent School District v. State Board of

Education (1986) noted that transportation services must be part of the ESY

package for a child, even if the bus must get that child from a babysitter's

out-of-district home.

The case of Bucks County Public Schools v. Commonwealth of Pennsylvania (1987)

showed that academic regression isn't the only qualification for ESY

eligibility. The judge in the Bucks County case stated that regression in

emotional development for severely emotionally disturbed children is often

" caused by interruptions in the educational programming, " and ordered that

prediction of regression in emotional development qualifies as a need for ESY.

Holmes v. Sobol (1988) was a significant case because it found that physical

therapy was a related service that could be provided for ESY, and further ruled

that a related service can be a sole special education program. This case stated

that without the maintenance of physical strength through therapy, the child

would not be able to benefit from his general education. In v. Gering

Public Schools (1990), the parents of a child with multiple disabilities

believed that a 12-month program could only be provided for their child in a

residential placement. This court agreed that the child needed a 12-month school

program in order to receive a free appropriate public education, but did not

require that it be provided in a residential facility. The court ordered the

school district to provide the12-month program at a local facility for multi

handicapped children, specifying that an interruption from one school to another

just for a summer program would provide an unacceptable level of regression for

the child.

Reusch v. Fountain (1994) blasted a land school district for deceptive and

purposeful policies which sought to deprive children of ESY services.The school

district had (a) refused to notify parents of a child's eligibility for ESY

services, (B) written misleading letters recommending asummer program that

required tuition from the parents, © told schooladministrators to refer

parents to central administration when they asked for ESY services, (d)

purposely didn't mention ESY services until it was too late to deliver them, and

(e) never told parents they had a right to request ESY services. The judge used

strong language as he set the parameters for ESY policies for children with

disabilities. " The MCPS practice of inadequate and untimely ESY notice must

cease. Notice of ESY designed to fully explain such services must be provided to

parents of disabled childrenin a timely fashion before annual review meetings.

The notice must not disguise or downplay the true nature of ESY or attempt to

confuse parents between free extended year services and tuition-charging summer

enrichmentprograms. " The court went further and required that additional

criteria be considered in addition to regression and recoupment time when

considering achild for ESY services. The court decided that " emerging skills "

and " breakthrough opportunities " (as when a child is on the brink of learning to

read) -- can and should be incorporated into the eligibility analysis. " A

fixed-length program was also ruled illegal by this court, which ordered the

school district to " make individualized determinations of the number of weeks,

days per week, and hours per day that each student receiving ESYshould be

provided.

" While litigation continued in courtrooms across the country, the Office of

Special Education Programs and the Office of Special Education and

Rehabilitative Services wrote policy letters, which provided interpretation of

the federal regulations for school districts. The Office of Civil Rights wrote

letters of finding which defined when the denial of ESY services violated a

person's civil rights. Together these letters provided parallel support for the

court decisions by (a) defining ESY criteria and related services in an ESY

program, (B) requiring school districts to look at issues beyond regression or

recoupment when determining ESY eligibility, ©emphasizing the need to set

higher ESY standards than simply working toward self-sufficiency, (d) refusing

to allow school districts to offer ESYprograms that were available only to the

most severely disabled children,and (e) requiring that integration with

nondisabled peers be provided in ESYprograms if required by the IEP.

The result of the court cases and substantive letters has led to the written

federal regulations, which describe how ESY services are to be implemented

according to IDEA. The regulations define ESY as " special education and related

services " which (a) go beyond the normal school year, (B) are addressed and

mandated by the IEP, and © are free to the parents. The regulations also

require that ESY services are available to each child with a disability and,

" The determination of whether a child with a disability needs extended school

year services must be made on an individual basis by the child's IEP team. " 34

CFR ? 300.309 (1997).

The regulations also add two notes clarifying these definitions. The first note

states that school districts cannot limit ESY services to " particular categories

of disability or unilaterally limit the duration of services. " The second note

gives states the authority to set standards for use in determining ESY

eligibility " on an individual basis, " suggesting the consideration of factors

such as the " likelihood of regression, slow recoupment, and predictive data

based on the opinion of professionals.

" References:

Alamo Heights Independent School District v. State Board of Education,

Education for the Handicapped Law Report 554:315 (5th Cir. 1986).

Armstrong v. Kline, Education for the Handicapped Law Report 551:195 (E.D.Pa.

1979). Baltimore (MD) City Public Schools (1986).

Office of Civil Rights Letter of Finding, Education for the Handicapped Law

Review 352:185.Battle v. Commonwealth,

Education for the Handicapped Law Report 551:647(3rd Cir. 1980).

Bucks County Public Schools v. Commonwealth of Pennsylvania, Education forthe

Handicapped Law Report 559:153 (Commonwealth Ct. of Pa. 1987).

Davila, R. R. (1990, Nov.).

Office of Special Education and RehabilitativeServices Policy Letter, 17

Education for the Handicapped Law Review 419.

Georgia Association for Retarted Citizens v. Mc, Education for

theHandicapped Law Report 555:251 (11th Cir. 1983).

Holmes v. Sobol, Education of the Handicapped Law Report 559:463 (W.D. Ny.1988).

Mesa (AZ) Public Schools (1989).

Office of Civil Rights Letter of Finding,16 Education for the Handicapped Law

Review 316.

Reusch v. Fountain, 21 Individuals with Disabilities Education Law Report1107

(D. Md. 1994).

Schrag, J. A. (1989, Aug.). Office of Special Education Programs PolicyLetter,

Education for the Handicapped Law Review 213:255.

Stacey G. v. Pasadena Indep endent School District, Education for theHandicapped

Law Report 554:206 (S.D. Tx. 1982).

Turnbull, H.R. III, & Turnbull, A.P. (1998).

Free appropriate public education: The law and children with disabilities (5th

ed.).

Denver, CO:Love Publishing Company.Will, M. (1987, Aug.).

Office of Special Education and Rehabilitative Services Policy Letter, Education

for the Handicapped Law Review 211:481.

v. Gering Public Schools, 17 Education ofthe Handicapped Law Report427

(Ne. S. Ct. 1990).

Extended School Year Services (ESY) - Info from www.slaw.com

http://www.wrightslaw.com/info/esy.index.htm

Many parents have questions about extended school year services. If you have

questions about a legal issue, you should do your own legal research. Do not

accept legal advice from school personnel. While they may tell you what they

believe is true, in many cases, they have not read the law and regulations for

themselves. You need to know what the law and regulations say!

Read what the IDEA statute says about your issue. Next read the federal

regulations and your state special ed regulations about your issue. (the IDEA

statute and regulations are in slaw: Special Education Law and in the

Statute and Regs section of the slaw site)

Next read a case or two about your issue (check the Caselaw Library). If you

take these steps, you will have a clear understanding of the issues and

variables.

You will find that extended school year (ESY) is not mentioned in the IDEA

statute, but is in the IDEA regulations. Read the IDEA regulation about ESYat 34

CFR Section 300.309 (page 165, slaw: Special Education Law).

We selected two cases about ESY to help you understand these issues:

Lawyer v. Chesterfield and Reusch v. Fountain. For more information, check the

Topics Pages - especially the FAPE and IEP pages.

" Windows of Opportunity " : Lawyer v. Chesterfield School Board (1993)Danny Lawyer

is a young child with autism. At age six, he had expressive language and

phonological processing problems. The experts who evaluated and treated Danny

advised his parents that his ability to beself-sufficient and independent later

in life would depend on his ability tocommunicate. During the summer, Danny

regressed in his ability to communicate. His behavior deteriorated. His school

district refused to provide any speech language therapy during the summer months

- and refused to reimburse his parents for the services they purchased for their

son. The parents requested a special education due process hearing and

prevailed. The school district appealed. The Review Officer overturned the

Hearing Officer's decision. The case was appealed to Federal Court.

After reviewing the record and hearing new testimony, Judge Spencer concluded,

" Regression is not the only factor " in deciding if a child needs ESY services.

The judge listed several additional factors that IEP teams should consider in

making ESY decisions:

Recoupment in the Fall;

Child's rate of progress;

Child's behavioral or physical problems;

Availability of alternative resources;

Areas of the child's curriculum that need continuous attention;

Child's vocational needs.

In " Lawyer, " Judge Spencer discussed regression and recoupment. He also

discussed the need to take advantage of " windows of opportunity " in educating

children with disabilities: " Danny's regression in the summer, coupled with

nominal recoupment, severely limits the educational benefits he receives from

instruction during the school year. His rate of progress isminimized by the

interplay of continuous regression and recoupment. " " Moreover, Danny's behavioral

problems are compounded by his severe language deficit. His inability to

effectively communicate triggers unacceptable behavior. Therefore, it is

critical that Danny be provided with continuous speech and communication

services. " " Finally, the evidence provided by expert witnesses indicates that

for children who suffer from moderate to severe childhood autism, there is a

small, but vital, window of opportunityin which they can effectively learn. Such

period is generally between theages of five and eight years old....The Court

concludes that it is extremely important that at this critical stage of

development, Danny receive uninterrupted speech language therapy.

" Read the decision in Lawyer v. Chesterfield.

Hostility to Providing ESY: Reusch v. Fountain (1994) In Reusch v. Fountain, 872

F.Supp. 1421 (D. MD 1994), a federal court addressed the school districts

" hostility to providing ESY. " In this case,the court found that parents were

prevented from advocating for their children by the districts refusal to provide

parents with notice about their right to request these services. The district

also engaged in delaying tactics by requiring parents to attend futile meetings.

The court found that, in this district, administrative convenience took

precedence over providing FAPE to children with disabilities. Educational

decisions were not individualized according to the needs of the child.

Six Factors for IEP Teams to Consider

In Reusch v. Fountain, the court listed six factors that the IEP team

shouldconsider in deciding if the child is eligible for ESY as a related

service:

1. Regression and recoupment - is the child likely to lose critical skills or

fail to recover these skills within in a reasonable time;

2. Degree of progress toward IEP goals and objectives;

3. Emerging skills/breakthrough opportunities - Will a lengthy summer break

cause significant problems for a child who is learning a key skill, likereading;

4. Interfering Behavior - does the childs behavior interfere with his or her

ability to benefit from special education;

5. Nature and/or severity of disability;

6. Special circumstances that interfere with childs ability to benefit from

special education.

Citing Pete's case, Florence County School District Four v. , the

District Court found that: " In any contest between systematic efficiency and the

provision of FAPE to a disabled child, Congress and the Supreme Court have made

it clear that the child must prevail. "

Other findings:

Notice and Timing - The importance of making a decision about ESY early enough

in the school year to allow the parents adequate time to exercisetheir rights

administrative review or appeal in a timely fashion. That the explanation about

ESY contained in a brochure distributed to all studentswas not sufficient and

ordered that the student's eligibility for ESY be considered at each annual

review meeting, and the parents sign a form acknowledging their receipt of this

information. The district must documentthe discussion and the decision reached

after consideration of ESYeligibilty at each annual review meeting.

Content and Duration - The content of child's ESY program must be determined on

an individual basis. The duration is also based on individualized determinations

of the number of weeks, days per week,and hours per day that each student

receiving ESY should be provided.

Copyright 1999-2002, W. D. and Pamela Darr .

All rightsreserved. www.wrightlaw.com

--

Posted by Carol Sadler to IEPadvocate4You at 3/14/2005 05:59:00 AM

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A question about this post. If a child moves to a new district with an IEP

already established from previous home location ( parents spent money on

advocate and therapists to sit in to get goals, services in) CAN the new

district just go ahead and change it or disregard what was written in?? (iep

would be about 6 months old only)

Ivy

>

> The new district will have an IEP mtg to adopt the IEP, however, they (the IEP

team which you are a part of) can agree to change items on the IEP. Just b/c an

IEP is new does NOT guarantee that a new district will use it, they could decide

to write a new IEP. I've had children come into my program with goals written

that truly make no sense (the child has mastered them, there is no need for,

etc).Good luck

>

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