Issues Regarding the Use of the Individualized Education Program (IEP) as an Accountability Measure under No Child Left Behind

 

Because of the alignment of the Individuals with Disabilities Education Act (IDEA) and No Child Left Behind, special education students are expected to have

  • access to the general curriculum
  • highly qualified teachers who know the academic content that they are teaching
  • individualized supports and services necessary to achieve the same  academic standards as all other students.

 

Schools, school districts and states are required to measure and report this progress as part of the NCLB accountability system.

 

It has been suggested that changes to the Elementary and Secondary Education Act in its next reauthorization should allow schools to use the Individualized Education Program (IEP) as the primary accountability tool for demonstrating the progress of special education students in order to achieve Adequate Yearly Progress (AYP). 

 

There are a multitude of reason why a student’s IEP cannot and should not be used for NCLB accountability.

 

1.    The IEP is a tool that serves multiple functions.  The IEP outlines agreed upon services and supports required to address the individual needs of a student so as to enable the him or her to participate in the regular education curriculum aligned to the standards set for all and with his or her peers without disabilities to the maximum extent appropriate.

 

Additionally, a significant portion of the IEP meeting and document are devoted to ensuring that the IEP complies with the procedural requirements of IDEA.  Part B regulations specify the content of the IEP:


 

§  Statement of a child’s present level of academic achievement and functional performance

§  Statement of measurable annual goals designed to meet the child’s needs that result from the child’s disability to enable a child to be involved in and make progress in the general education curriculum.

§  A description of how the child’s progress toward meeting the annual goals will be measured.

§  When periodic reports on the progress toward meeting annual goals will be provided to the parents.

§  Statement of the special education and related services and supplementary aids and services to be provided to the child.

§  A statement of the program modifications or supports for school personnel that will be provided.

§  An explanation, if any, of the extent to which the child will not participate in the regular classroom and in extracurricular and nonacademic activities

§  A statement of the accommodations that are necessary to measure academic achievement and functional performance of the child on State and district wide assessments

§  The projected dates for the beginning, frequency, location and duration of the special education and related services, supplementary aids and services and modifications and supports.

§  Transition services beginning no later than the first IEP after a student turns 16.

§  Statement of rights that transfer at Age of Majority.

 

2.  Additionally, the IEP has served as a tool for monitoring individual child progress based only on the effectiveness of the individualized services and supports developed to address the student’s disability related educational needs.

 

IEPs are not designed or utilized as tools for holding schools accountable for ensuring that students with disabilities are taught to the academic content and achievement standards established by the state for all students.  As result student goals are often set too low and do not align with state or district content standards.  Furthermore, aggregate performance data is impossible to obtain at a school, district or state level and no consequences are attached to a student’s failure to attain individual IEP goals.

 

In fact, recent data indicated that only a few states require that the IEPs of students with disabilities even address academic content standards.

 

Congress acknowledged these problems in the May 9, 1997 Committee on Labor and Human Resources Report accompanying S. 717:  “An exclusive focus on the components of the Individualized Education Program has often resulted in special education becoming detached from the curriculum and teaching and learning in schools”.   

 

3.  An example of this detachment is illustrated in the following chart  contrasting IEP goals that address deficit areas, strategies, accommodations and modifications with the actual age and grade level instructional goals based on the general education curriculum in the general education setting for the same student:

 

Language Arts/Reading IEP GOAL for 15 year old Maryland student with Down Syndrome

Actual instructional goals and activities in the general education classroom and curriculum school year 2006-2007

- Will use word bank, pictures or visual cues to generate and select topics using graphic organizer, webbing, writing questions on topic and discussion.

- Read original text of “Animal Farm”, the No Fear version of Shakespeare’s “As You Like It” and an abridged version of the Hobbit.

 

- Will use writing-to-learn strategies such as journals, listing graphics, think-aloud’s on paper to connect ideas and thinking about a lesson.

- Had 20 grade-level objectives per quarter to master in U.S. History.

- Worked on weather, chemistry and geology in science including Power Point presentation and oral presentations on grade level topics

*IEP Progress Report to Parents:

 

  • Goal achieved
  • Making sufficient progress to meet goal
  • Not making sufficient progress to meet goal

Progress Report to parents:  Quarterly grades based on the same assessment and projects used by the rest of the class.  Takes regular grade level assessment under NCLB and earned 337 in Reading – missing proficiency by 50 points.  In 2004 student missed proficiency on this assessment by 90 points and has closed the gap by 20 points each subsequent year.

*Of note as well is the minimal content of the IEP Report about progress toward achieving the annual goal contrasted with the detailed information reported to the parents regarding their son’s progress in Reading, History and Science as a result of state and district-wide assessments, graded projects and report cards.

 

4.  IEP Teams do not make curriculum decisions.  Only 57 percent of special education teachers say that they are “very” familiar with their state’s academic content for the subjects they teach. ( Source: Quality counts 2004: Count Me In, Education week 2004)  In fact, the earliest special education Supreme Court decision, Rowley in 1982, defined an “appropriate” education for children with disabilities as  “reasonably calculated to confer educational benefit”.  This set a low and confusing standard for accountability until NCLB shifted the policy goal for students to that of attaining a standard level of performance.  Under NCLB individual instruction has taken on new meaning as all students are to be held to grade level content standards and all but 30 percent held to the same achievement standards as non-disabled peers (Source: Closing the Achievement Gap and Students with disabilities. M McLaughlin).

 

5.  IDEA and NCLB are not incompatible.  While there might be a gap – sometimes significant – between a student’s present level of performance and the skills and knowledge required to meet grade level standards – the IEP should address what needs to happen in order for the student to meet the standards.  Once the IEP team has analyzed a student’s current performance and determined what the student needs to learn, the “specially designed instruction” (i.e. special education) and related services and support can be developed (Source: Aligning the IEP and Academic Content Standards to Improve Achievement, C. Cortiella 2006).

 

As one experienced parent advocate has said “The IEP says how our kids will learn.  No Child Left Behind says what they will learn”.

 

6.  14% of public school students currently receive special education supports nationally.  That rate is as high as 20% in some states.  To exclude students with disabilities from the determination of Adequate Yearly Progress as required by NCLB, or to marginalize their participation by using IEP goal attainment as an alternative measure will limit accountability for one of every 5 to 7 public school students and will surely result in a violation of their civil rights under section 504 of the Rehabilitation Act.