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In last week’s Endrew F. v. Douglas Country School District case, the US Supreme Court determined that to meet its requirements under federal law, “a school must offer an Individualized Education Plan (IEP) reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.” What does this mean for your child’s IEP? To understand, we must look at the cases that came before this monumental decision.
A LOOK TO THE PASTThe earlier standard on what satisfies the requirement of providing a free appropriate public education (FAPE) came from the 1982 Rowley case, in which the Court said the educational program in a child’s IEP must be “reasonably calculated to enable the child to receive educational benefits.” This standard was troublesome because it was vague. It essentially meant that a student with disabilities had to make some kind of benefit in order to move from one grade to the next.
The Endrew F. case arose in challenge to special education precedent in the 10th Circuit, which interpreted Rowley as establishing a “merely…more than de minimis” standard. In other words, any bit of progress could suffice to make an IEP adequate. A big part of the Endrew F. challenge stemmed from the comparison of students with disabilities being held to a “barely more than de minimis” standard of progress, while students without disabilities in mainstream classroom were held to grade-level standards.
THE FUTURE OF YOUR CHILD’S IEPSo, what could the Endrew F. decision change about a child’s IEP? The details still need to be worked out, but there is some language from the Supreme Court’s unanimous opinion that gives insight into their decision. “An IEP must aim to enable the child to make progress,” wrote the Court, “[a]nd the degree of progress contemplated by the IEP must be appropriate in light of the child’s circumstances.”
This implies a higher standard as compared to that from Rowley: the standard is no longer some progress, no matter how slight it might be, but rather appropriate progress given that particular student’s profile and abilities. The opinion compares the “individual circumstances” language to the definition of special education under the Individuals with Disabilities Education Act (IDEA), which already requires that “the unique needs of a child with a disability” be factored in during the creation of an IEP.
There is still no requirement that an IEP provide a student with disabilities the best program or services available. What improves from Endrew F. is the higher standard of progress that an IEP must provide for a student with disabilities, now taking into consideration what that student may achieve “in light of the child’s circumstances.” We must pay close attention to the Bureau of Special Education Appeals and other district and federal courts to see how they incorporate this new standard into their decisions, including determining who has the burden of proving appropriate progress.
To learn how to create an effective IEP, check out the Exceptional Lives IEP Guide:
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Terry Alves-Hunter, Foster Parent Advocate
Not in my womb, always in my heart
Learning & Emotional Assessment Program (LEAP) The Learning and Emotional Assessment Program (LEAP) at Massachusetts General Hospital assesses students and children ages 2 to 22 who have developmental difficulties and consults with their parents, teachers and care providers.
Our clinical professionals have devoted their training, research and clinical practice to acquiring the specialized skills needed to assess children with learning disabilities, psychological and developmental disorders. Our team loves working with children and has a natural ability to put them at ease.
The Department of Psychiatry offers a depth and breadth of resources available at few other hospitals or psychiatric centers, meaning your child receives comprehensive, state-of-the-art care without leaving our campus. Services available at the MassGeneral Hospital for Children include:
Referral forms Clinician's Referral From (PDF)
Parent Referral Form (PDF)
HIPAA Authorization Form for release of information (PDF)
Learn more about:
Our clinical assessments are designed to be a comfortable and often fascinating experience, and we find that many children enjoy the warm, one-on-one attention they receive. In addition, our professionals excel at discussing the benefits of assessments with even the most skeptical of adolescents. Our Staff
Our experienced professional staff includes Child psychologists, Licensed clinical psychologists, Neuropsychologists, Certified school psychologists, clinical psychology interns and postgraduate fellows.
Research is an ongoing companion to treatment in the LEAP program, with clinical test data collected daily. This data is used to help participants in LEAP, as well as in other programs and departments. Conditions We Evaluate
LEAP treats a variety of conditions and disorders. With the trained resources of Mass General Hospital's Dept. of Psychiatry, we are able to evaluate and treat a variety of conditions and disorders.
Contact Us LEAP (Learning and Emotional Assessment Program)
151 Merrimac St., 5th Floor
Boston, MA 02114
Boston Medical Center
Dr. Augustyn is the Director of the Division of Developmental and Behavioral Pediatrics at Boston Medical Center (BMC) and is a Professor at Boston University School of Medicine. She went to medical school at Loyola Stritch School of Medicine, completed her pediatric residency at UCLA and her Developmental and Behavioral Pediatric Fellowship at Boston University-Boston City Hospital. Her clinical work at BMC primarily involves the evaluation of children with various developmental delays including autism,speech and language delays, global developmental delay, learning disabilities, ADHD to mention a few.
Her research work has varied across her career and includes work on the effects of both in utero cocaine exposure and violence on early childhood and parenting and recently she has been a leader in developing the Center for Family Navigation at BU, a national leader in promoting and developing the use of navigators to support families of children with developmental disabilities.
Dr. Augustyn is co-editor of The Zuckerman Parker Handbook of Developmental and Behavioral Pediatrics for Primary Care and the section co-editor for Developmental and Behavioral Pediatrics for the online journal UpToDate. She currently sits on the sub board of Developmental and Behavioral Pediatrics at the American Board of Pediatrics and is on the Board of Directors of the Society of Developmental and Behavioral Pediatrics. She is also on the American Academy of Pediatrics planning committee for Practical Pediatrics, their national CME Program.
Deborah Frank, MD
Dr. Frank is the Director of the Grow Clinic for Children and a board-certified Developmental and Behavioral Pediatrician at Boston Medical Center (BMC). She is also a Professor of Pediatrics at Boston University School of Medicine. Dr. Frank attended Harvard Medical School and completed her residency at Children's Hospital Seattle. After her residency, she went on to complete a fellowship in Child Development at Children's Hospital Boston. Dr. Frank specializes in issues of growth and nutrition and the impact of hunger on child development.
Dr. Frank has written numerous scientific articles and papers. Her work has focused on breastfeeding promotion, women and children affected by substance use, nutrition among homeless pregnant women and children, Failure to Thrive, food insecurity, and the “heat or eat” phenomenon, the dilemma that many low-income families face in the winter when they have to make the critical choice between heating their homes and feeding their children. She is especially proud of successfully mentoring many pre-professional and professional colleagues.
Cited as a respected authority in her fields, Dr. Frank has frequently given testimony to state and federal legislative committees on the growing problem of hunger and associated hardships in the United States and its effects on our youngest children. She has recently been nominated by Congresswoman Nancy Pelosi to the newly established National Commission on Hunger. She is also an invited member of the Aspen’s Dialogue on Food Insecurity and Health Care Costs.
L. Kari Hironaka MD, MPH
Dr. Hironaka is a board-certified Developmental and Behavioral Pediatrician at Boston Medical Center. She completed her fellowship at Boston Medical Center. Dr. Hironaka specializes in health services research, health literacy and ADHD, as well as residency training.
John Maypole, MD
Dr. Maypole completed Pediatric Residency in 1999, and Pediatric Chief Residency in 2000 following his training at Yale University School of Medicine. Dr. Maypole has consistently included primary care, medical education, and in participating in and developing innovative clinical programs for complex children and their families. Dr. Maypole served as Associate Director of the Pediatric Integrative Medicine Education Project and performing Holistic Medicine consults and medical education at Children’s Hospital from 2003-2005. In 2005, Dr. Maypole became Director of the Department of Pediatrics at the South End Community Health Center while serving as an attending physician for the Comprehensive Care Program (CCP) in the Department of Pediatrics at Boston Medical Center. CCP is a multi-disciplinary team of providers who provide enhanced and coordinated primary care to the most medically complex patients and higher risk families in the Pediatric Department, including ex-premature infants, children with special health needs and neurodevelopmental disabilities. In February of 2013, Dr. Maypole came to Boston University/Boston Medical Center to work full time to develop approaches and programs to address this fast-growing segment of the pediatric population. In September of 2014, Dr. Maypole received an award from the Center for Medicare Medicaid Innovation, supporting a 3 year effort for the Massachusetts Alliance for Complex Care/4C program--a consultative, multidisciplinary care support model of care for PCPs and families of medically complex children, of which he is co-principal investigator. He is an associate professor of Pediatrics at BUSM. Dr. Maypole writes child health-related articles for a lay audience, for mainstream media and online publications.
Jenny Radesky, MD
Dr. Radesky is a board-eligible Developmental Behavioral Pediatrician and a board-certified general pediatrician who recently joined the faculty at Boston Medical Center after completing her fellowship training here. She attended Harvard Medical School and completed her pediatrics training at Seattle Children’s Hospital. Dr. Radesky is a clinician-investigator whose clinical interests include early childhood adversity, attachment relationships, and child self-regulation, as well as teaching trainees methods of observing parent-child interaction. Her research examines mobile/interactive media use by parents and young children and how this effects parent-child interaction and child social-emotional development. She is an active member of the AAP Council on Communications and Media.
Arathi Reddy, DO
Dr. Reddy is a board-certified Developmental and Behavioral Pediatrician at Boston Medical Center. She attended medical school at Western University of Allied Health Sciences in Pomona, CA and completed her residency at Morristown Memorial Hospital/ University of Medicine and Dentistry of New Jersey in Morristown, NJ. She completed her fellowship at Einstein Montefiore and worked in NYC prior to joining the faculty in March 2011.
Jodi Santosuosso, NP, MSN
Jodi is a certified nurse practitioner in the Developmental and Behavioral Pediatrics Division at Boston Medical Center. She attended University of Massachusetts College of Nursing and Health Sciences and completed her residency at University of Massachusetts, Boston. She joined the Boston Medical Center and Boston University School of Medicine faculty in April 2007. Jodi has had extensive training in developmental and behavioral pediatrics, gastrointestinal (GI) diseases and ear, nose and throat (ENT) disorders.
Laura Sices, MD, MSDr. Sices is a board-certified Developmental and Behavioral Pediatrician at Boston Medical Center (BMC). She attended medical school at University of Pennsylvania in Philadelphia, PA, completed her residency at The Children's Hospital of Philadelphia and completed her fellowship at University of Washington in Seattle, WA. Dr. Sices was on the faculty at Rainbow Babies and Children’s Hospital in Cleveland, OH before joining BMC in 2007. Dr. Sices’ clinical work focuses on assessment and management of children with a variety of different concerns, including developmental delays, speech and language delays and conditions, ADHD, learning disabilities and differences, and autism spectrum conditions. Her academic focus is on developmental screening and the early identification of developmental delays.
Naomi Steiner, MD
Dr. Steiner is the Director of Training at the Division of Developmental and Behavioral Pediatrics. Dr. Steiner studies how computers train the brain, which is an area of great interest in overlapping fields of ADHD, psychology, neuroscience and education, and closely followed by many as a complimentary or alternative approach to the traditional psychopharmacological treatment of ADHD. She is specifically interested in implementing neurofeedback attention training in schools. She is also interested in teaching self-regulation skills and relaxation breathing in schools. Dr. Steiner is multicultural and multilingual. In 2030 more than 50% of children will be raised bilingual in the United States! Dr. Steiner has written a book on how to successfully raise children bilingual (7 Steps to Raising a Bilingual Child), and instructs medical professional, teachers and parents on how children learn two languages, and how English Language Learners can be successful at school.
Mary Ellen Stolecki, NP, MSN
Mary Ellen is a board certified pediatric nurse practitioner in the Developmental and Behavioral Pediatrics Division at Boston Medical Center and an Instructor of Pediatrics at Boston University School of Medicine.
She specializes in primary care of the Child with Special Health Care Needs (CSHCN) in the Comprehensive Care Program. She also practices in the Pediatric Gastroenterology Division providing specialty care for gastrointestinal (GI) conditions.
Her clinical interests are primary care for medically complex children (as well as GI issues) of CSHCN including: care of the premature infant, autism, cerebral palsy, seizures, Down syndrome, Williams syndrome, Turner syndrome,achrondroplasia,and multiple congenital anomalies.
Jodi Wenger, MD
Jodi Wenger, MD is a graduate of Dartmouth Medical School who completed her pediatric residency at Boston Medical Center. She spent several years on the Navajo Reservation in northeastern Arizona before transitioning back to Dartmouth Hitchcock Medical Center in Lebanon, NH. She served as a pediatric hospitalist, outpatient provider and educator at Dartmouth Medical School.
She has always had an interest in children with special health care needs. She worked in the Comprehensive Care Program at BMC as a resident and is thrilled to return. She was the general pediatrician at the multidisciplinary spina bifida clinic at Dartmouth Hitchcock and cared for children with neurologic challenges while on the Navajo Reservation.
Dr. Wenger has also had an interest in resident work hour reform and continues to support the software she and her husband created during her chief resident year. Amion, continues to allow one to make fair physician call schedules that can be easily accessed online.
Barry Zuckerman, MD
Dr. Zuckerman is Professor and Chair Emeritus of Pediatrics at Boston University School of Medicine/Boston Medical Center. He is a national and international leader in child health and development. His research focuses on the interplay among biological, social and psychological factors as they contribute to children's health and development. Dr. Zuckerman and colleagues have developed four programs that transformed health care to better meet the needs of low income and minority children. The success of these efforts is that they are now all national programs; Reach Out and Read, Medical-Legal Partnership, Health Leads and Healthy Steps. In addition to more than 250 scientific publications, he has edited nine books, including three editions of Behavioral and Developmental Pediatrics: Handbook for Primary Care. He has served on prestigious national committees; National Commission on Children, Carnegie Commission on Young Children, Bright Futures, and has received numerous national and international awards including the C. Anderson Aldrich for Child Development and the Joseph St Geme Award for Leadership from AAP, and the Policy and Advocacy award and Health Care Delivery Award from the APA. He has consulted in Turkey, Bangladesh, and Thailand regarding child development.
- See more at: http://www.bmc.org/pediatrics-developmentalbehavioral/team.htm#sthash.UrLgPWRv.dpuf
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