Athletics and Students With Disabilities

Abstract

Public concern over the general health of children in the United States has risen during recent years due to dramatic decreases in physical activity levels and increases in obesity and other health-related issues. This article examines the participation of students with disabilities in extracurricular activities, particularly athletic activities, in light of recent federal guidance and examination of recent case law. Implications for practice are provided.

Keywords

athletics students with disabilities extracurricular activities

Concern over the general health of children in the United States has risen during recent years due to dramatic decreases in physical activity levels and increases in obesity and other health-related issues (Centers for Disease Control and Prevention [CDC], 2012; U.S. Department of Health and Human Services [HHS], 2010a). For example, the prevalence of obese children more than tripled from 5% in 1980 to 17% in 2008 (Ogden, Carroll, Curtin, Lamb, & Flegal, 2010). Unfortunately, recent studies suggest that less than 25% of children and youth participate in 60 minutes of physical activity each week; far less than the recommended 60 minutes of moderately intense physical activity each day (HHS, 2008, 2010b). Furthermore, according to the Center for Disease Control (CDC; 2006), 95% of high schools required students to take a physical education (PE) course; however, only 2% of high schools required daily PE or its equivalent for students for the entire year, and only 45% offered opportunities for students to participate in physical activity clubs.

While the obesity epidemic is steadily increasing in the general population, individuals with disabilities may be particularly susceptible to obesity due to lower levels of physical activity, side effects of medication, and chronic health conditions (Maiano, 2011; Rimmer, Rowland, & Yamaki, 2007). Poor overall health for students with disabilities exist despite research that speaks to the benefits of exercise, including the following from the Government Accountability Office (GAO), “Regular physical activity may help control or slow the progression of chronic disease, improve muscular strength, control body weight, and enhance students’ psychological well-being through additional social ties and improved self-confidence and self-esteem” (US GAO, 2010, p. 1; see also Murphy, Carbone, & American Academy of Pediatrics Council on Children With Disabilities, 2008). To counter the obesity epidemic, it is crucial to improve school health education and nutrition services and increase levels of school-based physical education and physical activity programs in general (CDC, 2012; HHS, 2010b; Office of Civil Rights [OCR], 2013; U.S. Department of Education [USDOE], 2011).

In 2010, the U.S. GAO reported that 92% of students with disabilities in Grades 1 through 7 and 88% in Grades 7 through 12 took PE in general education classes (GAO, 2010). In contrast, only 41% of students with disabilities in Grades 1 through 7 and 33% in Grades 7 through 12 participated in school- or community-based extracurricular athletics in 2001. Furthermore, only four states, Georgia, Minnesota, Ohio, and Vermont, offered adapted athletics through their state high school associations in the 2007-2008 school year (GAO, 2010). In light of the importance of physical activity and limited participation in extracurricular activities among students with disabilities, the USDOE (2011) and the OCR (2013) issued guidance to schools and local education agencies. Consequently, the purpose of this review is to examine relevant federal legislation, guidance documents, and case law involving the participation of students with disabilities in physical education classes and extracurricular activities with an emphasis on participation in athletic activities.

Extracurricular Athletics and Students With Disabilities

The guidance and litigation that we discuss in this article directly affect students with disabilities who attend public schools in the United States. At the onset, it is important to acknowledge that the federal guidance and litigation include students with disabilities who are eligible for special education services under the Individuals with Disabilities Education Act (IDEA) as well as students with disabilities who are not eligible under the IDEA but are protected against discrimination under Section 504 of the Rehabilitation Act of 1973 (hereafter Section 504). Section 504 also protects students who are eligible under the IDEA; thus, these students are dually covered.

The IDEA requires that individualized education programs (IEPs) for students with disabilities who are eligible for special education services must include

a statement of special in education and related services and supplementary aids and services . . . to be provided to the child, and a statement of the program modifications or supports for school personnel to be provided to enable the child . . . to be involved in and make progress in the general education curriculum . . . and to participate in extracurricular and other nonacademic activities. (IDEA Regulations 34 C.F.R. § 300.320 et seq.)

According to Tatgenhorst, Norlin, and Gorn (2014), however, participation in extracurricular activities, including athletics, will seldom be required for a student with disabilities under the IDEA to receive a free appropriate public education (FAPE). Thus, IEPs for students eligible under the IDEA will usually not include annual goals or special education services to allow a student to participate in extracurricular activities. However, when a student’s IEP team determines that participation in extracurricular activities is necessary for a student to receive a FAPE, such activities may be included in the IEP as special education and related services (Letter to Anonymous, 1990).

In 1990, the Office of Special Education programs stated that the IDEA does not require school districts to provide nonacademic services and extracurricular programming to students with disabilities, rather school districts must afford students with disabilities an equal opportunity to participate in such activities that are offered to nondisabled students (Letter to Anonymous, 1990). However, when appropriate and necessary, a student’s IEP team may be required to determine supplementary aids and services that are necessary for the student to receive an equal opportunity to participate in extracurricular activities (IDEA Regulations 34 C.F.R 300.107(a)).

Section 504 was the first federal civil rights law to protect the rights of persons with disabilities. According to Section 504, no persons with disabilities in the United States can, solely, by reason of their disability, be excluded from participation in, be denied the benefits of, or be discriminated against under any activity receiving federal financial assistance. Although Section 504 contains a FAPE requirement, participation in extracurricular activities is not a FAPE issue under the law (Norlin, 2014). Rather, participation in extracurricular activities is an issue of accessibility and equal opportunity under Section 504. Thus, it is critically important that school districts afford students with disabilities an equal opportunity to participate in extracurricular activities that the district offers. This may mean making reasonable accommodations to afford this opportunity to students.

Legislation

Although relevant Federal legislation such as the IDEA, Section 504, and Title II of the Americans with Disabilities Act (ADA, 2008) require that students with disabilities be afforded an equal opportunity to participate in PE and extracurricular activities, including athletics, there has been minimal guidance provided to states and schools regarding how school districts can accomplish this goal. Unfortunately, this lack of information and limited school district budgets may prevent schools from providing students with disabilities equal opportunities to participate in extracurricular activities to the maximum extent possible. Specifically, IDEA and Section 504 require that PE be available to children with disabilities to the same extent as same-age peers. Similarly, schools must provide students with disabilities an equal opportunity for participation in nonacademic and extracurricular services and activities, which may include athletics. Although separate, or different, PE and athletic activities may be offered, qualified students must continue to have the same opportunity to compete for teams as their peers. Additionally, Title II of the ADA prohibits disability discrimination in the services, programs, and activities of state and local governments (including public school districts), regardless of whether they receive Federal financial assistance (42 U.S.C. § 12132).

Federal Guidance

On January 25, 2013, the USDOE, OCR, issued a Dear Colleague Letter (DCL) to alert school districts of their responsibilities to ensure an equal opportunity for students with disabilities to participate in athletics, including intercollegiate, club, and intramural athletics for students with disabilities (USDOE, 2013a). The DCL addressed a number of important issues. First, the DCL addressed the need for school personnel to avoid operating programs on the basis of generalizations, assumptions, prejudices, or stereotypes about disability generally, or specific disabilities in particular (e.g., afford equal participation without categorical exclusions for students with health-related issues). Actions that school personnel take based on such beliefs will more than likely be discriminatory and, therefore, are to be avoided. Second, the DCL confirmed school districts’ duty to make reasonable modifications and provide those aids and services that are necessary to ensure an equal opportunity to participate, which include making reasonable modifications to its policies, practices, or procedures whenever such modifications are necessary to ensure equal opportunity. The only exception to this requirement is when a school district can show that making certain modifications would fundamentally alter a particular athletic program or give a student an unfair advantage. OCR noted that equal opportunity does not mean an automatic spot on an athletic team without regard to a level of skill or ability for participation in a competitive program or activity. Third, school personnel are to ensure that students with disabilities participate with students without disabilities to the maximum extent appropriate and avoid unnecessarily separate or different services, which could be discriminatory. For example, if services are provided in a separate setting and a student is unnecessarily segregated that may be discriminatory. OCR encourages school district officials to develop broad opportunities to include students with disabilities in all extracurricular athletic activities. Fourth, schools must ensure that students who cannot participate in the school district’s existing extracurricular athletics program—even with reasonable modifications or aids and services—should still have an equal opportunity to receive the benefits of extracurricular athletics. In such cases, additional opportunities for participation must be explored, and when the number of students with disabilities at an individual school is insufficient to field a team, school districts may (a) develop district-wide or regional teams for students with disabilities as opposed to a school-based team in order to provide competitive experiences, (b) combine male and female students with disabilities on teams together, or (c) offer allied or unified sports teams on which students with disabilities participate with students without disabilities.

The DCL on the participation of students with disabilities in extracurricular athletics caused a great deal of confusion among educators. For example, some officials compared the DCL with Title IX of the Civil Rights Act, which prohibits discrimination based on sex, in terms of importance to people with disabilities, whereas others believed that the DCL represented regulatory overreach and would result in unfunded financial hardships being imposed on school districts (Zirkel, 2013). In May 2013, the National School Boards Association (NSBA) sent OCR a request for clarification of the positions OCR had taken in the DCL, and on December 16, 2013, OCR issued its response to NSBA (USDOE, 2013b). In the response, the Deputy Assistant Secretary for Policy at OCR wrote that the purpose of the DCL was not to announce new obligations or rules but rather to clarify how OCR applies a provision of Section 504, which requires that students with disabilities be provided with equal access to extracurricular athletic activities. OCR noted that these requirements do not mean that every student with a disability has the right to be on an athletic team, nor does it mean that that school district must create separate or different athletic activities just for students with disabilities. Rather, the DCL was issued to clarify that school districts must meet their obligations under Section 504 by providing equal access to existing extracurricular athletic activities to students with disabilities.

In policy guidance issued in 2011, the USDOE (2011) clarified how school districts can increase participation of students with disabilities by eliminating common barriers. This can be done by (a) improving accessibility to the area or environment, (b) ensuring the availability of appropriate equipment (e.g., modified or specialized equipment), (c) ensuring that personnel involved in these activities have adequate preparation as well as opportunities for professional development, (d) allowing for adaptive opportunities and precise instruction, (e) preparing teachers and coaches in managing behavior to address the interactional components of disabilities within the context of competition, (f) applying the universal design for learning (UDL) model to the PE curriculum, and (g) planning for assessments that allow accurate and fair rating of student progress and achievement. Additionally, officials at the USDOE (2013b) also suggested school district personnel with appropriate knowledge and expertise should make reasonable, timely, good-faith efforts to determine whether there are reasonable modifications, or aids and services, that provide students with disabilities equal access to particular extracurricular activities must be made.

Litigation

Litigation regarding physical activity and students with disabilities generally falls under two distinct topics: physical education and extracurricular activities (e.g., clubs), or interscholastic athletics activities (e.g., school sports). Having different governing bodies charged with operating the respective activities makes the distinction an important one. For example, physical education and extracurricular activities generally fall under the purview of the state education agencies, school districts, and laws of those bodies, whereas autonomous athletic associations generally govern interscholastic athletics activities with their own bylaws.

Physical Education

Issues surrounding PE and students with disabilities are varied and often complex, ranging from failure to adapt PE to meet the needs of a student with a disability to harassment allegations. Adapting PE activities and practices are sometimes essential to providing students with disabilities a FAPE under either the IDEA or Section 504. Of course, a student’s IEP team, in the case of an IDEA-eligible student, or a student’s 504 team, in the case of a student with a Section 504 plan, are the only individuals who can make such a determination. Additionally, PE and other related arts can be an important part of a student’s educational program because these classes usually allow students with disabilities to be educated alongside their nondisabled peers. This may be especially important for students with severe and profound disabilities because related arts may be the only interactions they have with their nondisabled peers.

Access to PE is not enough, however, as some students may have physical limitations that make participation in physical education classes problematic, difficult, or impossible without modifications. In such cases, supplementary aids and services and program modifications should be considered. When supplementary aids and services are required for a student with disabilities to participate in PE, it is very important that all PE teachers and staff understand the aids, services, or modifications and implement them appropriately. If such services or modifications are not implemented, and as a result a student is unable to participate, that could be a FAPE violation under the IDEA or Section 504. In extreme cases, it could even lead to school district liability.

Extracurricular Activities

Extracurricular activities present a more complex set of issues due primarily to the organization that administers the activity (e.g., school or community). School administered activities must adhere to the same rules and regulations imposed on its daily academic activities (e.g., IDEA, Section 504). Whereas privately administered activities may not be held to the same laws and regulations, in the case of students covered by the IDEA, they must adhere to Section 504 and Title II of the ADA.

Interscholastic Athletics

Litigation regarding access to athletic activities to students with disabilities has typically involved access to interscholastic athletics and involves one of four main areas: age restrictions, an eight-semester rule, academic eligibility, and physical restrictions (Sullivan, Lantz, & Zirkel, 2000). These cases are typically brought under Section 504 of the Rehabilitation Act or the Americans with Disabilities Act and center on whether the student is otherwise qualified to participate in the activity and if waiving a specified rule is deemed a reasonable accommodation.

Age Restrictions

A majority of high school athletic associations (n = 46) have enacted maximum age requirements (age < 20) that may prevent students with disabilities from participating because they have been in school longer than their peers. In the few cases where the age restriction was not explicitly set at 19 years, age was either not specified or provided an allowance for 20 year olds in certain circumstances (e.g., Minnesota; Minnesota State High School League, 2014). These maximum age restrictions are often cited as vital to athletic participation by ensuring the safety of younger athletes, leveling the playing field by reducing the advantage of older players on teams, and to deter individuals (parents, athletes, coaches) from postponing education for athletic aims (Sullivan et al., 2000).

As described by Sullivan et al. (2000), courts are likely to follow one of two options when deciding these cases. The more prevalent findings are to uphold age restrictions set forth by athletic associations, considering these rules “essential” and determining that to waive such rules would be a fundamental change to the established program. However, some courts have found that waivers of the rule should be handled on an individual basis with consideration of student factors such as size, ability, and any competitive advantage that may be obtained by the player’s age. One such case was heard in the Supreme Court of West Virginia in Baisden v. West Virginia Secondary Schools Activities Commission (2002). Jarrett Baisden was a senior at Spring Valley High School who wanted to play football on the high school team. However, Jarrett was beyond the age that the West Virginia Secondary School Athletics Commission (WVSSA) allowed to play in high school sports. The principal of Spring Valley referred the matter to the WVSSAC. The WVSSAC affirmed that Jarrett was not eligible to play; therefore, Baisden appealed the WVSSACs decision to a court noting that Jarrett had repeated two grades due to a learning disability and because that had not been taken into account, the WVSSAC had discriminated against Jarrett because of his disability. The judge in the lower court issued an injunction prohibiting the WVSSAC from enforcing its age rule against Jarrett, thus allowing him to play. The school district appealed the decision to the Supreme Court of Appeals for the state of West Virginia.

The court noted that the issue of whether age 19 rules should be applied to students with disabilities had been the subject of considerable litigation, with mixed results. According to the court, these rules were typically strictly enforced because of safety issues when larger, stronger, older, and more experienced athletes were allowed to compete against younger students. The court ruled that because age alone did not determine if a student was qualified to participate in an interscholastic sport and discrimination against students with disabilities can be avoided when reasonable accommodations can be made. Thus, the court wrote that waivers of age limits should be granted where a student’s disability had delayed his or her progression through grades and it can be shown that waiving the age rule will not materially alter the particular athletic activity in question. The court also ruled that the WVSSAC should consider such situations on a case-by-case basis and a decision to grant or refuse the waiver request should be made after a thorough consideration of all relevant factors. The court then applied the facts of Jarrett’s case to the waiver issue. In its final decision the court held that because of Jarrett’s size and age, at the time of the requests Jarrett was 6′4″ and 280 pounds, granting the waiver would not be a reasonable accommodation because the safety of the younger smaller players would be severely compromised. The waiver, the court wrote, would fundamentally alter the nature of the interscholastic program.

Readers should note, however, that state and federal courts throughout the country have not been uniform in their responses to the waiver of age rules and students with disabilities. For example, some courts have held that because the age rules are an important component of interscholastic athletics, any waiver of an age rule would constitute a fundamental alternation of the athletic activity, which is not required under antidiscrimination law. Other courts have held that because the age limit is applied equally to students with and without disabilities it is not discriminatory (see Pottgen v. Missouri State High School Association, 1994; Sandison v. Michigan High School, 1995).

Eight-Semester Rule

Similar to age restrictions, most high school athletic associations (n = 46)¹ have established rules that limit the amount of semesters a student is deemed eligible for participation in athletics. These semester rules generally regard a student eligible for a maximum of eight consecutive semesters from when the student entered the ninth grade. Such a ruling seeks to limit participation to four consecutive seasons of high school enrollment (i.e., four seasons to participate in football) and excludes a student from participating in a fifth season of athletics if they have repeated a grade, or were otherwise not in school.

The vast majority of court rulings have upheld the athletic association semester rules, suggesting that they are necessary to discourage stakeholders from postponing a student’s education for athletic ends, that they are based on the passage of time and not ability or disability (Sullivan et al., 2000). For example, a fifth-year senior was not allowed to participate in football after his eighth semester of high school (Tesmer v. Colorado High School Activities Association, 2006). The student had been diagnosed with attention deficit hyperactivity disorder (ADHD) in the third grade, but had not received any treatment since the eighth grade. The court found for the school district stating that the student did not qualify under the ADA or state laws because the student’s disability did not substantially limit any life activities, even though he failed, and repeated, the ninth grade allegedly due to his ADHD.

Academic Eligibility

Academic eligibility rules are closely related to the two previous restrictions in that, to varying degrees, a student with a disability’s academic performance is directly connected to the student’s participation in the activities. However, academic eligibility rules can come from two possible sources: the school district itself or the athletic association governing body. Eligibility rules are usually centered on one or more of the following: minimum credits earned in preceding semesters, minimum grade point average (GPA) requirements in previous semesters (e.g., 2.0 GPA), and/or minimum grade requirements (i.e., students are not allowed to earn an “F” in the preceding semester). However, these grade requirements are difficult to enforce with regard to students with disabilities. For example, the U.S. District Court for the Northern District of Ohio heard a case involving a student with a learning disability who was not allowed to participate in athletics due to receipt of a failing grade in English and therefore did not have the required GPA (Ingram v. Toledo City School District Board of Education, 2004). However, the judge in this case found that the school district failed to implement the student’s IEP as written and that the student was therefore allowed to participate in sports.

Similarly, in Northshore (WA) School District No. 417 (2006) the OCR found that strict adherence to GPA standards are not necessary to extracurricular activities. In this case, a high school student with a learning disability was not allowed to try out for the cheerleading team due to her GPA of 2.364, below the cheerleading team’s requirement of a 2.80 GPA. In ruling for the student, the OCR cited the district’s lower GPA requirements for other extracurricular activities and the fact that grades in special education classes were accepted even though many of those grades are often based on a different curriculum and grading standards, making the eligibility standard arbitrary.

Physical Restrictions

Many of the limitations posed by athletic associations (e.g., age limits) are done so under the reasoning that the rule exists to protect the safety of other students and to neutralize a competitive advantage that may be gained by an individual being older than others (Sullivan et al., 2000). However, there are subsets of rules that are based on the idea of protecting the student from harm, those being rules defining necessary physical characteristics (e.g., paired organs) to participate safely in the activity. These rules are often discussed under Section 504, which states that exclusion from activities is not always inappropriate if the there is substantial justification for the policy (Grube v. Bethlehem Area School District, 1982). In the Grube case, a student with only one kidney was barred from participating on the school’s football team. However, the district court found that the decision to exclude the student was based solely on his disability, medical rationale for the exclusion was inconsistent, and the district’s decision to exclude the student was therefore not justified.

In summary, litigation that has addressed access to athletic activities in schools for students with disabilities has been a long-standing concern for administrators and educators. Whereas some of the rules regarding student’s participation in extracurricular sports are perhaps made in good faith (e.g., paired organs), they can still infringe on a student with disability’s rights. Still other rules (e.g., GPA requirements) are fraught with legal considerations that make their use and implementation suspect.

Implications for Practice

In this section, we offer recommendations to school districts and special education administrators to help ensure that their school district personnel are following the requirements of Section 504 and the law with respect to providing an equal opportunity for students with disabilities to be involved in PE and extracurricular athletics.

Recommendation 1: Principals should ensure that their faculty and staff understand their responsibilities under the IDEA and Section 504

Principals need to ensure that all of their administration, faculty, and staff understand the IDEA and Section 504 and their responsibilities under the law. One way to accomplish this is to offer professional development activities in which the basics of the laws are presented (e.g., who is protected, what protections students receive, what constitutes discrimination) and what administrators, faculty, and staff must do to ensure that the laws are followed and implemented appropriately. School districts are responsible for proper implementation of the laws, and in cases in which these laws are violated the school district personnel may find themselves in due process hearings, or state, or federal court.

Recommendation 2: Students with disabilities must be provided with an equal opportunity to participate in physical education classes and activities

When schools provide PE to all students, students with disabilities must have an equal opportunity to participate. When adapted PE is included in an IEP, the school district is obligated to provide such services as written in a student’s IEP. When a student’s IEP contains supplementary aids, services, or program modifications regarding the student’s participation in PE, the PE teacher, the principal, and the school district is responsible for ensuring that the IEP is implemented as written.

Recommendation 3: Principals need to make certain that all students with disabilities have an equal opportunity to tryout for, and participate in, extracurricular athletics

Students with disabilities have the same right to tryout and participate in a school’s extracurricular activities, as students who do not have disabilities. School district personnel must consider the use of reasonable modifications and provide aids and services that are needed to ensure an equal opportunity to participate. Decisions regarding modifications, aids, and services that will allow students with disabilities to participate in extracurricular athletics should be made by a student’s IEP or Section 504 team rather than by an individual. School district personnel who are in charge of extracurricular activities may have legitimate safety considerations in allowing students to try out for and participate in extracurricular athletics. However, school district officials need to be cautious about making decisions to exclude certain students because of safety concerns and be certain that a student’s participation may actually cause a legitimate safety risk to the student or others.

Recommendation 4: When students with disabilities have an IEP, and the student is interested in extracurricular activities, IEP team members should address how the student can participate in such activities

In situations in which a student’s IEP team determines that the student needs to participate in particular extracurricular activities in order to receive a FAPE, special education and related services should be provided to allow the student to participate. Such situations will probably not occur often; it is more likely that a student will want to try out or participate for noneducational reasons. When this is the case, the IEP team should consider the use of supplementary aids and services and program modifications to enable the student to participate.

Recommendation 5: Principals should ensure that all involved teachers, staff, and other personnel understand necessary accommodations

When a student with disabilities desires to participate in extracurricular activities and athletics, but is denied an opportunity to participate, this will very likely be a violation of Section 504. However, situations do arise when a student is given an opportunity to participate, but accommodations that were necessary to allow the student to participate and were included in his or her IEP or Section 504 plan, but were not implemented, will most likely be a violation of the IDEA or Section 504. School districts have a large amount of freedom in determining the methods used to inform stakeholders of accommodations necessary for students with disabilities. However, districts are responsible for ensuring that school staff be informed of the needs of students with disabilities, and if the district protocols are not followed, schools are responsible for any injuries caused by staff.

Creating clear systems to inform involved personnel regarding the participation of students with disabilities is a necessary step for school districts to provide for both the access and safety of students with disabilities participating in physical activities. The student’s special education teacher should also ensure that a student’s general education teachers are kept informed of requirements included in the student’s IEP or Section 504 plan.

Recommendation 6: Consider age, semester, and GPA requirements on an individual basis

The establishment of age restrictions or maximum semester rules for participation in school sports does not expressly violate IDEA, Section 504, or the ADA. Moreover, such restrictions exist to protect younger players from injury due to the increased maturity of older students and because they are applied to students with and without disabilities equally. As the court in the previously discussed Baisden case asserted, all waiver applications should be considered on a case-by-case basis and either granted or refused only after a thorough evaluation of all relevant factors.

School districts should also take care in imposing minimum GPA requirements. Whereas they are not necessarily discriminatory, the district must be able to establish that reasons for the requirement are necessary. In the case of GPA requirements establishing the necessity of such requirements may be difficult.

Summary

Given the benefits of physical education and participation in extracurricular activities, federal guidance should serve to put school district officials on notice that they are to expand opportunities to ensure an equal opportunity to participate in extracurricular and nonacademic activities for students with disabilities. To ensure that these obligations are met, principals should take systematic steps to ensure that students with disabilities can try out for extracurricular activities, including athletics, and that they have access to the same nonacademic activities, as do their nondisabled peers. This may involve providing supplementary aids and services to the IEPs and Section 504 plans of students with disabilities. With respect to athletics, however, legislation and federal guidance does not require that school district officials compromise student safety, give students with disabilities an unfair advantage over nondisabled students, or change the fundamental nature of an athletic activity. Most important, schools and leaders of extracurricular activities should keep in mind that these activities are beneficial for all students, and should heed the unofficial motto of the Olympics, spoken by the Bishop of Pennsylvania at the 1908 London Olympics, “The important thing in these Olympiads is not to win, but to take part” (International Olympic Committee, 2013, p. 1).

Footnotes

Declaration of Conflicting Interests

The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.

Funding

The author(s) received no financial support for the research, authorship, and/or publication of this article.

Notes

Author Biographies

Mickey Losinski is an Assistant Professor of Special Education at Kansas State University. His research focuses on preventative interventions for students with challenging behaviors, research synthesis and identifying evidence-based pactices, and legal and policy issues in special education.

Antonis Katsiyannis is an Alumni Distinguished professor of special education at Clemson University. His research interests include legal and policy issues in special education, students with E/BD, and delinquency.

Mitchell Yell is the Fred and Francis Lester Palmetto Chaired Professor in Teacher Education and a Professor in Special Education in the College of Education at the University of South Carolina (USC) in Columbia, South Carolina. His professional interests include special education law, evidence based interventions for children and youth with mild disabilities, classroom management, and progress monitoring.

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