See You in Court! How to Avoid IDEA Transition–Related Mediations and Due Process Hearings

Abstract

School compliance with the Individuals with Disabilities Education Act (IDEA) transition services language requirements in this country has been an issue of concern to parents of students with disabilities as well as special education attorneys and advocates for quite some time. Evidence exists in special education case law about court rulings regarding poor transition programming and services provided by school districts to students with disabilities. The purpose of this article is to review literature on these legal cases, describe a small-scale study that investigated the most common transition-related issues mediated by special education attorneys in the state of California, and make recommendations to public school districts on how to avoid transition-related legal disputes on the IDEA transition services language requirements.

Keywords

IDEA law/legal issues transition mediations due process hearings

The Individuals with Disabilities Education Act (IDEA) of 2004 contains specific language related to the transition of students with disabilities from school to adult life:

Transition services are a coordinated set of activities that promote movement from school to such postschool activities as postsecondary education, vocational training, employment, adult services, independent living and community participation. They must be based on the individual student’s needs, taking into account his or her preferences and interests. Transition services must include instruction, community experiences, and development of employment and other postschool adult living objectives. If appropriate, daily living skills and functional vocational evaluation may also be included. (IDEA, 20 U.S.C. §1401 (34); 34 C.F.R. §300.43)

School districts address these requirements in the individualized education program (IEP) plans for all students with disabilities aged 16 and older. The National Transition Technical Assistance Center (NTTAC; see https://www.transitionta.org) created the Indicator 13 Checklist in an effort to help school districts write IDEA transition compliant IEPs. This checklist contains eight criteria, all of which need to be met in the transition components of the IEP in order for the overall document to be considered in compliance with the IDEA transition services requirements.

Despite transition services being required for children with disabilities receiving special education services since 1990, students with disabilities have achieved poorer postschool outcomes in the areas of postsecondary education, employment, and independent living compared with their nondisabled peers (National Longitudinal Transition Study–1 [NLTS-1], Wagner, Newman, Cameto, Garza, & Levine, 2005; National Longitudinal Transition Study–2 [NLTS-2], Newman, Wagner, Cameto, & Konkey, 2009; Wagner, Newman, & Javitz, 2014). This has been an ongoing issue of concern to educators and parents of students with disabilities.

Parents of transition-aged students with disabilities who are dissatisfied with school district–provided transition services often hire attorneys, frequently leading to transition-related mediations and settlement agreements between parents and school districts. Existing special education case law offers evidence of court rulings that school districts failed to properly implement the IDEA transition services requirements. Articles written by Eggert and Minutelli (2011), Katsiyannis, Losinski, and Prince (2012), and Prince, Plotner, and Yell (2014) discussed such special education court cases. A summary of the major transition-related issues presented by these authors include the following: inadequate transition assessment, planning, and services; insufficient transition services in IEPs, including Indicator 13 noncompliant postsecondary goals and IEP goals; parents not being notified of graduation requirements and expected graduation date of their child; and failure to invite state adult service agency representatives to IEP meetings. In many instances, it was determined by the courts that students with disabilities were denied a Free Appropriate Public Education (FAPE). School districts were subsequently ordered by the courts to take several actions, examples of which included the following: revise IEPs and provide instruction in transition-related areas of need; conduct an Independent Educational Evaluation (IEE) transition assessment; and provide compensatory education services (e.g., transition services, college tuition, tutoring, reimbursement of incidental college expenses, and reimbursement to parents for private residential school tuition).

A recent Supreme Court decision in Endrew F. v. Douglas County School District RE-1 (2017) ruled that a FAPE should include more than making minimal progress for students who cannot be educated in the general education classroom per Board of Education of the Hendrick Hudson Central School District v. Rowley (1982). The Court opined that FAPE should be interpreted to mean “an educational program reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances” (pp. 14–15). Given this newly interpreted meaning of FAPE and its implications for preparing students for their transition from high school, we expect more mediations and due process proceedings to occur when young adults with disabilities graduate or exit from high school without the skills needed to achieve their postsecondary goals. Therefore, it is important to understand the transition-related issues that result in mediations or due process hearings so that school districts can avoid potential legal disputes related to the IDEA transition services language requirements.

Study Purpose

The primary purpose of this small-scale study was to survey California special education attorneys to determine the most common IDEA transition–related issues in mediations or due process hearings in which they had been involved. A second purpose of the study was to determine the most common outcomes/rulings that occurred in the aforementioned mediations or due process hearings in which these attorneys had been involved. The following research questions guided this study:

Research Question 1: What are the most common IDEA transition–related issues that are the focus of mediations or due process hearings by special education attorneys in the state of California?

Research Question 2: What are the most common outcomes/rulings resulting from IDEA transition–related mediations or due process hearings by special education attorneys in the state of California?

This study was intended to be small scale in nature and was limited to attorneys in the state of California for several reasons. First, one of the authors of the study had previous experience working with the sample pool of attorneys in the capacity of performing IEE transition assessments of students with disabilities. It was believed that this relationship might increase the likelihood of the known attorneys to participate in the study. Second, the authors had limited resources and contact information for recruiting a nationwide sample of attorneys involved in transition-related legal matters. Third, the authors were hopeful the information gained from this small-scale study would be useful in informing them of how to effectively design a large-scale nationwide study on this topic in the future.

Method

Data Collection Instrument

An online survey was developed to obtain anonymous special education attorney responses to a variety of questions about their involvement in IDEA transition–related mediations and due process hearings in the state of California. The following demographic information about the attorneys was obtained: (a) gender, (b) number of years in practice, (c) total number of mediations or due process hearings in which they had been involved as an attorney, (d) total number of times they had represented the student/family in these legal matters, and (e) total number of times they had represented the school district in these legal matters.

The next section of the survey sought information about the specific IDEA transition compliance issues that were the subject of the mediations or due process hearings. Attorneys were instructed to place a checkmark next to any or all the following issues that applied: (a) age-appropriate transition assessment information; (b) postsecondary goals; (c) annual IEP goals linked to postsecondary goals; (d) transition activities, services, and supports; (e) specification of course of study and expected school completion date; (f) school district issuing high school diploma to the student; (f) agency linkages; (g) age of majority requirements; (h) student self-advocacy and attendance at the IEP meeting; (i) annual updating of the transition portion of the IEP; and (j) offer of FAPE. The attorneys were subsequently asked to rank order Items (a) to (j) from the most common to least common IDEA transition compliance issues that were the subject of the mediations or due process hearings in which they had been involved.

The third section of the survey sought information about the specific outcomes/rulings that resulted from the mediations or due process hearings in which the attorneys had been involved. Attorneys were instructed to place a checkmark next to any or all of the following outcomes/rulings that applied: (a) compensatory education services (e.g., awarding of additional year(s) of instruction, educational tutoring, participation in a specialized reading remediation program), (b) psychoeducational evaluation, (c) speech and language assessment, (d) occupational therapy assessment, (e) augmentative/alternative communication assessment, (f) transition assessment, and (g) nonpublic school placement. The attorneys were subsequently asked to rank order Items (a) to (g) from most common to least common outcomes/rulings that resulted from the mediations or due process hearings in which they had been involved.

The final section of the survey contained a response box in which the attorneys were given the option to write any other relevant information related to their involvement in IDEA transition–related mediations or due process hearings.

Participants

All of the participants in this study were special education attorneys practicing law in the state of California and had experience in mediations or due process hearings related to the IDEA transition services requirements. As stated previously, all of the attorneys were familiar to one of the authors of this study who had completed an IEE transition assessment for a transition-aged student with a disability on the attorneys’ behalf.

Of the 20 attorneys initially contacted, 11 (55%) agreed to participate in the study. Ten subsequently completed the entire online survey (50% response rate), and one of the attorneys completed a portion but not the entire online survey. Nine of the attorneys identified themselves as being female (81.8%), and two of the attorneys identified themselves as being male (18.2%). The mean number of years in practice of the 11 attorneys was 12.6 years (SD = 11.3 years; range = 2–37.5 years). The mean number of mediations in which all 11 attorneys reported having been involved was 234.3 (SD = 33.5; range = 4–1,000), and in all instances, they reported having represented the student and family in these mediations. The mean number of due process hearings in which the 11 attorneys reported having being involved was 26.9 (SD = 37.4; range = 0–100), and all but one of the attorneys reported to have represented the student and family in these due process hearings.

Procedure

The attorneys were initially sent an email inviting them to participate in the study, including a description of the purpose of the study, procedures, estimated time to complete the online survey, potential risks, option to withdraw from the study, and informed consent requirement. Attorneys who expressed an interest in participating in the study were sent a web link that re-explained all of this information, obtained the attorney’s electronic signature verifying their informed consent, and a link to proceed to the online survey. All attorney survey responses were anonymous, and procedures were implemented preventing the researchers from being able to identify or trace the web addresses of the responding attorneys. Attorneys who did not respond to the initial email invitation to participate in the study were contacted a second or third time either by telephone or by email. No further contact was subsequently made with these nonresponding attorneys.

Results

Research Question 1

What are the most common IDEA transition–related issues that are the focus of mediations or due process hearings by special education attorneys in the state of California?

The IDEA transition compliance issues that were the focus of the mediations or due process hearings of the attorneys surveyed in this study are displayed in Table 1, along with the frequency and percentage of attorneys who reported these results. The data show that 70% to 90% of the attorneys reported having been involved in mediations or due process hearings that focused on postsecondary goals; transition activities, services, and supports; offer of FAPE; annual IEP goals linked to postsecondary goals; or age-appropriate transition assessment information. The attorneys reported that 30% of the mediations or due process hearings in which they had been involved focused on specification of course of study/expected school completion date and annual updating of the transition portions of the IEP. Roughly 20% or less of the attorneys reported having been involved in mediations or due process hearings focused on age of majority requirement, agency linkages, and student self-advocacy and attendance at IEP meeting.

Table 1.

IDEA Transition Compliance Issues That Were the Focus of Mediations or Due Process Hearings (N = 10).

IDEA transition compliance issue	Focus of mediations/due process hearings
IDEA transition compliance issue	Yes, n (%)	No, n (%)
Age-appropriate transition assessment information	7 (70)	3 (30)
Postsecondary goals	9 (90)	1 (10)
Annual IEP goals linked to postsecondary goals	8 (80)	2 (20)
Transition activities, services, and supports	9 (90)	1 (10)
Specification of course of study/expected school completion date	3 (30)	7 (70)
School district issuing high school diploma to student	4 (40)	6 (60)
Agency linkages	2 (20)	8 (80)
Age of majority requirement	1 (10)	9 (90)
Student self-advocacy and attendance at IEP meeting	2 (20)	8 (80)
Annual updating of transition portions of IEP	3 (30)	7 (70)
Offer of Free Appropriate Public Education	9 (90)	1 (10)

Note. IDEA = Individuals with Disabilities Education Improvement Act; IEP = individualized education program.

The attorneys were asked to rank order from most to least common the IDEA transition compliance issues that were the focus of the mediations or due process hearings in which they had been involved. This information is shown in Table 2, with the most common compliance issues indicated by a lower number and the least common compliance issues indicated by a higher number. The most common IDEA transition compliance issues indicated by at least 50% of the attorneys were age-appropriate transition assessment information; postsecondary goals; transition activities, services, and supports; and offer of FAPE. The IDEA transition compliance issues that were ranked as the least common by at least 50% of the attorneys were agency linkages, age of majority requirement, student self-advocacy and attendance at IEP meeting, and annual updating of the transition portions of the IEP.

Table 2.

Frequencies and Percentages for Attorneys Who Ranked IDEA Transition Compliance Issues From Most Common to Least Common.

Compliance issue	Ranking from most common (1) to least common (11)n (%)
Compliance issue	1	2	3	4	5	6	7	8	9	10	11
Age-appropriate transition assessment information	3 (30)	4 (40)	2 (20)				1 (10)
Postsecondary goals	1 (10)	3 (30)	2 (20)	3 (30)		1 (10)
Annual IEP goals linked to postsecondary goals			2 (20)	2 (20)	4 (40)	2 (20)
Transition activities, services, and supports	2 (20)	2 (20)	2 (20)	1 (10)	2 (20)	1 (10)
Specification of course of study/expected school completion date					1 (10)	2 (20)	2 (20)	3 (30)	2 (20)
School district issuing high school diploma to student			1 (10)			1 (10)	4 (40)	1 (10)	1 (10)		2 (20)
Agency linkages	1 (10)				1 (10)		2 (20)	2 (20)	2 (20)		2 (20)
Age of majority requirement							1 (10)	1 (10)	2 (20)	3 (30)	3 (30)
Student self-advocacy and attendance at IEP meeting	1 (10)							3 (30)		4 (40)	2 (20)
Annual updating of transition portions of IEP				1 (10)	2 (20)	2 (20)			2 (20)	2 (20)	1 (10)
Offer of Free Appropriate Public Education	3 (30)	1 (10)	1 (10)	3 (30)		1 (10)				1 (10)

Note. IDEA = Individuals with Disabilities Education Improvement Act; IEP = individualized education program.

Research Question 2

What are the most common outcomes/rulings resulting from IDEA transition–related mediations or due process hearings by special education attorneys in the state of California?

Table 3 displays data on the IDEA transition outcomes/rulings that resulted from the mediations or due process hearings in which the attorneys had been involved. All of the surveyed attorneys (i.e., 100%) indicated that compensatory education services was an outcome/ruling in the mediations or due process hearings. At least 70% to 80% of the attorneys indicated psychoeducational evaluation, transition assessment, and nonpublic school placement were outcomes/rulings of the mediations or due process hearings.

Table 3.

Outcomes/Rulings Resulting From IDEA Transition Mediations and Due Process Hearings.

Outcome/ruling	Yes, n (%)	No, n (%)
Compensatory education services	10 (100)	0 (0)
Psychoeducational evaluation	8 (80)	2 (20)
Speech and language assessment	5 (50)	5 (50)
Occupational therapy assessment	5 (50)	5 (50)
Augmentative/alternative communication assessment	6 (60)	4 (40)
Transition assessment	8 (80)	2 (20)
Nonpublic school placement	7 (70)	3 (30)

Note. IDEA = Individuals with Disabilities Education Improvement Act.

The attorneys were also asked to rank order from most common to least common the outcomes/rulings that resulted from the mediations or due process hearings. These data are displayed in Table 4. The top four most common outcomes/rulings indicated by the attorneys were compensatory education services, psychoeducational evaluation, transition assessment, and nonpublic school placement. The least common outcomes/rulings indicated by the attorneys were augmentative/alternative communication assessment, occupational therapy assessment, and speech and language assessment.

Table 4.

Rank Order Data From Most Common to Least Common on the Outcomes/Rulings of IDEA Transition Mediations and Due Process Hearings.

Outcome ruling	Ranking from most common (1) to least common (7)n (%)
Outcome ruling	1	2	3	4	5	6	7
Compensatory education services	6 (66.6)	2 (22.2)	1 (11.1)
Psychoeducational evaluation		3 (33.3)	3 (33.3)	3 (33.3)
Speech and language assessment			2 (22.2)	3 (33.3)	1 (11.1)	3 (33.3)
Occupational therapy assessment				2 (22.2)	4 (44.4)	1 (11.1)	2 (22.2)
Augmentative/alternative communication assessment					4 (44.4)	3 (33.3)	2 (22.2)
Transition assessment	2 (22.2)	1 (1.11)	2 (22.2)			2 (22.2)	2 (22.2)
Nonpublic school placement	1 (11.1)	3 (33.3)	1 (11.1)	1 (11.1)			3 (33.3)

Note. IDEA = Individuals with Disabilities Education Improvement Act.

Discussion

The vast majority (i.e., 70%–90%) of the California special education attorneys surveyed in this study reported having been involved in mediations or due process hearings dealing with similar IDEA transition–related issues as those summarized in our special education case law literature review. These common issues were quality of postsecondary goals; transition activities, services, and supports; annual IEP goals linked to postsecondary goals; age-appropriate transition assessment information; and offer of FAPE. Similarly, the outcomes/rulings resulting from the mediations and due process hearings of the special education attorneys surveyed in this study were similar to the outcomes/rulings reported in our special education case law literature review. These included the ordering of compensatory education services, a psychoeducational evaluation, a transition assessment, and nonpublic school placement for a transition-aged student with a disability. Similar results occurred when the special education attorneys in this study were asked to rank order from most to least common the transition-related compliance issues they had been involved with in mediations or due process hearings and the outcomes/rulings that resulted from these mediations or due process hearings.

The current study was intended to be a small-scale investigation of the topic and was limited in sample size, geographical location, and number of attorneys who participated. Nevertheless, the study yielded similar results to those found in existing special education case law literature on the subject of litigation of the IDEA transition services requirements. California special education attorneys who responded to the survey reported the same common issues and outcomes/rulings as those litigated in mediations and due process hearings nationwide. Implications and recommendations related to these findings are discussed next.

Implications and Recommendations

Public school districts and secondary level special education teachers should consider taking a number of important actions to avoid being involved in mediations and due process hearings related to the IDEA transition services language requirements. This begins by conducting quality age-appropriate transition assessments. By this, we mean selecting transition assessment materials and methods that address all aspects of adult life and contain sufficient validity and reliability data. Second, secondary special education teachers need to write observable, measureable, and results-oriented postsecondary goals. These postsecondary goals should identify specific, observable, and measureable outcomes in postsecondary education or training, employment, and independent living to be achieved by students with disabilities in their adult years. Third, secondary special educators need to write observable and measurable transition-related annual IEP goals that are clearly linked to the student’s postsecondary goals. Finally, special educators need to identify on the transition portions of the IEP-appropriate and comprehensive transition activities, services, and supports that will promote the student’s achievement of their postsecondary transition goals.

There are a number of excellent organizations that offer materials and resources related to these recommendations. Two potential resources for obtaining transition assessment materials are the National Technical Assistance Center on Transition (NTACT; https://ww.transitionta.org) and the Garrett Center on Transition and Disability Studies (Garrett Center; https://www.shsu.edu/centers/garrettcenter/). With respect to NTACT, readers are encouraged to download the Transition Assessment Toolkit via the Transition Planning link on the NTACT website homepage. The toolkit offers a comprehensive overview of the transition assessment process and presents information about informal transition assessment methods (e.g., interviews and questionnaires, curriculum-based assessments, transition planning inventories) and formal transition assessment methods (e.g., achievement, aptitude and intelligence tests, adaptive behavior and independent living tests, career development measures, and self-determination assessments). The Garrett Center website has resources for educators, families, and students to help them with all areas of transition, including transition assessment. Transition assessment materials containing sufficient validity and reliability data can be obtained from the Transition Assessment and Goal Generator (TAGG) located at the Zarrow Center for Learning Enrichment at The University of Oklahoma (https://tagg.ou.edu/tagg). Courts have ruled that transition assessments used by school districts must be valid and reliable to comply with IDEA transition services requirements (see article by Prince et al., 2014). Examples of transition assessment constructs in the TAGG that meet this criteria include strengths and limitations, disability awareness, persistence, interacting with others, goals settings and attainment, employment, student involvement in the IEP, and support community. A recent article written by Greene (2018) illustrated for special education teachers how to write IDEA compliant transition portions of an IEP. The article also includes examples and resources of age-appropriate transition assessments and how to adequately summarize transition assessment results in a student’s IEP. Finally, secondary special education personnel interested in improving their skills in the area of transition services for students with disabilities should consider joining the Division on Career Development and Transition (DCDT), a subdivision of the Council for Exceptional Children. DCDT offers its members an excellent journal containing up-to-date transition research and practitioner-related articles, information on professional conferences on the topic of transition, and reviews of transition-related materials and resources.

Another important implication and recommendation related to the findings from this study is the need to improve the quality of secondary level special education teacher training in the area of transition services. Because university teacher preparation programs are driven by federal and state policies and priorities, it is important to be able to evaluate special educators’ knowledge and skills related to providing transition services to students with disabilities so that policy makers can be informed of additional needs in their states (Morningstar & Clavenna-Deane, 2014). Most preservice teacher preparation programs for special educators do not provide the level of training needed to effectively plan and deliver transition services to students with disabilities (Benitez, Morningstar, & Frey, 2009; Morningstar, Hirano, Roberts-Dahm, Teo, & Kleinhammer-Tramill, 2018). Indeed, in-service training seems to be the primary method special education teachers receive information on transition planning and implementation (Benitez et al., 2009). In response to this situation, the journal Career Development and Transition for Exceptional Individuals published a special issue on this topic. The intent of the special issue as stated by the guest editor of the journal “was to provide the field with critical information related to quality, availability, and status of secondary personnel preparation training and funding across this country” (Mazzotti, 2018, p. 3).

Finally, public school districts should consider creating a task force of secondary-level special education teachers, parents of transition-aged students with disabilities, transition-aged students, special education program administrators, related services personnel, and special education attorneys or advocates to study the issue of compliance with the IDEA transition services requirements. Part of the task force’s work should involve investigating mediations and due process hearings that have occurred in the school district related to the IDEA transition services requirements and the outcomes/rulings that resulted from these legal matters.

Study Limitations

As stated previously, the primary limitations of this study were that it was (a) based on a very small sample size and response rate of special education attorneys who were familiar to one of the authors, (b) was limited to special education attorneys practicing law in the state of California, and (c) primarily involved attorneys who had represented parents and students with disabilities in transition-related mediations or due process hearings versus attorneys who had also represented school districts. It should be noted, however, the mean number of mediations in which the attorneys who participated in this study had been involved was substantial (e.g., 234) and to a lesser degree the number of due process hearings in which they had been involved (e.g., 26.9). Moreover, it should be noted that due process hearings are comparatively less common compared with mediations that result in settlement agreements between parents of students with disabilities and school districts. Nevertheless, the small sample size does not allow one to generalize to the larger population of special education attorneys in California.

Suggestions for Future Research

There are several lines of future research that can potentially be pursued on this topic. First, a more thorough and comprehensive investigation of special education case law literature is suggested. Specific court cases and rulings dealing with the IDEA transition compliance issues identified in Table 1 covering the time periods 1990, when transition was initially federally mandated, to the present would be informative. An investigation of this type would shed light on the historical aspects of transition-related special education case law.

A second recommendation for future research would be to expand the subject pool in the current study to include a nationwide sample of special education attorneys, school district directors of special education, and Disability Rights organizations. Attempts should be made to recruit a greater number of nationwide special education attorneys who have represented public school districts in transition-related legal disputes as opposed to only attorneys who have represented families of students with disabilities. With respect to school district directors of special education, it would be interesting to survey them about the frequency and reasons behind their having chosen in the past to enter into a settlement agreement with a family in a transition-related legal dispute rather than proceed to a due process hearing. For example, how much was “cost-benefit” a factor in their choice to enter into a settlement agreement?

A final recommendation for future research would be to conduct focus group interviews with parents, students with disabilities, special education attorneys, and school district directors of special education who have been involved in transition-related mediations and due process hearings. Part of these interviews should focus on the common reasons associated with transition-related legal disputes (i.e., the circumstances that precipitated parents filing a legal complaint with the school district) and the eventual outcome that occurred in the matter (e.g., specific items offered in a negotiated transition-related settlement agreement; court-ordered outcomes and rulings resulting from a transition-related due process hearing). Of equal interest would be to ask school district directors of special education and their attorneys about the issues and challenges they have faced in transition-related legal disputes. A qualitative study investigating any or all of these aspects of transition-related legal disputes would allow researchers to gain a greater depth of understanding on this topic.

Summary and Conclusion

Compliance with the IDEA transition services language requirements in this country has been an issue of concern to parents of students with disabilities, as well as special education attorneys and advocates, for quite some time. Evidence exists in special education case law demonstrating that a number of public school districts throughout the nation have failed to properly implement several of the important transition services mandates of the IDEA. These include key areas such as conducting age-appropriate transition assessments; writing Indicator 13 compliant postsecondary goals and associated IEP annual goals; addressing transition activities, services, and supports on the transition portions of the IEP; and meeting FAPE requirements for transition-aged students with disabilities. Similar findings occurred in this study investigating the IDEA transition–related issues mediated by a small group of special education attorneys in the state of California. The findings of this study also lend support to the need to improve special education teacher preparation, professional development, and program monitoring in public school districts to reduce the number of transition-related mediations and due process hearings which may occur in the future. It is hoped the results and recommendations from this study are informative, will lead to further research and discussion on this topic, and will potentially reduce the number of transition-related mediations and due process hearings in the future.

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.

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