8. How Parents Can Prepare and Advocate

8.1 Staying Organized

• Maintain a binder or digital folder of all IEPs, 504 plans, emails, assessment reports, meeting notes, and progress reports.
• Summaries of phone calls or informal conversations should also be documented by email to create a record.

8.2 Understanding Your Rights

• Review the Procedural Safeguards notice provided by SDUSD. It outlines due process hearing timelines, independent evaluation rights, and complaint procedures.
• You may request an IEP meeting at any time if concerns arise.

8.3 Asking Targeted Questions

When receiving an IEP offer, you might ask:

• “How often will my child receive services, and who provides them?”
• “What evidence supports that these goals are sufficiently ambitious, per Endrew F.?”
• “Have you considered staff observations from middle school or my private evaluation?”
• “Why was a non-public school or more specialized environment not considered given my child’s documented history?”

8.4 Seeking Support

• Advocates/Attorneys: A professional can help you interpret assessment data, attend meetings, or advise on strategy if you reach an impasse.
• Independent Evaluations: You can request an IEE if you disagree with SDUSD’s assessment of your child.
• Mediation: Sometimes a neutral mediator can help you and the district find a compromise without a full due process hearing.

8.5 Effective Advocacy Strategies

Being an effective advocate means actively participating in your child’s education planning, communicating clearly, and standing up for their needs. Below are detailed strategies for parents when working with schools:

Communication Tips

• Establish a Collaborative Tone: Communicate with teachers and administrators in a clear, respectful manner. Articulate your concerns and questions calmly, focusing on solutions. Remember that you and the school share a common goal – helping your child succeed [28†L49-L57]. Keep emotions in check and approach discussions as a team member rather than an adversary. Losing your temper or getting overly emotional can hinder progress, so try to stay focused on facts and your child’s needs [22†L96-L104].
• Know Who to Talk To: Raise concerns with the appropriate decision-makers. Whenever possible, start at the “lowest level” – for example, discuss classroom issues with the teacher first [31†L197-L203]. If that doesn’t resolve the problem, escalate to higher authorities (such as the principal or special education director) in an orderly way. Identify who has the authority to address your issue and build positive relationships with them [31†L152-L161]. It’s often helpful to speak with someone you have a good rapport with, and to agree on a plan and timeline for follow-up [31†L154-L163].
• Use Clear, Fact-Based Language: When advocating, frame your requests in objective terms. Instead of saying “I feel my child needs this accommodation,” say “My child needs this accommodation because <specific reason backed by data or observations>.” Using language of necessity and backing it up with facts or evaluations aligns your communication with legal standards and avoids it being dismissed as merely a personal desire [33†L364-L372].

Documentation Best Practices

• Keep Detailed Records: Documentation is crucial when advocating for your child. Maintain a well-organized file of all relevant documents – evaluation reports, medical diagnoses, previous IEPs/504 plans, report cards, and correspondence with the school. Keep records of all communications (emails, letters, meeting notes) with teachers and administrators [38†L1-L4]. These records serve as valuable evidence if disputes arise or if you need to track the school’s follow-through [38†L1-L4].
• Put It in Writing: Whenever you make an important request or notice an issue, follow up in writing (email or letter). For example, if you request an evaluation or a meeting by phone, send a brief written confirmation afterward. Written requests trigger legal timelines the school must follow and create a paper trail of what was asked and when [27†L64-L72]. Always date your communications and keep copies. If you have a phone or in-person conversation with school staff, consider writing a polite summary email to document what was discussed and any agreed actions [27†L68-L72].
• Organize and Prepare Documentation for Meetings: Before IEP or 504 meetings, review your documents and highlight key points (such as lack of progress in certain areas or recommendations from doctors/therapists). Bring a binder or digital folder to meetings with all pertinent records. This shows you are prepared and allows you to reference specifics on the spot (for instance, pointing to an evaluation result that supports a service you’re requesting). Being able to readily cite data or prior agreements can strengthen your position during negotiations.

Negotiation Techniques

• Know What You Want (and Why): Before meetings, clearly identify your child’s needs and what services or accommodations you believe will meet those needs. Be ready to explain and support your requests with evidence [31†L133-L141]. For example, if you think your child needs reading intervention four times a week, be prepared to cite test scores or expert recommendations that justify this frequency. The first step in negotiation is having a well-founded request and the information to back it up [31†L133-L141].
• Bring Data and Expert Support: Schools give more weight to requests grounded in objective data. If possible, gather input from experts (doctors, psychologists, private evaluators, or therapists) who can document your child’s needs. You might have letters or reports from these professionals, or even invite them to participate in the meeting (in person or by phone) to support your position. It’s harder for a team to ignore a qualified expert sitting in the meeting or an expert report presented in writing [33†L323-L331]. For instance, a parent advocating for speech therapy could bring a speech-language evaluation that recommends that service.
• Be Open to Collaboration and Compromise: Effective negotiation often requires finding a solution that all team members can accept. Come to meetings with a few alternative solutions in mind, and listen to the school’s ideas as well. If there are multiple ways to meet an identified need, understand that the school may prefer one method over another. As long as the school’s proposal is appropriate and meets your child’s need, being flexible can lead to quicker agreement and better implementation [31†L142-L150]. However, do not compromise on essentials your child is legally entitled to – ensure any solution still provides adequate support.
• Reference Legal Rights Tactfully: If the school is resistant to a request, it can be helpful to (politely) reference your child’s rights. For example, you might remind the team that under IDEA’s procedural safeguards, any denial of services should be accompanied by a written explanation (called Prior Written Notice) explaining the reasons and what evidence was used to decide [27†L79-L87][27†L93-L101]. This signals that you are knowledgeable about the law and expect the team to follow it. Similarly, know that you have the right to request an Independent Educational Evaluation (IEE) at the school’s expense if you disagree with the school’s evaluation of your child. Bringing up an IEE request can sometimes encourage a school to reconsider or properly justify their decision [33†L333-L342].
• Remain Persistent and Follow Up: Advocacy is often a marathon, not a sprint. Be prepared for multiple discussions. If the first meeting doesn’t fully resolve your concerns, politely schedule a follow-up. Document any interim steps the school agreed to take (for example, additional testing or consulting a specialist) and check back on those. Persistence pays off – continue to push for the services and accommodations your child needs, even if you encounter delays or resistance [28†L61-L67]. At the same time, maintain professionalism so the door remains open for ongoing negotiation.

8.6 Case Studies of Successful Advocacy

Examining real-life examples can illustrate how parents effectively navigate the IEP/504 process. Below are two case studies (anonymized) demonstrating successful parent advocacy and the outcomes achieved:

Case Study A: Securing a 504 Plan for a Child with ADHD

Background: A mother suspected her first-grade daughter, who had ADHD, needed classroom accommodations for focus and impulsivity. Initially, the school dismissed her request for a Section 504 plan – one teacher incorrectly told her that 504 accommodations were given at the teacher’s discretion and deemed them “not necessary.” Being new to advocacy, the parent did not push back at that time [2†L75-L82].

Advocacy Actions: By fifth grade, the child was struggling significantly in public school, and the mother decided it was “time to get a 504 in place” [2†L99-L107]. She educated herself on the legal rights under Section 504, using resources from an ADHD advocacy organization. Specifically, she:

• Read a “504 Primer” that reinforced her child’s legal guarantee to accommodations, which empowered her with knowledge of what interventions to request [2†L107-L114].
• Used an ADHD parent toolkit to envision possible accommodations and involve her daughter in selecting which supports would help (e.g. preferential seating, movement breaks) [2†L113-L121].
• Collaborated with a parent coach and had her daughter, herself, and the school guidance counselor each fill out an executive function chart to identify the child’s strengths and weaknesses. This prepared everyone with a shared understanding of the child’s needs going into the meeting [2†L119-L127].

Armed with a list of desired accommodations and evidence of her child’s challenges, the mother formally requested a 504 planning meeting. The school’s response was positive – a meeting was scheduled within a few weeks. During the meeting, the mother presented her daughter’s profile (strengths, challenges, and suggested accommodations) and maintained a collaborative tone. The team (guidance counselor, nurse, psychologist, principal, and teacher) discussed each proposed accommodation and adjusted wording as needed to fit the classroom context. The atmosphere remained “collaborative and inspirational,” with all members focused on “how much we can do to support this struggling student” [2†L139-L143].

Outcome: After an hour and a half, the team agreed on a comprehensive Section 504 plan with about a dozen instructional and behavioral accommodations [2†L139-L143]. The plan was implemented immediately. This case shows how a parent’s preparation (legal knowledge, specific requests, involvement of experts like a coach and counselor) and positive collaboration with the school resulted in timely support for the child.

Case Study B: Using Documentation and Persistence to Improve an IEP

Background: A student in private school was receiving some special education services (occupational therapy and counseling) from the public district, but had been denied resource room (academic support) despite struggles. The child’s mother, guided by a special education teacher, suspected the district was not fulfilling its obligations. They requested a reevaluation and IEP meeting in early October, but the district delayed scheduling it until late February.

Advocacy Actions: The mother followed the teacher’s advice and kept meticulous records of all correspondence with the district [3†L53-L61]. When the district finally set a meeting (months late), a representative even tried to discourage the mother from attending, hinting they would deny services regardless. Undeterred, the mother (with the support of the private school special ed teacher) insisted on holding the meeting as scheduled [3†L59-L64]. Key advocacy steps they took:

• Knowing the Law: Anticipating a battle, the special education teacher reviewed her IDEA law handbook before the meeting to be ready with legal points [3†L63-L66].
• Insisting on Proper Evaluation: In the IEP meeting, the district team had pre-written a denial of resource services, but the teacher-advocate noticed that the required classroom observation had never been done. She calmly pointed this out and refused to proceed further until a complete evaluation, including an observation, was conducted [4†L81-L89]. By halting the meeting to demand proper procedure, they prevented the school from rushing to deny services without full information.
• Maintaining Composure: Despite provocation (“don’t bother coming” and a long wait on meeting day), the mother and her advocate remained calm and persistent. They did not accept verbal denials or incomplete data. This level-headed approach kept the focus on the child’s needs rather than on conflict.

Outcome: About six weeks later, after the district completed the missing evaluation component, a new IEP meeting convened with a different team. This time, the student was approved for all the services that were initially denied. The child received resource room support in addition to occupational therapy and counseling services [4†L91-L99]. Furthermore, because the district had been so delayed (and thus out of compliance with timelines), the parent requested compensatory services – the district agreed to provide make-up sessions over the summer for the missed counseling and OT services [4†L93-L97]. This case study highlights how persistence, thorough documentation, and knowing the procedural rights (like insisting on required evaluations and proper process) can turn a “no” into a “yes” and ultimately secure a better educational program.

These case studies demonstrate that when parents prepare diligently, document everything, and advocate firmly but collaboratively, they can significantly improve outcomes. Whether it’s obtaining a needed accommodation plan or reversing an unjust denial of services, informed advocacy makes a difference.

8.7 Legal Precedents and Rights

Understanding the legal framework of special education is essential for advocacy. Two main federal laws protect students with disabilities in school: the Individuals with Disabilities Education Act (IDEA), which covers IEPs, and Section 504 of the Rehabilitation Act, which covers 504 plans. Over the years, several landmark cases have defined the rights of students under these laws. Below is a summary of key legal precedents and principles that shape what support your child is entitled to:

• Board of Education v. Rowley (1982): This was the first U.S. Supreme Court interpretation of IDEA (then called the EHA). In Rowley, the Court held that schools must provide a “Free Appropriate Public Education” (FAPE) that confers educational benefit, but not necessarily maximize a child’s potential [12†L267-L274]. The case involved a deaf student (Amy Rowley) whose parents wanted a sign language interpreter. The Court decided that because Amy was doing well with the supports already provided, the school’s responsibility was met. The ruling established that an IEP must be reasonably calculated to help the child make progress, but it need not provide the best possible education or optimize the child’s outcomes [12†L267-L274]. In essence, FAPE under Rowley meant “some educational benefit” – more than trivial progress, but not an obligation to reach the child’s full potential.
• Endrew F. v. Douglas County School District (2017): This Supreme Court case raised the standard for what constitutes an appropriate education under IDEA. Endrew F. was a student with autism whose IEP goals remained virtually unchanged year after year due to minimal progress [6†L75-L83]. His parents argued that “some” (minimal) progress was not enough; the Supreme Court agreed. The unanimous decision rejected the “de minimis” (barely more than nothing) benefit standard and held that IEPs must be appropriately ambitious. Chief Justice Roberts wrote that “a student offered an educational program providing ‘merely more than de minimis’ progress... can hardly be said to have been offered an education at all” [9†L102-L110]. Instead, the IEP must be “reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances” [9†L113-L122]. This means goals should be challenging and tailored to the child’s unique needs, so every child has the chance to meet meaningful objectives. The Endrew F. ruling affirmed that children with disabilities are entitled to more than minimal progress; their education programs should aim for significant growth commensurate with their abilities [9†L139-L146]. For parents, Endrew F. is a powerful precedent to cite when an IEP seems unduly unambitious or stagnates – schools must offer programs that allow for meaningful progress.
• Honig v. Doe (1988): This Supreme Court case addressed the rights of students with disabilities in discipline. The Court ruled that a school cannot unilaterally expel or suspend a student with disabilities for behavior that is a manifestation of their disability beyond 10 days, as that would deny the student FAPE. Honig led to what is now the “manifestation determination” process in IDEA: when a child’s misbehavior is linked to their disability, the school must try to accommodate the behavior through the IEP (for example, with a behavior intervention plan) rather than exclude the child from school. This case underscored that students’ rights to education cannot be stripped away without careful consideration of disability-related causes.
• Section 504 of the Rehabilitation Act (1973): Unlike IDEA, Section 504 is a civil rights law that covers all ages and programs receiving federal funds, not just K-12 education. It ensures that a child with any disability that “substantially limits a major life activity” (learning, walking, concentrating, etc.) has equal access to education. Key rights under Section 504 include reasonable accommodations (changes to how things are done, like extended time on tests or ramps for wheelchair users) to “level the playing field.” Importantly, Section 504’s standard is non-discrimination: schools must provide aids and services so that students with disabilities have opportunities equivalent to those of peers. As guidance explains, “Section 504 ensures that the child with a disability has equal access to an education. The child may receive accommodations and modifications” as needed [37†L228-L236]. There have been various court decisions and Office for Civil Rights (OCR) guidance enforcing this principle. One notable Supreme Court case, Fry v. Napoleon Community Schools (2017), clarified that families can pursue claims under Section 504/ADA (for example, requesting a service animal for a child) without first exhausting IDEA procedures, if the issue is fundamentally about equal access rather than the IEP itself. In practice, if you feel the school is denying necessary accommodations, you can file a complaint with the U.S. Department of Education’s OCR under Section 504.

What These Mean for Parents: These legal precedents empower parents in advocacy. They mean, for example, you can insist on an IEP that is ambitious (citing Endrew F.) and not accept one that shows only minimal progress. You can remind the team that Rowley and Endrew F. together require the IEP to be reasonably calculated for appropriate progress given your child’s situation – not just the easiest or cheapest program. If the school proposes to shorten your child’s day or suspend them due to behavior, Honig supports your stance that the school must accommodate the behavior rather than remove the child. And if your child isn’t eligible for an IEP, remember they might still get support under Section 504 – the school must not discriminate or deny access due to disability. Knowing these rights and cases gives you a firm foundation when negotiating with the school and, if necessary, in pursuing mediation or due process.

8.8 Support Networks and Resources

You don’t have to navigate the IEP/504 process alone. There are many organizations, professionals, and fellow parents who can offer guidance and assistance. Here are key support networks and resources for parent advocates:

• Parent Training and Information Centers (PTIs): Every state has at least one PTI funded by the U.S. Department of Education. PTIs provide free workshops, resources, and individual assistance to families on special education topics. They can educate you on your child’s rights under IDEA, Section 504, and ADA, and advise how to handle school meetings [14†L111-L119][14†L119-L127]. PTIs often know local policies and can help you prepare for IEP meetings or resolve disagreements. To find your state’s PTI, visit the Center for Parent Information and Resources’ state-by-state directory [14†L151-L159]. Many PTI staff are parents of children with disabilities themselves, so they offer empathy plus expertise.
• Advocacy Organizations: National and local nonprofits can be invaluable. For example, the Council of Parent Attorneys and Advocates (COPAA) is a national network of special education attorneys and advocates focused on students’ educational rights. COPAA’s mission is “to protect and enforce the legal and civil rights of students with disabilities and their families” and to promote excellence in advocacy [18†L50-L58]. COPAA provides training for parents and even an online directory to help you find a qualified special education advocate or attorney in your area [18†L51-L59]. Another major network is the National Disability Rights Network (NDRN), which coordinates Protection & Advocacy agencies in each state. These agencies (often named “Disability Rights [State]”) are federally mandated to offer legally-based advocacy for people with disabilities, including students. Collectively, the P&A network is the largest provider of legal advocacy services to people with disabilities in the U.S., with an office in every state and territory [18†L63-L71].
• Specialized Disability Organizations: Depending on your child’s needs, consider reaching out to groups focused on that disability. For instance, CHADD (Children and Adults with Attention-Deficit/Hyperactivity Disorder) is a leading national organization for ADHD – they provide resources on school accommodations and have local chapters [2†L101-L109]. The Autism Society and Autism Speaks offer toolkits for IEPs and support networks for families of autistic children. The Learning Disabilities Association of America (LDA) and Understood.org offer guidance for dyslexia, dyscalculia, and other learning differences. These organizations often have helplines or parent mentors who can share advice.
• Parent Support Groups and Communities: Connecting with other parents who have been through the process can provide emotional support and practical tips. Look for local parent support groups – some school districts have Special Education Parent-Teacher Associations (PTAs) or advisory committees. There are also many online communities. For example, the IEP/504 Support & Assistance group (a national Facebook group) brings together caregivers to share experiences and advice on dealing with school challenges [18†L75-L83]. Another community is the “Special Ed Mom Survival Guide” group, managed by an advocate, where parents discuss questions about IEPs and 504s and point each other to useful resources [18†L81-L88]. Parent-to-parent programs can match you with an experienced parent mentor – Parent to Parent USA is an organization that facilitates one-on-one matches for families seeking guidance and emotional support [18†L87-L93].
• Legal Aid and Pro Bono Services: If you need legal advice or representation and can’t afford a private attorney, look for legal aid organizations or law school clinics in your area that handle education cases. As mentioned, each state’s Protection & Advocacy agency (affiliated with NDRN) may assist at no cost. Some states have nonprofit law centers focused on special education. Additionally, COPAA’s directory can help find lawyers who sometimes take sliding scale or pro bono cases. Keep in mind that under IDEA, if you prevail in a due process hearing or court case, you may be entitled to have the school district pay your attorney fees – this can make it easier to find an attorney to take a strong case.
• Educational Advocates: These are professionals (not necessarily lawyers) who specialize in helping parents with IEPs/504s. They can attend meetings with you, review IEP documents, and advise on strategies. Some advocates have formal training (COPAA offers a Special Education Advocate Training program) or certification. When choosing an advocate, look for someone experienced and knowledgeable about special education law and your child’s type of needs [15†L33-L40]. An advocate can be especially useful if meetings have become contentious or if you feel overwhelmed by the process.
• Informational Resources: Equip yourself with knowledge. Websites like Wrightslaw (run by a special education attorney) offer a wealth of articles about IEP/504 rights, advocacy tactics, and case law updates. Wrightslaw also has a free newsletter The Special Ed Advocate that keeps parents informed of new developments [15†L19-L27]. Understood.org provides parent-friendly explanations of legal rights, school strategies, and has a community forum. The U.S. Department of Education’s website (and state education department sites) have guides on IDEA procedural safeguards and Section 504 FAQs [34†L9-L17]. By using these resources, you’ll become more confident in navigating the system.

In summary, don’t hesitate to reach out and build a support network. By learning from experts and peers, you’ll feel less alone and more empowered in advocating for your child.

8.9 Common Pitfalls and How to Avoid Them

Even well-intentioned parents can make missteps in the advocacy process that weaken their effectiveness. Here are some common pitfalls in IEP/504 advocacy and how to avoid them:

• Pitfall: Not viewing yourself as an equal member of the team. Some parents feel they must defer to teachers and experts entirely, assuming the “professionals know best.” In reality, parents are experts on their child and have unique insights.
  Avoidance Tip: Recognize your role is just as important as anyone else’s at the table. Don’t be intimidated into silence – your knowledge of your child’s strengths, challenges, and history is invaluable. Remember that while educators have expertise in education, you have expertise in your child. As one guide put it, parents are often “intuitively correct” about what their child needs, even if they lack formal training [25†L45-L53]. Trust your observations and speak up if something proposed doesn’t feel right.
• Pitfall: Failing to educate yourself on rights and processes. Special education law and procedures can seem overwhelming, but not knowing the basics can hurt your child’s case. For example, if you aren’t aware of your right to request an evaluation or the timeline the school must follow, you might accept unnecessary delays.
  Avoidance Tip: Take time to learn key provisions of IDEA and Section 504, and your child’s diagnosis. Read up on your child’s disability to understand how it affects learning, and familiarize yourself with the IEP/504 process. Many parents start out “ill-equipped” and assume the school will automatically do what’s best, only to realize later that they should have been more informed [25†L23-L32][25†L27-L34]. By learning your rights (for instance, knowing that any service denial must come with a written explanation, or that you can appeal decisions), you can advocate from a position of knowledge. Leverage the free workshops or materials from PTIs and advocacy websites to get up to speed. An informed parent is a powerful advocate.
• Pitfall: Poor documentation and communication trails. In the rush of school life, it’s easy to rely on informal conversations or to forget to save emails. However, without written records, misunderstandings can occur and promises may not be honored.
  Avoidance Tip: Document, document, document. Always follow up important discussions or decisions in writing, and keep those copies (emails, letters, meeting notes) organized. For instance, if a teacher verbally agrees to try a new reading intervention, send a thank-you email recapping that “starting Monday, Mrs. Smith will begin 30-minute daily reading intervention,” etc. This creates a record if plans falter. If you make a request and the school doesn’t respond, a written reminder can prompt action or serve as evidence if escalation is needed. Also, write down dates and summaries of incidents (like your child coming home frustrated, or noting lack of support on a particular day). These notes could be useful later to show patterns. As one expert notes, writing things down (in a journal or letters) is a key step to “protect your child’s interests” [22†L111-L119].
• Pitfall: Letting emotions take over. It’s natural to feel emotional when discussing your child’s difficulties – many parents experience anger, frustration, or sadness if they feel the school is not helping enough. But reacting with hostility or tears in a meeting may shift focus away from your child’s needs.
  Avoidance Tip: Prepare yourself to stay as calm and objective as possible in school meetings. If you feel too emotional, consider bringing a support person (a spouse, friend, advocate) who can step in or take notes while you collect yourself. It might help to script or practice what you want to say beforehand. During the meeting, if tension rises, breathe and refocus on problem-solving. Use facts and avoid personal attacks. Keeping your cool not only makes you more persuasive, it also models a collaborative spirit. As Wrightslaw aptly points out, a parent’s emotions can be their “Achilles’ heel” in advocacy [22†L96-L104].
• Pitfall: Accepting inadequate plans or vague promises. Sometimes in meetings, to avoid conflict, parents might nod along or accept an IEP/504 that they actually have reservations about. Or they might take the school’s word that “we’ll see how it goes” without clear specifics.
  Avoidance Tip: Be assertive in a polite way. If a proposed goal or service seems insufficient or unclear, ask questions and request specifics. For example, if an IEP says “Will improve reading,” ask “Can we specify by how much or what level of progress is expected in a year?” Ensure services are clearly documented (frequency, duration, setting). Don’t leave a meeting with only verbal assurances – get any agreed actions written into the plan or in the meeting notes. If you’re unsure about the plan, you have the right to pause and review (you don’t have to sign immediately). Holding the team to a high standard (as Endrew F. encourages) is advocating for your child’s benefit, not being “difficult.”
• Pitfall: Going it alone and burning out. Advocating can be exhausting, especially if you’re doing everything yourself. Some parents try to handle complex cases alone and may feel overwhelmed or isolated, which can lead to mistakes or giving up.
  Avoidance Tip: Seek support – whether moral support from other parents or professional support from advocates/attorneys for complicated issues. Even bringing a friend to a meeting just to have another set of ears can help. Practice self-care; taking care of your own stress levels will help you be a more effective advocate in the long run. Asking for help is not a sign of weakness; it’s a strategy to strengthen your advocacy.

8.10 Conclusion

Navigating IEPs and 504 plans can be challenging, but with the right preparation and support, parents can be powerful advocates for their children. Use effective strategies to communicate and negotiate, learn from success stories, ground yourself in the legal rights at play, lean on the many support resources out there, and avoid common mistakes. By doing so, you will help ensure your child receives the education and support they deserve – truly achieving the promise of an appropriate education for every student [9†L139-L146][37†L228-L236].