New York City Department of Education, Impartial Hearing Decision

FINDINGS OF FACT AND DECISION

Case Number: 173891

Student’s Name:

Date of Birth:

District:

Hearing Requested By: _ Parent

Dates of Hearing: June 29, 2018

October 1, 2018

April 4, 2019

May 31, 2019 Actual Record Close Date: June 18, 2019 Hearing Officer: Linda Agoston

NAMES AND TITLES OF PERSONS WHO APPEARED

JUNE 18, 2018

Attorney Parent

Department of Education Representative Department of Education

NAMES AND TITLES OF PERSONS WHO APPEARED

OCTOBER 1, 2018

Attorney Parent

Department of Education Representative Department of Education

NAMES AND TITLES OF PERSONS WHO APPEARED

APRIL 4, 2019

Attorney Parent

Department of Education Representative Department of Education

NAMES AND TITLES OF PERSONS WHO APPEARED

MAY 31, 2019

Advocate Parent

Parents

Director of Parent

Ph.D., via telephone at the Department of Department of Education Education Representative

On June 26, 2018, I was designated by the New York City Department of Education ("DOE") as impartial hearing officer, pursuant to the Individuals with Disabilities Education Act, ("IDEA") 20 U.S.C. §1415(b)(2) and Article 89 of the Education Law of the State of New York in the matter of (hereinafter ). . and the Parents through their attorney who initiated this hearing on June 26, 2018, and corrected their complaint on June 27, 2018. Hearings were held on June 29, 2018, October 1, 2018, April 4, 2019 and May 31, 2019. An Interim Order on Pendency was issued on July 2, 2018. I ordered that the Department of Education ("DOE") fund the placement at for the 2018-2019 school year and continue to provide related services through a related service authorization ("RSA") of individual counseling once per week for 30 minutes; individual occupational therapy ("OT") 3 times per week for 30 minutes per session; individual physical therapy ("PT") 3 times per week for 30 minutes per session; individual speech and language therapy ("SLT") 5 times per week for 30 minutes per session; school nurse services; a full-time individual health paraprofessional and a transportation paraprofessional and transportation as well as fund Applied Analysis ("ABA") Special Education Teacher Support Services ("SETSS") for 12 hours per week per the unappealed impartial hearing officer's decision dated July 18, 2017 (Exh. B at 3, 10, 11) and the Individualized Educational Program ("IEP") dated May 3, 2017 C at 12) The Parents seek prospective payment from the DOE of for tuition for 2018-2019 school year and that the DOE provide 12 hours of ABA per week after school and to provide RSAs for the 2018-2019 school year individual counseling once per week for 30 minutes; individual OT 3 times per week for 30 minutes per session; individual PT 3 times per week for 30 minutes per session; individual SLT 5 times per week for 30 minutes per session; school nurse services; a full-time individual health paraprofessional and __ transportation paraprofessional and transportation (Exh. at 6).

The hearing was requested by the Parent to challenge the February 28, 2018 review and recommendation of the and to obtain funding for a unilateral placement at (Tr. at 56). is a non for profit, private entity lacking State Education Department approval located in for children with special needs (Exh. S). The total amount of tuition for a 12-month program was (Exh. R at 5).

The parties moved to extend the compliance date in light of anticipated testimony, the scheduling of witnesses and submission of evidence and closing memoranda. In considering the requests I weighed the cumulative impact of the relevant factors and found that the need of the parties for additional time to prepare and present their positions in accordance with the requirements of due process was greater than any delay in the resolution of this matter. Accordingly, the joint requests for extensions of the compliance dates were granted and the required documentation provided to the parties (Tr. at 26-31;128; Exhs. /-X). The parents' representative submitted her post-hearing statement on June 18, 2019 and the district representative declined to submit a post-hearing statement. The actual record close date is June 18, 2019 and the decision due date is July 1, 2019.

Appended to the record are the names of the persons who appeared at the hearing and the documents admitted into evidence.

BACKGROUND

isa old girl who is attending , a nonsectarian, not-for-profit special education school with 3 programs: a that is approved by New York State to provide education to students with disabilities, an elementary school program and a high school program (Tr. at 59). . attended the for the 2018-2019 school year (Id.). . was diagnosed with which was removed after and was diagnosed with (Exh. 8. at 1) and she received (Exh. E at 2).

A Developmental Educational Report was conducted on . on November 24, 2015, when she was a (Exh. 8 at 5). The evaluator used the Developmental Assessment of Young noted that > " (Exh. 8 at 2). The indicated that . had a recommended support for . by a "to guide the teacher and the paraprofessional in "(Exh. 8 at 5).

A Teacher Report was conducted on February 8, 2018, for . when she was . The Teacher Report indicated that . had The Teacher reported that . required one-on-one ("1:1) teaching to acquire new skills and methodology in school and at to continue the progress since she entered the school in 2016 (Exh. K at 1). The Teacher indicated because of the diagnosis of that . required close monitoring of must be supervised so that she and that . wore a (Exh.K at 3) and that she was health paraprofessional at all times as

A Student Progress Report for SLT was conducted on February 12, 2018, for . and the reporter noted that . was attending and had received 1:1 SLT 5 times per week and that

A Student Progress Report for OT was conducted during at some point after September 12, 2017, for . and the OT provider noted that . presented "with delays in the areas of

A Student Progress Report for PT was conducted on February 12, 2018, for and the reporter noted that . was attending and had received 1:1PT 3 times per week for 30 minutes per session and that . required continued PT for the same frequency and duration given her need of (Exh. M at 3).

A Counseling Progress Report for . was conducted on February 16, 2018, for . and the provider noted that . presented and received counseling once per week for 30 minutes

On February 28, 2018, the met and classified . with Other Health Impairment and recommended that she be placed in special class with a in ina class with a staff to student ratio of class with related services of individual OT twice per week for 30 sessions; individual counseling once per week for 30 minutes; individual PT 3 times per week for 30 minutes per session; individual SLT 5 times per week for 30 minutes per session; a school nurse service as needed; a full-time health paraprofessional, a transportation paraprofessional and SETSS-ABA services 12 times per week for 60 minutes per session (Exhs. | at 25;F at 13).

On August 10, 2018, the amendment to the JEP removed the transportation paraprofessional per Parent's verbal agreement (Exh. 10 at 1) and the February 28, 2018, IEP was amended to remove the transportation paraprofessional (Exhs. 11 at 25;G at 13).

The Prior Written Notice dated September 10, 2018, indicated that . was eligible for special education service and was recommended to be placed in a NYC DOE Specialized School in a special class with a staffing ratio of with adaptive physical education and related services of individual OT, PT, SLT, counseling, school nurse services, SETSS-ABA services and a health paraprofessional for a 12-month school year (Exh. 14 at 1).

On June 27, 2018, the Parents requested prospective payment for the tuition at , costs, related services, and transportation at for the 2018-2019 school year (Exh. E at 1). The Parents asserted that the DOE failed to provide a free and appropriate public education ("FAPE") in the least restrictive environment ("LRE") as the February 28, 2018 IEP was defective for the following reasons: (1) the IEP was not reasonably calculated to enable . to progress; (2) the IEP did not include a (3) there was no programmatic provision of ABA as the specific methodology for classroom instruction; of with all students classified as autistic was not appropriate. The Parents argued that the proposed classroom teacher did not use given s inability to transition and walk for a (Exh. E at 2-4). The Parents maintained that the placement at was appropriate and that the equities favored them and requested a finding that the DOE failed to a FAPE for the 2018-2019 school year and parents requested an order to fund the tuition at in the amount of for a 12-month program and to fund the related services and 12 hours of ABA per week after school (Tr. at 119); and requested an order for RSAs for the parents for related services (Tr. at 118;Exh. E at 6).

THE DISTRICT’S CASE

The district's representative did not submit any witnesses to support its position that a FAPE was offered for the 2018-2019 school year, but rested on the evidence (Tr. at AO).

THE PARENTS' CASE

The Parents' case as presented in the testimony of .'s mother and the Director of ; testified that she was the Director of the program at and that she had a Master's degree in education and special education and a doctorate in clinical psychology and worked in both general and special education for more than and that she was a NYS certified special education elementary teacher (Tr. at 57;60). She recalled that had programs: an NYS approved program, a and a private high school program (Tr. at 59). She described . as a student with complex as well as and cognitive challenges and that . was placed in the with a population of — and placed in a class of (Tr. at 100). She stated that .'s head teacher was a NYS certified teacher and .'s teaching assistant was also a NYS certified teacher and that the class had as well as a (Tr. at 96). She stated that the staff developed goals to . and opined that progressed in her ability to understand and that . greatly progressed socially as (Tr. at 97). She opined required a BIP and the lack of a BIP rendered the IEP defective as she required large amount of interventions (Tr. at 63). She stressed that . received her related services of SLT 5 times per week; OT and PT 3 times per week, and counseling once per week through RSAs at and that the all the related service providers and paraprofessionals worked with the staff to enable . to acquire the facilitation of language and that . was mainstreamed for school, (Tr. at 77-78). She stated that . was placed in a so that she could receive individual discrete from the special education staff and that . could generalized skills from different teachers (Tr. at 81). She stated that . was working on (Tr. at 80).

to at and the at school coordinated with the provider at so that the school program matched the program to ensure that . reduced (Tr. at 83). noted that the was located in a large floor with a very classroom of children in each class (Tr. at 100). She explained the following curricula used in .'s class included: so that could learn to request a (Tr. at 76-77). She explained that there were periods so that . could acquire (Tr. at 79). She stated that the staff trained the related service providers to ensure that . could (Exh. T; Tr. at 87) and that the OT provider worked on (Tr. at 88). She recalled that . never received her related services during her mainstreaming and that that . used iPads, and the smart board to generalize skills (Tr. at 79-80). She stated that . received find (Tr. at 84). She opined that . required 12 hours of after school ABA as she required direct teaching to generalized skills at (Tr. at 101).

The Parent testified regarding her daughter's educational history and noted that she participated in the IEP meeting for the 2018-2019 school year on the February 28, 2018, and recalled that there was no discussion of goals and no discussion of “s need for instruction (Tr. at 107). She stressed that there was no discussion of a FBA and BIP to address Ss negative and that there was no discussion of the 12 hours weekly of ABA in the after-school program (Tr. at 109). She opined that her daughter progressed in the 2018-2019 school year and that she was learning to (Tr. at 104). She stated that her daughter spoke with her family and was able to with the her ABA provider in the after-school program (Tr. at 105). She stated that the transportation paraprofessional was removed from the IEP because her daughter would not let the paraprofessional release her from the bus restraints, and that her daughter's improved so that she was able to remain in the bus without a_ transportation paraprofessional (Tr. at 106). She recalled that she told the team that the afterschool program was an integral part of her daughter's educational program and that the February 2018 team merely recycled the prior school year's IPE (Tr. at 109). She stated that she visited the proposed school and recalled that the and that her daughter would not be able to (Tr. at 114). She recalled that her attorney wrote to the to convey her concerns (Exh. Q) and that there was no response (Tr. at 116). She opined that her daughter progressed at during the 2018-2019 school year (Tr. at 116), and that the reinforced skills learned at school (Tr. at 117) and that her daughter (Tr. at 118). She stated she signed the enrollment contract for the 2018-2019 school year (Exh. R) and that based on her income (Exh. U) for a that she could not afford the tuition (Tr. at 119).

FINDINGS OF FACT AND CONCLUSIONS OF LAW

Under IDEA, New York State law and both the federal and State regulations, the right to a FAPE is guaranteed. There is no obligation on the part of the school district to provide the best education for the Student but that education must be appropriate so that there is an opportunity for the student to make progress in his education. States receiving federal funds are required to provide "all children with disabilities" a "free and appropriate public education" (20 U.S.C. Section 1400[d][1][A]). (Gagliardo v. Arlington Cent. Sch. Dist., 489 F.3d 105, 122 [2d. Cir. 2007]). FAPE consists of specialized education and related services designed to meet a student’s unique need, provided in conformity with a comprehensive written IEP (34 C.F.R. Section 300.13). To meet its burden of showing that it had offered to provide a FAPE to a student, the board of education must show (a) that it complied with the procedural requirements set forth in the IDEA, and (b) that the IEP developed by its through the IDEA's procedures is reasonably calculated to enable the student to receive educational benefits (Bd. of Educ. v. Rowley, 458 U.S. 176, 206, 207 [1982]). As for the program itself, the Second Circuit has observed that “for an IEP to be reasonably calculated to enable the child to receive educational benefits, it must be likely to produce progress, not regression" (Weixel v. Bd. of Educ., 287 F.3d 138, 151 [2d Cir. 2002], quoting M.S. ex rel. SS. V. Bd. of Educ. of the City Sch. Dist. of the City of Yonkers, 231 F.3d 96 at 103 (2d Cir. 2000); see Walczak v. Florida Union Free Sch. Dist., 142 F.3d 119 at 130 (2d Cir. 1998). This progress, however, must be meaningful; 1.e., more than mere trivial advancement (/d. at 130). The student's recommended program must also be provided in the least restrictive environment (20 U.S.C. § 1412[a][S][A]; 34 C.F.R. § 300.550[b]; 8 NYCRR 200.6[a][1]).

For tuition reimbursement cases a board of education may be required to pay for educational services obtained for a child by the child’s parent, if the services offered by the board of education were inadequate or inappropriate, the services selected by the parent were appropriate, and equitable considerations support the parent’s claim. (School Committee of the Town of Burlington v. Dept. Education, Massachusetts, 471 U.S. 359 [1985]; Florence County School District Four et al. v. Carter by Carter, 510 U.S. 7 [1993]; see also, Frank G. and Dianne G. v. Bd. of Educ. of Hyde Park, 459 F.3d 356 [2d Cir. 2006] cert denied, Board of Educ. of Hyde Park Cent. School Dist. v. Frank G., 2007 WL 2982269 [Oct. 15, 2007]). The burden of persuasion in an administrative hearing challenging the appropriateness of an IEP is on the Department of Education. N.Y. Educ. Law §4404[1 ][c].

I find the DOE representative presented no witnesses and did not dispute any claims of the Parents that FAPE was not offered for the 2018-2019 school year. The parents' attorney asserted that "the DOE rested on the evidence, which does not support a claim that the 2018-2019 IEP was adequate or that the proposed school was appropriate" (Exh. X7 at 3). I find that without a DOE witness testimony to explain how .'s deficits were addressed within the IEP and other DOE documents as well as to explain the 's rationale in recommending the disputed program, the DOE was unable to meet their burden. The SRO has found that allegations that are left unchallenged are deemed as true. (See Application of a Student with a Disability, Appeal No. 01-044). I find the evidence in the record is consistent with the allegations and I find that the DOE could not establish Prong | based only on their evidence.

It is the DOE’s burden to establish that the recommended program was supported by sufficient evaluative material (8 NYCRR 200.4[b][4][5][6]). The parents’ attorney asserted the program did not provide . with sufficient support. She argued that the recommended program of did not provide individual instruction and that . required the constant prompting and attention of an adult and the IEP failed to provide appropriate goals and did not include that ABA and 1:1 discrete trial that required to be educated (Exh. E at 3), and failed to provide appropriate FBA/BIP (Exh. E at 2) and failed to recommend ABA at school or at as recommended by .'S private evaluation and failed to recommend an appropriate placement (Exh. E at 5). The Parents asserted that the physical disability prevented . from to the located in another building (Exh. E at 4) at the proposed placement and that the related services were provided in a small room in the proposed placement and that . was highly distractible and required with the related service providers (Tr. at E at 5).

Under the IDEA, if a procedural violation is alleged, an administrative officer may find that a student did not receive a FAPE only if the procedural inadequacies (a) impeded the student's right to a FAPE, (b) significantly impeded the parents' opportunity to participate in the decision-making process regarding the provision of a FAPE to the student, or (c) caused a deprivation of educational benefits (20 U.S.C. § 1415[f][3][E] [11]; 34 C.F.R. § 300.513[a][2]; 8 NYCRR 200.5[j][4][ii]).

I find that the Parents were never provided with any explanations of why the district refused to provide . with a more specialized program that included ABA. Moreover, the DOE had documentation of s continued, significant speech and needs at the time of the meeting and I find that the was on notice of the in the Teacher Report, the SLT, OT and PT Reports (Exh. K at 4; L at 3; N at 2; M at 3) and the need to monitor her (id.). I find that the team was aware of her to by the Teacher and Counseling Progress Reports (Exhs. K at 4; 4 at 1). I find that the DAYC-2 and the Vineland II indicated that . "scored between in all developmental areas" (Exh. 8 at 2). The Vineland II report indicated that . had a 75% delay in Adaptive and she functioned at the age of in personal daily living skills (Exh. 8 at 3). The Vineland II report indicated that functioned at the age of in daily (Exh. 8 at 5). I find that the recommended support to (Id.). I find that the February 28, 2018 IEP failed to consider .'S private evaluation and failed to consider the recommendations for ABA in and out of school. I find the was aware that . exhibited a pattern of interfering of (Exh. K at 4) and I find that . required a more supportive program than the was willing to provide.

The Parents’ attorney stated the did not consider the Parent in developing the IEP nor did the did not involve the Parent in the development of the goals and did not consider s need for instruction and asserted that the IEP was not reasonably calculated to enable . to make progress (Exh. X7 at 3). I agree.

I find that the IEP team ignored the Parent's concerns at the February 28, 2018 IEP meeting for a placement with ABA therapy in school and at- supplemental ABA. I credit the Parent's testimony that she told the team members that her daughter required ABA to and I find that the team ignored the Parent's request for more support which significantly impeded the Parent's opportunity to participate in the decision making process. I find the program recommended was made in contradiction of the Parent and recommendations for ABA in school and at caused a deprivation of educational benefits.

The parents' attorney asserted that the February 28, 2018 IEP was inadequate because the goals failed to address s deficits. The parents' attorney asserted that there was the goals were (Exh. E at 3). agree and find that the goals did not promote the acquisition of skills. I further find that the IEP benchmarks did not include sufficient specificity and I find that the goals were vague and were insufficient to address

The parents' attorney asserted that the lack of an FBA or BIP rendered the IEP defective as . had a history of and required a large amount of support (Exh. E at 2). I find the FBA must provide a baseline of the of the day per 8 N.Y.C.R.R. § 200.22[a][2-3]. I credit the testimony of regarding the deficiencies of the February 28, 2018 IEP because it failed to include a FBA and BIP (Tr. at 63) and I credit her testimony that . required a FBA and BIP to address her and I find that the IEP failed to sufficient support to address |S

Accordingly I find that FAPE was not offered for the 2018-2019 school year and the Parents prevailed on the Prong 1.

The Parents have the burden to prove that the services they obtained for . are appropriate to his needs. The fact that the facility selected by the parent to provide the educational services to the child is not approved as a school for children with disabilities is not dispositive of the parents’ claim for tuition reimbursement (Florence County School District Four v. Carter by Carter, 114 S.Ct. 361 [1993]). The Parents must prove that . will receive an appropriate educational benefit from the program at the non-public school, and the parents offered substantial evidence to meet this burden. The Parent must prove that the student will receive an appropriate educational benefit from the program at Setona. The Second Circuit framed the legal standard for the second prong in Frank G. v. Board of Education, 459 F.3d 356 (2d Cir. 2006) and Gagliardo v. Arlington Central School District, 489 F.3d 105 (2d Cir. 2007). Under Frank G. the Court held that "to qualify for reimbursement under the IDEA, Parents need not show that a private placement furnishes every special service necessary to maximize their child’s potential. They need only demonstrate that the placement provides educational instruction specially designed to meet the unique needs of a handicapped child, supported by such services as are necessary to permit the child to benefit from instruction."

I find that the testimony adduced at the hearing demonstrated that .'S placement at the in very and enabled . to be . I credit the testimony of the Director and find the students in 's class were (Tr. at 73) and that the school provided (Exh. T) and that the social skills program led by the school psychologist provided (Tr. at 95-96). I find that . had movements . I credit the Director's testimony and find that . progressed in her (Tr. at 97). I find that her communication improved as she was now able to (Tr. at 76-77). The uncontested testimony established that .'s Issues were addressed by the use of ABA programs and individual discrete trial teaching and I find that progressed in (Tr. at 793117), and I find that . was now able to identity objects could now count to 69 (Tr. at 99).

I find the testimony from Director persuasive that the special education supports of ABA instruction along with the curricula of FACES, and ABLSS addressed her academic goals. I find the daily data collection and plans addressed .'S interfering . I find that socials skills were worked on her class by the school psychologist. I find the of smart boards and iPads addressed .'s sensory needs based on her . I find the ; teachers and related service providers enabled . to generalize skills and I find the movement addressed her distraction issues and her interfering . I find that . progressed in ; and her ability to attend. I also find that offered opportunities for interaction with non-disabled peers and was the . I further credit the Director's testimony and find that . required both the ABA program and the ABA program to to progress .

Therefore, I find the was an appropriate placement. Based on the foregoing, I find the parent satisfied the Prong 2.

The third prong of the test for tuition reimbursement is whether the equities favor the Parents’ position. I find the testimony adduced at the hearing established that the Parent cooperated with the district. I find the Parent established that she was unable to pay to the tuition by her uncontested testimony. I find that Parents who have satisfied each of the Burlington factors. have a right to retroactive direct tuition payment relief (Mr. and MM.V.. A ex. rel D.A v. New York City Dep't of Educ., 769 F. Supp. 2d 403, 427-429 (S.D.N.Y. 2011). I find that the Parent provided detailed and uncontradicted information as to her lack of financial resources to pay the tuition. I credit the Parent's testimony and I find that the Parent lacked the financial resources to pay the tuition for the 2018-2019 school year. I find the parents meet the Connors criteria for prospective funding for the cost of the 2018-2019 tuition school and the parent is entitled to direct retroactive payment. "Once the Burlington prerequisites relative to a non-approved private school are met, and a parent shows that his or her financial circumstances eliminate the opportunity for unilateral placement in the non-approved school, the public school must pay the cost of the private placement immediately" (Connor v. Mills, 34 F.Supp.2d 795 at 805-806, 132 Ed. Law Rep. 767 (N.D.N.Y)).

Order

It is ordered that the DOE provide prospective payment of for the tuition at for the 2018-2019 school year upon proof of attendance within 30 days of the submission of proof of attendance. It is further ordered that the DOE provide 12 hours of ABA per week for the after-school program for the 2018-2019 school year and provide RSAs for the 2018-2019 school year for individual counseling once per week for 30 minutes; individual OT 3 times per week for 30 minutes per session; individual PT 3 times per week for 30 minutes per session; individual SLT 5 times per week for 30 minutes per session; school nurse services; a full-time individual health paraprofessional and transportation paraprofessional and transportation.

LINDA AGOSTON, ESQ.

Impartial Hearing Officer

Dated: June 25, 2019

PLEASE TAKE NOTICE

The Parents and/or the New York City Department of Education has a right to obtain a review of this decision by a State Review Officer of the New York State Education Department under Part 200.5(k) of the Regulations of the Commissioner of Education, Section 4404 of the Education Law, and the Individuals with Disabilities Education Act.

Directions and forms can be found on the Office of State Review website:

http://www.sro.nysed.gov/RevisedRegulationsOverview. html

DOCUMENTATION ENTERED INTO THE RECORD ON JUNE 29, 2018

A. Impartial Hearing Request, 6/29/18, 8 pp. Parent B Findings of Fact and Decision, 7/18/17, 13 pp.

Parent

C. IEP, 5/3/17, 17 pp. Parent

D. IEP, 8/31/16, 17 pp. Parent

DOCUMENTATION ENTERED INTO THE RECORD ON OCTOBER 1, 2018

I Decision on extension, 8/1/18, 1 p. THO

I Decision on extension, 10/1/18, 1 p. THO

DOCUMENTATION ENTERED INTO THE RECORD ON APRIL 4, 2019

I Decision on extension, 8/1/18, 1 p. THO

I Decision on extension, 10/1/18, 1 p. THO

IT Decision on extension, 10/30/18, 1 p. THO

IV Decision on extension, 11/30/18, 1 p. THO

V Decision on extension, 12/18/18, 1 p. THO

VI Decision on extension, 1/30/19, 1 p. [HO

VI Decision on extension, 3/1/19, 1 p. [HO

VIIT Decision on extension, 4/1/19, 1 p. [HO

IX Decision on extension, 4/4/19, Ip. [HO

DOCUMENTATION ENTERED INTO THE RECORD ON MAY 31, 2019

Impartial hearing request corrected, 6/27/18, 9 pp.

Parent

“ATROVOAZOAM-

IEP, 8/10/18, 18 pp. Parent

Prior written notice, 3/14/18, 3 pp. Parent

School location letter, 6/8/18, 1 p. Parent

Prior written notice, 8/10/18, 3 pp. Parent

Teacher's report, 2/8/18, 5 pp. Parent

Speech-language report, 2/12/18, 4 pp. Parent

Physical therapy report, 2/12/18, 3 pp. Parent

Occupational therapy report, 9/12/17, 3 pp. Parent

ABA report, undated, 5 pp. Parent

Correspondence to the , 6/6/18, 2 pp. Parent

Correspondence to , 6/22/18, 4 pp. Parent

Enrollment contract, 7/1/18, 5 pp. Parent

Description of program, undated, 4 pp. Parent

Class schedule and profile, 2018-2019, 5 pp. Parent

Gel!

Tax return, 2018, 1 p. Parent

IEP, 2/28/18, 32 pp. District

Prior written notice and school location letter, 3/14/18 and 6/8/18, 7 pp. District

Student annual progress report, 2/8/18, 4 pp. District

OFnMfWTeH

Counseling progress report, 2/16/18, 2 pp. District

Withdrawn

Withdrawn

Withdrawn

Developmental education report, 11/24/15, 8 pp. District

Letter requesting removal of bus paraprofessional, 8/9/18, 1 p. District

Letter requesting waiver to eliminate transportation paraprofessional from the IEP, 8/10/18, 1 p. District

Amended IEP, 8/10/18, 32 pp. District

Withdrawn

Withdrawn

Prior written notice (notice of recommendation),8/10/18, 5 pp. District

Decision on extension, 8/1/18, 1 p. IHO

Decision on extension, 10/1/18, 1 p. IHO IT Decision on extension, 10/30/18, 1 p. IHO IV Decision on extension, 11/30/18, 1 p. IHO

Decision on extension, 12/18/18, 1 p. IHO VI Decision on extension, 1/30/19, 1 p. IHO VI Decision on extension, 3/1/19, 1 p. IHO VIIT Decision on extension, 4/1/19, 1 p. IHO IX Decision on extension, 4/4/19, Ip. IHO Decision on extension, 5/31/19, Ip. IHO

POST HEARING SUBMISSION

XT Parents' Closing Brief, 6/18/19, 15 pp. THO