Impartial Hearing Decision

190760

FINDING OF FACT AND DECISION Case Number: Student’s Name: Hearing Requested By: Hearing Officer: ARCD: 11/5/2020 190760 Redacted Parents Martin J. Kehoe III, Esq.

Introduction

This document constitutes the Decision and Order of the undersigned, the duly designated Impartial Hearing Officer (THO) in an Impartial Hearing brought pursuant to the Individuals with Disabilities Education Act (IDEA) and the New York State Education Laws. The School District will be referred to as District, the parents as Parents and the student will be referred to as Student. This is a reimbursement case. A hearing was held February 4, 2020; March 25, 2020; April 28, 2020; April 29, 2020; and May 13, 2020.

Overview

I will briefly apply a three-prong analysis to this case, examining first whether the District met its burden to demonstrate the appropriateness of their program, second whether the Parents met their burden to demonstrate the appropriateness of the placement at Private School, and third whether equitable considerations favor the District or the Parents in this matter.

Parents’ Position

In the complaint notice, dated November 8, 2019, the Parents alleged that the District failed to provide a Free and Appropriate Public Education (FAPE) for the 2019-2020 school year. The Parents alleged that the District failed in their “Child Find” duties. The Parents are seeking tuition reimbursement for the Private School where they unilaterally placed the Student; payment for related services from December 3, 2019 through June 30, 2020; payment for the costs of private evaluations (Neuropsychological); compensatory education for related services from September 7, 2017 through June 30, 2018; Related Service Authorizations (RSAs) for related services from September 7, 2017 through June 30, 2018; and compensatory education for related services from September 5, 2019 through June 30, 2020'.

District’s Position

The District submitted evidence but did not call any witnesses. (T. 29).

Student History

The Student has diagnoses of specific learning disorder with impairment in reading (dyslexia); specific learning disorder with impairment in mathematics; attention deficit hyperactivity disorder (ADHD), combined type; generalized anxiety disorder; and major disparate depressive disorder. (Ex. G). On the Weschler Adult Intelligence Scaled — Fourth Edition (WAIS — IV) the Student had a verbal comprehension index score and a perceptual reasoning index score in the high average range; a general abilities index score in the high average range; a processing speed index score and a full scale score in the average range; _ and a working memory index score in the low average range (Ex. G). On the Weschler Individual Achievement Tests — Third Edition (WIAT-IID, the Student had average scores in numerical operations, spelling, sentence building, sentence combining, and math problem solving; low average range scores in math fluency — math multiplication, and math fluency — subtraction; and a borderline range score in math fluency ~ addition (Ex. G). On the Gray Oral Reading Tests (GORT — 5 Form A), the Student had scores in the average ' The claim for related services and/or compensatory services were abandoned during the hearing (T. p.35)

range in rate, accuracy, and fluency, and in the low average range in comprehension (Ex. G). The Student has weaknesses in executive functioning (Ex. G). The Clinical Psychologist testified about the Student’s diagnosis of specific learning disorder in reading and mathematics (T. 89). She described the Student’s problems: “Attention issues are ongoing in a combined type, where she has both the inattentive presentation now, as well as, ongoing impulsivity, which includes sensation seeking, trouble self-regulating, trouble resisting distractions, and working memory. . . so her anxiety has gone well below clinical. . . significantly distressing and interfering and co- morbid with that is a depressive mood or major depression. . .” (T. 90-91). She explained, “But I do see her as a complex case, with, you know, both the emotional disturbance, the attention executive functions, as well as, the third layer of learning disabilities” (T. 92). She testified that the Student’s anxiety and attentional issues are inter-related (T. 95).

Background of the Case

The hospital sent a letter, dated December 17, 2018, to confirm that the Student began attending the partial hospitalization program that day (Ex. L). The letter and documents were delivered to the CSE on November 21, 2019, by UPS (Ex. C). The Parents signed consent for evaluation on or about December 4, 2019 (Ex. 9). The District conducted a social history on December 4, 2019 (Ex. 7). The Teacher Report from the Private School, dated January 21, 2020, described the Student as one grade level below comprehension, reading fluency, and math; having symptoms related to ADHD; impairment in executive functioning; and depression and anxiety (Ex. F).

A CSE meeting was held for the Student on January 31, 2020 to determine the Student’s eligibility for special education services (Ex. 3, Ex. E). The District sent a letter of ineligibility for special education services to the Parents, dated January 31, 2020 (Ex. 1). The Clinical Psychologist who conducted the Student’s neuropsychological evaluation, wrote a letter dated February 6, 2020, recommending modifications and accommodations for the Student (Ex. N). The Parents wrote a letter to the CSE Chair, dated March 2, 2020, stating their disagreement with the CSE’s decision to deny eligibility for special education services to the Student. They wrote that the CSE did not review the evaluations they provided or consider the Student’s disabilities when making their decision. The Parents wrote that the CSE made their decision on the criteria of grades and excluded the Parents from meaningful participation in the CSE meeting. They stated the District had failed to identify the Student as a student with disabilities and provide her with the instruction and services to meet her needs (Ex. O). | The Parent testified by affidavit about the Student’s difficulties in school. She said the Student had a 504-accommodation plan in the District high school, but her academics and mental health declined and she developed depression, anxiety and school avoidance and was hospitalized during the 2018 — 2019 school year. The Student was admitted to a partial hospitalization program on December 17, 2018 and on January 19, 2019, the Parents enrolled the Student in a residential program for treatment which provided treatment and classes. She was discharged on March 1, 2019 after making significant progress and was enrolled in a partial hospitalization step down program. The Parent stated that a social worker at the hospital recommended that the Student be evaluated for an IEP and that she attend a specific District high school. The Parent testified that the CSE did not respond to the Parent’s letter requesting an IEP for the Student (Ex. H). After the Student was enrolled in the District high High school recommended by the social worker, the Student “begin “began to regress academically which caused her grades to drop. In addition, her problematic behaviors returned...” The Principal at the high school recommended she contact the CSE and the Parents sent a new letter, dated May 31, 2019, requesting an evaluation and an appropriate school (Ex. I). The Parent testified that she had the Student evaluated by the Clinical Psychologist and in the summer of 2019, the Parents sought the advice of an educational advocacy service to find an appropriate placement. The Parent stated that as the District had not responded to their request for special education services and a placement, they enrolled the Student in the Private School and notified the CSE (Ex. O). The Clinical Psychologist who evaluated the Student testified by affidavit, “[the Student] underachieves across the board for child of her reasoning ability. She is particularly inefficient, below Average in role retrieval of math facts, deleterious to her math achievement. Comprehension is below Average, taxed by relative dysfluency with text. Written output is below expectation for her reasoning ability...” (Ex. U). “Weaknesses in executive functioning continue to involve and exasperate the identified learning disorders and affect her broader behavioral functioning.” (Ex. U).

Recommendations

The Clinical Psychologist who evaluated the Student recommended “an accommodating and supportive academic environment. She needs individual support in a small, structured, therapeutic, and warm environment for college — bounced adolescents with ADHD and social/emotional issues who have not made expected progress in more traditional school settings.... She needs clear expectations, opportunity for academic advisement and multiple points in the day, and a school counseling center to support return to the classroom when she is overwhelmed, anxious, and sad.” (Ex. G). When asked about her recommendation, the Clinical Psychologist stated, “I’m looking for a school where the staff is well versed in a dialectical behavioral therapy, where they can interface with her treatment team outside of school, so that we can implement and transfer the skills that she’s picking up in her outpatient setting and transfer that over to her school setting where she spends 8 hours a day” (T. 94).

Analysis

A board of education may be required to reimburse parents for their expenditures for private education services obtained for a student by his or her parents, if the services offered by the board of education were inadequate or inappropriate, the services selected by the parents were appropriate, and equitable considerations support the parents’ claim. Florence County Sch. Dist. Four v. Carter. 510 U.S. 7 (1993); Sch. Comm. Of Burlington v. Dep't. of Educ., 471 U.S. 359, 369-70 (1985).

Prong I

- The purpose of IDEA is to provide students with a “basic floor of opportunity” of access to specialized instruction and related services that are individually designed to provide educational benefits. Board of Education, Hendrick Hudson CSD v. Rowley, 458 U.S. 176, 189-190, 102 S. Ct. 3034 (1982); Walczak v. Florida UFSD, 142 F.3d 119 (2nd Cir. 1998). Neither the IDEA, nor Article 89 of the New York State Education Law, requires a school district to provide special education and related services designed to maximize the potential of a disabled student. Nor do federal and state education laws require a school district to provide the best possible educational program and related services, or match those services requested by a parent. Application of a Child With a Disability (City School District of Buffalo), S.R.O. Decision 04-20 (2004). Rather, the goals and mandates of the IDEA and N.Y. Education Law are relatively modest: namely, to provide appropriate specialized education and related services sufficient for the disabled student to benefit from his/her education. Straube v. Florida UFSD, 801 F. Supp. 1164, 1175-1176 (S.D.N.Y. 1992); Moubry v. Independent School District, 9 F. Supp.2d 1086, 1104 (D. Minn. 1998) (citing Rowley) This straightforward obligation of the District is accompanied by the requirement to demonstrate the appropriateness of the program recommended by its CSE. (Application of a Child Suspected of Having a Disability, Appeal No. 93-9; Application of a Child with a Handicapping Condition, Appeal No. 92-7; Application of a Handicapped Child, 22 Ed Dept Rep 487 [1983]). To meet its burden, a board of education must show that its recommended program is reasonably calculated to confer educational benefits (Bd. of Educ. v. Rowley, 458 U.S. 176 [1982]). The recommended program must also be provided in the least restrictive environment (34 C.F.R. § 300.550[b]; 8 NYCRR200.6[a][1]). The District has submitted documents in this case presumably for the purpose of persuading the record that their actions at the CSE not to classify the Student in the 2019-2020 school year were justified. But they did not call any witnesses to defend their position. The Parents assert that District failed the Student programmatically and that there were procedural violations in the CSE process that effectively impacted parental participation, inter alia. The District bore the burden of both production and persuasion to establish that it provided the Student with a FAPE as weil as all other issues alleged in the DPC. N.Y. Educ. Law §4404(1)(c); See Application of a Student with a Disability, Appeal No. (“SRO No.”) 16- 028; 13-200; SRO No. 11-091; SRO No. 11-053; (all holding that, in cases that do not involve a unilateral placement, the burden of proof is on the District). See also L.O. v. New York City Dep't of Educ., No. 15-1019, 2016 WL 2942301 (2d Cir. May 20, 2016). In this case the District did not demonstrate that their program (or lack of a program) was appropriate for the Student. Rather I am left to speculate concerning the particulars of the review process, the rationale employed by the CSE members and the deliberations that may or may not have contributed to a final recommendation. The District failed to demonstrate a justification for their lack of classification.12 month 12:1:1 special class and specialized school is appropriate for the Student. They did not call any witnesses to justify the failure to create an IEP was appropriate and failed to demonstrate that they provided a FAPE. L.O. v. N.Y. City Dep't of Educ. , 822 F.3d 95, 111 2016 U.S. App. LEXIS 9239. {, therefore, rule for the Parent on Prong I.

Prong II

I must now consider whether the Parents met their burden of proving the appropriateness of the placement of the Student at the Private School. On Prong II, New York federal courts have held that parental placements are “subject to fewer constraints than that applied to the school authorities.” Schreiber v. FE. Ramapo Cent. Sch. Dist., 700 F. Supp 529 [S.D.N.Y. 2010] The Second Circuit has clearly stated: “,, [PJarents 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.” Gagliardo vy. Arlington Cent. Sch. Dist., 489 F.3d 105 [2d Cir. 2007] quoting Frank G. v. Bd. of Educ., 459 F.3d 356, 364 [2d Cir. 2006] Moreover, parents "may not be subject to the same mainstreaming requirements as a school board." Frank G. v. Bd. of Ed. of Hyde Park [2d Cir. 2006] quoting MS. v. Bd. of Ed. of City Sch. Dist. of Yonkers, 231 F.3d 96, 105 [2d Cir. 2000] citing Warren G. v. Cumberland County Sch. Dist, 190 F.3d 80, 84 [3d Cir. 1999] (holding that "the test for the parents’ private placement is that it is appropriate, and not that it is perfect”). The Clinical Director at the Private School testified that the Student is in outpatient therapy and is in a student support group at the Private School once a week, facilitated by a licensed clinical psychologist (T. 65). The Parent testified that the Student is doing well now and has comprehensive therapeutic support (T. 43). “She’s incredibly engaged. Academically, she’s doing so much better.” (T. 43) The Parent stated that the Student is receiving dialectical behavioral therapy outside of school and has daily meetings with counselors and therapists at school (T. 49), The Student made great progress in the Private School, with good grades, and positive teacher comments, indicating she was striving to succeed in school (Ex. P, Ex. Q). When asked if the required special education services in order to make progress, the Clinical Psychologist said “yes.” (T. 94). The Private School is for students who function below the levels expected based on their potential, and include students who have been diagnosed as learning disabled with or attention deficit disorder, or who may have struggled with adjustment difficulties, problems with peers, mild depression or anxiety (Ex. R). Students are assigned to an advisor who meets with the student at least three times each day and assists with punctuality and attendance, class assignments, academic expectations, problems with peers, and difficulties with teachers. The Private School psychologists collaborate with outside psychotherapists. The Private School has an average class size of under 10 (Ex. R). The Clinical Director testified that the Private School has five full-time psychologists on staff, three licensed doctoral level clinical or school psychologists, and one doctorate level student intern. Students have on-demand access to counseling through the counseling center. Students are able to join weekly student support groups facilitated by the school psychologists. Students have access to a full — time learning a specialist and the learning center. (Ex. S). The Clinical Director at the Private School described the Student’s program. The Student goes to the counseling center as needed for support, she participates in a weekly group for juniors focused on future planning and college readiness, she meets with her advisor three times a day to address executive functioning skills, the clinical team collaborates with her outpatient treatment team, the Student is in small classes with accommodations, is provided chunking of information, frequent breaks, previewing of material, reviewing and checking for understanding, access to 1:1 and small group support during study periods. The Student’s teachers and advisors meet every morning with clinicians and collaborate with the Student’s outpatient therapist and psychiatrist. (Ex. S). The Clinical Director testified that the Student “consistently attends school. She participates in classes. She achieves high grades. She developed meaningful connections with adults and peers... Teacher reports note as strong academics, maturity and thoughtfulness. She has become more engaged in the classroom. Advisors and clinicians note [the Student’s] advocacy for an receptiveness to help.” (Ex. 8). The Parent testified, “since attending [the Private School], {the Student] has made significant academic and emotional progress and is excited to go to school.” (Ex. O). Accordingly, I find that the placement provides educational instruction specially designed to meet the unique needs of the Student. Moreover, the Parents have established that such services as are necessary to permit the Student to benefit from instruction.

Prong OI

As a final point, a board of education may be required to reimburse parents for their expenditures for private educational services obtained for a student by his or her parents where equitable considerations support the parents’ claim (Florence County Sch. Dist. Four v. Carter, 510 U.S. 7 [1993]; Sch. Comm. of Burlington v. Dep't of Educ., 471 U.S. 359, 369-70 [1985]; R.E., 694 F.3d at 184-85; T.P., 554 F.3d at 252). In Burlington, the Court found that Congress intended retroactive reimbursement to parents by school officials as an available remedy in a proper case under the IDEA (471 U.S. at 370-71; see Gagliardo, 489 F.3d at 111; Cerra, 427 F.3d at 192). "Reimbursement merely requires [a district] to belatedly pay expenses that it should have paid all along and would have borne in the first instance" had it offered the student a FAPE (Burlington, 471 U.S. at 370-71; see 20 U.S.C. § 1412{a][10][C][ii]; 34 CFR 300.148). The burden of proof is on the school district during an impartial hearing, except that a parent seeking tuition reimbursement for a unilateral placement has the burden of proof regarding the appropriateness of such placement (Educ. Law § 4404[1][c]; see R.E., 694 F.3d at 184-85; M.P.G. v. New York City Dep't of Educ., 2010 WL 3398256, at 7 [S.D.N.Y. Aug. 27, 2010]). Tuition reimbursement may be reduced or denied if parents do not provide notice of the unilateral placement either at the most recent CSE meeting prior to removing the child from public school, or by written notice ten business days before such removal, "that they were rejecting the placement proposed by the public agency to provide a [FAPE] to their child, including stating their concerns and their intent to enroll their child in a private school at public expense." (20 U.S.C. § 612[a][10][C][iii][I] ; see 34 C.F.R. § 300.148[d]) This Statutory provision "serves the important purpose of giving the school system an opportunity, before the child is removed, to assemble a team, evaluate the child, devise an appropriate plan, and determine whether a [FAPE] can be provided in the public schools." (Greenland Sch. Dist. v. Amy N., 358 F.3d 150, 160 [1st Cir. 2004]) In a letter dated April 5, 2019, the Student’s Mother requested that the Student be evaluated for an IEP. The Parents sent a letter to the District, dated May 31, 2019, requesting that the Student be evaluated for placement in a non-public school, stating that her current program was not meeting the Student’s needs and she was regressing. (Ex. I). The Student’s psychologist and psychiatrist sent a letter to the CSE, dated July 16, 2019, stating the Student’s need for therapeutic support within school and outpatient treatment; writing that she “would benefit from attending a school with a strong therapeutic component in order to continue to assist her recovery.” (Ex. 2, Ex. G). The Parents sent a 10 day notice letter to the CSE Chair, dated August 20, 2019, describing their attempts to obtain a CSE meeting for the Student since April 5, 2019, and stating their intention to unilaterally place the Student in the Private School and seek tuition reimbursement (Ex. M). The Parents sent a letter to the CSE Chair, dated November 20, 2019, informing her that they were re-sending the Student’s private evaluations and other documents (Ex. B),. The Parent testified, “Had the [the District] issued an appropriate placement for the 2019 — 2020 school year, I would have placed my daughter in a [District] school. [The District] did not recommend a placement for the 2019 — 2020 school year.” (Ex. O). In this case I find that the Parents provided ample notice to the CSE and cooperated with the CSE.

Summary

In this case, the District did not provide the Student with a FAPE for the 2019-2020 school year. The District was already aware that during the 2018-2019 school year the Student had mental health problems causing her to be hospitalized and placed in a residential program. After returning to a District high school, the Student regressed academically and emotionally. In April and in May of 2019, the Parent asked the District to evaluate the Student and give her an appropriate placement. The District did not respond to the Parent’s request, and the Parent had the Student privately evaluated and enrolled her in a therapeutic private school. In the neuropsychological evaluation, the Student was diagnosed with learning disorders as well as ADHD, generalized anxiety disorder, and major depressive disorder, demonstrating the need for a program that would address her academic weaknesses and emotional disabilities. The Private School was appropriate for the Student and provided her with the emotional support and academic support she needed to learn. The Student made great progress in the private school, and I find that it was a program and placement that met her special education needs. I therefore, rule for the Parent. I also find that the Parent should receive reimbursement for the Independent Neuropsychological Evaluation, as the District failed to evaluate the Student in a timely manner, and in all areas of need.

It is therefore ORDERED

The District shall provide reimbursement/direct funding for the Private School and associated transportation for the 2019-2020 school year; and reimbursement for the Independent Neuropsychological Evaluation at market rate upon presentation of proper invoices. Dated: November 5, 2020 Marfirf J. Kehoe IIIfEsq. Impartial Hearing Officer

NOTICE OF RIGHT TO APPEAL

Within 40 days of the date of this decision, the parent and/or the Public School District has a right to appeal the decision to a State Review Officer (SRO) of the New York State Education Department under section 4404 of the Education Law and the Individuals with Disabilities Education Act. If either party plans to appeal the decision, a notice of intention to seek review shall be personally served upon the opposing party no later than 25 days after the date of the decision sought to be reviewed. An appealing party's request for review shall be personally served upon the opposing party within 40 days from the date of the decision sought to be reviewed. An appealing party shail file the notice of intention to seek review, notice of request for review, request for review, and proof of service with the Office of State Review of the State Education Department within two days after service of the request for review is complete. The rules of procedure for appeals before an SRO are found in Part 279 of the Regulations of the Commissioner of Education. A copy of the rules in Part 279 and model forms are available at http://www.sro.nysed.gov.

CERTIF ICATION

IMPARTIAL HEARING OFFICER In the Matter of: (Name of Student) Hearing Dates: 2/4/20; 3/26/20; 4/28/20; 4/29/20; 5/3/20 , Martin Kehoe , Impartial Hearing Officer in this matter | DO HEREBY CERTIFY that the attached Evidence and attached Index of Exhibits itemize the entire record before me in the above entitled matter as of this date. | FURTHER CERTIFY that the materials submitted herewith are either the original or true copy of the original documents submitted in this matter. VASE 11/04/2020 Signature of impartial Hearing Officer Date Signed Comments/Notes:

City of New York Department of Education Disclosure Exhibit Description of Exhibit Pages Date No. ] Letter of Ineligibility and Attendance Page 32 1/31/20 2 Letter from Drs. and 2 7/16/2019 3 Meeting Notice Committee on Special Education 3 12/30/2019 4 Present Levels of Performance and Individual Needs 4 Undated 5 Letter from Drs. and , MD 2 7/16/19 6 Neuropsychological Evaluation 11 6/24/20 7 Social History Evaluation 3 12/4/19 8 Notice for Psychological and Social History 2 11/4/19 Evaluations 9 Letters of Consent 2 12/4/20

PARENT EVIDENCE Student’s Name:CaseNumber; 190760 Date of Hearing: 05/03/2020 (useseparate sheet for each date of hearing) Enter Exhibit No. . ig Le Number DateDateDate Marked for ID” Brief Description of Exhibitof Pages | Offered Admitted Withdrawnseeattached Parent exhibits: marked with uppercase letters(A-Z); Joint Parent & Department of Education exhibits: marked with lowercase letters (a-z) nef itted, orwithdrawnon thedateindicatedabove. Hj) ZAL fj A ME pate: 11/04/2020(ignature) ~ ImpartialHearing Officer: March2020

IN THE MATTER OF THE IMPARTIAL HEARING

REQUESTED BY THE PARENTS OF

‘Case 190760

AGAINST

REGION HEARING DATE: April 28, 2020

EXHIBIT | DATE DOCUMENT #PAGES A 11/8/19 | HEARING REQUEST 9 B 11/20/19 | LETTER TO CSE RE: SUBMISSION OF DR. 1 EVALUATION Cc 11/21/19 | PROOF OF DELIVERY FOR LETTER TOCSERE: | 2 EVALUATION D 6/24/19 |PSYCHOLOGICAL EVALUATION BY DR. 11 E 12/30/19 | CSE MEETING NOTICE 4 F 1/21/20 |TEACHER REPORT FOR IEP 7 G 7/16/19 | LETTER IN SUPPOR FROM DR. 2 H 4/5/19 REQUEST FOR IEP EVALUATION 1 I 5/31/19 | FAPE LETTER 1 J 1/28/19 | PHYSICIAN NOTE FROM 3 K 4/15/19 DISCHARGE PLAN 4 L 12/17/18 | LETTER RE: PARTIAL 1 HOSPITALIZATION : M 8/20/19 |TEN DAY NOTICE 1 N 2/26/20 | LETTER FROM DR. 2 O 3/2/20 POST IEP REJECTION LETTER 6 P 2016-2020 | OFFICIAL TRANSCRIPT 2 Q 1/20/20 | SECOND QUARTER PROGRESS REPORT 9 R VARIOUS | FINANCIAL DOCUMENTS- FINANCIAL 15 AFFIDAVIT; PROOF OF PAYMENT; SCHOOL CONTRACT; SCHOOL SCHEDULE; SCHOOL INFORMATION; SCHOOL ATTENDANCE RECORD S 4/27/20 |AFFIDAVIT OF DR. 9 T 4/27/20 | AFFIDAVIT OF 4 U 5/12/20 | AFFIDAVIT OF DR. 8

IMPARTIALHEARINGOFFICE Pleasesubmitform and evidence to: IHOEvidence@schools.nyc.gov [a IMPARTIAL HEARING OFFICEREVIDENCE Student’s Name:Case Number: !90760 Date of Hearing: 05/03/2020 (useseparate sheet for each date of hearing) Enter Exhibit No. . wigs wsNo. of DateDateDateMarkedforID"BriefDescriptionofExhibitPagesOfferedAdmittedWithdrawn #1Parents closing brief 17 | 06/12/2020 | 06/12/2020 *impartial Hearing OfficerExhibits: marked with Roman numerals (i,Hi, fil...) 4 Icertifythattheevidencelistedherein.wapydimittédorwithdrawnonthedateindicatedabove. Impartial Hearing Officer: W Aerv (elgnature) pate: 11/04/2020 t= March2020