New York City Department of Education, Impartial Hearing Decision

FINDINGS OF FACT AND DECISION

NAMES AND TITLES OF PERSONS WHO APPEARED

JANUARY 5, 2022

For the Student:

[REDACTED] Parent Attorney

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

NAMES AND TITLES OF PERSONS WHO APPEARED

FEBRUARY 17, 2022

For the Student:

[REDACTED] Parent Attorney

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

NAMES AND TITLES OF PERSONS WHO APPEARED

MARCH 29, 2022

For the Student:

[REDACTED] Parent Attorney

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

NAMES AND TITLES OF PERSONS WHO APPEARED

APRIL 25, 2022

For the Student:

[REDACTED] Parent Attorney

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

NAMES AND TITLES OF PERSONS WHO APPEARED

MAY 26, 2022

For the Student:

[REDACTED] Parent Attorney

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

NAMES AND TITLES OF PERSONS WHO APPEARED

JULY 18, 2022

For the Student:

[REDACTED] Parent Attorney

[REDACTED] Parent/Mother

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

NAMES AND TITLES OF PERSONS WHO APPEARED

AUGUST 17, 2022

For the Student:

[REDACTED] Parent Attorney

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

NAMES AND TITLES OF PERSONS WHO APPEARED

OCTOBER 20, 2022

For the Student:

[REDACTED] Parent Attorney

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

NAMES AND TITLES OF PERSONS WHO APPEARED

NOVEMBER 21, 2022

For the Student:

[REDACTED] Parent Attorney

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

NAMES AND TITLES OF PERSONS WHO APPEARED

NOVEMBER 28, 2022

For the Student:

[REDACTED] Parent Attorney

[REDACTED] Parent/Mother

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

[REDACTED] Teacher

NAMES AND TITLES OF PERSONS WHO APPEARED

JANUARY 10, 2023

[REDACTED] Parent Attorney

[REDACTED] Parent/Mother

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

[REDACTED] School Psychologist

NAMES AND TITLES OF PERSONS WHO APPEARED

FEBRUARY 7, 2023

For the Student:

[REDACTED] Parent Attorney

[REDACTED] Parent/Mother

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

[REDACTED] School Principal, [REDACTED]

[REDACTED] Assistant Principal, [REDACTED]

NAMES AND TITLES OF PERSONS WHO APPEARED

MARCH 16, 2023

For the Student:

[REDACTED] Parent Attorney

[REDACTED] Parent/Mother

[REDACTED] Principal, [REDACTED]

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

NAMES AND TITLES OF PERSONS WHO APPEARED

APRIL 20, 2023

For the Student:

[REDACTED] Parent Attorney

For the Department of Education:

[REDACTED] DOE District Representative, CSE [REDACTED]

INTRODUCTION

On December 13, 2021, New York City Department of Education (DOE) appointed me to act as the impartial hearing officer (IHO) in a case brought under the Federal Individuals with Disabilities Education Act (IDEA) [20 USC §1415(f)(3)] ("IDEA") by the parent (Parent) of [REDACTED] ([REDACTED]) for the school year 2019/20. The Parent requested the hearing by filing an impartial hearing request with the DOE on or about May 29, 2021. The DPC is carried under New York City ("NYC") Case No: 208546. The impartial hearing was held over a series of dates to complete the record on April 20, 2023. The timelines have also been extended to allow the parties opportunity to fully prepare, secure witnesses and obtain transcripts. The record officially closed on June 1, 2023. A list of persons who appeared at the hearing and the documents entered into evidence is annexed hereto.

BACKGROUND AND POSITIONS OF THE PARTIES

At the start of the 2019/20 school year, [REDACTED] was [REDACTED]-year-old young man classified by the Department of Education (DOE) as a student with "Autism" (Exhibit 1). He was diagnosed with Pervasive Developmental Disorder around the age of two and was later diagnosed with both autism spectrum disorder, schizoaffective disorder, social anxiety disorder, and ADHD (Exhibit R). Historically, [REDACTED] attended a series of educational placements, including district placements, home schooling and unilateral private placements. He began attending the [REDACTED] school during the 2018/19 school year as a tenth-grader. On January 14, 2019 the DOE held an IEP meeting and for the 2019/20 school year recommended a District 75 Special Class 8:1:1 in all subjects, along with related services of Counseling (1x40, 1:1 and 1x40, group of 2), Occupational Therapy (1x40, 1:1 and 1x40, group of 2), Speech Language Therapy (1x40, 1:1 and 1x40, group of 2) and Parent Counseling and Training (4 times per year – 60 minutes) on a 12-month-basis (Exhibit 1). The ensuing recommended placement was [REDACTED] (Exhibit 4) – a placement that had been deemed inappropriate by Parent upon visiting same for the 2018/19 school year and further found inappropriate via a hearing for the 2018/19 school year (Exhibit N). Thereafter, Parent provided their notice of intent to re-enroll [REDACTED] at [REDACTED] for the 2019/20 school year (Exhibit B) and subsequently filed a DPC seeking funding/prospective funding/reimbursement for tuition alleging the DOE failed both procedurally and substantively to offer [REDACTED] a FAPE for the 2019/20 school year in violation of the IDEA and enumerated a series of allegations (Exhibit A).

In an effort to support their position, the parents presented two witnesses: [REDACTED], [REDACTED]'s mother and [REDACTED], Principal, [REDACTED], along with a documentary exhibit package consisting of twenty pieces of evidence (Exhibits A-T).

The DOE asserted that a FAPE was provided to [REDACTED] for the 2019/20 school year (T @ 42-46) in that the IEP in place provided a very highly, very structured, specialized educational program, that transition goals were created and that the recommended placement would be able to provide the special class and the related services as per the mandates of the January 14, 2019 IEP.

In an effort to support their position, the DOE presented four witnesses: [REDACTED], Special Education Teacher participant at the IEP meeting, [REDACTED], School Psychologist participant at the IEP meeting, [REDACTED], School Principal at [REDACTED] and [REDACTED], Assistant Principal at [REDACTED], along with a documentary exhibit package consisting of ten pieces of evidence (Exhibits 1-10).

FINDINGS OF FACT AND DECISION

The Individuals with Disabilities Education Act (IDEA) (20 U.S.C. §§ 1400-1482) was enacted with the primary purpose to ensure that students with disabilities have available to them a free and appropriate public education (FAPE) (20 U.S.C. § 1400[d][1][A]; see Schaffer v. Weast, 126 S. Ct. 528, 531 [2005]; Bd. of Educ. v. Rowley, 458 S. Ct. 176, 179-81, 200-01 [1982]; Frank G. v. Bd. of Educ., 459 F.3d 356, 371 [2d Cir. 2006]). It is clear that the legislative intent of 20 US Code Section 1412 of the IDEA is to provide a FAPE to all children with disabilities so that these individuals may ultimately lead productive independent lives as adults, to the maximum extent possible (20 U.S.C. Sx 1400[d][1][A]; see Mrs. W v. Tirozzi, 832 F.2d 748 [2nd Cir. 1987]. A FAPE includes special education and related services designed to meet the student's unique needs, provided in conformity with a comprehensive written IEP (20 U.S.C. § 1401[9][D]; 34 C.F.R. § 300.17; see 20 U.S.C. § 1414[d]; 34 C.F.R. § 300.22). An IEP is designed as a "written statement" that addresses the educational needs of a child with a disability (20 U.S.C. § 1401[14]; 34 C.F.R. § 300.22; 8 NYCRR 200.1[y]). At the beginning of each school year, a school district is required to have an IEP in effect "for each child with a disability in its jurisdiction" (20 U.S.C. § 1414[d][2]; 34 C.F.R. § 300.323[a]; see also Cerra v. Pawling Cent. Sch. Dist., 427 F.3d 186, 194 [2d Cir. 2005] (finding the district fulfilled its legal obligations by providing the IEP before the first day of school). The student's recommended program must also be provided in the least restrictive environment (LRE) (34 C.F.R. § 300.114[a]; 8 NYCRR 200.6[A][1]). A FAPE is offered to a student when the board of education (a) complied with the procedural requirements set forth in the IDEA, and (b) the IEP developed by its CSE through the IDEA's procedures is reasonably calculated to enable the student to receive educational benefits (Bd. of Educ. v. Rowley, 458 U.S. at 176, 206, 207 [1982]). The IDEA directs that, in general, a decision by an impartial hearing officer or state review officer must be made on substantive grounds based on a determination of whether or not the child received a FAPE (20 U.S.C. § 1415[f][3][E][i]). Under the IDEA, if a procedural violation is alleged, an administrative officer may find that a child did not receive a FAPE only if the procedural inadequacies (a) impeded the child'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 child, or (c) caused a deprivation of educational benefits to the child (20 U.S.C. § 1415[f][3][E][ii]; see 8 NYCRR 2005[j][4][ii]). The IDEA mandates that a student with a disability be provided with a FAPE tailored to meet his unique needs and one that is "reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances." Endrew F. v. Douglas Cty. Sch. Dist., 580 U.S. ___, 137 S.Ct.988, 999 (2017). A focus on the particular child is at the core of the IDEA. Endrew F., 137 S.Ct. at 999. Under 20 U.S.C. Section 1414(d)(3)(A), the IDEA mandates an IEP team to consider a child's strengths, weaknesses and deficiencies, as well as the results of the most recent evaluations of the child together with developmental and functional needs of the child. In order to determine the student's requirements and needs, the team must review and consider evaluations, assessment and information provided by the child's parents, teachers and service providers and thereon determine the type of program required for the child. 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. Department of 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 R. and Dianne R. 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 R., 2007 WL 2982269 [Oct. 15, 2007].

The case at hand is a tuition reimbursement case and is therefore governed by the holding of the U.S. Supreme Court in Burlington School Comm. v. Dept of Education (471 U.S. 359 [1985]). That case set forth a three-prong test for determining if tuition reimbursement is warranted: (1) were the services offered by the school district inadequate or inappropriate; (2) where the services selected by the parents appropriate; and (3) do equitable considerations support the parents' claim. Recently enacted state legislation puts the burden of proof for the first prong on the school district and for the second prong on the parent (Chap. 583 of Laws of 2007).

Prong I:

In the instant matter, the DOE bears the burden of presentation and persuasion in all allegations raised in the DPC. An appropriate program begins with an IEP which accurately reflects the results of evaluations to identify the child's needs, establishes annual goals and short-term instructional objectives which are related to the child's educational deficits, and provides for the use of appropriate special education services to address the child's special education needs. Application of a Child with a Disability, Appeal No 93-12; Application of a Child with a Disability, Appeal No 93-9; Application of a Child with a Handicapping Condition, Appeal No 92-7; Matter of Handicapped Child, 22 Ed.

Herein, in the presentation of its case, the DOE produced two witnesses who had participated in the IEP meeting of January 14, 2019, both whom lacked independent recollection of said meeting. These witnesses failed to bring forth cogent reasoning for failing to evaluate [REDACTED] in all areas of suspected need and failed to overcome parent allegations that same resulted in inappropriate IEP goals and transition services established for the student. Further, while the DOE witnesses from the recommended placement opined that the recommended placement would be appropriate for [REDACTED], neither was able to detail such appropriateness. Particularly noteworthy, [REDACTED] testified nothing had substantially changed between the 2018/19 and 2019/20 school year in terms of how the school was able to serve its students (T @ 233).

Upon due consideration, I find that the DOE failed to overcome their burden of proof in that it failed to provide evidence establishing substantiative reasoning and rationale for the recommendations made in the student's IEP and failed to substantiate how the IEP afforded [REDACTED] a FAPE. The DOE failed to rebut Parent's allegations that the IEP was inappropriate. Thereon, I find the DOE failed to meet its affirmative burden of showing that it provided a FAPE to [REDACTED] for the 2019/20 school year by providing an appropriate IEP and placement, resulting in a denial of FAPE.

Prong II:

Having determined that the DOE did not offer the student a FAPE for the 2019/20 school year, I now proceed to evaluating the appropriateness of the parents' unilateral placement of the student at [REDACTED]. The parent's failure to select a program approved by the state in favor of an unapproved option is not itself a bar to reimbursement (Florence County Sch Dist Four v. Carter 510 U.S. 7 [1993]). The private placement need not employ certified special education teachers, Carter, supra. The Second Circuit has set forth the standard for determining whether parents have carried their burden of demonstrating the appropriateness of the unilateral placement: "No one factor is necessarily dispositive in determining whether parents' unilateral placement is reasonably calculated to enable the child to receive educational benefits. Grades, test scores and regular advancement may constitute evidence that a child is receiving educational benefit, but courts assessing the propriety of a unilateral placement consider the totality of the circumstances in determining whether that placement reasonably serves a child's individual needs. 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". (Gagliardo, 489 F.3d at 112, quoting Frank G., 459 F.3d at 364-65).

In the case at hand, the DOE evidence and cross-examination of parent witnesses failed to generate material challenge to Parent assertions. Contrarily, the evidence and testimony presented by the Parent supports that [REDACTED] was an appropriate placement for [REDACTED] during the 2019/20 school year. As per the submitted documents, "The [REDACTED] School offers students with special needs a comprehensive and nurturing educational environment……..Our mission is to provide the core academic, social, and life skills needed by our students to progress meaningfully, and develop into productive citizens in their communities…..[REDACTED]'s small student-teacher ratios allow for differentiated instruction to meet your child's individual learning needs……The [REDACTED] program is designed to prepare disabled high school students to transition into young adulthood by maximizing their strengths and preparing them for the world of work ahead" (Exhibit D).

[REDACTED] described in detail the program at [REDACTED] and attested to being very familiar with [REDACTED]. She stated:

"During that year, [REDACTED] was placed in a classroom with seven other students the same age. The class was grouped based upon levels of academics and social skills, as well as behavioral needs and provided [REDACTED] with similarly functioning peers who could provide positive social and behavioral models. [REDACTED]'s class was instructed by two teachers, both of whom had their Master's degree in Special Education and were New York State certified special education teachers, and he also had a paraprofessional, provided through insurance, to provide additional support throughout the day. Math and literacy coaches oversaw instruction in math and reading" (Exhibit T).

"He required an individual behavior plan that provided prompts to help manage obsessive thoughts, breaks to reduce frustration, and the use of de-escalation techniques. [REDACTED] provided a small class, counseling twice per week, and the counselor was available for check-ins when [REDACTED]'s thoughts began to spiral. [REDACTED] also had attention and executive functioning challenges. They used frequent prompting, graphic organizers, a visual schedule on the board, checklists and other organizational strategies to effectively address those challenges and [REDACTED]'s ability to follow prompts improved through the year" (Exhibit T).

"In terms of academic support, [REDACTED] provided preteaching, and individualized multisensory instruction incorporating visuals and repetition. [REDACTED] received a high level of individual and small group instruction, made possible by his small class size. Individualized reading and writing instruction enabled [REDACTED] to progress academically, specifically in writing essays, reading aloud, and math budgeting and taxes" (Exhibit T).

"[REDACTED] provided counseling, and speech/language twice weekly. The occupational therapist had previously determined that [REDACTED] no longer required occupational therapy. Vocational and life skills were addressed and [REDACTED] had an internship in an [REDACTED] warehouse" (Exhibit T).

She opined that [REDACTED] was appropriately placed [REDACTED] for the 2019/20 school year and made progress in that setting. [REDACTED] expressed: "In my professional opinion, [REDACTED] appropriately met [REDACTED]'s needs for the 2019/20 school year. Our program was able to support him academically, socially, and emotionally by providing him with peers who were appropriate for him and by creating an environment where he felt safe. We provided him with individualized instruction and related services to address his areas of need. He progressed academically and acquired transition/life skills that helped him become more independent" (Exhibit T);

"I have had the opportunity to review the January 14, 2019 Department of Education IEP that was created for [REDACTED] for the 2019/20 school year. Based upon what I know of and his needs, I do not believe this IEP was appropriate for him for the 2019/20 school year. [REDACTED] was recommended to attend a class consisting of 8 students, one teacher, and one paraprofessional for the 2019/20 school year, which would have been too large a class for [REDACTED] without an individual paraprofessional. Such a classroom would not have provided with the level of individual attention, individual and small group instruction, or appropriate support that he needed in order to function effectively and to learn" (Exhibit T).

She opined that [REDACTED] did not require a 12-month program for the 2019/20 school year as she did not note regression that would indicate he so required (T @ 258).

Review of [REDACTED]'s progress report corroborates his progress throughout the 2019/20 school year at [REDACTED] (Exhibits E and I).

[REDACTED], [REDACTED]'s mother testified that she expressed her concerns to the IEP team that [REDACTED] requires one to one instruction because of his behavioral needs, she articulated that she believes [REDACTED] to be an appropriate placement for [REDACTED] and that the DOE has funded that program for him since his initial enrollment, that the DOE did not evaluate [REDACTED] prior to the January 14, 2019 IEP meeting, and further testified that her family household income does not afford the opportunity to pay the tuition at [REDACTED] (Exhibit R and T @ 274).

In totality, the record reflects [REDACTED] provided a rich supportive environment that correlated well with [REDACTED], that the curriculum was specifically tailored to meet [REDACTED]'s needs and that he received a highly individualized instruction that enabled him to make appropriate progress. Based upon the foregoing, I find that the student made meaningful progress at [REDACTED] for the 2019/20 school year across the board: academically, socially and emotionally. The record reflects that [REDACTED] was a placement that was "specifically designed to meet the unique needs" of the student Frank G, supra and that [REDACTED] has made progress therein (Exhibits E and I).

Prong III:

Having found [REDACTED] an appropriate placement, I now consider equitable considerations, the final criterion for a reimbursement award. In weighing the equities, "the critical consideration, as the Court sees it, is whether they have cooperated in good faith to attempt to develop an IEP to the maximum extent possible, Schaffer, supra. There is nothing in the record to show that the parents were anything other than cooperative. The DOE did not present any evidence or testimony regarding the equity considerations for the 2019/20 school year. All indications are that the Parent cooperated with the DOE and did not interfere in any way with the DOE's obligation to provide a FAPE for the student for the 2019/20 school year. [REDACTED]'s Parents put the DOE on timely notice of [REDACTED]'s unilateral placement and their intent to seek reimbursement (Exhibit B). As per Parent's credible assertion, the DOE failed to address the Parent's concerns or to develop an alternative program or placement recommendations.

This case involves a situation where the Parent's financial circumstances limit their ability to make payment to [REDACTED] (Exhibit Q and R @ 274-275). [REDACTED] testified that the family income renders a hardship to pay the annual tuition. Established case law warrants a finding that under such circumstances a school district must pay the monies owed, assuming parent's claim is meritorious with regard to the three Burlington factors. In Conners v. Mills, 34 F. Supp. 2d 795 (N.D.N.Y.) at 805, the court reasoned:

"By prohibiting prospective placement, Defendants would deny assistance to families that are not able to front the cost of a private, non-approved school, without exception…Given the fragile state of many disabled children, and their dire need for constant and consistent care, even brief periods of inappropriate schooling could lead to tremendous educational, social, emotional and psychological deterioration. Families of greater economic means would not be faced with such a grim prospect. It simply cannot be the case that an act designed to grant "all" disabled children access to needed services could undermine that very goal by making such access dependent upon a family's financial situation."

The record reflects a portion of [REDACTED]'s school day (approximately 20%) at [REDACTED] is devoted to prayer and religious studies (Exhibit F, T @ 265-266). I do not find that the DOE is to be responsible to fund same but that parents have every right to do so.

Moreso, the record reflects the student did not attend [REDACTED] for the full 10-month school year due to medical conditions (Exhibits M and R, T @ 266-267).

I find (1). that the DOE failed to offer the student a FAPE for the 2019/20 school year, (2). that the unilateral placement of the student at [REDACTED] was appropriate (3). that the program at [REDACTED] was "reasonably calculated" to provide [REDACTED] with meaningful educational benefits and (4). that equitable considerations weighed in favor of the parents' request for reimbursement for all costs (less religious component and time period student not in attendance) associated with the placement of the student at [REDACTED] for the 2019/20 school year. Based upon the foregoing,

ORDER

It is hereby ordered that within thirty (30) days of receipt of this Order,

1. The Department of Education shall fund the cost of the student's tuition at the [REDACTED] for the 2019/20 school year by providing direct payment to the school in the amount of 55,000; and

2. The Department of Education shall reimburse Parent in the amount of $900.

All reimbursements and/or direct funding shall be supported by the presentation of appropriate documentation.

This Order excludes any sessions that may have been previously paid by the DOE pursuant to any Pendency Agreement/Order.

Dated: June 5, 2023

Maria R. Dispenza

MARIA R. DISPENZA, ESQ.

Impartial Hearing Officer

NOTICE OF RIGHT TO APPEAL

PLEASE TAKE NOTICE

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 shall 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.

DOCUMENTATION ENTERED INTO THE RECORD ON AUGUST 17, 2022

1. DOE: IEP, 01/14/19 – 23pp DOE

2. Attendance Page, 01/14/19 – 1pp DOE

3. Prior Written Notice, 05/31/19 – 4pp DOE

4. School Location Letter, 05/31/19 – 2pp DOE

5. [REDACTED] School Progress Report, Fall 2018– 5pp DOE

6. Hospital Discharge Report, 10/10/18 – 9pp 7. Level 1 Vocational Interview with Parent, 06/01/18 – 2pp DOE

8. Psychological Evaluation, 01/18/18 -7pp DOE

9. Occupational Therapy Evaluation, 01/14/17 – 5pp DOE

10. Speech Language Therapy Evaluation, 07/26/16 -6pp Parent: DOE

A. Impartial Hearing Request with Proof of Filing, 05/29/21 - 10pp

B. Ten-Day Notice, 08/15/19 - 2pp

C. Psychological Evaluation, 01/18/18 - 7pp

D. [REDACTED] Program Description, Undated - 1pp

E. [REDACTED] Fall Progress Report, Fall 2019/20- 3pp

F. [REDACTED] Schedule, 2019/20 - 1pp G. [REDACTED] Remote Learning Plan, 2019/20 - 1pp

H. Zoom Schedule, 2019/20 - 2pp

I. Progress Report Fall 2019/20 - 2pp Spring

J. Tuition Affidavit, 04/28/22 - 1pp

K. Enrollment Contract, 11/05/19 – 1pp

L. Hospitalization Letter from [REDACTED], 10/17/19 – 2pp

M. Hospitalization Letter from [REDACTED], 03/10/20 – 1pp N. 2018/19 FOFD, 10/19/20 – 18pp

O. Proof of Payment, 03/2020 – 1pp

DOCUMENTATION ENTERED INTO THE RECORD ON MARCH 16, 2023

P. Additional Affidavit of Payment, 02/18/20 – 1pp Q. Parent's Tax Return, 10/14/20 – 2pp

R. Affidavit of [REDACTED], Undated – 3pp

S. Updated Tuition Affidavit, 01/09/23 – 1pp

T. Affidavit of [REDACTED], Undated – 5pp

DOCUMENTATION ENTERED INTO THE RECORD ON APRIL 20, 2023

IHO-1. Parent Closing Brief, 04/20/23 - 26pp