This is Mark Jacob. I am the now retired founder and past executive director of PADDA. PADDA was one of the ten original Community Parent Resource Centers funded by the US Department of Education’s Office for Special Education Programs. We assisted over 200 families each year from 1998 through 2006.
I have worked as a consultant and educational disability advocate for 22 years. With a grant from the Virginia Board for People with Disabilities, I created and produced, Your Pocket Advocate, a user friendly brochure guiding parents and caregivers through the special education Maze. My feedback and input has been sought in the past by policymakers,and legislators both at the state and federal level.
I am partially retired now…but do still work part time in this venue assisting families and their kids. In my opinion, the proposed regulations will take us back in time to a place we all desperately tried to escape from.
I recall eligibility meetings where parents were asked to leave the room while a decision was reached about their child. Parents had no ownership of the process. Children were warehoused with no hope of participating in the general curriculum, because parental involvement was precluded. Local Education Agencies were sole proprietors of the process. Getting through child study meetings was the first gauntlet a parent had to run. An eligibility determination was the second gauntlet. The system was unbalanced, constraining and oppressive. Parents were without representation. Their presence at meetings was offered as a courtesy only. I have great fears that these proposed regulations represent the beginning of a return to those times and dynamics.
The changes will hurt and damage children and the process in the following ways:
School personnel will be allowed to terminate special education services for your children without parent consent.
There will be no STATE required timelines, no required STATE procedures for involving parents.
School personnel will be allowed to deny a parents request for IEP meeting to determine progress or make changes.
Parents will not be a required part of developing Functional Behavioral Assessments or Behavioral Intervention Plans to provide valuable data about how the child’s disabilities impacts learning.
Parents will not be provided information on progress towards IEP goals.
Children with Developmental Delays will NOT be allowed to receive services after the age of five.
I strongly urge the policymakers and those finalizing the decision to look to the recommendations proffered by the Virginia Coalition for Students with Disabilities dated May 2008. As one who understands this venue, not only as an operative…but as a parent of a former student with severe disabilities…I strongly support the Virginia Coalition’s recommendations. We in Virginia have been pacesetters for many years. I remember the Virginian’s with Disabilities Act, and the fact that our state education agency was the first to include Attention Deficit Disorder and Attention Deficit Hyperactivity Disorder in their Special Education regulations. We need to keep moving forward…it is after all about our children.
