- CLE letter in support of the Advocacy Institute’s comments to OSERS’ Rethinking Special Education Framework (Dec 21st, 2018, PDF) CLE is pleased to support the extensive comments prepared by Candace Cortiella, Director of the Advocacy Institute, that reflect a thoughtful and careful review of the three comonents of Results Driven Accountability (“RDA”): State Performance Plans/Annual Performance Reports, Annual Determinations, and Differentiated Monitoring and Support.
- CLE and Advocacy Institute’s comments to USED 7/2014, on CEIS and Significant Disproportionality (2014, PDF)
- CLE Comments on proposed rulemaking (9-18-13) to amend regulations re: local maintenance of effort under IDEA (December 9th, 2013, PDF)
- CLE Comments on PARCC Special Access Accomodations Continuing an ongoing dialogue on ensuring all students have an equality opportunity to meaningfully access curriculums, CLE provided comments on a draft version of Special Access Accommodations criteria for the PARCC assessment. The current criteria preclude students from being validly assessed in a manner consistent with the PARCC’s claims, contrary to both the Standards for Educational and Psychology Testing and their rights under Section 504 of the Rehabilitation Act. (April 15th, 2013, PDF)
- Letter to USED Office of Special Education Programs requesting that it rescind its “informal guidance” regarding local MOE issued on 06/16/11 (August 17th, 2011, PDF)
- Response from the Office of Special Education and Rehabilitative Services and OSEP (April 4th, 2012, PDF) In its response to Kathleen Boundy and CLE, OCEP and OSERS rescind the position expressed by OSEP’s “informal guidance”, acknowledging CLE’s interpretation; “the level of effort that an LEA must meet in the year after it fails to maintain effort is the level of effort that it should have met in the prior year, and not the LEA’s actual expenditures.”
- CLE & Advocacy Institute public comment to the National Council on Disability (December 8th, 2011, PDF)
- CLE Comments Re: Re-alignment of IDEA and ESEA (October 21st, 2010 PDF)
- CLE Urges Department of Education to Correct Misinterpretation Allowing Districts to Reduce Maintenance of Effort under IDEA(August 11th, 2009, PDF)
- w. attached memorandum: “Legal Bases for Challenging Local Maintenance of Effort Reduction under IDEA” (August 11th, 2009, PDF) How SEAs must make their determinations of whether LEAs are meeting their requirements under §616(a) of IDEA and how this interpretation is applied to §613(a)(2)(C).
- CLE Comments to USED in response to Notice of Proposed Rulemaking under IDEA (May 13th, 2008, PDF) Comments responding to USED’s proposed regulations authorizing the right of parents to revoke unilaterally consent to their child’s receipt of special education services and continuing obligations of the LEA and proposed modifications allowing lay advocates to represent parents at due process hearings.
- CLE Solicitation for Feedback to PTIs and CPRCs re: NPRM Revocation of Consent under IDEA (May 13th, 2008, PDF) A series of questions and discussion points for parents and advocates to consider.
- Brief Overview of IDEA Regulations re/Revocation of Consent for Special Education, et al. effective (December 2nd, 2008, PDF) A brief description of changes resulting from USED’s final regulations on selective issues pertaining to revocation of consent for special education, non-attorney parent representation at due process hearings, state monitoring and enforcement.
- CLE Comments to USED, in response to NPRM regarding IDEA Amendments of 2004, issued June 21, 2005 (September 5th, 2005, PDF) An extensive set of comments to the Office of Special Education & Rehabilitative Services responsive to the office’s proposed regulations under the IDEA, as amended.
- CLE Comments to USED in response to the Request for Comments and Recommendations on Regulatory Issues Concerning IDEA 2004, issued December 29, 2004 (February 28th, 2005, PDF) 47 pages of comments identifying areas of concern where CLE believes Department guidance, through new regulations and/or modifications/deletions of existing regulations, would be useful for effectively implementing the recently amended Individuals with Disabilities Education Improvement Act of 2004 (IDEA).
- CLE comments to USED Office of Special Education and Rehabilitation Services on Report of the President’s Commission on Excellence Regarding Education (August 19th, 2002, PDF) CLE responds to (1) selected Commission recommendations for statutory change that are deemed particularly alarming; (2) selected recommendations with which CLE particularly agrees; and (3) broader Commission statements that evince a misunderstanding of current law.
- CLE Letter (Boundy) to Hon. Senators Judd Gregg and Edward M. Kennedy, Conferees to H.R. 1350, Reauthorization of IDEA (November 4th, 2004, PDF) CLE identifies concerns with HR 1350 that undermine legal protections under IDEA and are inconsistent with basic principles for all students under Title I/NCLB ( e.g., eliminating the right to “stay-put” during appeals; encouraging disciplinary exclusions, dropouts and removals of students who will NOT be counted for purposes of “AYP”; quashing the affirmative duty to provide FAPE to eligible children so that ALL children might learn; codifying unequal and low expectations for students with disabilities); and includes recommendations to preserve the protections of IDEA consistent with the principles of NCLB.
- Comments of CLE, with Nat’l Council of Centers for Independent Living and Coalition of Parent Centers, to Conferees on Reauthorization of IDEA 2004, (November 1st, 2004, PDF) Comments and recommendations to the Conferees on the Reauthorization of IDEA 2004 from CLE, the National Council of Centers for Independent Living, and the National Coalition of Parent Centers.