Endrew F. Standard: How to Achieve Compliant IEPs

IDEA Jul 28, 2023

The Endrew F. Standard is a legal ruling that sets the bar for what constitutes an appropriate education for students with disabilities under the Individuals with Disabilities Education Act (IDEA).

The Endrew F. Standard redefined the creation of IEP (Individualized Education Plan) for students in special ed classes.

It states that every school must offer a personalized IEP that addresses the unique necessities of a child since the student is entitled to FAPE (free appropriate public education) under IDEA.

The IEP should enable the child to make progress in academics and functional learning in accordance with the child’s circumstances.

To understand the Endrew F. Standard and its impact on a student’s IEP, let us first understand how it came into existence.

How Did the Endrew F. Standard Come to Be?

Endrew was a child with autism. He had graduated fourth grade but his parents put their foot down after checking their son’s fifth grade IEP.

According to his parents, the new IEP was identical to the IEPs that were offered to Endrew in the past years. Those IEPs did not help Endrew progress and they admitted their child to a private school. The private school offered a tailored IEP for Endrew that helped him learn and progress.

However, Endrew’s parents could not receive reimbursement for the private school's tuition. That led them to file a complaint and seek reimbursement at a due process hearing. They went to the US District Court for the District of Colorado following dismissal from the hearing officer.

The District Court upheld the hearing officer's decision, and Endrew's parents appealed again to the U.S. Court of Appeals for the Tenth Circuit. The Tenth Circuit also upheld the District Court's decision, stating that the district school had provided an optimally designed IEP in accordance with IDEA.

Endrew's parents were not satisfied with the Tenth Circuit's decision, so they appealed to the U.S. Supreme Court. In 2017, the Supreme Court overturned the Tenth Circuit's decision and established the Endrew F. Standard.

This standard sets a higher bar for what constitutes an appropriate education for students with disabilities under IDEA. It has had a significant impact on the way IEPs are developed and implemented.

Schools are now required to provide students with IEPs that are more individualized and rigorous, and that are designed to help students make meaningful progress.

The Endrew F. case is also an important reminder that parents have a right to advocate for their children's educational rights.

Is Providing an IEP Enough to Offer Educational Benefits to a Child with a Disability?

The Endrew F. case established a substantive standard for determining whether a child's IEP is sufficient to help them make progress. If the IEP provides nothing but minimal progress (merely more than de minimis) then that IEP is not suited for the child with a disability.

The Endrew F. case changed the way a school offers IEPs to children with disabilities. It set a new standard for the creation of IEPs for students who are performing at grade level and those not performing at grade level.

The Endrew F. case overturned the Tenth Circuit's decision, which had held that IEPs only needed to provide "merely more than de minimis" progress.

The Supreme Court found that this standard was too low, and that it did not provide students with disabilities with the opportunity to receive an appropriate education.

So, the new standard is more than the “bare minimum,” supported by the Tenth Circuit decision earlier.

The US Supreme Court decision clearly stated that the IEP goals for each child may differ, but they should get the chance to face and meet challenging objectives.

What Does It Mean in Terms of IEP Goal Tracking?

The basic purpose of an IEP is to provide opportunities for the child for making academic as well as functional progress. The child should show improvement in terms of academics and functional learning.

Thus, each student must receive a “reasonably calculated” IEP that suits their unique needs. At the same time, each child will have different sets of goals. Any set of IEP goals that do not provide the child the chance to meet challenging objectives goes directly against the core of the IDEA.

The US Supreme Court’s decision made it clear that monitoring the achievements of a child is crucial for measuring their academic growth.

Systematic and regular IEP goal tracking is the only way to objectively determine whether the child is at par with or exceeding grade-level proficiency.

For example -

Report generation: IEP monitoring reports should be shared with parents during IEP meetings.
Report accuracy: These reports should be comprehensive and may even contain comparative analyses between current and previous IEPs to show the progress of the student.
Report sharing: Accurate and timely IEP goal tracking & reporting enables teachers, parents, and school districts to easily ascertain whether the child is involved in and making progress in terms of the general education curriculum.

Advanced IEP data collection software like AbleSpace also enable special education teachers to create fresh IEPs for the new academic year as per a student’s past achievements, failures, and potential for growth.

What Is a ‘Reasonably Calculated IEP’ for a Child?

A school must provide each student with disability/disabilities a “reasonably calculated” IEP for meeting the substantiative obligation under IDEA. ‘Reasonably calculated’ refers to programs that are tailored so a child can progress appropriately.

Now, the Supreme Court did not clearly define what “appropriate progress” should encompass for a child. But, each IEP team must conform to the practices, policies, and procedures that relate to:

Identification of the current levels of academic and functional performance.
Setting & routine tracking of measurable goals; These goals can be academic and functional.
Standardizing a method to monitor these goals and reporting the child’s progress.

Therefore, the teacher must be able to show that:

The child is receiving an IEP that is appropriate for them.
Changes are being implemented to their IEP per the student’s performance in class.
The child is receiving all the support and services from the district school necessary for their progress.

To meet the Endrew F. Standard, the school needs to consult thorough, evidence-based, and meaningful assessments of the child’s performance over a period of time. That demands the teacher take multiple notes, make observations during each session, and communicate objectively with all parties involved in the IEP-making process.

How IEP Goal Tracking App Helps Create Reasonably Calculated IEPs

Turning to a user-friendly and feature-packed IEP goal-tracking tool like AbleSpace is the smartest way to keep a child’s progress up-to-date.

Here’s what you can expect when you start using AbleSpace - a software tailored to the needs of special ed teachers, special ed departments and school districts:

Collection of Multiple Data Types: Special ed teachers can effortlessly collect multiple types of data, including the student’s accuracy, frequency of goal-achievement, task analysis, prompt counting, and rating scales.
Visualization of Data: Turn data into different types of graphs for each student to visualize their progress.
Easy Report Sharing: Special ed teachers can share pre-built reports with their colleagues, school board, and parents.
Seamless Communication: Cutting-edge IEP goal tracking software facilitates easy and fast communication between all IEP design stakeholders.
Collaboration: Modern IEP and data collection apps are collaboration-friendly; there’s no room for errors or miscommunications since teachers can assess and monitor student progress in real-time with a few clicks.
Community Support: Lastly, IEP goal tracking apps tailored to special ed teachers like AbleSpace allows the teachers to become a part of a much larger community of school-based special education professionals. You can share your doubts and receive answers from fellow professionals working in your state or district.

The Endrew F. Standard sets a higher bar for creating appropriate IEPs, emphasizing individualized and rigorous plans to help students make meaningful progress.

Schools must adhere to this standard and monitor student achievements closely. Utilizing a comprehensive tool like AbleSpace can facilitate accurate IEP goal tracking and ensure compliance, benefiting both students and educators.

By incorporating the Endrew F. Standard and advanced technology like AbleSpace, schools can make significant strides in providing every student with the appropriate education they deserve.

Together, we can empower students with special ed needs & their teachers, and pave the way for a brighter future.