What Makes an Education “Appropriate”? Building It on Relationships

*Updated February 2023

The Supreme Court of the United States decided a case with far-reaching impact on millions of children and their families. The case, brought by the parents of an autistic student in Colorado, challenged how much public schools are obligated to do to educate students with learning differences and disabilities.

The Federal Individuals with Disabilities Education Act, known as IDEA, requires states to provide every student with a “free and appropriate public education” (often referred to as FAPE). But states and districts vary greatly in how they define “appropriate.” In the Colorado case, known as Endrew F. v. Douglas County School District, the parents argued that the school offered their son only a “just-above-trivial” education, and the court agreed that he was entitled to more.

In more than two decades as a psychologist working with school-age children, I have often faced this exact question: which accommodations or services are most suitable for a given child? Parents, teachers, administrators, and others often disagree. All too often, parents need to dispute Individualized Education Plans (IEPs), school officials fight back, and we waste time and money while a child languishes.

The resulting stress is often palpable, creating unbearable predicaments for parents, whose efforts to protect and support their sons or daughters is met with legal jargon that has nothing to do with their particular child. Even the few who can afford legal counsel sometimes must settle for what the IEP team considers a “minimally adequate” educational program.

Students are left to the mercy of well-meaning IEP-team members, who may or may not agree with parents’ firsthand knowledge of their child, or with private providers closely acquainted with the child. I have frequently had the surreal experience of sitting in on an IEP and wondering whether members of the school team are describing the same child I have worked with in my practice for years.

What makes the Supreme Court case even more significant is the reason the boy’s parents have fought so hard. His behaviors—running away, banging his head, dropping to the floor—were interfering with his learning. Having control over one’s behaviors—or more importantly, having the capacity for emotional regulation (achieving a calm and alert state)—is a precursor to learning for all children. Without this control, learning is challenged if not impossible. And this type of control is built one way: through meaningful relationships.

It’s crucial to understand that these behaviors, so common in children with developmental disabilities, are stress responses. In developing IEPs, we must address them not only in the “social-emotional” category, but in all of a child’s academic goals. Every IEP team should assure that a child has the chance to develop emotional regulation through trusting relationships. Without that opportunity, meaningful learning is impossible.

The Endrew F. case isn’t just about changing the definition of FAPE. It illustrates the need to change how we view children labeled as having special needs. It highlights the flawed view that professionals—rather than parents—are the experts on a child.

It also shows how educators need to understand the meaning underlying a child’s behaviors in order to teach the child.

Having a higher standard doesn’t need to cost more money. But it does call for increased teamwork between professionals and parents and it requires professionals to build (or rebuild) trust in relationships with students and parents alike.

We can all improve the process.

Professionals can:

—View parents as valued members of the IEP team who have vital information necessary to serve the child’s individual needs.

—Work together with parents to discover how the child learns best, and how to help the child achieve emotional and behavioral regulation through nurturing relationships.

—Insure that all staff learn the basics of developmental and relationship-based practice, which creates healthy partnerships with students and parents.

—Learn from neurodiverse individuals themselves about their experiences with education—what worked and what didn’t. Ido Kedar, for example, openly describes how the neurotypical approach of his elementary-school classrooms failed him.

Parents can:

—Understand that educators are overburdened and facing their own stressors, and that their training may not have fully prepared them to manage the academic, cognitive, emotional, and behavioral complexity of neurodiverse children.

—Realize that clinical practice models lag behind current research and that often administrators and teachers cannot readily access up-to-date information.

—Provide information to your team that matches with your parenting beliefs, culture, values, and how your child’s differences are interpreted and treated by professionals.

The best way to support children will always be through the healing power of human relationships. If we make relationships a priority, we will build children’s programs on a solid foundation and give children the best chance to develop into citizens with character and resilience.

I share more about more about how educators and other providers can support children’s social and emotional development in Beyond Behaviors and Brain-Body Parenting.

We also have a compassionate learning community based on my approach for parents.


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