today's policy contexts for special education and students with specific learning disabilities

Hammill Institute on Disabilities

Today's Policy Contexts for Special Education and Students with Specific Learning DisabilitiesAuthor(s): H. Rutherford Turnbull, IIISource: Learning Disability Quarterly, Vol. 32, No. 1 (Winter, 2009), pp. 3-9Published by: Sage Publications, Inc.Stable URL: http://www.jstor.org/stable/25474658 .

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KEYNOTE, 2008 INTERNATIONAL CONFERENCE, COUNCIL FOR LEARNING DISABILITIES, KANSAS CITY, MISSOURI, OCTOBER 2-4

TODAY'S POLICY CONTEXTS FOR SPECIAL EDUCATION AND STUDENTS WITH SPECIFIC

LEARNING DISABILITIES

H. Rutherford Turnbull, III

H. RUTHERFORD TURNBULL, III, LIB., UM, Beach Center on Disability, The University of Kansas.

A year ago, when Professor Dan Boudah asked me to address the annual meeting of the Council for Learning Disabilities, I accepted eagerly, believing I might share

my perspectives about the Individuals with Disabilities Education Act (IDEA) and its meaning for students with

specific learning disabilities. I had planned to focus on the provisions that relate to

(a) the nondiscriminatory evaluation of students sus

pected of having a specific learning disability and (b) the responsibilities of teachers, students, and parents. I had planned to link evaluation and responsibility to civil rights, education reform, and welfare reform.

However, a year ago, we as a nation were facing dif

ferent prospects than we are now. A year ago, it seemed we might focus on IDEA, the No Child Left Behind Act

(NCLB), and students with specific learning disabilities

(SLD) rather narrowly and that it was less urgent to con

textualize special education, to put it into the context of the world around it. Today, it is essential to do so. So that's what I will seek to do -

give you some knowledge, from my perspective as a lawyer/policy analyst, about

special education and the factors that mightily influ ence it.

A USEFUL METAPHOR: THE RUSSIAN DOLL - NESTED DOLLS: MATYROSHKA To contextualize special education - its challenges

and opportunities - allow me to use a metaphor, one I

borrow (in these days of globalization and the "flat"

world) from an unlikely source, Russia.

Undoubtedly, most of us are familiar with the "Russian doll" - the Matyroshka. It has a small doll inside a larger one; the larger one inside an even larger one; the yet-larger one inside the largest. As we open the

doll, starting with the largest doll, we find yet another, and then another, until we finally arrive at the smallest doll. The English author John LeCarre (1975) used the doll to symbolize the inner workings of the British intel

ligence service, in his book Tinker, Tailor, Soldier, Spy. The farther LeCarre carried his readers into the innards of the spy service, the more he uncovered the littlest, but most dangerous, doll.

I suggest that we start opening the doll from the inside out, rather than the outside in. Let's start with the smallest doll -

specific learning disabilities and spe cial education - and then think about special education and the context and the factors influencing it today.

TWO ISSUES INVOLVING STUDENTS WITH SPECIFIC LEARNING DISABILITIES

The littlest doll represents the issues related directly to students with learning disabilities. Two aspects of this

tiny doll fascinate me. One relates to the discrepancy model, costs, classification, and the criticism of the

"dependency model." The other relates to the process for law reform and the practice called response to inter

Volume 32, Winter 2009 3



vention. Both are significant because they have the

potential to shape rather significantly the population called "students with specific learning disabilities" and the services they receive.

Discrepancy Model, Escalating Costs, Alleged Overclassification, and Dependency Theory

First, there is the discrepancy model for determining whether a student has a specific learning disability. That model allows educators a great deal of discretion in whether to classify a student as having SLD and

thereby offer the benefits of individualized education.

Encountering many students whose ability and per formance were not congruent, educators began to clas

sify them as having SLD. The number of students with

learning disabilities consequently increased annually (U.S. Department of Education, 2007). The growth in the population concerned policymak

ers and others. For one thing, it escalated education

costs; special education is more expensive than general education. For another, it placed some students into

special education who would not need those services

if they had been effectively educated in the general curriculum.

These two concerns surfaced with gusto when

Chester Finn (2001), a former assistant secretary in the

U.S. Department of Education and a close advisor to

President Bush, and others wrote a manifesto about

reforming special education for the 21st century. The concerns resurfaced nearly immediately thereafter when the President's Commission on Excellence in

Special Education (PCESE; 2002) recommended signifi cant changes in IDEA.

The Finn and PCESE texts stated that special educa tion was too expensive and over-populated; it was not

special enough. They argued that educators were wait

ing for students to fail before intervening specially, ask

ing: Why wait until the student is in about the fourth

grade to determine whether there is a discrepancy?

Why wait for the student to fail before intervening

powerfully? Even more fundamentally, Finn and PCESE argued

that special education was teaching students to be

dependent. By providing supports to some students

who might not need them, special educators were

teaching students that they were different from stu

dents not classified into special education; that they were indeed so different that they needed special sup

port. They further argued that this teaching gave stu

dents a sense of entitlement. That sense of entitlement was simply this: that, after

leaving school, they are entitled to support in all envi

ronments of their lives; that they cannot stand on their

own, be self-reliant, and be economically productive.

In other words, these students learned helplessness and

dependency; their learning disadvantaged them and cost the rest of us dearly: We faced claims to support those who could support themselves, and we lost their

productivity even as they lost their independence.

Law Reform, Procedural and Substantive Barriers to Overclassification, and Response to Intervention

The second fascinating aspect of SLD classification relates to the law's usual ways of shaping results;

namely, by using procedural or substantive barriers that impede a result that the law disfavors. We have to remember that IDEA is process-driven; it prescribes

who must do what, for whom, when, how, and why, with respect to such important matters as school disci

pline (the zero-reject principle), nondiscriminatory evaluation, appropriate education and IEP develop

ment and implementation, placement in the least restrictive environment, procedural safeguards sur

rounding all of the above, and due process for adjudi

cating disputes (Turnbull, Stowe, & Huerta, 2006). At the same time, IDEA (in its provisions related to

procedural safeguards in classification, 20 U.S.C. Sec.

1414(a) through (c), also imposes substantive barriers to

classifying a student as having a disability. It imposes even more standards for determining if the student has a specific learning disability (the so-called inclusionary and exclusionary standards in 20 U.S.C. Sec. 1402(30)), and it creates substantive presumptions in favor of the

education of all students with disabilities within the

general curriculum (least restrictive environment) (20 U.S.C. Sec. 1412(a)(5) and Sec. 1414(a)

- (d)).

The question that Finn and PCESE faced was this: How might special education law - a "reformed"

IDEA - blunt the dependency model? One answer was

to amend IDEA so that educators would be encouraged to use a different standard for classification into SLD

than the traditional discrepancy standard. Not surprisingly, Congress adopted the Finn-PCESE

approach. The new standard is "response to interven

tion" (RTI), now codified into the IDEA provisions,

allowing educators to use either the discrepancy stan

dard or an RTI standard (20 U.S.C. Sec. 1414(B)(6)). Under this substantive standard, educators may

decline to classify a student as eligible for SLD or other

categories until after the student has had the benefit of

evidence-based intervention. Lacking any benefit, it is

legitimate to classify the student as having SLD.

The procedural aspect of this law reform is rather

light-handed: IDEA allows but does not require educa

tors to use RTI to evaluate a student. The substantive

aspect is weightier: IDEA expects the intervention to be

evidence-based.

Learning Disability Quarterly 4



RTI, then, becomes a preventive technique - a pro

phylactic against costly, erroneous, and dependency inculcating special education. It becomes a school

system technique to reduce the number of students classified into SLD. More than that, RTI reflects a concern that classifica

tion into special education may not serve some stu

dents well and, further, that categorization (into one

type of disability) equally disserves some students.

Thoughtful specialists ask: Does classification and its

subsumed categorization produce an appropriate edu cation? Does it really contribute to students' economic

self-sufficiency, independent living, and full participa tion in the community, these being the four national

policy outcomes that IDEA (20 U.S.C. Sec. 1401(c)(1)),

together with the Americans with Disabilities Act

(ADA; 20 U.S.C. Sec. 12101), declare. Seen in the light of the argument that classification

and categorization may ill serve some students and the

nation, RTI becomes an approach that is not grounded in the notion of categories and special interventions for students in disability categories but an approach to pro

viding an appropriate, high-quality education for all students (where "all" includes those with SLD).

There are, then, at least the following major critiques of special education for students with SLD: overclassifi cation and miscategorization, unwarranted high costs, and learned helplessness/dependency. These connect

powerfully to several factors outside the field of special education.

SPECIAL EDUCATIONS CONNECTION TO ANTI-POVERTY POLICY AND

WELFARE REFORM Let us return to the Matyroshka, our metaphor for

analysis. As mentioned, in that metaphor, we work out ward from the tiniest doll to the largest. We are now at the level where our "doll" takes on the guise of special education's connection to factors outside its own four corners.

The first factor from outside the special education field relates to anti-poverty policies that provided cash benefits to families with dependent and disabled children. The 1996 welfare reform law (Personal Responsibility and Work Opportunity Reconciliation Act of 1996, P.L. 104-193) transformed the old policies. It provided that the federal and state governments

would provide welfare benefits for a limited time, two

years, on condition that the recipient seek work or edu cation for work.

At its core the welfare reform law said that each per son must seek to do as much as he can for himself; there is a limit to the largess of the public. It emphasized personal responsibility. It also concluded that the

nation can no longer afford to support so many people to be dependent; it is time to be serious about contain

ing the costs of the welfare state. Soon after the Republican Congress enacted and

Democratic President Clinton signed the welfare

reform law, the Supreme Court interpreted ADA to mean that a person who has mitigated her disability is no longer "disabled" and entitled to ADA's protections (Sutton v. United Air Lines, 527 U.S. 471, 1999). There, and in later cases, the Court intended to permit

employers to escape claims of disability discrimination and operate their businesses as they saw fit (Turnbull, 2005, 2008). More than that, the Court intended to

reduce the number of people who could invoke ADA

protections - that is, to reduce the number of "dis

abled" people as a matter of law. The fact that Congress recently "restored" the ADA to its "original intent" by effectively overturning the Court's employment law decisions (ADA Amendments Act, P.L. 110-235, effec tive January 1, 2009) suggests that the Congress still favors categorization; it still acknowledges that there is a subpopulation of people who lack the intellectual, sensory, or physical capacities to function in typical domains of life without support.

However, the mere fact that IDEA and ADA still

acknowledge the existence and needs of that popula tion does not directly affect RTI, although there is an interaction between those statutes and the RTI

approach. The interaction is twofold: RTI will still be a means for improving the education of all students and it also may be a means for excluding from special edu cation many students who otherwise might be included. (Some students who would be excluded from IDEA because of RTI may still be entitled to reasonable accommodations under Sec. 504 of the Rehabilitation

Act, which Congress amended to conform to its ADA

amendments.)

There are three notable parallels between IDEA'S 2004 RTI provisions, the welfare reform law, and the Court's decisions limiting the scope of ADA. Each seeks to narrow or reduce the class of people who are entitled to special benefits (special education, public support, and reasonable accommodations). Each intends to con tain the costs of social and educational services. And each criticizes the dependency model and proclaims that people who can do for themselves should do for themselves: They should become more responsible for themselves and to other citizens. To that end, both

they and their educators should become more account able (a desideratum sought by NCLB and its presence within the provisions of IDEA calling for student assess ment and state plans for improving special education

results).




The Demand for Accountability in Government

Sponsored Programs: GPRA and Special Education Prodded by President Clinton and Vice President

Gore, Congress enacted the Government Performance and Results Act of 1993 (GPRA). Briefly, that law

required federal agencies and their sponsored programs to justify themselves by proving they produced the results they said they would produce. Accountability is the concern represented by the next larger Russian doll.

GPRA is the original source of the accountability pro visions in NCLB and IDEA as amended in 2004. But those provisions reflected more than conformity with GPRA. They implicitly criticized general and special educators for failing to educate students to be produc tive in the marketplace and to have such knowledge that they will be informed voters.

NCLB and IDEA sought accountability by insisting that teachers be highly qualified, that they use evi dence-based teaching techniques, and that they assess

their students' progress in core subjects. But neither law, and none of the appropriations related to them, suffi

ciently enlarged schools' capacity to deliver results and be fairly held accountable.

BARRIERS TO RESULTS AND CHALLENGES TO ACCOUNTABILITY

Underfunding of IDEA and NCLB is only part of the

issue about school capacity development. It seems to be

the focus of much of political talk nowadays -

pledges to "fully fund" IDEA abound. No doubt, more money

would be helpful, especially if it were better spent (such as on RTI, school-wide positive behavior support, uni

versal design of the curriculum, and workforce capacity building).

But more than money is needed. The next larger doll

brings us face to face with a host of factors beyond "just" money. Conversations about school capacity

- princi

pally, the ability of the teacher corps to improve stu

dents' performance - have led to a pass that the higher

education industry could have only dimly seen a decade

ago and that now makes it shiver: Reform of teacher

preparation programs is now a matter of federal/con

gressional interest. Predictably, debates and data gather

ing continue about how to restructure schools'

governance and administration so they will produce better educated students. The pressure on special educa

tion comes from both Congress and state legislatures and now blends ivy-hall, preservice autonomy and prac tices with building-level administrative adjustments,

including the nature and intensity of inservice training.

Beyond the policies favoring highly qualified teachers

and evidence-based intervention, and beyond the dis

course about funding, higher education's role, and

school structure lie still other challenges to improved

results. You are familiar with the debates about teacher

tenure, union contracts, charter schools, public funding of private schools through vouchers, and home-school

ing. These debates mirror dissatisfaction with public schools' capacity to deliver results and meet accounta

bility standards. Indeed, some of these topics -

espe

cially charter schools, voucherization, and assistance to

private school students - reflect profound dissatisfac tion with not only the results of secularized public edu cation but also the lack of morals teaching and

citizenship-training by the secularized system. As many in our nation have sought to inject private morality into

public behavior, they seem to turn away from the

public sector, yet seek support from it for their less

than-public or purely private schooling.

The Research Enterprise and Knowledge Translation

As we proceed outward in our Matyroshka, we find that the next doll represents the research enterprise and the challenge of knowledge translation. Research tells educators and parents what works and, thus, what teachers should do. Research is indispensable for

progress. But there is the age-old problem of knowledge translation, exacerbated by the World Wide Web and its

ever-improving capacities and use. The knowledge

explosion presents teachers and parents with two prob lems: There is so much information available, but it is in

terms not easily accessible by laypersons or even busy teachers.

Plentitude paradoxically produces hunger; consumers

have much to choose from but cannot feast. Teachers

and parents are hungry; they want to know what works

best. They want that information now, in simple lan

guage. They want a practical answer to what to do. But

academicians and the research enterprise do not satisfy their hunger or slake their thirst. With few exceptions, such as those offered by Don Hammill and Don Deshler

through the tests, training institutes, and toolkits they have developed, we have not found a way to let teach ers and parents drink from a spigot instead of from a

fire-hose that pumps out a geyser of water (Turnbull, A., & Turnbull, R., 2008).

One of the most pressing research questions of the day

may well be: What is the best evidence for how to trans

late knowledge and put it to use for students, teachers, and families? This question begets other questions: Are

teachers doing what research shows they should do, are

parents equally able to access the research in form and

style that they find useful, and are researchers making it

easy for teachers and parents to know what to do? Do

teachers' and parents' accumulated experiences inform

practice? Is policy favorable to best practice? In short, are parents and teachers able to take wisdom-based




action (Turnbull, A., & Turnbull, R, 2008)? In posing these questions, we ask them of ourselves.

Self-Reflection and Role; SLD Construct These questions bring us yet another Russian doll.

This doll is not painted like the other dolls. Instead, it is a mirror that demands self-reflection. It asks you: Do

you have the sense that "learning disabilities" is a some

what outdated construct. Below, I reflect some remarks

that one of my colleagues made to me recently. That colleague pointed out that the "pure LD" spe

cialist is no longer as prominent in today's schools as in

yesterday's. Roles such as "LD coordinators" or "LD

teachers" seem to have morphed as co-teaching becomes a norm. There also seem to be fewer "LD text

books" than before. The question facing organizations such as the Council for Learning Disabilities, my col

league says, is one of audience: Who are our members? What are their interests and roles?

More than this, says my colleague, some recent research shows that, over time, the reading skills of stu

dents with the SLD classification and those without the SLD classification seem to be similar even though the interventions for these students have been different. That research causes us to ask: Is the SLD student

really that different from a non-SLD student? In asking it, my colleague suggests, we must confront the fact that the construct we have called SLD may not be as defen sible and distinguishable as it once was. If my col

league's observations ring true for you, it is because my colleague has a finely tuned ear.

QUESTIONING THE MEANING OF THE CONSTRUCT CALLED DISABILITY

It may also be true that the entire construct called dis

ability has been scrutinized as never before since 1975, when Congress first enacted IDEA (as Education for All

Handicapped Children Act, P. L. 94-142). There is a com mon set of questions underlying the critique of the dis

crepancy standard, the option for RTI and the insistence on evidence-based interventions (EBI), the critique of the dependency model, and the meaning of "SLD."

These questions include the following: Who really has a disability? How many people have an authentic

disability? How many just learn and perform somewhat

differently than "the norm," and does that fact mean

they have a disability? In particular, are students with

specific learning disabilities really "disabled"? Are other

"high-incidence" students really disabled? These are not idle academic musings. Instead, they

are serious inquiries into the nature and meaning of

disability. In a variety of contexts, policymakers are

asking: What is "disability" and what is its relationship to education and other human service systems?

The Disability Construct, Special Education, and

Related Human Service Systems It behooves us to understand the changes that may

emanate from a close examination of the construct

called disability. To understand, we come to the largest of the Russian dolls - the one that represents human service systems. We can identify those systems and the

potentially good and bad news that they convey to us

in special education.

The Social Welfare System and Comorbidity One of the human service systems in this country is

the social welfare system. Special education links to it

because there is a powerful correlation between disabil

ity on the one hand and poverty, single-family status, and ethnicity/cultural/linguistic difference on the other. That's the bad news.

The good news is that family support policies can

blunt the correlation. That is, the more we strengthen families, such as by enlarging family and medical leave benefits and preserving the Supplemental Security Income programs, the more we can prevent disability.

The Health Care System and III Health as Precursors for Special Education

Another human service system is our health care sys tem. Special education links to it because children who are not born healthy, raised in healthy homes, nour ished well, and who are denied effective early interven tion and do not receive robust medical treatment become special education students. That's the bad news.

The good news abounds. We need only look at pro grams related to the State Children's Health Insurance

Program (SCHIP), mental health parity, Medicaid's EPSDT program (Early Periodic Screening, Diagnosis and Treatment), state insurance law reform for students with autism, reduction of Medicaid waiting lists,

enlargement of home and community-based services, personal assistance programs, and participant-directed

services, the recent enactment of the Kennedy Brownback Act (P.L. 110-374) offering prenatal coun

seling and postnatal information and support, the limited federally approved use of stem-cell research, and the support by the president-elect and key mem bers of Congress of the Community Choice Act (which would expand participant direction of federal medical insurance benefits).

The Criminal Justice System, Zero Tolerance, Manifestation Determination, Placements of Last

Resort, and School-Wide Positive Behavior

Supports A third human service system is the justice system.

That system has become the placement of last resort, or even the placement that some educators prefer when

they are ineffective in educating students who pose




significant behavioral challenges. Zero-tolerance poli cies push students out of school and into the justice system. Further, IDEA'S current discipline provisions

make it more difficult for a student to prove that his behavior is a manifestation of his disability and thus to

escape discipline that is meted out to nondisabled stu dents (20 U.S.C. Sec. 1415(k)) (Turnbull et al., 2006). Unable to invoke IDEA'S protection if he cannot prove manifestation, the student faces the justice system. In

short, his behavior is criminalized. The good news is that IDEA favors school-wide

positive behavior supports (PBS) (20 U.S.C. Sec.

1401(c)(5)(F)), and the use of PBS spreading. Moreover, some school districts offer alternative programs, thus

diverting some students from the justice system. In

reality, the justice system itself does not really want

students with disabilities.

The Employment System, Transition, and

Economic Self-Sufficiency A fourth system is the employment system. No mat

ter how effective our transition-to-work programs are,

employment eludes most students with disabilities.

And no matter how well Congress has "restored" the

Americans with Disabilities Act and rescued it from the

Supreme Court's anti-disability interpretations, the fact remains that economic self-sufficiency

- real work for

real wages in real jobs - will remain an aspiration, not

become a reality, for many special education students.

That is not because special education does a poor job in preparing students for transition and work; in many cases, it does an excellent job. Instead, it is because the

nation's present, and likely future, economic prospects are not bright. That's the bad news.

The good news is that more students with disabilities are accessing higher education than ever before; they will be more skilled to work and more likely to be

employed. Further, tax incentives for hiring people with disabilities benefit employers and employees alike. Asset development is a favored policy and can

assist people with disabilities in owning businesses

and being self-employed. Assistive technology makes

employment more accessible. And transition from

school is receiving more attention as IDEA and NCLB

become more focused on the outcomes than on the

processes of education.

The Social Security System, Disability Entitlements, and Cost Containment

A fifth system is the entire Social Security system.

Demographics pose a huge challenge to the Social

Security system as the wage-earning population is

shrinking compared to the benefit-taking populations. To contain costs means limiting eligibility and reduc

ing benefits in Medicare and Medicaid. Each approach

promises to make life more difficult for people with disabilities and their families; each puts pressure on the special education system to limit the number of students classified into special education and to train those in it to be more economically self-sufficient. That's the bad news.

The good news is that policymakers are favoring programs that allow people to work, even to accumu

late assets for independence, without losing their

benefits.

Special Education, Its Contexts, Arnold Toynbnee, George Orwell, and a Declaration of Values

There are other systems whose reformation benefits students with disabilities. Transportation and housing are the two most prominent. I do not need to belabor

my point. In a word, it is that special education -

especially the education of students with specific learning dis

abilities - exists in a context far larger than IDEA and

NCLB. If we are intent on improving special education for the benefit of the students, their families, and our

selves, we must pay attention to these factors and

forces and shape them as best we can to accommodate students and others with disabilities. Contexts outside

of special education shape our future. The English historian Arnold Toynbee famously

observed that history proves that, given a challenge, mankind never fails to respond and create a better new

world. Toynbee had it right. You special educators have

always been doing that. You will continue to do so.

Another Englishman, George Orwell, famously observed: Knowledge is power. As a student of the

human condition in a policy context, I have tried to

give you some knowledge to be powerful so you can

prove Toynbee right and again meet the challenges we face.

And as the father of a man who is now 41 years old

and has three disabilities, I must thank you for your contributions as educators and active citizens. With

me and my partner, Ann, you proclaim that less able is

not less worthy (Turnbull, 1976). Now, more than ever, we need to make the nation heed that declaration of

values.

REFERENCES ADA Amendments Act, P.L. 110-325

Americans with Disabilities Act, 20 U.S.C. Sec. 12101

Finn, C. E., Rotherman, A. J., & Hokanson, C. R. (Eds.). (2001).

Rethinking special education for a new century. New York:

Fordham Foundation and Progressive Policy Institute.

Government Performance and Results Act of 1993, P.L. 1-3-62.

Individuals with Disabilities Education Act (as amended), 20

U.S.C. Sec. 1401 et seq.

Kennedy-Brownback Act, P.L. 110-374.

LeCarre, J. (1975). Tinker, tailor, soldier, spy. New York: Scribners.




Personal Responsibility and Work Opportunity Reconciliation Act

of 1996, P.L. 104-193.

President's Commission on Excellence in Special Education.

(2002). Report Washington, DC: U.S. Government Printing Office.

Sutton v. United Air Lines, 527 U.S. 471, 1999.

Turnbull, A., & Turnbull, H. R. (2008). Whole L.I.V.E.S.: Wisdom

based action for transition. Proposal to U.S. Department of

Education, National Institute on Disability and Rehabilitation

Research, by Beach Center on Disability, The University of

Kansas.

Turnbull, A., Turnbull, R., 8c Stowe, M. J. (2008). Knowledge to

action framework. Proposal to U.S. Department of Education, Office of Special Education, by Beach Center on Disability, The

University of Kansas.

Turnbull, H. R. (2008). Judicial reveries: The Supreme Court

encounters disability. Kansas Journal of Law and Public Policy,

17(3), 509-519.

Turnbull, H. R., Stowe, M. J., & Huerta, M. E. (2006). Free appropri ate public education (6th rev. ed.). Denver: Love Publishing Co.

Turnbull, H. R. (2005). Individuals with Disabilities Education Act

Reauthorization: Accountability and personal responsibility. Remedial and Special Education, 26(6), 320-326,

Turnbull, R. (1976). Families in crisis. In T. Tjossem (Ed.), Intervention strategies for high risk infants and young children (pp.

776-779). Baltimore: University Park Press.

U.S. Department of Education. (2007). Annual report to Congress on

the implementation of the Individuals with Disabilities Education Act. Washington, DC: Author.

Please address correspondence about this article to: H. Rutherford

Turnbull III, Beach Center on Disability, The University of Kansas, 3111 Haworth Hall, 1200 Sunnyside Drive, Lawrence, KS 66045; e-mail: [email protected]




today's policy contexts for special education and students with specific learning disabilities

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