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Teachers + Families = Success for All Students

Six Things to Never


Say or Hear During
an IEP Meeting
Educators as Advocates
for Families
Gregory A. Cheatham 冨 Juliet E. Hart

Ida Malian 冨 Joan McDonald

Education professionals and parents disabilities, others do not (Pugach, Current research on parental reports
need to be able to understand federal 2005; Wolery & Odom, 2000; Young, of their experiences during the IEP
requirements for individualized educa- 2008), citing lack of resources, class process suggests that favorable percep-
tion program (IEP) meetings, both to size, and inadequate training for tions are the exception rather than the
ensure compliance and also so that teachers (Carlson, Brauen, Klein, norm. In their review of 10 studies on
TEACHING Exceptional Children, Vol. 44, No. 3, pp. 50-57. Copyright 2012 CEC.

they are able to recognize potential Shroll, & Willig, 2002). Similarly, parental views of the IEP process pub-
violations. Part of this understanding schools may provide families with lished since 2004, Reiman, Beck,
should include knowledge of certain little helpful information regarding Coppola, and Engiles (2010) found
“core principles” of the Individuals IDEA (Lake & Billingsley, 2000)—or only one study reporting that the
With Disabilities Education Act (IDEA; majority of parent participants indicat-
provide them with information that’s
2006): zero reject, nondiscriminatory ed overall positive experiences (i.e.,
not easy to understand (Fitzgerald &
evaluation, individualized and appro- Fish, 2008). The remaining studies
Watkins, 2006; Mandic, Rudd, Hehir,
priate education, least restrictive envi- indicated that parents felt high levels
& Acevedo-Garcia, 2010). Thus, many
ronment, procedural due process, and of dissatisfaction during IEP meetings,
families may face challenges in their
parent participation (H. R. Turnbull, with parents citing difficulty process-
pursuit of an IDEA-mandated equitable
Stowe, & Huerta, 2007). ing the information (Stoner et al.,
Although many schools have made education for their children with dis- 2005), being intimidated by educators
significant strides in providing special abilities (Harry, 2008; Hess, Molina, & and blamed for their children’s aca-
education services to students with Kozleski, 2006); these struggles are demic and behavioral difficulties (Fish,
disabilities, recent studies indicate that evidenced by the frequency of adjudi- 2006), and being relegated to roles in
many barriers still exist to fully imple- cated due process hearings nationwide which their participation was limited
menting IDEA. For example, although (i.e., approximately 2,800 per year; to listening to information about their
some general and special educators Zirkel & Gischlar, 2008)—which likely child’s education, answering ques-
and school administrators support represents only a proportion of fami- tions, and signing preset forms on stu-
inclusive services for students with ly–school disputes. dents’ goals (Childre & Chambers,

50 COUNCIL FOR EXCEPTIONAL CHILDREN


2005). These findings underscore the • Zero reject: All students with disabil- mutually accountable; these safe-
importance of supporting educators ities are entitled to a free appropri- guards also provide dispute resolu-
with research-based recommendations ate public education (34 C.F.R. §§ tion procedures (34 C.F.R. §
for enlisting parents as collaborators 300.121 and 300.122; Timothy W. v. 300.507[a] and 300.508[a]–[c]).
during the IEP process. Rochester School District, 1989). • Parent participation: Parents and
When educators and parents collab- • Nondiscriminatory evaluation: students with disabilities are part-
orate to confront and resolve disputes, Assessment of students with or sus- ners with educators in decision
parent satisfaction with special educa- pected of having a disability must making about students’ education
tion services can increase (Mueller, be fair (34 C.F.R. § 303.323). (34 C.F.R. § 300.345).
Singer, & Draper, 2008). The Council • Individualized and appropriate edu- IEP team members must also have the
for Exceptional Children’s (CEC) best cation: Students with disabilities confidence to speak up when its man-
practice recommendations for collabo- must receive individualized services dates are not being followed. In this
ration (2009) provides guidance for to provide a beneficial education
way, special educators can speak up in
parents and educators to work together (34 C.F.R. §§ 300.320–300.324).
response to things that should not be
in the best interest of the student. • Least restrictive environment (LRE): said during IEP meetings.
Some first steps towards productively To the greatest extent beneficial, Following are six illustrative case
addressing conflicts that may arise dur- students with disabilities should be vignettes, which include statements
ing the IEP process include IEP team educated in a typical setting with that parents and professionals should
members understanding the IDEA students who do not have disabili- not hear at IEP meetings, a commen-
requirements, including the core princi- ties (34 C.F.R. § 300.550[b][1] and tary about each case vignette, and sug-
ples of IDEA (H. R. Turnbull & Turn- [2]). gested responses for educational pro-
bull, 1998; H. R. Turnbull, Stowe, & • Procedural due process (safeguards): fessionals should they encounter situa-
Huerta, 2007) listed below: Schools and parents hold each other tions similar to those in the vignette.

TEACHING EXCEPTIONAL CHILDREN 冨 JAN/FEB 2012 51


1. The Time Saver level of academic achievement and about Jonas and, like you, we’d like to
functional performance (34 C.F.R. § work together to develop the best IEP
At a recent IEP meeting, Jonas’s 320[a]), which leads to collaborative goals for Jonas that we can.”
mother entered the conference room development of IEP goals during the
and enjoyed a friendly chat with the IEP meeting. The IEP team determines 2. The LRE Plea
general education teacher, special which goals are most appropriate and
education teacher, and the school most likely to meet the individual Marissa is an energetic 5-year-old
principal. The group began the for- needs of the student. This individual- with communication and cognitive
mal part of the meeting by sharing ization and personalization means that delays, previously served successful-
their concerns for 15-year-old Jonas the team must adapt any “off-the- ly in an inclusive preschool setting.
at school. Jonas’s mother said that shelf” goals to meet the individual stu- At the start of Marissa’s IEP meet-
she had been worried about Jonas’s dent’s needs. ing, Marissa’s parents were happy to
math skills for years. At the time of Moreover, IDEA requires that par- learn that the professionals at their
the IEP meeting, he continued to lag ents must be provided opportunities daughter’s new elementary school
behind his peers, but had made for meaningful participation in any dis- seemed to have collaborated effec-
progress. The teachers confirmed cussion of their children’s education tively with her previous preschool
that Jonas continued to have difficul- (34 CFR § 300.322). Clearly, Jonas’s teachers. However, when discussing
ty with math problem solving, in mother was excluded from collaborat- the setting for her special education
both science and math class, despite ing with the other IEP team members services, the educators were reluc-
the help of his special and general regarding Jonas’s goals. Simply reading tant to place Marissa in a general
education teachers. The special edu- a list of predetermined goals and ask- education kindergarten setting.
cation teacher said, “Good news! We ing for a parent signature does not “Because she’s new to kindergarten
have a new book with tons of IEP engage parents in collaborative deci- and to the school,” one teacher
goals. We picked a few and entered sion making; instead, it relegates them said, “let’s see how well Marissa
them on the IEP. So the IEP’s all to recipients of the school profes- does in a resource room or self-con-
done. I’ll read the goals and then sionals’ decisions (A. Turnbull, Turn- tained classroom before we place
you can sign here.” bull, Erwin, Soodak, & Shogren, 2010). her in a more inclusive setting
School personnel can enhance parent where she may be overwhelmed.”
participation by allowing sufficient Marissa’s parents were disappoint-
Special education professionals are
ed, because they strongly believed
seemingly always pressed for time. Any time for meetings, refraining from com-
Marissa benefited from being edu-
strategy that can save time is valuable. pleting forms in advance of parental
cated with her typical peers and pre-
This vignette involves two principles of input, and perhaps even providing par-
viously had been successful in this
IDEA that are relevant to Jonas’s math ents with a copy of draft IEP goals and
type of setting.
goals: individualized/appropriate edu- objectives a few weeks before the
cation and parent participation. First, meeting. All of these actions are part of
to meet IDEA requirements for an indi- a democratic process that enhances Many educators are apprehensive
vidualized appropriate education, spe- parental sense of ownership as team about inclusive settings. Some believe
cial education teachers must support members (Blue-Banning, Summers, that students with disabilities need
students’ access to the general educa- Frankland, Nelson, & Beegle, 2004; specialized settings outside of the gen-
tion curriculum and meet state stan- Fish, 2006, 2008). Instead of a directive eral education classroom to best access
dards (U.S. Department of Education, to sign an IEP absent meaningful individualized instruction (Kavale &
2010). Goals and objectives should be parental input, what IEP team mem- Forness, 2000). Others may not believe
developed as a team, on the basis of bers should hear is the friendly buzz of students with disabilities should be
formal and informal assessment data voices as educators and parents work held to the same academic standards
regarding the child’s current strengths together toward understanding and as students without disabilities (Agran,
and weaknesses gathered through a agreement about the students’ Alper, & Wehmeyer, 2002), which can
nondiscriminatory evaluation (A. strengths and areas for improvement, lead to recommendations like that of
Turnbull, Turnbull, & Wehmeyer, 2010; which naturally leads to individualized the educators on Marissa’s team.
34 CFR § 303.322). Although a “bank” goals and objectives. However, the IDEA principles of
of IEP goals can be a productive place least restrictive environment (LRE) and
to start the process of identifying stu- ✔ The Right Response appropriate education apply here. LRE
dent goals (and many school districts Instead of “I have already prepared the guarantees a student’s right to be edu-
provide them), these resources may not goals; please sign here,” educators cated in the setting most like that for
be appropriate as goals to meet an should emphasize, “I think we can all peers without disabilities wherein the
individual student’s needs. IDEA agree how important it is to work as a student can be successful with appro-
requires teachers to gather assessment team for Jonas. Other IEP team mem- priate supports and services (Palley,
data to determine the student’s present bers have important things to share 2006; 34 C.F.R. § 300.550[b][1] and

52 COUNCIL FOR EXCEPTIONAL CHILDREN


[2]). The result is a presumption of about ideas for strategies to support resources (34 C.F.R. § 300.321[a]).
educating students with disabilities in her, we’ll feel confident in providing During IEP meetings, the LEA repre-
general education settings; this pre- Marissa the opportunity to start off in sentative has the responsibility to (a)
sumption may be set aside by the team the kindergarten classroom.” make sure the appropriate special edu-
(which includes the parents) only after cation services are provided to the stu-
intensive supports, supplementary 3. Who’s in Charge? dent and (b) supervise and commit
aides, and services have been provided resources for those services listed on
in the general education classroom Suzie is a third grader who loves the IEP. It is the responsibility of the
without success (Friend & Bursuck, science. She has a specific learning LEA representative and the other mem-
2009). Therefore, the discussion of disability in reading decoding and bers of the IEP team to ensure that
Marissa’s placement must begin with comprehension. The IEP meeting these decisions and responsibilities are
consideration of the general education included the special education met and that procedural safeguards
setting before moving to a discussion teacher, the general education regarding the participation of appropri-
of more restrictive settings—instead of teacher, the speech/language pathol- ate team members are followed. The
the reverse. The IEP team should also ogist, and Suzie’s mother, and was IEP team should be appropriately con-
outline the continuum of services avail- going very well. After developing vened (i.e., all required members pres-
able to Marissa and meet the IDEA the IEP goals based on the state ent) before proceeding. This means
requirement for appropriate education standards (as required by IDEA, 34 that the team members include the
by tailoring a program to meet her C.F.R. § 200.1[f][2][ii][B]), they special education teacher, the general
individual needs. determined Suzie should receive 2 education teacher, a representative of
Universal design for learning is a hours a week of speech/language the district/school who has the author-
research-based strategy that promotes services to meet her academic goals. ity to release the resources of both time
inclusion of students with disabilities However, no local education agency and personnel, the parent, and any
(A. Turnbull, Turnbull, & Wehmeyer, (LEA) representative, such as the other required member necessary to
2010) and can result in academic and principal or special education direc- conduct the IEP meeting.
social benefits for all students (Cole, tor, was present (or designated) at
Waldron, & Majd 2004; Idol, 2006; the meeting, as required by IDEA. ✔ The Right Response
McGregor & Vogelsberg, 1998; Salend & As the meeting was winding down, In planning the IEP meeting, educators
Duhaney, 1999; see www.cast.org/udl). the special education teacher said, should ensure that everyone who is
The IEP team meeting should include a “I need to check with the special required to be at the meeting attends.
discussion of the specific techniques education director before determin- At the beginning of the meeting, the
and adaptations that address Marissa’s ing the recommended level of team should be able to answer the
presenting areas of need and how speech/language services for Suzie” question “Which IEP team member is
these can be integrated as part of the and left the meeting room to get the
ultimately responsible to supervise and
teacher’s instructional delivery natural- LEA’s signature.
ensure that appropriate educational
ly and throughout the course of the services will be provided for this
school day. child?”

School personnel can enhance parent participation by allowing 4. The Search Ain’t Over
Until It’s Over
sufficient time for meetings, refraining from completing forms in
advance of parental input, and perhaps even providing parents with a Johnny is a fifth-grade student
whose IEP meeting started off
copy of draft IEP goals and objectives a few weeks before the meeting. congenially until it came to
addressing IEP goals—when
The salient IDEA principle in this Johnny’s parents noticed that his
✔ The Right Response situation is the assurance of proce- proposed reading goals were nearly
The IEP meeting should include a fruit- dural safeguards (i.e., due process the same as those in his IEP from
ful discussion about the availability of rights; 34 C.F.R. § 300.507[a] and the previous school year. When his
strategies for supporting the student in 300.508[a]–[c]). Procedural due process father asked why, the special
the least restrictive environment. A ensures that schools carry out IDEA education teacher explained, “I
teacher can say, “I can appreciate your principles. IDEA mandates that the IEP don’t know what else to try with
concerns for Marissa’s success given team include a representative of the him. He has not improved this year
the new challenges she and all of the school system who is qualified to pro- even after I’ve tried every strategy
other new students will experience in vide or supervise special education and to help him attain his goals and
the kindergarten classroom. I have no is also knowledgeable about the general nothing works.”
doubt that if we put our heads together education curriculum and school

TEACHING EXCEPTIONAL CHILDREN 冨 JAN/FEB 2012 53


The IDEA principle of an individual- student, how long each strategy was
ized/appropriate education (34 CFR §§ used, and evidence illustrating the
300.121 and 300.122) is important effectiveness of use, the team might
here. The key word in the vignette is instead ask the teacher, “Have you
everything. At times, teachers continue discussed this challenge with other
to implement familiar strategies rather professionals to see if they have any
than investigating different research- other research-based teaching sugges-
based interventions or discussing tions?” or “What kinds of professional
ideas for strategies with parents and development could benefit the IEP
other professionals. After an IEP is team’s decisions about instructing
written for a student, it is the respon- Johnny?”
sibility of the special education
teacher to continually measure 5. Pass The Buck
progress against the IEP goals. This
can be accomplished through system- Nick is an 11th-grade student with
atic progress monitoring—when teach- learning disabilities who is in an
ers assess student performance on a inclusive class for mathematics for
regular basis to determine whether the first time this year. At the IEP
meeting, the mathematics teacher
children are benefiting from instruc-
shared some positive comments
tion, implement research-based strate-
about Nick’s behavior in class but
gies, and then monitor students’
struggled when describing Nick’s
progress or lack thereof (Fuchs &
mathematics performance: It
Fuchs, 2003). The special education
seemed to him that Nick viewed
teacher’s role is similar to that of a
high school as more about socializ-
detective: to research instructional
ing than academics. In frustration,
strategies while also collecting data to
the mathematics teacher blurted
determine if the strategy is effective,
out, “Look, honestly, Nick, you are
and to discard those strategies that are
just not interested in mathematics
ineffective (i.e., strategies that do not
like the other students. I prepare for
help students make progress on their
the class each day. I have asked you
IEP goals).
a million times how you learn best
School districts must provide ongo-
and you always reply, ‘I don’t
ing training for teachers regarding
know.’ Perhaps if he spent an hour
research-based instructional strategies
or two at home each night on math-
to meet the needs of individual stu-
ematics and you [his parents]
dents with disabilities. The parent can
encouraged him to do better at
also be a resource for ideas regarding other students who have similar chal-
school, we wouldn’t have this prob-
the child’s learning style, which may lenges. Student outcomes can suffer;
lem. Or if not, we could refer him to
help in researching appropriate strate- according to Kerr and Nelson (2010),
a separate class that caters to stu-
gies. Discussing interventions with parents may avoid interactions with
dents who are not motivated where
other professionals (e.g., administra- school personnel because of perceived
he can be more successful.”
tors, school social workers, psycholo- blaming by teachers. It is incumbent
gist, curriculum specialists, and/or upon the school staff to invite parents’
other teachers) is also a way to discov- Two principles of IDEA apply here: LRE suggestions and their participation in
er ideas to implement with the student. and parent participation. Teachers in their student’s education. Friend (2011)
The U.S. Department of Education content-area classes may not have admonished teachers to be aware of
refers states and districts to some received adequate preparation for parents’ diverse understandings of their
Internet web sites, which supply quali- inclusive practices (DeSimone & children’s special needs and empha-
ty information regarding research- Parmar, 2006). As frustration grows, sized that the teacher’s responsibility is
based strategies (e.g., http://nichcy. particularly because the other students to overcome negative perceptions, to
org/research/basics/disabilities, http:// in the class seem to grasp concepts offer help to families, and to provide
www.nectac.org/topics/evbased quickly, teachers may assume that the services that are exemplary and appro-
/evbased.asp). home environment is to blame. priate to the individual student. In this
Consequently, they may recommend case, a mutual sharing of information
✔ The Right Response alternative placements for the student’s regarding Nick’s specific math chal-
After reviewing the list of strategies “own good,” placing the student in a lenges should have set the agenda for
that have been implemented with the more restrictive environment with the discussion.

54 COUNCIL FOR EXCEPTIONAL CHILDREN


ences of the school year. Further, stu-
dents who were involved with the stu-
dent-led IEP process felt greater
empowerment when they were actively
involved in their decision-making
process (Barrie & McDonald, 2002).

✔ The Right Response


During the IEP meeting, teachers
should stress the common goal of
meeting the student’s needs (e.g., “We
are all concerned about Nick’s suc-
cess.”). Asking IEP team participants to
highlight the student’s strengths can
help identify ways to enhance progress
toward goals. For instance, the math
teacher could say to the parent, “I
remember you said that Nick uses a
computer assisted design program at
home—he loves to construct buildings
and produce blueprints. You also said
that he rarely declines a math chal-
lenge. How do you think we could
incorporate some of Nick’s interests
into classroom activities and his learn-
ing goals?”

6. The Old Standby

Jacob is a friendly 13-year-old boy


with retinitis pigmentosa, a heredi-
tary eye disorder characterized by
progressive vision loss. Although he
has participated actively in school
programs (including general educa-
tion classes) over the course of his
Parents’ participation in decisions address the challenges Nick faced in
childhood, Jacob has experienced
regarding the education of their stu- class.
persistent visual loss, resulting in
dent with special needs is emphasized Nick himself should also be a criti-
significant low vision, and receives
in IDEA. Viewing parents as a support cal participant in the development of
special education services via an
for mutual academic and behavioral his IEP. Mason, McGahee-Kovac, and
IEP. Jacob’s family recently moved
goals rather than the source of the Johnson (2004) found that students
to a new school district in another
school problems should underlie col- who led their IEP meetings meaning-
state just at the start of the school
laborative efforts (Duchnowski, 2007; fully contributed to them, demon-
year. At the IEP team meeting, the
strated an understanding of their dis-
Eber & Keenan, 2004). Helping families educators told his parents that their
ability rights and accommodations,
support academic and behavior school did not serve students with
increased in their self-confidence, were
improvements made at school is an significant vision problems or stu-
able to self-advocate, interacted more
effective collaborative approach to dents who are blind, stating “We
positively with adults, assumed more
addressing inconsistency between don’t have the personnel to serve
responsibility for themselves, and were
home and school behaviors. Moreover, students with vision impairments.
more aware of their limitations as well
parents need to have input about inter- We always refer these students to
as the resources available to them;
ventions if they are expected to support the school for the blind, which has
moreover, parental participation
excellent programming for students
learning goals (Kerr & Nelson, 2010). increased. Students in Hawbaker’s
like Jacob and can better cater to
Nick’s parents needed the opportunity (2007) study consistently reported that
his unique needs.”
to communicate his successes at home leading their IEP meeting was one of
and to use those as a springboard to the most memorable learning experi-

TEACHING EXCEPTIONAL CHILDREN 冨 JAN/FEB 2012 55


School District, 1989). Although the the letter and spirit of IDEA. Although
team members may not believe that educators are typically well meaning in
they are refusing Jacob an appropriate their efforts to educate students with
education—because they are offering disabilities, some things should never
an alternative that they believe is a be said or heard during IEP meetings.
more appropriate placement—the team When education professionals know
is still subtly violating the zero reject the six principles of IDEA and words to
principle. Regardless of the nature or respond to potential violations of the
severity of the disability, the school principles, IEP teams can better meet
district has the responsibility to provide the needs of students with disabilities.
a free and appropriate education by
implementing the existing IEP or start- References
ing the assessment process to develop Agran, M., Alper, S., & Wehmeyer, M.
a new one. Schools must document (2002). Access to the general curriculum
for students with disabilities: What it
efforts to provide an appropriate edu- means to teachers. Education and
cation at the student’s home school Training in Mental Retardation and
and in the least restrictive environment Developmental Disabilities, 37, 123–133.
before determining an alternative set- Barrie, W., & McDonald, J. (2002). Adminis-
ting is more suitable to address the stu- trative support for student-led individual-
ized education programs. Remedial and
dent’s needs. Special Education, 23, 116–121. doi:10
.1177/074193250202300208
✔ The Right Response Blue-Banning, M., Summers, J. A., Frank-
Jacob’s school personnel showed a land, H. C., Nelson, L. L., & Beegle, G.
(2004). Dimensions of family and profes-
lack of effort to provide appropriate
sional partnerships: Constructive guide-
services, instead relying on “the old lines for collaboration. Exceptional
standby”; their recommendations were Children, 70, 167–184.
based on the way things had always Carlson, E., Brauen, M., Klein, S., Shroll, K.,
been done. A more appropriate & Willig, S. (2002, July). SPeNSE: Study
response to a situation like this would of personnel needs in special education.
Key findings. Washington, DC: U.S.
be for the teachers and parents to Department of Education Office of
emphasize the child’s strengths and Special Education Programs. Retrieved
previous services as outlined in his IEP. from http://spense.education.ufl.edu
For example, an educator could say, /KeyFindings.pdf
“Because Jacob’s parents knew that he Childre, A., & Chambers, C. R. (2005).
Many educators may have concerns
Family perceptions of student-centered
about serving students with relatively was slowly losing his sight, he has planning and IEP meetings. Education
low-incidence disabilities with which developed, with the help of his teach- and Training in Developmental Dis-
they may not be familiar. At the sec- ers, the necessary mobility skills to abilities, 40, 217–233.
ondary level, many teachers still move safely from class to class and Cole, C., Waldron, N., & Majd, M. (2004).
other skills to compensate for his low Academic progress of students across
believe students with severe disabilities
inclusive and traditional settings. Mental
cannot be appropriately served in gen- vision. He has always been placed with Retardation, 42, 136-144. doi:10.1352
/0047-6765(2004)42<136:APOSAI>2
.0.CO;2
Regardless of the nature or severity of the disability, Council for Exceptional Children. (2009).
What every special educator must know:
the school district has the responsibility to provide a free Ethics, standards, and guidelines. Arling-
ton, VA: Author.
and appropriate education by implementing the existing IEP DeSimone, J. R., & Parmar, R. S. (2006).
Middle school mathematics teachers’
or starting the assessment process to develop a new one. beliefs about inclusion of students with
learning disabilities. Learning Disabilities
Research & Practice, 21, 98–110. doi:10.
eral education classes or even in their his same-age peers and we should con- 1111/j.1540-5826.2006.00210.x
neighborhood schools (Smith, 2000). tinue that level of service. Let’s consult Duchnowski, A. (2007, October). The role of
The IDEA principle of zero reject with the state school for resources and mental health services in school-wide PBS.
applies in this case: special education support to help us with Jacob here.” Paper presented at the Forum on School-
Wide Positive Behavior Interventions and
services must be available wherever
Final Thoughts Support: Planning for Systems Change,
there are students who qualify for its Chicago, IL.
benefits (A. Turnbull, Turnbull, & Weh- Families and schools face many chal- Eber, L. & Keenan, S. (2004). Collaboration
meyer, 2010; Timothy W. v. Rochester lenges as they work toward following with other agencies: Wraparound and

56 COUNCIL FOR EXCEPTIONAL CHILDREN


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In R. B. Rutherford, M. M. Quinn, & S. R. /074193250002100407 Timothy W. v. Rochester School District,
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Families, professionals, and exceptionali-
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56–68. Turnbull, A., Turnbull, R., & Wehmeyer, M.
son, L. (2004). How to help students lead
Fish, W. W. (2008). The IEP meeting: Per- their IEP meetings. TEACHING Excep- (2010). Exceptional lives: Special educa-
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