APA Comments on the Goals and Performance Measures for the Individuals with Disabilities Education Act (IDEA) -- July 2004

July 2, 2004
Stephanie Smith Lee
Director
Office of Special Education Programs

U.S. Department of Education
550 12th Street, SW, Suite 400
Washington, DC 20004

Dear Ms. Lee:

On behalf of the 150,000 members and affiliates of the American Psychological Association (APA), I am writing to provide comments on the draft Goals and Performance Measures proposed by the Office of Special Education Programs (OSEP) for the Individuals with Disabilities Education Act (IDEA). APA, the world's largest organization representing the field of psychology, has a long-standing commitment to promoting the optimal development and education of children. APA's membership includes researchers, practitioners, and educators whose work has played a pivotal role in our society's understanding of the cognitive, social, and emotional development of children. Prevention and intervention efforts to promote children's academic performance and emotional adjustment have also been a long-term focus of our members.

APA recognizes OSEP for its commitment to promoting best practices in the field of special education. This has helped ensure that all children receive "a free, appropriate public education" and the opportunity to succeed and reach their full potential. The proposed IDEA Goals and Performance Measures place an important emphasis on helping families with children with disabilities and on early intervention efforts. Early intervention services have been shown to be cost effective and to achieve desired results when they are based on empirical research.

With respect to specific feedback, APA supports the suggestions for the IDEA Goals and Performance Measures presented by key organizational stakeholders at the June 29th meeting and offers the following additional comments for your consideration. As requested, these pertain to clarity, usefulness in establishing appropriate measurement strategies, and appropriateness for the long-term, desired outcomes of these programs. (While we are well aware of your tight timeframe, we trust that the final version of the document will reflect careful editing.)

Long Term IDEA Goals and Strategies

Item 1, Bullet 2
Although it is most common for a child's learning and behavior difficulties to be manifest before third grade, this is not always the case. Therefore, such intervention efforts need to be focused more broadly. This is especially true for immigrant and refugee children and for English as Second Language (ESL) students, as many school districts do not test until the student has spent three years in regular education.

Item 3, Bullet 1
It is essential to not only identify "knowledge and attributes" of teachers and service providers related to improved student outcomes but also to ensure that these are communicated in personnel training programs. Accordingly, a second bullet might be added as follows: "Enhance special education personnel training program curricula with the knowledge and attributes found to be effective for highly qualified personnel."

Item 5
In light of IDEA's mandate that services be individualized, not every student with a disability will pursue postsecondary education. The goal is to provide the means for individuals with disabilities to live as fully productive and independent lives as possible. This may be achieved through education and/or employment. Accordingly, APA suggests that this item be reworded as follows: "Children with disabilities will graduate and be prepared to complete postsecondary education, become gainfully employed, and/or live independently..."

Part B - Grants to States

Objective 1
While the goal of 100% of children with disabilities meeting or exceeding basic levels in reading or math on federal and state assessments is laudatory and consistent with the goals of the No Child Left Behind Act, it is generally recognized that this is not a feasible standard. While the 100% goal may motivate schools to perform better, it would be useful to develop a more realistic standard for all students.

Part D - Research and Innovation

Objective 1, Indicator 1.2
This states that all research and development projects addressing causal questions will employ randomized experimental designs within ten years. APA is concerned that this gold standard for research may not always be possible to attain due to ethical concerns (e.g., withholding promising treatment from a control group) or for other reasons. Consequently, this goal would be better worded as follows: "By 2013-2014, projects that address causal questions will employ randomized experimental designs, when appropriate."

In closing, we wish to commend the Office of Special Education Programs for developing and soliciting comments on the Goals and Performance Standards for IDEA to help ensure the best educational experience for our nation's children with disabilities. We hope that our comments will be of help to OSEP and to the Department in finalizing this document. If APA can be of any further assistance to you in this process, please contact Jeff McIntyre of our Public Policy Office at 202-336-6064.

Sincerely,

L. Michael Honaker, Ph.D.
Deputy Chief Executive Officer/
Chief Operating Officer