Provision of SDI and Supports for Students with Behavioral Complexities

Students with complex behaviors are oftentimes placed in general education without sufficient support.  It is essential to ensure that these students receive specially designed instruction and all of the supports required by the IEP. Teachers must be aware of best practices, observant to triggers and have strategies to reduce them.  There are a limited number of students who, despite the use of best practices, continue to have consistent, extremely disruptive and occasionally dangerous behaviors in the general education environment.

Students who meet the qualifications under Emotional Behavioral Disorders must receive SDI to meet each of their unique individual needs. As with all students who qualify for special education services, they must receive SDI calculated to confer benefit in their Least Restrictive Environment. .

The Least Restrictive Environment decision for a student with emotional behavior needs can be complicated. The Holland v. Sacramento 9th Circuit Court decision provides some guidance:

Sacramento City Unified Sch. Dist. v. Rachel H.,14 F.3d 1398 (9th Cir. 1994). In applying this test, we consider:

  1. the academic benefits of placement in a mainstream setting, with any supplementary aides and services that might be appropriate;
  2. the non-academic benefits of mainstream placement, such as language and behavior models provided by non-disabled students;
  3. the negative effects the student’s presence may have on the teacher and other students; and
  4. the cost of educating the student in a mainstream environment. Id. at 1401, 1404.
  5. placement under the IDEA. Id. at 1402.

In a Clyde K v. Puyallup School District Case the Ninth Circuit Court justices applied the 4 part test from Sacramento City Unified Sch. Dist. v. Rachel H. 14 F.3d 1398 (9th Cir. 1994).

Clyde K. v. Puyallup School Dist. No. 3 35 F.3d 1396 (9th Cir. 1994) Decided Sep 13, 1994

the record indicates that Ryan’s presence in classes at Ballou had an overwhelmingly negative effect on teachers and other students. By March 1992, Ryan’s behavior had become dangerously aggressive: He violently attacked two students before being expelled for assaulting a school staff member. The record supports the district court’s finding that Ryan’s behavioral problems interfered with the ability of other students to learn. Disruptive behavior that significantly impairs the education of other students strongly suggests a mainstream placement is no longer appropriate.

Several Communiity Complaint decisions demonstrate the requirements for following the IEP and Behavior Intervention plans.

When planning to provide more time in general education, the IEP team needs to ensure that all of the supports called for in the IEP are provided. They must also monitor the student’s progress to document benefit.  In an analysis of Endrew the US Dept. of Education states in Ques. 16, “ Where necessary to provide FAPE, IEPs must include consideration of behavioral needs in the development, review, and revision of IEPs. (17) IEP Teams must consider and, if necessary to provide FAPE, include appropriate behavioral goals and objectives and other appropriate services and supports in the IEPs of children whose behavior impedes their own learning or the learning of their peers.”