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Administrative Advocacy
- CLE Comments to NPRM RE: Civil Rights Data Collection (November 10, 2009) (PDF)
- CLE Urges Department of Education to Correct Misinterpretation Allowing Districts to Reduce Maintenance of Effort under IDEA (PDF)
- Comments by CLE (Attorney Joanne Karger) to MA Grad. & Dropout Prevention & Recovery Commission (4/29/09) (PDF) Comments in Response to the Commission's Legislative charge, reflecting CLE's position that the most effective way to address the dropout problem is to ensure that students receive the high-quality education to which they are entitled under law and that students not be deprived of an education as an administrative response to problematic behavior.
- Testimony (Boundy) RE: proposed Title I/NCLB Regulations, USED Public Hearing, Boston (5/14/08) (PDF) Limited Testimony on Proposed Regulations to No Child Left Behind RE: Failure to Require Use of Multiple Measures in Assessment and the Graduation Rate recommending the use of a cumulative graduation rate formula to include students who graduate in more than four years after being retained or dropping out.
- CLE Comments to USED in response to Notice of Proposed Rulemaking under IDEA, May 13, 2008 (PDF) Comments in response to USED’s proposed regulations authorizing the right of parents to revoke unilaterally consent to their child's receipt of special education services and continuing obligations of the LEA and proposed modifications allowing lay advocates to represent parents at due process hearings.
- CLE Solicitation for Feedback to PTIs and CPRCs re: NPRM (May 13, 2008) Revocation of Consent under IDEA (PDF) A series of questions and discussion points for parents and advocates to consider.
- CLE Comments to USED in response to NPRM (April 23, 2008) RE: Title I addressing need need for Multiple Measures to ensure test validity and fairness (PDF)
- CLE Comments to USED in response to NPRM (March 24, 2008) RE: Family Educational Rights Privacy Act (FERPA) (PDF) Comments support importance of confidentiality requirements of IDEA within FERPA, concerns about eroding rights and protections of students, when prior consent is not required for disclosure of personally identifiable information, including to third party contractors and school volunteers.
- Brief Overview of IDEA Regulations re/Revocation of Consent for Special Education, et al. effective Dec. 31, 2008 (PDF) CLE disseminated to its networks a brief description of changes resulting from USED’s final regulations on selective issues pertaining to revocation of consent for special education, non-attorney parent representation at due process hearings, state monitoring and enforcement.
- CLE Testimony (Boundy) RE: Family Involvement under Title I/NCLB, Hearings convened by Public Education Network, Boston (1/11/06) (PDF) Testimony underscores areas of concern that students, including those with disabilities and English language learners, are not being taught to high level standards; are not being assessed using multiple measures; and parent communities are not adequately involved in school improvement efforts as required by NCLB.
- CLE Comments to USED, in response to NPRM regarding IDEA Amendments of 2004, issued June 21, 2005 (PDF) CLE submits a fairly extensive set of comments to the Office of Special Education & Rehabilitative Services responsive to the office’s proposed regulations under the IDEA, as amended.
- Letter (Boundy) to Hon. Margaret Spellings, Secy. U.S. Dept. of ED, re/modified assessments of students with disabilities (3/22/05) (PDF) Letter from CLE joined by the National Council on Independent Living, Advocacy Institute, National Down Syndrome Congress, National Down Syndrome Society, and TASH in opposition to USED's allowance of up to 2% of all students assessed based on modified achievement standards being counted as proficient scores from alternative assessments based on alternatives achievement standards.
- CLE comments in response to USED’s NPRM re/Modified assessments and students with disabilities, Title I/NCLB (Dec. 15, 2005) (PDF) CLE sets forth the bases for challenging USED’s proposed regulations authorizing assessment of students with disabilities based on modified achievement standards as drawing invalid inferences and discriminatory.
- CLE Comments to USED in response to the Request for Comments and Recommendations on Regulatory Issues Concerning IDEA 2004, issued December 29, 2004 (PDF) CLE submits 47 pages of comments identifying areas of concern where CLE believes that Department guidance through new regulations and/or modifications/deletions of existing regulations would be useful for effectively implementing the recently amended Individuals with Disabilities Education Improvement Act of 2004.
- CLE comments in response to USED's NPRM RE: Assessments under Title I/NCLB (May, 19, 2003) (PDF) CLE responses to Questions regarding Proposed Regulations for Title I, including Whether existing research supports setting the cap at 1% for students with the most significant cognitive abilities whose achievement can be measured against alternative standards? What implementation issues would arise from the definition of "studnets with the most significant cognitive abilities" at the school, local and state levels? Any issues with compliance with requirements seeking to reduce the regulatory burden of the program? How the Department of Education should continue to monitor and review the regulations once finalized?
- CLE comments to USED Office of Special Education and Rehabilitation Services on Report of the President's Commission on Excellence Regarding Education (Aug. 19, 2002) (PDF)
- CLE comments in response to USED NPRM RE: Title I/NCLB (Aug. 6, 2002) (PDF) CLE provides comprehensive and extensive set of comments to proposed regulations under Title I of ESEA, as amended by No Child Left Behind Act (XX pp).
- CLE comments in response to USED in response to NPRM RE: Standards and Assessments of Students with Disabilities, Title I/NCLB (May 5, 2002) (PDF) Comments submitted by CLE joined by the Citizens' Commission on Civil Rights and the National Council of La Raza on proposed Title I regulations on standards and assessments of students with disabilities, including concerns about use of norm-referenced testing and test validity with respect to state and local assessments, and lack of inclusion of parents in drafting the proposals, and other issues.
- CLE comments to USED, Office for Civil Rights draft publication: "The Use of Tests When Making High-Stakes Decisions" (June 6, 2000) (PDF) CLE’s extensive critique, General Comments and Specific Changes to Text of Draft, propose a more rigorous analysis of civil rights principles calling for more attention to real-world application of the ways that high-stakes tests are being used in the context of education reform, and heightened and more technical attention to questions pertaining to test validity.
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