AASA Joins 8 National Education Groups in Opposing New OSERS Guidance on Dyslexia

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Yesterday, AASA joined the Council of Administrators of Special Education, the National Education Association, the National Association of State Directors of Special Education, and several other groups in a letter to the U.S. Department of Education’s Office of Special Education and Rehabilitative Services requesting that the Department not issue new guidance or directives to schools encouraging the use of the terms dyslexia, dyscalculia, dysgraphia or any other medical or mental health diagnostic term within the context of IDEA procedures. This letter was in response to a letter sent in June by the National Center for Learning Disabilities and 13 other disability advocacy groups that maintains that guidance is needed because “schools may be reluctant” to use terms like dyslexia in a child’s IEP, instead opting to refer to the disability as a “specific learning disability.” They claim that "without indicating the specific terms dyslexia, dyscalculia, or dysgraphia when appropriate, this phrase [specific learning disabilities] on an IEP is simply too vague a description to communicate to a teacher that the child needs intensive, explicit, systematic, evidence-based instruction to make progress."

The rationale used to justify the requested guidance is of concern to AASA and other organizations because it assumes that the inclusion of the terms dyslexia, dyscalculia, and dysgraphia in an IEP will “ensure that the interventions goals and objectives outlined in the IEP match with the students’ specific needs.” In particular, there is an implication that "a diagnostic label alone dictates instructional programming which is completely counter to the individualization of instruction mandated by the IDEA. IDEA does mention dyslexia as an example of a medical or mental health diagnosis that might lead to a determination of IDEA eligibility in the category of learning disabilities along with perceptual disabilities, brain injury, minimal brain dysfunction, and developmental aphasia. However, it is not necessary for schools to include any of those terms in a student’s IEP to ensure appropriate services are provided because schools must already consider medical and mental health diagnoses in their eligibility determinations and instructional programming."

We believe advocates are requesting this guidance, and specifically clarification regarding the inclusion of these terms in an IEP, because they want to use these labels to force the hand of districts to use specific instructional methodologies or demand new or different services for students with learning disabilities that are not specific to “dyslexia” for example. However, the terms dyslexia, dyscalculia, and dysgraphia are derived from reference materials like DSM-V and ICD that represent medical and psychiatric criteria for diagnosis and classification. If OSERS were to use guidance that accepts a DSM-V for these specific issues as equivalent to assessments conducted under the guidelines set forth in IDEA, then eligibility for services would potentially be opened for all diagnoses contained within this manual. IDEA already mentions dyslexia as an example of a medical or mental health diagnosis that might lead to a determination of IDEA eligibility in the category of learning disabilities, so it is not necessary for schools to include any of those terms in a student’s IEP to ensure appropriate services are provided. Moreover, the body of research districts rely on to educate students with specific learning disabilities is well-established thanks to the National Reading Panel, the What Works Clearninghouse, etc., so the process, accommodations and services districts provide to students with specific learning disabilities would be unchanged.

 


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