The 2009 Forest Grove School District v. T.A. United States Supreme Court case could have significant implications for school psychology practice. The Court ruled that the parents of a student with a disability were entitled to private school tuition reimbursement even though T.A. had not been identified with a disability or previously provided with special education services. The district multidisciplinary team had not identified T.A.’s disability in part because of a limited psychoeducational evaluation that did not assess him in “all areas of suspected disability” which is a requirement of the Individuals with Disabilities Education Act (IDEA; 20 U.S.C. § 1414(b)(3)(B)). Dissatisfied with the team’s decision, the parents sought an independent comprehensive evaluation of T.A.’s psychological processes which revealed the full nature of his disability and needs. Although T.A. had been unresponsive to interventions in his home school, this comprehensive psychoeducational evaluation led to more targeted interventions in his private school placement and likely contributed to T.A.’s subsequent academic and behavioral success. This Supreme Court case highlights the need for school-based teams to conduct comprehensive evaluations in all areas of suspected disability, including psychological processes such as attention, memory, and executive function. The relevant IDEA 2004 and governing 2006 federal regulations are presented, followed by recommendations for school psychologist assessment practices to ensure compliance with IDEA statutory and regulatory requirements.
Attention problems are ubiquitous in clinical practice, commonly found in many childhood learning and behavior disorders. Practitioners need cost- and time-effective methods for determining whether children have attention problems due to attention-deficit/hyperactivity disorder (ADHD) or numerous other conditions. This study examined the utility of a 15-minute ADHD screening battery designed to differentiate ADHD (including inattentive, IT, and combined, CT, subtypes), specific learning disability (SLD), and typical child samples. Results for the 368 children (age 6 to 12 years) revealed that the Trail Making Test-Part B (Time/Errors), Hale-Denckla Cancellation Test (Time/Correct), and Child Attention Profile (Inattention/Overactivity) teacher ratings discriminated between typical and ADHD groups (87% correct classification; sensitivity = .64; specificity = .92) and differentiated between IT, CT, and SLD groups (80% correct classification; IT sensitivity = .82, and specificity = .96; CT sensitivity = .84, and specificity = .82). Discriminant function and Bonferroni post hoc results revealed different neuropsychological and behavioral patterns among groups.
In this issue, Professor Perry Zirkel argues that the points presented in the Dixon, Eusebio, Turton, Wright, and Hale treatise of the Forest Grove School District v. T.A. Supreme Court case confuses "legal requirements with professional norms." Although we appreciate Zirkel's acknowledgment that our position reflects the professional norm-that comprehensive evaluation of psychological processes is critical for identifying children with learning and other disabilitiesthis position does not equate with "confusion" regarding the Individuals with Disabilities Education Improvement Act statutory or regulatory requirements, or legal precedents, presented in Dixon et al. On the contrary, Dixon et al. specifically address all three requirements in their article, suggesting Zirkel's rebuttal is not supported. The resultant effects of Zirkel's arguments on public opinion, professional conduct, and individual children served by the law will be elucidated in this rebuttal.
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