“…As a result, how LEAs determine eligibility for ESY services is quite varied. In determining eligibility for ESY services, the courts have suggested, but not required, a regression-recoupment standard for LEAs to apply (Burke & Decker, 2017; Sobeck, 2017). Under this standard, a student’s need for ESY services is a function of whether the student is deemed likely to “substantially regress” (Queenan, 2015, p. 168) over the summer break without being able to readily recoup those losses (i.e., typically within the first 6 weeks of school) (Queenan, 2012, 2015).…”