Wallingford-Swarthmore School District | Case 22377-18-19 | 2019-07-01

This is a redacted version of the original decision. Select details have been removed from the decision to preserve anonymity of the student. The redactions do not affect the substance of the document. Pennsylvania Special Education Hearing Officer Final Decision and Order CLOSED EXPEDITED HEARING ODR File Number: 22377/18-19 Date of Hearing: June 26, 2019 Child’s Name: E.A. Birthdate: [redacted] Parents: [redacted] Counsel for Parents Pro Se Local Education Agency: Wallingford-Swarthmore School District 200 S. Providence Road Wallingford, PA 19086 Counsel for the LEA Amy Brooks Esquire Wisler, Pearlstine, Talone, Craig, Garrity & Potash Blue Bell Executive Campus 460 Norristown Road, Suite 110 Blue Bell, PA 19422-2323 Hearing Officer: Linda M. Valentini, Psy.D, CHO Certified Hearing Official Date of Decision: July 1, 2019

2 Background Student1 is a mid-teen aged, rising 10th grade District resident who is eligible for special education pursuant to the Individuals with Disabilities Education Act (IDEA) and Pennsylvania Chapter 14 under the classifications of emotional disturbance, autism, other health impairment and specific learning disability. As such, the Student is also an individual with a disability as defined under Section 504 of the Rehabilitation Act, 29 U.S.C. § 794 and a protected handicapped student under Pennsylvania Chapter 15.2 The Parents3 acting pro se requested this hearing because they believe that the District’s proposal for Student’s Extended School Year (ESY) program is inappropriate; they seek an order placing Student in a special needs camp program. The District maintains that its offer for ESY is appropriate and that the program sought by the Parents is inappropriate. Neither party disputes Student’s need for ESY services. 1 In the interest of confidentiality and privacy, Student’s name and gender, and other potentially identifiable information, are not used in the body of this decision. The identifying information appearing on the cover page or elsewhere in this decision will be redacted prior to posting on the website of the Office for Dispute Resolution as part of its obligation to make special education hearing officer decisions available to the public pursuant to 20 U.S.C. § 1415(h)(4)(A) and 34 C.F.R. § 300.513(d)(2). 2 20 U.S.C. §§ 1400-1482. The federal regulations implementing the IDEA are set forth in 34 C.F.R. §§ 300.1 – 300. 818. The applicable Pennsylvania regulations are set forth in 22 Pa. Code §§ 14.101 – 14.163 (Chapter 14) 29 U.S.C. § 794. The federal regulations implementing Section 504 are codified in 34 C.F.R. §§ 104.1 – 104.61. The applicable Pennsylvania regulations are set forth in 22 Pa. Code §§ 15.1 – 15.11 (Chapter 15). 3 Student’s mother corresponded in writing, attended meetings with District personnel and participated in the hearing. It is understood that she was acting on behalf of both herself and Student’s father. The singular “Parent” is used when appropriate.

3 The Parents’ Complaint/Hearing Request is dated June 18, 2019. Because the matter concerns ESY programming for summer 2019 the hearing was scheduled in accord with the mandated expedited ESY timelines – thirty (30) days from the filing of the complaint to the issuance of the final decision and order. The Parent subsequently requested in an email and again at the outset of the hearing to be granted a continuance in order to seek legal representation4. Her request was noted, but denied given the expedited timelines. Understanding that rapidly preparing for a hearing is difficult for a pro se parent with no previous experience with due process, I assigned the burden of proof regarding its proposed program to the District, while keeping the burden of proving the appropriateness of the Parents’ preferred program with the Parents. In weighing the testimonial and documentary evidence before me, as well as reading the parties’ written closing arguments, under the law I cannot award the Parents the relief they seek and must find in favor of the District. Issue 1. Is the District’s offer of ESY appropriate? 2. If the District’s ESY offer is not appropriate, is the Parents’ preferred program appropriate? 3. If the District’s offer of ESY is not appropriate, and the Parents’ preferred program is appropriate, are there equitable considerations that would reduce or eliminate the District’s obligation to fund the Parents’ preferred program? 4In an email dated June 13th the Parent expressed her intention to retain legal counsel but had not done so as of the date she filed the Complaint pro se. [S-13]

4 Findings of Fact5 1. Student is a mid-teen aged student who, in addition to the primary IDEA eligibility classification of emotional disturbance has also been classified as having autism, other health impairment and specific learning disability. Additionally Student carries the diagnoses of Attention Deficit Hyperactivity Disorder combined type (ADHD), Disruptive Mood Dysregulation Disorder, Major Depressive Disorder recurrent and Unspecified Anxiety Disorder. [S-9, P-1] 2. Student’s current IEP was created on November 29, 2018 and revised on June 6, 2019 at an IEP meeting convened to review an FBA and incorporate a new Positive Behavior Support Plan. [NT 45-46; S-9] 3. The IEP presents the following Academic needs: Develop written expression skills, develop spelling and (writing) mechanics, develop reading comprehension skills, develop math skills, develop visual- motor integration skills, and develop student skills. [NT 45-46; S-9] 4. As of mid-March 2019 Student’s reading level was listed as 5th grade, and math level was listed as 3rd grade. [S-13] 5. Student’s special education teacher estimates that Student is currently at 5th or 6th grade level with regard to written expression and reading, and on a 3rd to 4th grade level in math. [NT 92-93] 6. Although Student’s work output/completion decreases when Student is struggling with emotional regulation or navigating a social situation, Student’s special education teacher/case manager believes that 5 The transcript contains testimony as follows: Parent NT 19-74; Student NT 76-82 and 156- 161; Special Education Teacher/Case Manager NT 84-130; ESS Coordinator/Counselor NT 133-150; Director of Student Services NT 151-154.

5 Student’s learning disability affects Student’s learning more so than does Student’s emotional disturbance. [NT 91-93, 103, 112-113] 7. The IEP presents the following Behavioral needs: Control of behavioral responses, respect for adults and peers, following school rules, and acting appropriately in class and not disrupting other students’ learning. [S-9] 8. Student becomes irritated easily when people get into Student’s personal space or when Student is told to do things “over and over”. [NT 76-79] 9. Although Student can verbalize what should be done in given situations, in the moment Student frequently cannot implement an appropriate response. Student requires opportunities to practice learned social skills. [NT 30-32] 10. The ESY portion of the current IEP presents goals in the areas of written expression, reading comprehension, math, following directions, and appropriate peer interaction/expression. [S-9] 11. The District’s proposed ESY program is Extended Day Emotional Support to be provided at the District’s middle school. The program runs from July 8 through August 1, 2019, four (4) days per week, from 8:30 am to 1:30 pm. [S-9] 12. Emotional support services to be provided by the District through a local mental health center in the proposed ESY program are individual counseling once a week for 30 minutes and group counseling twice a week for 30 minutes. [S-9] 13. In addition to the emotional support services provided through the local mental health center, in the proposed ESY program Student would also receive outsourced services through a private counseling

6 agency: group counseling twice a week for 1 ½ hours and individual counseling once every other week for 30 to 50 minutes. [NT 134-138] 14. In the District’s ESY program the time period from 8:30 to 11:30 is focused on academics. Some students remain in the emotional support classroom for those academics, and other students go into some of the secondary classrooms for academics. From 11:30 to 1:30, group and individual counseling, social skills instruction, and social skills experiences such as swimming and cooking are offered. [NT 152-153] 15. A new Positive Behavior Support Plan (PBSP) based on a recent FBA will be implemented in the proposed ESY program.6 [NT 88; S-8] 16. The Parents’ preferred program runs from July 1 to August 16, five days per week, 9:00 am to 2:00pm. The three hours in the morning are governed by a mental health treatment plan that provides for mental health/behavioral health supports. These three hours are based on medical necessity criteria and are funded through medical assistance. From 12:00 to 2:00, the portion for which the Parents are seeking funding from the District, there are supervised group activities such as swimming which allow Student to practice the skills learned in the morning. [NT 38, 71-72] 17. The Parents’ preferred program does not offer academics. [NT 43, 153] 18. The Parent believes that the services through the private counseling agency during the regular school year (5 days a week 6 Although the Parent reportedly voiced her approval of the PBSP at the June 6th IEP meeting, in the course of the hearing the Parent said that she does not approve the revised PBSP and believes that it needs to be revised again. [NT 119-120, 125]

7 group counseling for up to 40 minutes and once a week individual counseling for up to 30 minutes) are not effective and believes that they will not be effective in the District’s ESY program. [NT 52-54] 19. Parent believes the ESY goals are appropriate but cannot be met in the District’s ESY program because of an over-riding need to address Student’s behaviors such as she believes would happen at the Parents’ preferred program. [NT 51] 20. One of Student’s private counseling agency group counselors 7 throughout the school year will also be a counselor in the proposed ESY program. Although Student was able to cooperate with this individual in group counseling during the school year, Student experiences this person’s presentation as “overdramatic” and “too hype” (overexcited) and feels that she needs to “chill out and stuff”. [NT 82-83, 156, 159-161] 21. As of the date of the hearing Student has been enrolled in and will be attending the Parents’ preferred program. [NT 42] 22. On April 12, 2019 the Parent had written to Student’s special education teacher/case manager saying that she had decided to send Student to the Parents’ preferred program “to work on social behavior” and “was wondering if you can help with that in any way”. She added that she believed “a change in space would be great for [Student] to develop [Student’s] social skills”. [S-13] 23. The teacher/case manager did not interpret Parent’s communication to be a request that the District designate the Parents’ preferred program as Student’s ESY program. [NT 99-101] 7 Not the counselor who testified at the hearing.

8 24. That afternoon the teacher/case manager replied that he was not familiar with the Parents’ referred program but “would be happy to help in any way” that he could. [S-13] 25. On April 30, 2019 the Parent emailed the teacher/case manager asking if the agency offering the Parents’ preferred program had contacted him. The teacher/case manager responded that day that he had been in touch with an individual from that agency who would be coming to the school to observe Student on May 7th. [S-13] 26. On April 30, 2019 the teacher/case manager emailed another District employee informing her that the Parents “would like to enroll [Student] in a Therapeutic Summer Camp” this summer, that a representative from the organization was coming to observe Student and asking if there was anything more needed on his end. [S-13] 27. Although the Parents did not notify the District in writing that they were seeking District funding for the afternoon portion of their preferred program, the Parent discussed funding for the first time at the end of the June 6th IEP meeting. [NT 43, 48-49, 96-97] 28. The Parent received a copy of the Procedural Safeguards at the June 6th meeting. [NT 46-47] 29. Pursuant to the June 6th IEP meeting the District issued a Notice of Recommended Educational Placement (NOREP) that included eligibility for ESY services. The Parent returned the Signed NOREP having checked the box indicating that she requested an informal meeting with school personnel. [S-10] 30. On June 13, 2019 the teacher/case manager emailed the Parent telling her that “the school based team is not able to recommend the [Parents’ preferred program] as an offer of FAPE for ESY services”. The email explains that the District has clear data that identifies

9 Student’s needs to be academic as well as social and that the District’s ESY program will address Student’s academic and social needs while the Parents’ preferred program “is solely a social skills program and would not address [Student’s] academic needs”. [S-13] 31. Several minutes later on that same date the Parent responded that she did not agree, noting, “I have been patient with your interventions but now I have to respectfully disagree and get a lawyer involved”. [S-13] 32. Shortly thereafter on that same morning the Parent noted that she would “like to change back to my original signature and decision on the FBA”. [S-13] 33. On June 14, 2019 the District issued another NOREP. On June 18, 2019 the Parent signed the NOREP disapproving the District’s ESY recommendation and checked the box indicating the Parents wanted a due process hearing. [S-11, S-15] Legal Basis Burden of Proof The burden of proof, generally, consists of two elements: the burden of production [which party presents its evidence first] and the burden of persuasion [which party’s evidence outweighs the other party’s evidence in the judgment of the fact finder, in this case the hearing officer]. In special education due process hearings, the burden of persuasion lies with the party asking for the hearing. If the parties provide evidence that is equally balanced, or in “equipoise”, then the party asking for the hearing cannot prevail, having failed to present weightier evidence than the other party. Schaffer v. Weast, 546 U.S. 49, 62 (2005); L.E. v. Ramsey Board of Education, 435 F.3d 384, 392 (3d Cir. 2006); Ridley S.D. v. M.R., 680 F.3d

10 260 (3rd Cir. 2012). I determined that the appropriate lens with which to examine the issue was the Burlington Carter tuition reimbursement test. In this case the Parents asked for the hearing however, for equitable reasons discussed above. I assigned the burden of proof regarding the appropriateness of the District’s ESY program to the District, while requiring the Parents to shoulder the burden of proof as to the appropriateness of their preferred program. As the testimonial and documentary evidence demonstrates, the District met its assigned burden regarding the appropriateness of the ESY program while the Parents did not meet their burden of proving the appropriateness of their preferred program. Credibility During a due process hearing the hearing officer is charged with the responsibility of judging the credibility of witnesses, weighing evidence and, accordingly, rendering a decision incorporating findings of fact, discussion and conclusions of law. Hearing officers have the plenary responsibility to make “express, qualitative determinations regarding the relative credibility and persuasiveness of the witnesses Blount v. Lancaster-Lebanon Intermediate Unit, 2003 LEXIS 21639 at *28 (2003); The District Court "must accept the state agency's credibility determinations unless the non- testimonial extrinsic evidence in the record would justify a contrary conclusion." D.K. v. Abington School District, 696 F.3d 233, 243 (3d Cir. 2014);.see also generally David G. v. Council Rock School District, 2009 WL 3064732 (E.D. Pa. 2009); T.E. v. Cumberland Valley School District, 2014 U.S. Dist. LEXIS 1471 *11-12 (M.D. Pa. 2014); A.S. v. Office for Dispute Resolution (Quakertown Community School District, 88 A.3d 256, 266 (Pa. Commw. 2014); Rylan M. v Dover Area Sch. Dist., No. 1:16-CV-1260, 2017 U.S. Dist. LEXIS 70265 (M.D. Pa. May 9, 2017). In this case all witnesses appeared to be testifying to the best of his/her recollections and there were no material differences as to the relevant facts of the case.

11 FAPE Having been found eligible for special education, Student is entitled by federal law, the Individuals with Disabilities Education Act as Reauthorized by Congress December 2004, 20 U.S.C. Section 600 et seq. and Pennsylvania Special Education Regulations at 22 PA Code § 14 et seq. to receive a free appropriate public education (FAPE). Congress enacted the IDEA to ensure that all children with disabilities are provided a 'free appropriate public education which emphasizes special education and related services designed to meet their unique needs and to assure that the rights of such children and their parents or guardians are protected.' Forest Grove School District v. T.A., 557 U.S. 230, 239, 129 S. Ct. 2484, 2491, 174 L. Ed.2d 168 (2009)(quoting School Committee Of Town of Burlington, Mass. v. Department of Education Of Massachusetts, 471 U.S. 359, 367, 105 S. Ct. 1996, 85 L. Ed.2d 385 (1985)). FAPE is defined in part as: individualized to meet the educational or early intervention needs of the student; reasonably calculated to yield meaningful educational or early intervention benefit and student or child progress; and provided in conformity with an Individualized Educational Program (IEP). Further, a child’s special education program must be reasonably calculated to enable the child to receive meaningful educational benefit at the time that it was developed. (Board of Education v. Rowley, 458 U.S. 176, 102 S. Ct. 3034 (1982). FAPE “consists of educational instruction specifically designed to meet the unique needs of the handicapped child supported by such services as are necessary to permit the child to benefit from the instruction." Ridley School District v. M.R., 680 F.3d at 268-269, citing Rowley. The Third Circuit has interpreted the phrase “free appropriate public education” to require “significant learning” and “meaningful benefit” under the IDEA. Ridgewood Board of Education v. N.E., 172 F.3d 238, 247 (3d Cir. 1999).

12 The Third Circuit has ruled that special education and related services are appropriate when they are reasonably calculated to provide a child with “meaningful educational benefits” in light of the student's “intellectual potential.” Shore Reg'l High Sch. Bd. f Ed. v. P.S. 381 F.3d 194, 198 (3d Cir. 2004) (quoting Polk v. Cent. Susquehanna Intermediate Unit 16, 853 F.2d 171, 182-85 (3d Cir. 1988)); Mary Courtney T. v. School District of Philadelphia, 575 F.3d 235, 240 (3d Cir. 2009) (citations omitted). Recently, the U.S. Supreme Court considered a lower court’s application of the Rowley standard, observing that an IEP “is constructed only after careful consideration of the child’s present levels of achievement, disability, and potential for growth.” Endrew F. v. Douglas Cnty. Sch. Dist. RE-1, 137 S. Ct. 988 (2017). The Court concluded that “the IDEA demands … an educational program reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.” Id. at 352. This standard is consistent with the above interpretations of Rowley by the Third Circuit. Local Educational Agencies [LEAs] need not provide the optimal level of service, maximize a child’s opportunity, or even set a level that would confer additional benefits; the child must be offered a basic floor of opportunity. See Lachman v. Illinois State Bd. of Educ., 852 F.2d 290 (7th Cir.), cert. denied, 488 U.S. 925 (1988); Ridley Sch. Dist. v. MR, 680 F.3d 260, 269 (3rd Cir. 2012). The IDEA entitles Student to an appropriate educational opportunity, but an IEP is not required to incorporate every program, aid, or service that parents desire for their child. Mary Courtney T; Ridley. An eligible student is not entitled to the best possible program, to the type of program preferred by a parent, or to a guaranteed outcome in terms of a specific level of achievement, as noted in several recent federal district court decisions. See, e.g., J. L. v. North Penn School District, 2011 WL 601621 (E.D. Pa. 2011). What the statute guarantees is

13 an “appropriate” education, “not one that provides everything that might be thought desirable by ‘loving parents.’” Tucker v. Bayshore Union Free School District, 873 F.2d 563, 567 (2d Cir. 1989). In a homespun and frequently paraphrased statement, the court in Doe v. Tullahoma City Schools accepted a School District's argument that it was only required to "...provide the educational equivalent of a serviceable Chevrolet to every handicapped student." and that "....the Board is not required to provide a Cadillac..." Doe ex rel. Doe v. Bd. of Ed. of Tullahoma City Sch., 9 F.3d 455, 459-460 (6th Cir. 1993). Endrew F. did not disturb this standard which entitles a child to what is reasonable, not to what is ideal. Parental Participation A placement decision is a determination of where a student’s IEP will be implemented. Placement decisions for children with disabilities must be made consistently with 34 CFR 300.116. The IEP team, including parents, makes placement decisions. Like the formulation of an IEP, a placement decision is not a unilateral matter for LEA determination 34 CFR 300.116(a)(1) however, is also clear that parental preference cannot have been the sole nor predominant factor in a placement decision. The IDEA merely mandates parental participation in the placement decision 34 CFR 300.116(a)(1), but does not suggest the degree of weight parental preference should be given. The Parents based part of their case on Student’s negative perception of the personality of one of the persons who would be participating in the proposed ESY program for about three hours per week. However, the applicable law does not permit parents to usurp the school district's role in selecting its staff to carry out the IEP's provisions. G.K. v. Montgomery Cty. Intermediate Unit, 2015 U.S. Dist. LEXIS 94667, at *42 (E.D. Pa. July 17, 2015).

14 ESY Acknowledging that some students may require programming beyond the regular school year, the federal legislature deemed that Extended School Year services are to be provided to an eligible child if necessary to assure that the child receives a free, appropriate public education (FAPE). 34 C.F.R. §300.106(a)(2). Pennsylvania regulations provide additional guidance for determining ESY eligibility, requiring that the factors listed in 22 Pa. Code §14.132 (a)(2) (i)— (vii) be taken into account. 22 Pa. Code § 14.132(a)(2) (i)—(vii) provides in relevant part: a) In addition to the requirements incorporated by reference in 34 CFR 300.106 (relating to extended school year services), school entities shall use the following standards for determining whether a student with disabilities requires ESY as part of the student’s program: 1. At each IEP meeting for a student with disabilities, the school entity shall determine whether the student is eligible for ESY services and, if so, make subsequent determinations about the services to be provided. 2. In considering whether a student is eligible for ESY services, the IEP team shall consider the following factors; however, no single factor will be considered determinative: i. Whether the student reverts to a lower level of functioning as evidenced by a measurable decrease in skills or behaviors which occurs as a result of an interruption in educational programming (Regression). ii. Whether the student has the capacity to recover the skills or behavior patterns in which regression occurred to a

15 level demonstrated prior to the interruption of educational programming (Recoupment). iii. Whether the student’s difficulties with regression and recoupment make it unlikely that the student will maintain the skills and behaviors relevant to IEP goals and objectives. iv. The extent to which the student has mastered and consolidated an important skill or behavior at the point when educational programming would be interrupted. v. The extent to which a skill or behavior is particularly crucial for the student to meet the IEP goals of self- sufficiency and independence from caretakers. vi. The extent to which successive interruptions in educational programming result in a student’s withdrawal from the learning process. vii. Whether the student’s disability is severe, such as autism/pervasive developmental disorder, serious emotional disturbance, severe mental retardation, degenerative impairments with mental involvement and severe multiple disabilities. b) Reliable sources of information regarding a student’s educational needs, propensity to progress, recoupment potential and year-to-year progress may include the following: 1. Progress on goals in consecutive IEPs. 2. Progress reports maintained by educators, therapists and others having direct contact with the student before and after interruptions in the education program.

16 3. Reports by parents of negative changes in adaptive behaviors or in other skill areas. 4. Medical or other agency reports indicating degenerative-type difficulties, which become exacerbated during breaks in educational services. 5. Observations and opinions by educators, parents and others. 6. Results of tests, including criterion-referenced tests, curriculum- based assessments, ecological life skills assessments and other equivalent measures. c) The need for ESY services will not be based on any of the following: 1. The desire or need for day care or respite care services. 2. The desire or need for a summer recreation program. 3. The desire or need for other programs or services that, while they may provide educational benefit, are not required to ensure the provision of a free appropriate public education. In determining whether the LEA has offered an appropriate ESY program, as is the case for determining whether an LEA has offered an appropriate IEP, the proper standard is whether the proposed program is reasonably calculated to confer meaningful educational benefit. Rowley, Ridgewood, Mary Courtney T, Endrew F. Tuition Reimbursement As the Parents had made the decision to place Student in their preferred program, and sought the District’s financial support for the portion of the program not covered by medical assistance, I decided this matter as a tuition reimbursement case. The Burlington-Carter test, named for School Committee of Burlington v. Department of Education of Massachusetts, 471 U.S. 359 (1985) and Florence County School District v. Carter, 510 U.S. 7

17 (1993), is the proper test for tuition reimbursement. See also, Forest Grove School District. v. T.A., 557 U.S. 230, 246–47 (2009); Lauren W. v. DeFlaminis, 480 F.3d 259 (3rd Cir. 2007). The Burlington-Carter test is a three-part test. First, the Parents must establish that the District failed to offer a FAPE to the Student. Second, the Parents must establish that their preferred placement is appropriate for the Student. Third, I must consider whether equitable factors warrant either a denial or a reduction of reimbursement to the Parents. Those steps are taken in sequence and the analysis ends if the party requesting reimbursement fails at any level. Discussion The IDEA and Pennsylvania law are very clear on what ESY is supposed to accomplish: ESY is provided to prevent a child from losing educational ground over a long break in schooling, such as during the summer. An ESY program continues the goals and objectives of the IEP during the summer months, after the school year has concluded, so the student does not regress from one school year to the next.” L.G. v. Wissahickon School District, 2011 WL 13572 at *6 (E.D.Pa. 2011). The IDEA’s standard for “appropriateness” is put forth above. The issue is not which ESY program is better, but whether the District’s proposed program is in and of itself appropriate. Evidence presented during the hearing establishes that the ESY program is appropriate for Student. It addresses both the academic needs and the behavioral needs put forth in the IEP for the year just ended, and provides goals designed to prevent regression over the summer. Additionally, it offers social skills instruction and the opportunity to practice these skills in academic and non-academic activities. As the District’s program offer is appropriate, the inquiry ends. However, it does bear pointing out that even had I found the District’s program not to be

18 appropriate, I could not order it to fund the Parents’ preferred program as that program is not appropriate to deliver FAPE for purposes of ESY. Although the Parents’ preferred program offers socialization opportunities, it does not offer any academic instruction despite Student’s clear needs in the areas of reading, math and written expression. When a student’s needs are both academic and behavioral/social an extended school year program that does not offer academic instruction cannot be deemed appropriate. Accordingly the District will not be ordered to fund the portion of the Parents’ preferred program not covered by medical assistance. ORDER It is hereby ordered that: 1. The District’s offer of ESY is appropriate. 2. The Parents’ preferred program is not an appropriate extended school year program. 3. There is no need to discuss equitable considerations as the District is not required to fund the Parents’ preferred program. Any claims not specifically addressed by this decision and order are denied and dismissed. Linda M. Valentini, Psy.D., CHO July 1, 2019 Linda M. Valentini, Psy.D. CHO Special Education Hearing Officer NAHO Certified Hearing Official