American Academy of School Psychology

Response to Report of the President's Commission on Excellence in Special Education

Fredrick A. Schrank, PhD, ABPP Olympia, WA; Rosemary Flanagan, PhD, ABPP Rockville Centre, NY; Jeffrey A. Miller, PhD, ABPP Pittsburgh, PA; Linda C. Caterino, PhD, ABPP Tempe, AZ; John Brantley, PhD, ABPP Chapel Hill, NC; David A. Utech, PhD, ABPP Chicago, IL; Mark E. Swerdlik, PhD, ABPP Normal, IL; Irwin A. Hyman, EdD, ABPP Philadelphia, PA; Ronald A. Davis, PhD, ABPP Tempe, AZ;

The American Academy of School Psychology (AASP) consists of all holders of the Diplomate in School Psychology awarded by the American Board of Professional Psychology (ABPP). The AASP maintains a charge to promote the highest professional standards in school psychology. In so doing, the AASP strives to represent a balanced voice based on the views of very experienced professionals who are broadly trained to blend scientific evidence with clinical experience in school psychology practice.

The AASP is greatly concerned about certain aspects of the Report of the President's Commission on Excellence in Special Education (hereafter called the President's Commission Report or the Report) that propose drastic changes to the Individuals with Disabilities Education Act (IDEA). This position paper represents the views of the majority (92%) of members of AASP and its ad hoc committee on this issue. We seek to clarify these concerns and offer our recommendation about needed changes in IDEA.

The President's Commission Report recommends that the special education identification process should be drastically changed, particularly in the area of learning disabilities. Although we agree with the Report's emphasis on early intervention to prevent academic failure, we are concerned with the Report's focus on the shortcomings of an IQ or composite score in identifying the core processes that cause learning problems. The Report's perspective on this matter appears to reflect the thinking of only one constituency in a long, ongoing debate about the nature, diagnosis, education and treatment of students with learning disabilities. We assert that there is definitive evidence that children with bona fide learning disabilities, as currently understood by most neurologists, psychologists and researchers, have problems with typical academic learning. These problems may be biologically-based and affect, in widely-varying degrees and patterns, the ability to process, remember, and produce information. Further, the diagnosis of disability and development of interventions in this area is complex and is dependent on the scientific knowledge and practical experience of skilled practitioners. For example, children with learning disabilities may have concomitant psycho-educational problems such as Attention-Deficit Hyperactivity Disorder, behavior management needs, and/or low self-esteem.

We contend that appropriately trained and knowledgeable school psychologists, often as part of a multidisciplinary team, are needed to assess children, adolescents, and young adults with potential learning disorders in order to determine the presence, nature, and severity of a disability. Specific knowledge gained from the assessment provides a scientific basis for recommended treatment and intervention plans. Assessment is a complex process that requires multiple sources of information, including standardized, norm-referenced tests, interviews, observations, curriculum-based assessments, and informed clinical judgment. Because of this, we believe that some of the delimiting statements in the Report will be damaging to the effective utilization of a comprehensive approach to the identification and education of individuals with learning disabilities.

Use Norm-Referenced Tests Appropriately in Learning Disabilities Assessment and Programming

The AASP believes that psycho-educational assessment, using psychometrically sound norm-referenced instruments, is an important part of school interventions. These are tests that have been nationally standardized on large numbers of individuals to derive a measurement tool that is dependable and accurate. Reliable and valid psychometric instruments provide documentation of both ability and disability, assist in identifying needed services and interventions, and provide the necessary benchmarks for yearly monitoring of academic performance. As part of a comprehensive assessment, reliable and valid tests are necessary for an objective understanding of the core psychological processes that influence learning. This is known as cognitive assessment.

Cognitive assessment provides useful information about an individual's capabilities including, but not limited to, an overall measure of general intellectual ability. Rather than testing solely to obtain an IQ score, cognitive assessments should more appropriately be used to identify the core processes or functions causing an academic problem that are amenable to intervention or that require educational accommodations. Importantly, norm-referenced documentation of limitations in cognitive processing is required for legal protections and the provision of a rationale for the need for accommodations. In addition, cognitive assessments provide the link between identification of special education needs and intervention plans. Students' strengths and weaknesses in cognitive abilities are used to design specific academic interventions. Strengths and weaknesses in different cognitive processes are linked to identification and treatment of specific learning disabilities, including memory storage and retrieval, auditory processing, processing speed, attention, abstract reasoning, and language development. Finally, cognitive tests are useful for early identification of information-processing weaknesses (such as a delay in auditory processing or phonological awareness) that can lead to academic failure if left untreated.

Although not all referral concerns require norm-referenced assessment as a precondition of intervention plans or instructional modifications, in order to qualify for special education services, students should be evaluated on an individual basis and objectively assessed for the presence and severity of intra-individual differences in cognitive abilities, language capabilities, behavior, and areas of academic achievement. Additionally, a comprehensive evaluation should include multiple sources of information, including standardized, norm-referenced tests, interviews, observations, curriculum-based assessments, and informed clinical judgment. However, the core of a comprehensive evaluation is an accurate, norm-referenced assessment of student strengths and weaknesses in a variety of cognitive processes.

Eliminate the Mandated Discrepancy Formula but Not Comprehensive Assessment

Many Fellows of the AASP are senior school psychologists who share an historical perspective on the Education of all Handicapped Children Act (EAHCA, now IDEA). In 1975, when the EAHCA was first enacted, many states reported problems with establishing objective criteria for identifying a learning disability. With the goal of establishing objective criteria for identifying children for services, the criterion of a discrepancy between intellectual ability and achievement was suggested in an effort to help make a distinction between children with learning disabilities and those with other academic problems. From the outset, however, the concept of an ability/achievement discrepancy was controversial. The criterion has resulted in much dissatisfaction, particularly as it is interpreted in various state statutes and implemented by local education agency practices. Today, conceptualizations of the presence and nature of specific learning disabilities are changing. The concept of an ability/achievement discrepancy has outlived its usefulness and should no longer be used as a necessary condition for provision of special services.

Broaden Rather Than Delimit the Tools and Techniques Available To Diagnose Learning Disabilities

Based on the language suggested in the IDEA, many state regulations required that determination of a learning disability to be dependent on a specific degree of discrepancy between a child's intellectual ability and achievement. In many states and local education agencies, this created a litmus test for identification of a learning disability. In some local education agency practices, the presence of a defined ability/achievement discrepancy was used as the sole, determining criteria for service provision. As a consequence, these local education agencies have been out of compliance with the intent of the federal legislation because they have been using a single score to drive eligibility decisions (An ability/achievement comparison between any two tests results in a single discrepancy score). In contrast, the IDEA [300.541 (a) (3)] requires that a variety of sources must be considered in making eligibility decisions. Thus, the sole use of a discrepancy score, despite claims that it represents results from two tests, violates the requirement that eligibility must not be based on a single test or procedure.

Consequently, the AASP recommends that the criterion of an ability/achievement discrepancy should not be viewed as essential to qualify a student for services. Many students with neurologically based learning disorders do not exhibit an ability/achievement discrepancy. A learning disability can affect intelligence test performance as well as achievement test performance. Scores on both ability and performance measures may be lowered by the disability to the extent that there is not a severe discrepancy between the two. Granted, however, an ability/achievement discrepancy can sometimes be used to document a type of intra-individual variability that may have educational implications. Alternatively, other evidence of intra-individual variability in cognitive processing and academic achievement, such as evidence of specific processing deficits that contribute to lower ability and achievement scores, should be acceptable evidence toward documenting the presence of a learning disability.

As experienced school psychologists, we believe the development of effective interventions is dependent on a variety of approaches. Therefore we are always looking to broaden our perspectives rather than to be bound by legislative mandates, which may reflect only one particular methodology or interpretation of research. We caution that any single, mandated method for assessing and diagnosing learning disabilities that excludes reliance on reliable and valid assessments will be inadequate. Although alternative identification procedures have been proposed (and we do not rule out their use to compliment other procedures), none has achieved general acceptance in education or professional psychology. None of the proposed alternatives meet the criterion of technical adequacy. Any alternative procedure that does not include an emphasis on technically sound assessment will necessarily produce untoward variability in service delivery due to reliability, validity, and administration problems. The alternative procedures may be more likely to deny services to students with specific learning disabilities while granting services to students who do not show evidence of special educational needs. Ultimately, less reliance on comprehensive, norm-referenced assessment procedures will lead to less specificity in regard to the nature of the learning problem and, consequently, greater inequities in service delivery.

Recommendation

The AASP recommends that the current IDEA regulations remain essentially unchanged. Most current disability classification categories in the IDEA are well-supported by psychological diagnostic criteria. Further, we support the use of norm-referenced cognitive assessments and complementary alternative measures for determining special education program eligibility and program planning. We also support the use of norm-referenced assessments of academic achievement and complementary alternative measures to provide the necessary benchmarks for yearly performance monitoring, as suggested in the Report. We recommend that the ability/achievement discrepancy formula should be eliminated as a mandate. Language should be included in the reauthorized legislation that discourages the use of an ability/achievement discrepancy formula as the sole or determining measure of the presence of learning disabilities. To wit:
The American Academy of School Psychology recommends that the current IDEA regulations be reauthorized with some amendments. In particular, we recommend that the current regulations on criteria for determining eligibility for students with specific learning disabilities [300.540.541,542] should be amended to discourage the use of an ability-achievement discrepancy formula as a sole or determining measure of the presence of learning disabilities.

                                                                                             September 17, 2002

American Academy of School Psychology Ad-hoc Committee on the Report of the President's Commission on Excellence in Special Education


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