16.  Accountability for IEP Goals [8 VAC 20-81-110, pg. 140]
 
I oppose the proposed provision that holds LEAs, teachers or other school staff unaccountable if a child does not achieve the growth projected in the annual goals, including benchmarks or objectives.  If there is no accountability for IEP goals, then the IEP is meaningless as a measure of success in providing a child with a disability a free and appropriate education.
 
17.  Parent Requests for an IEP Meeting [8 VAC 20-81-110, pg. 140]
 
I oppose the proposed provision that permits LEAs to refuse a parent's request for an IEP meeting if they consider such a request "unreasonable."  No request to promote and continue the dialogue between parents and schools should be considered unreasonable.  This provision works against the parent-school partnership at the heart of Virginia's special education process and denies a parent's legitimate right to pursue changes to their child's IEP.