I support the following statement:

Virginia proposes to remove the current requirements that IEPs include short-term objectives and benchmarks in IEPs.

Does this proposed regulation benefit children with disabilities and their families? No.

Short-term objectives and benchmarks are steps that measure the child's progress toward the annual goals in the IEP. Short-term objectives provide teachers and parents with a clear way to evaluate the child's progress. Eliminating short-term objectives will create problems for teachers and parents.

Although Congress removed the requirement to include short-term objectives and benchmarks in IEPs, they did not discourage states from continuing to use objectives or benchmarks. Why did Congress eliminate the requirements to include short-term objectives in IEPs?

According to the US Department of Education's Commentary to the Regulations at:

"By eliminating the need to develop benchmarks or short-term objectives, [this] could result in teachers spending less time on each IEP ...  Based on average compensation for teachers of $48 per hour, a reduction in time as modest as 15 minutes could save approximately $12 per IEP ... " (Federal Register, Vol. 71, No. 156, August 14, 2006 at page 46747)

Does eliminating short-term objectives or benchmarks from IEPs benefit children with disabilities and their families? No.

Congress made this change so IDEA 2004 would be more palatable to school administrators. It is unseemly and unnecessary for Virginia to follow this path.