On behalf of the American Academy of Pediatrics, Virginia Chapter I would like to submit comments on the revision to the Regulations Governing Special Education Programs for Children With Disabilities in Virginia. The AAP-VA Chapter supports comments submitted by the Virginia Coalition for Students with Disabilities.

Specifically, we support the Coalition’s comments in the following areas:
•    Recommendations that support increased transparency, accountability, participation and inclusion for students with disabilities under the sections of IEP, Least Restrictive Environment and Placement, and Procedural Safeguards;
•    Recommendations on Discipline Procedures, especially those that will result in students being removed from any educational opportunities.  We find that many schools are using these procedures as a means not to serve students who are problematic rather than find appropriate programs, placements and techniques to provide them with the free and appropriate education they are legally entitled to receive; and
•    Recommendations on Mediation and Due Process Hearing as these are extraordinarily stressful and expensive means of addressing differences between families and schools that could be more easily avoided.  Further, the regulations create unfair advantages for school systems and the proposed regulations overstep VDOE's authority in a number of areas.

Thank you for your consideration.  Please feel free to contact me at (540) 241-0312 if you have any questions.

Sincerely,
 
Robert C. Gunther, MD, MPH, FAAP

President, Virginia Chapter

American Academy of Pediatrics

2201 West Broad Street
Suite 205
Richmond, VA 23220
Phone: 804/643-6631