Journal of Disability Policy Studies
21(1) 3–8
© Hammill Institute on Disabilities 2010
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DOI: 10.1177/1044207310366522
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The Individuals with Disabilities Education Act (IDEA)
obligates school districts to identify students with disabili-
ties and provide them with a free and appropriate public
education, or “FAPE,” that includes special education ser-
vices. At times, school districts and parents disagree about
whether a child is eligible under the IDEA or whether the
proposed services are appropriate. The primary mechanism
for dispute resolution under the IDEA is a due process hear-
ing. More specifically, the IDEA regulations [§ 300.507(a)]
provide that “a parent or a public agency may file a due
process complaint on . . . the identification, evaluation or
educational placement of a child with a disability, or the
provision of FAPE to the child.”
Under the IDEA provision for due process hearings
[§ 1415(g)], states have a choice of a one-tier system that is
limited to the hearing officer level, or a two-tier system that
provides a second officer review level to the administrative
dispute resolution system prior to either party resorting to
court action. In a one-tier system, the state provides a pool
of impartial hearing officers (IHOs)—who in some states
are full-time state employees in the role of administrative
law judge and in other states are part-time, contracted attor-
neys or special education personnel—to conduct adminis-
trative adjudications. IDEA has historically provided only
brief and broad requirements for hearing officers limited
to impartiality, prohibiting state education department
employment, local district employment (with regard to the
child at issue), or other professional conflict of interest
[§1415(f)(3)(A)].
Because of continuing concerns about the time-consum-
ing and adversarial nature of this administrative dispute
resolution mechanism (Goldberg & Kuriloff, 1991; Zirkel,
1994, 2005), Congress included in the amendments to the
IDEA, which went into effect on July 1, 2005, new require-
ments. First, IDEA 2004 added proficiency qualifications
for hearing officers, requiring competence in conducting
hearings, knowledge of special education law, and ability to
write legally appropriate decisions [§1415(f)(3)(A)]. This
new provision still leaves ample latitude for state-by-state
choices as to the background, selection, and part-time ver-
sus full-time status of hearing officers. Second, IDEA added
the requirement of a “resolution session” as an informal
dispute-resolution step prior to a due process hearing [§
1415(f)(1)(B)]. One of the features of this new procedure is
that the school district may not bring its attorney if the par-
ents are not accompanied by their attorney. Whether this
new resolution session provision is reducing the number of
due process hearings has been subject to speculation
(Edwards, 2005).
The continuing contentions about the nature and opera-
tion of the one-tier and two-tier systems under IDEA have
1
Lehigh University, Bethlehem, PA, USA
2
East Stroudsburg University, PA, USA
Corresponding Author:
Gina Scala, Special Education/Rehabilitation, East Stroudsburg University,
200 Prospect Street, Stroud Hall, Room 105, East Stroudsburg, PA 18301-
2999, USA Email: spedgrs@aol.com
Due Process Hearing Systems Under
the IDEA: A State-by-State Survey
Perry A. Zirkel
1
and Gina Scala
2
Abstract
The primary mechanism for dispute resolution under IDEA (Individuals with Disabilities Education Act) is a due process
hearing. The total number of adjudicated hearings under IDEA has dropped from the high level during the latter part of the
1990s and the early part of the current decade. Yet relatively few jurisdictions, led by the District of Columbia and New
York, account for the overwhelming majority of these decisions. This article presents the results of a state-by-state survey
of the hearing officer system. This current “snapshot” identifies the key features, including (a) whether the system is one-
tier or two-tiered; (b) whether the IHOs are part-time or full-time; (c) whether their legal background is primarily in law or
special education; (d) which agency assigns them and its procedures for the assignment; and (e) what is the updated volume
of adjudicated hearings—i.e., those conducted to completion resulting in a written decision.
Keywords
impartial hearing officers, one-tier, two-tier, due process