Practitioner Development

Endrew and FAPE: Concepts and Implications for All Students With Disabilities.

Kauffman et al. (2021) · Behavior modification 2021
★ The Verdict

Endrew raised the FAPE bar—behavior plans must now show clear, meaningful growth or risk legal challenge.

✓ Read this if BCBAs who write or supervise IEP goals in public schools.
✗ Skip if Clinicians in clinic-only or private-pay settings where FAPE does not apply.

01Research in Context

01

What this study did

The authors unpacked the 2017 Endrew Supreme Court ruling. They asked what the new FAPE standard means for behavior plans in schools.

The paper is a legal think-piece, not an experiment. It looks at how the court raised the bar for meaningful progress.

02

What they found

Endrew says "some benefit" is no longer enough. Plans must now show measurable, meaningful growth.

The ruling pushes BCBAs to write goals that are ambitious and data-rich. Weak or flat graphs may not pass review.

03

How this fits with other research

Corr et al. (2025) show FCT cuts problem behavior in schools. Their review gives you tools that can meet Endrew’s higher bar.

Duncan et al. (2023) found EF needs are rarely written into IEPs for included students with ASD. Endrew makes that gap risky; goals must target real growth, not just access.

Perez et al. (2015) linked poor family-school ties to future due-process filings. Endrew adds fuel: parents can now point to weak progress data in court.

04

Why it matters

You must show steep, meaningful change in each review period. Pick interventions with solid evidence like FCT, write ambitious but reachable goals, and graph every point. If the slope flattens, reconvene and revise. Endrew gives families a clear lane to challenge you—be ready with data that prove progress.

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Open each active IEP graph, draw an aim line that shows ambitious growth, and flag any flat data for immediate revision.

02At a glance

Intervention
not applicable
Design
theoretical
Population
autism spectrum disorder, mixed clinical
Finding
not reported

03Original abstract

The opinion of the Supreme Court of the United States in the Endrew case has implications for the education of all students with disabilities. Implications for several categories of disability are discussed: those with autism spectrum disorder and those with disabilities often considered high incidence, particularly those placed for a significant portion of their school day in general education. The aspects of the Individuals with Disabilities Education Act most relevant to the Endrew case are also compared with Article 24 of the United Nations's Convention on the Rights of Persons with Disabilities. The opinion in Endrew may affect the course of special education and the role of behavior modification in meeting the needs of all students with disabilities.

Behavior modification, 2021 · doi:10.1177/0145445519832990