More than de minimis: FAPE in the Post Endrew F. Era.
Endrew F. says every IEP goal must use an evidence-based tool and show strong weekly gains.
01Research in Context
What this study did
Fyke et al. (2021) wrote a short guide for a special issue on the Endrew F. court case.
They explained how the ruling raised the legal bar for FAPE. FAPE means Free Appropriate Public Education.
The authors told readers to pick goals and services that give clear, big gains, not tiny ones.
What they found
The paper does not give new data. It sums up court language and lists the invited articles.
The key point: after Endrew F., an IEP must show a child will make measurable, ambitious progress.
Goals need evidence-based tools and weekly data shared with parents.
How this fits with other research
Tiernan et al. (2022) looked at thirty years of Precision Teaching for reading and math. Their review gives you a ready menu of evidence-based academic goals that meet the new FAPE standard.
Merlo et al. (2023) showed one way to hit the standard. Two preschoolers used the BEHAVE app while learning to ask for items. Gains showed up right away at home and school.
Barbash (2021) cheers for Direct Instruction. That method also counts as evidence-based and fits the Endrew F. call.
Why it matters
You now have court backing to demand more than tiny steps. Pick goals tied to proven tools like Precision Teaching, Direct Instruction, or app-based mand training. Track data every week and send the chart to parents. If progress stalls, change the method, not the goalpost.
Want CEUs on This Topic?
The ABA Clubhouse has 60+ free CEUs — live every Wednesday. Ethics, supervision & clinical topics.
Join Free →Add one Precision Teaching fluency aim to a current academic goal and graph it daily.
02At a glance
03Original abstract
Federal regulations for special education services have focused primarily on procedural issues since the Rowley decision, which held that Individualized Education Programs (IEPs) need only be reasonably calculated to yield educational benefit. However, the minimum threshold for benefit has changed with the recent Endrew F. decision as IEPs must yield more than de minimis progress. To ensure sufficient progress toward the achievement of ambitious goals, schools must develop IEPs that meet procedural and substantive requirements, employ interventions with clear evidence of effectiveness, effectively measure student response to services, and to communicate this information with parents/guardians so that they can actively participate in this process. Manuscripts invited for this special issue include investigations of IEP quality; co-teaching; intervention studies in reading, writing, and mathematics; meta-analytic findings regarding social studies education; and a discussion of the implications of Endrew F. for different student disability populations. These papers discuss challenges faced by stakeholders with vested interests in students with disabilities as well as areas of continued development and refinement in evidence-based practice.
Behavior modification, 2021 · doi:10.1177/0145445519880836