Making a Reasonable Calculation: A Strategic Amendment to the IDEA

The Individuals with Disabilities Education Act (IDEA) lays out a powerful set of protections and procedural safeguards for students with disabilities in public schools. Nevertheless, there is a persistent debate as to how far schools must go to fulfill their mandate under the IDEA. The Supreme Court recently addressed this question with its decision in Endrew F. v. Douglas Cty. School District Re-1, holding that an educational program for a student with a disability must be “reasonably calculated” to enable a child’s progress in light of their circumstances. Currently, the Act’s statutory language mandates Individual Education Program (IEP) teams to consider a variety of factors including “the strengths of each child,” “the concerns of the parents,” “the results of the . . . most recent evaluation of the child,” and “the academic, developmental, and functional needs of the child.”1 This Note proposes an amendment to the IDEA, inspired by the Strengths, Weaknesses, Opportunities, and Threats (SWOT) analysis framework used in business strategy, that adds external “threats” to this list of factors. This amendment will help parents, advocates, and schools better understand the Endrew F. standard and implement it with fidelity to the IDEA’s broad mandate.