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  • Writer's pictureAdam Dayan, Esq.

Curious Incident Podcast Episode 13: Implementing Decisions and Settlements

Updated: Feb 28, 2023

About This Episode

Host Adam Dayan, an NYC Special Education Attorney, discusses the process of implementing favorable special education decisions and settlements with Janice Deutsch, Lead Paralegal at the Law Offices of Adam Dayan. This conversation highlighted how to move forward once a favorable outcome has been secured.

Together they discuss:

  • how the implementation process works once special education legal matters have been resolved favorably

  • what constitutes proper documentation and the importance of maintaining it

  • tips for making the implementation process smoother

This is a unique chance for parents of children with special needs to learn about the details of what must be done at the end of a case so that parents can keep accurate records from the beginning of the case and help expedite prompt payment from the school district.

(LISTEN) The Curious Incident Podcast Episode 13: Implementing Decisions and Settlements

Transcript Below

You can aslo listen to our discussion on your favorite podcast player including:

Do you have questions about your child's education? Call Special Education Attorney Adam Dayan at the Law Offices of Adam Dayan: (646) 866-7157 and request a consultation with our New York attorneys today.


Speaker 1: This is Curious Incident, a podcast for special needs families and your window into the world of special education. Special needs parenting can be challenging, and we want to make it easier by providing you with the resources you need to help your child. Let's delve deep into the world of learning differently with your host, special education attorney Adam Dayan. Adam Dayan: It's a special privilege to be able to welcome my lead paralegal, Janice Deutsch, to this podcast. Janice has worked at our firm for the last two-plus years. Janice's role operates on multiple levels. On the case management level she oversees the litigation support team, which includes the paralegals and administrative personnel. On the staff development level she plans and conducts training for new team members. On the supervisory level she monitors our legal production deadlines and workflow for the support team, and addresses any needs or concerns raised by our attorneys or our managers.

Procedurally Janice helps develop or improve our office procedures to increase our effectiveness in meeting our overall mission and our internal goals. While she still handles litigation tasks if additional support is needed, most of Janice's role, as you'll hear today, is now related to what comes after litigation, when we have settled the case or taken it to a hearing and received a decision. Janice, a fellow CUNY graduate, has three Bachelor of Arts degrees in the areas of Secondary Education and Special Education, Speech Pathology and audiology, and Linguistics from Brooklyn College, where she graduated summa cum laude. Janice, it's great to be with you here today. Janice Deutsch: Thank you so much, Adam. It's great to be here. Adam Dayan: Tell our listeners what made you become a paralegal at a special education law firm in the first place. Janice Deutsch: At the time I joined your firm I had been a litigation paralegal for about 16 years, but I had other careers before that. I had an extensive background in research and writing, and before that I was a special ed classroom teacher. I spent four years teaching students with disabilities in self-contained classrooms in a public high school. And my first degree, as you mentioned earlier, is in secondary special education. Adam Dayan: Wonderful. Let's jump into the implementation side of your expertise at our firm. How would you explain implementation in the context of the work we do to our listeners who are unfamiliar with the legal process and are first getting started on their journey? Janice Deutsch: There are a couple of pathways that the legal process takes when we are advocating for our clients to obtain programs and services from the Department of Education. There are two main paths that the litigation process follows. When we file a due process complaint, it's generally because we are arguing on behalf of the parents that the DOE didn't do something that they should have done to provide the appropriate program and services for the child. We're saying that they failed to do something or they did something they should not have done, and we're trying to correct that.

When we file a due process complaint, which you'll often hear us refer to as a DPC, there are two pathways that the DOE takes to resolve the claim. They review everything we've said that they've done or failed to do. And they either decide, "We disagree. We're going to contest this, you have to prove it. We're going to go to a hearing." Going to a hearing is the longer process for resolving a complaint. There is a shorter process called settlement, where the DOE, at its sole discretion, can decide, "We've looked at your complaint. We either agree with some of the things that you've said, or we believe that an impartial hearing officer will uphold your complaint. And we would rather settle the case without going to the hearing." The shorter process is going to settlement. The longer process is going to a hearing.

For the purposes of implementation, which is the subject of our discussion today, if we go to the settlement route, if the DOE agrees, if they consent to refer the case to settlement, we gather certain documentation that supports the claims that are made in the due process complaint. We submit them, somebody at the Department of Education's Office of Legal Services reviews that, and they come back with an offer. "We will take this action. We will pay this amount of money to make your claim go away, to resolve all the issues."

If they present an offer, we present it to our clients with a recommendation. This is what they're offering. This is the advantages of accepting. This is maybe the disadvantage of accepting. And if the client agrees to accept what is offered in settlement, the attorneys get together, they draft a document called a stipulation of settlement that spells out the terms. The DOE will pay this to the parent. The DOE will pay that to the school. If there's an evaluation requested, they'll perform it or they will pay a certain amount of money for a private evaluator. All the terms are spelled out in the stipulation. And once that's signed, all the further complaint issues will be resolved.

If we don't settle the case, if the DOE is contesting the claims of the parent and wants to defend their action in handling the educational needs of the child, we go to the hearing. We compile all the documentation we need, we get the witnesses, we get the documents into evidence. The DOE of course, has the right to produce their own witnesses and their own documentation, and we put it before a hearing officer. The hearing officer then reviews all of the facts, contested and uncontested, and considers the law, considers the history, and makes a determination. The DOE either did what they were supposed to do or they failed to do what they were supposed to do. For each of the elements in the complaint they'll make a separate determination. The DOE acted properly or they didn't, and then come to a decision. The IHO will come to a decision to say for each element where the DOE failed to act properly, what they have to do or what they have to pay as a consequence of that.

So we have one pathway that leads to a negotiated settlement and a document called the stipulation. We have another pathway that leads to a hearing, and a findings of fact and decision, what we call an FOFD. In both of those cases, the document that results is what triggers the implementation process. Adam Dayan: Thank you, Janice, for laying that out beautifully. We're going to spend the rest of this conversation, the rest of this episode, unpacking what you just laid out. We'll talk more about documents that are required. We're going to talk more about the timeline for these different paths. And we'll talk more about the components of an offer or an FOFD as it pertains to implementation.

Let's distinguish between implementation as it pertains to settlement agreements, versus final decisions or pendency orders. And I think that's a concept that we haven't touched on yet, I'm talking about pendency orders. Can you talk about the differences in basic terms? Janice Deutsch: Implementation of a stipulation and implementation of an FOFD, or a pendency agreement, which I'll discuss momentarily, follows two main separate pathways. And the main distinctions are related to the scope of the document itself, the content of what goes into a stipulation or an FOFD or a pendency order.

The other main difference is the time it takes to complete the implementation, the steps that we need to follow. And the steps that the Department of Education needs to follow in order to pay out what is required by those documents. Let's start with the content of the documents. Adam Dayan: Excellent. Janice Deutsch: The foundation document, in a stipulation it will be very specific as to the terms of the agreement that has been negotiated between the party. So if the due process complaint is asking for full cost of tuition at a private placement, the DOE might offer to pay 100% to the school or reimburse the parent for the portion that they have already paid and pay the balance to the school. If there is a reimbursement for transportation or an evaluation or for related services, all of those items are individually spelled out in the stipulation language so that the people at the Department of Education, who are implementing this, they know what documents they are looking for specifically that show the proof, if the parent is seeking reimbursement, that the parent paid those funds. If the school is seeking the balance due on the tuition, they're looking for a particular document that shows what is owed.

It's very clear-cut and there are usually fewer elements in a stipulation. An FOFD, by contrast, can have way more elements, and they can be a little bit more complicated to determine because it won't necessarily say, "Pay this amount in tuition. Pay that amount for an evaluation." It might say that. But what it also might say is, "Reimburse the parent for whatever they paid. Reimburse the school for whatever is owed. Reimburse an evaluator for up to this amount of money," and so on. It doesn't specifically give dollar amount and payee, so there's a little bit more figuring it out from the documentation. When we are requesting the supporting documentation for a stipulation, very frequently we already have the documentation because it was part of our negotiation process. Where we are implementing an FOFD, we don't know until the hearing officer makes a decision what documentation will have to be submitted in support of the decision. That's in terms of the content of the document. What are the awards that we're seeking to get paid for, and what are the documents that are needed to support that?

Moving on to the time that it takes to implement. That's the second major distinction. Because there are fewer elements typically in a stipulation and the documents are mostly already known, both to us and to the Department of Education, there's a little bit less that goes into the review process. The document gathering, the document review, document redaction, all of the things that we have to do to submit that takes less time. And on the DOE side it takes less time for them to review it. Fewer elements, fewer documents, faster processing.

Again, by contrast, the FOFD is much more extensive. There could be eight different areas that we have to provide supporting documentation for. The documents could be more voluminous. If we need proofs of the payment, we might have to redact 20 to 100 pages of credit card statements and so on. The process on our end for gathering the documents tends to be a little bit longer, and the process of reviewing the documents on the DOE end is also more time-consuming.

What we try to do on our end is make it as simple as possible for the people on the DOE reviewing end. They have a separate unit for implementing FOFDs and the pendency, that I'll describe in a moment. It's a separate unit from the NPSP, which is the unit that reviews the settlement stipulations. Adam Dayan: I just want to make sure that listeners are not getting lost in the alphabet soup that is special education law, to use the phrase that a federal judge once used. Just to clarify again, FOFD relates to a hearing officer's decision. NPSP, which you just mentioned, is the office that processes settlement agreements. And if there are any other acronyms that come up, we'll define them so that everyone is clear about what they are. Janice Deutsch: We definitely need one more acronym. IU is how you'll hear us refer to the implementation unit. That's the unit that deals with implementing the hearing decisions and the pendency agreements. Adam Dayan: Thank you. Janice Deutsch: When we submit our documentation to the IU, there used to be a turnaround time, sometimes spelled out in the decision itself, that said the DOE was supposed to pay out everything they owed within 30 days. Adam Dayan: 35 days, I think. Janice Deutsch: Yes, I think it was 35 days. The pandemic kind of threw a monkey wrench into that process. There was a tremendous backlog while the DOE was getting set up to work remotely. There was short staffing involved. There were a number of factors that went into these delays.

One of our roles here is to submit the documentation, make sure all of the records are accurate and clear, everything is spelled out. If there are any discrepancies between the supporting documents and what the FOFD orders, we make it clear from the outset. And our goal is to expedite, to make the process as simple and straightforward as possible for the people at the IU.

Among the things that we sometimes have to do is follow up when we don't get a payment, when we don't get a request for further information, when we don't get a request for clarification of the documentation we've submitted, we give them a poke. We say, "Hey, we submitted this 30 days ago, 90 days ago. We haven't gotten a response from you. Please let us know if there's anything else you need, or tell us when the payment will be forthcoming."

It's a lengthy process on both ends. On our end for gathering the document and assembling them in a format that is reasonable for the representatives at IU to process. Or alternatively, for the people at the NPSP who are processing the stipulations, we want to make it as simple and straightforward for them to get it processed quickly, effectively, efficiently and properly. Speaker 1: If you like what you are hearing, please let us know by subscribing to The Curious Incident Podcast, and letting other special needs parents know about it too. If you have thoughts, questions, comments, or would like to suggest ideas for a future episode, we'd love to hear it, so email your feedback to Adam Dayan: Okay, so what is pendency or a pendency order, and where does that fit in here? Janice Deutsch: We had talked about the two pathways to resolving a complaint. Once the complaint is resolved by a hearing decision, the FOFD spells out what program and services the child should have had and did not have for the school year in question. After that point, the DOE is on notice that that was what was required for the child. And they are obligated to produce that program and those services, whatever the services are, for the child going forward.

If they don't create an appropriate program for the following school year, the parent has the right to file another complaint to enforce the terms of the prior order and, as needed, to ask for additional services or altered services. But they can file another complaint to ensure that their child is getting the program that the IHO, the impartial hearing officer, deemed was appropriate. Adam Dayan: Okay. So they file that new complaint, they get the pendency order stating what the DOE is required to continue. And now let's focus on how that pendency order gets implemented. Janice Deutsch: The pendency order is submitted with the new complaint for the upcoming school year. And it says, "Based on this FOFD for such and such case, the DOE was required to do this." Sometimes the DOE will just sign off on that, they will not contest it. And we will take that uncontested document, we'll gather the supporting documentation to show, okay, if the order of pendency says the child should have full tuition reimbursement, we show that the child is enrolled in school, that the parent is paying money or the school is owed money. We gather all that documentation and we submit it, along with some additional supplemental documents that are required under pendency.

Pendency implementation goes on a month-to-month basis. It's a little bit different than an FO D where the school year might be completed. A stipulation may be implemented during the course of the school year, but it may wait until the end of the school year to be fully implemented. Pendency, by its definition, only continues as long as there is a legal case pending.

And so on a month-to-month basis we have to continue to prove that the child is enrolled in and attending the school. We have to update any documentation as to the amount that the parent has paid, the school is still owed. And we go on a month-to-month basis where the documentation we submit and the payments we demand are spelled out just for that month, until the conclusion of the school year. When the school year is over, we have the final attendance record. If anything hasn't been paid along the process of the school year, we resubmit everything at the end. "Here is the full attendance. Here's the final tuition affidavit. You need now to pay everything that was owed for the entirety of the school year." Adam Dayan: Okay, great. That's very helpful, thank you. Now paint a picture for a best-case scenario and a reasonable timeline for implementation after a settlement. And what about implementation after a final decision or pendency? Janice Deutsch: There is a significant difference in the timeframe for each of those scenarios. The best-case scenario for a stipulation, the turnaround time is expected at 30 days, once we have submitted our documentation. It's not 30 days from the time the stipulation is signed and the agreement is made, it's once we submit our supporting documents with that stipulation to the NPSP unit.

30 days is the best-case scenario. We tend not to worry about not getting paid until 60 days has elapsed. To give them time to review our documents for this case and all the other documents that they have for all the other cases, we now anticipate that we should be getting paid, or at least partially paid, within that 60 days. Individual elements of a stipulated agreement will be processed separately. The tuition, if that's required, for the parent and tuition for the school, will be two separate things. Some things will be paid directly to the provider, the school, the evaluator, the related service provider. Other things will come to the parent, usually through our office, and we'll process that accordingly. If it comes through our office rather than go directly, we will process that out to the person who is the intended recipient. That process may add a couple of weeks to the full execution, the full implementation. Once it's approved for disbursement, it goes to another office to actually send out the funding. Adam Dayan: And in our experience right now, that system seems to operate pretty predictably. After a stipulation has been finalized, the process for payment is more reliable and consistent than in some of the other areas we're going to speak about today. Correct? Janice Deutsch: Correct. The process at NPSP is pretty smooth. It's really basically down to a science. There are very few gray areas because, as I mentioned, the stipulation spells out everything. "This dollar amount to this payee, that dollar amount to that payee," and there are usually very few questions that require clarification.

We do occasionally get some, where there's a new provider that the DOE doesn't have the appropriate documentation about that provider. That might be something that would hold up the disbursement of the funds. We get the information about what's needed, we correct it, and the process thereafter goes fairly smoothly. Adam Dayan: Okay. And shifting gears to the other areas we mentioned, final decision or pendency, what's a best-case scenario there? Janice Deutsch: That's a little bit harder to predict because a lot of the details are very either case specific or document specific. If the FOFD says, "Here's a dollar amount, pay it to that person. Here's another dollar amount, pay it to that person." And there's no wiggle room, there's no figuring it out as you go along, then the process goes a little bit more smoothly.

If, however, the FOFD says pay the school 100% of the cost of the related services, but 88% of tuition, we first have to figure out what full tuition would have been. Then figure out the 88%. Then figure out what portion of that the parent has already paid and what portion of that goes to the school and so on. There's a little bit more legwork involved in getting the details and then matching it up with the documentation.

Again, there's also the issue of what documentation is actually going to support the award that the hearing officer directed. If, for example, they say this provider can have up to this number of hours of service, an ABA provider can provide up to 12 hours of service per week. But doesn't specify a rate or specifies at an enhanced rate, without dictating what that rate could be. There are areas in which we have to navigate the documentation to demonstrate what the hours were. And if they provided more than 12 hours per week, what is compensable and what is not, what can be paid and what can't. The process of going through the FOFD, basically line by line, to determine what has been awarded, what documentation is needed to demonstrate the entitlement of the parent, the school, the provider, the transportation company, whatever, the process of doing that is something that generally takes longer on an FOFD than it does on a stipulation or on a pendency agreement. We train our paralegals to go through the FOFD and the available documentation the way that we believe the Department of Education will go through it, so that we cross all our t's and dot all our i's before we're submitting the documentation.

Best-case scenario now, I had mentioned that they were supposed to pay within 30 days. Sometimes the FOFD says they're supposed to pay it within 14 days of receiving our documentation. Best-case scenario now is closer to 90 days than it is to 35, or whatever shorter time is specified in the FOFD. The reality for us is we're dealing ... Once it's out of our hands and it's in the hands of the Department of Education, we have no control over the sequence in which they review the cases that come before them. We have no control over the time it takes them to review all of the documentation.

So we pop in periodically and we say, "Hey, it's been 30 days, it's been 60 days, it's been 90 days. Please let us know if you need something else, or please issue this disbursement immediately or promptly." We try to start off being, "We understand your limitations and we understand your burdens, but we have this order and we need it to be implemented fairly soon." Speaker 1: If you like what you are hearing, please let us know by subscribing to our podcast and letting others know about it too. If you have thoughts, questions, comments, or would like to suggest ideas for a future episode, we'd love to hear it, so email your feedback to Adam Dayan: What are some common forms of documentation that are needed for the New York City Department of Education to implement a settlement agreement? Is it typically the same documentation required for a hearing officer's order? Janice Deutsch: There is a fair amount of overlap in the documents that we present, regardless of whether we're implementing a stipulation or an FOFD or a pendency order. If the foundation document involves payment of tuition, whether it's a stipulation or an FOFD or a pendency agreement, we have to prove that the child is enrolled in the specific program. We have to prove what the tuition was, how much was paid by the parent or by a third party, and how much still remains owed to the school. So there are certain documents that are consistent. We need an enrollment contract that says the parent enrolled their child in this school for such and such a time period at such and such a rate of tuition that covers the attendance of the school, and if there are any services that go along with that, what's covered.

It also might detail their obligation to pay on a certain schedule, which means that we have to look at that and say, "Did the parent pay those amounts on that schedule?" And if so, can we get the proof of the payment. So there's a certain number of documents that go into proving the financial aspects. The first thing we will need, regardless of whether it is a stipulation or an FOFD or pendency order, we will need an affidavit from the school, documenting the financial transactions. This was the total amount that was charged. This is any adjustments. This is what the parent paid when, how much, by what method. And this is what's still owed to the school.

That's a sworn statement from the school. It says that the parent paid these five things, these five payments. We then need the proof of that from the parent. We need to show that the money came from the parent and not from a third party. So depending on the method by which the parent paid there are certain documentation requirements that the DOE is looking for. If it says the parent paid by credit card, they need the credit card statement. If the parent paid by check, they need a copy of the canceled check. That means the front and the back of the check. If the parent paid by an electronic funds transfer, there's other bank statements and transfer documents and so on.

Based on the elements that are in the foundation document, the stip or the FOFD or the OP, another acronym, order of pendency, we will seek out different documentation, and for tuition there is a great deal of overlap. For other issues, there might be some additional documents that we need. The payment of transportation, for example, requires not just the proof of payment for the transportation, but it has to match up with the child's attendance record.

The enrollment contract says, "I enrolled my child in this school." The attendance record shows that the child actually attended the school for the entirety of the school year. If, for example, a child is removed from school for a period of two months from medical treatment, the DOE might say you can't recover for that time. And if you're a applying for transportation reimbursement for the entirety of the school year based on a flat rate arrangement with a transportation company, you can't have reimbursement for the time that your child was not traveling back and forth to and from school.

So we have the enrollment contract for the child who was in this program. We have the tuition affidavit for, "This is what it cost, this is what the parent paid." We have the attendance record to prove that the student was actually attending the program. We have all the proofs of payment for whatever the parent is seeking reimbursement for. There are other documents that come into play only under specific circumstances. It would be a little bit cumbersome to talk about all the range of circumstances, but just to give you one example. If, for transportation, the parent hired a cab and paid in cash, there isn't a proof of payment in a bank statement, an electronic fund transfer, a credit card statement. They paid in cash. We would need an affidavit from the parent that they paid this amount. We'd also need an affidavit from the person who received the cash payment.

So these types of things, these are some of the nuances of implementation, based on what documentation is standard and what might be specific to the individual award in the document. An invoice from a provider, an invoice from an evaluator, all of these things are contingent on the content of the document. Adam Dayan: And we get into these nuances and sometimes questions arise as to, "How should I be paying? What documentation should I keep? How am I going to prove this later?" And so we always encourage parents, and I would encourage anyone who's listening now, if you're going to be setting up this type of relationship, whether it's for transportation or a different service, if you have any doubt as to what is a reliable way of paying for the service or documenting the payments, ask. And ask early so that you can get clarity on how that should be done, and make sure that you're doing it correctly along the way and keeping the appropriate documentation. Right? Janice Deutsch: Indeed. We often, when we do our initial requests for documents, we often spell out, "It should be in this form. It should not be in that form." Some things are simple as mechanics. Send us a PDF of the document whenever it's possible. Don't send us a screenshot because it may not be accepted by the Department of Education. We tell people, if you are paying in cash, please make sure that the person you're paying is willing to and available to sign an affidavit, to document that this transaction or these transactions have occurred.

We enumerate what the requirements are, the details of what would constitute a valid enrollment contract as opposed to an invalid one. So you've signed a contract, but the school has not. The implementation unit looks at that and says, "We don't know that this is a valid contract and that the school is owed anything." We look at a tuition affidavit. By definition an affidavit has to be a notarized document, sworn to under oath. If it's not notarized or it's not properly notarized, we will contest it. We'll send it back to whoever issued it and say, "We need this to be spelled out. We need that to be signed. We need more clarity in this area." And we'll wait until we have the appropriate documentation. If we're looking to demonstrate that the child was in school and therefore the parent is entitled to reimbursement for transportation, we look at the attendance record. If it only says the number of absences for the student for the month, that doesn't tell the implementation unit what days the child was actually in the school building. It's not matched up with the school calendar and so on. So we will send a further request, either through the parent or directly to the school, and say, "Please give us the actual attendance record of when the child was in the building."

When we go through the documents, we've given the parents a heads-up, we've given the school a heads-up on the particulars of what is needed, including the content of the various documents. When we get those documents back, as I mentioned, we train our paralegals to go through it the way that the implementation unit would. They're looking for information that is missing. They're looking for information that doesn't match other documentation or what we've claimed the documentation will say. And they're looking for any items that might be questioned by the Department of Education.

For example, the parent pays a monthly tuition installment, but they also pay an administrative fee each month to have a payment plan. So the credit card record might say that this monthly installment of tuition is $500, but the credit card charge is $525. We need to be able to explain that upfront, why the documentation doesn't match between the proof of payment and the tuition affidavit. These are the most common things, the missing information, the mismatches of information, and the items that would raise questions on the part of the implementation unit, that we try in advance to work out to resolve or to explain when we submit the documents to the IU. Adam Dayan: We've talked about some of the common mistakes when it comes to schools or providers completing the documents you just discussed. Are there any other common mistakes that you want to share or any other examples you want to give? Janice Deutsch: There are a few things that come up periodically. When school years change over, the case number that was applicable in the prior year will no longer be applicable in the next school year. We have providers who work with students from year to year, and if they submit an invoice under the old case number it will not be accepted under the new case number. So that's one of the mismatches. If the information on the document doesn't align with the current case, it gets sent back, it gets bounced before it will get paid.

We have had times where one provider is providing more than one service to the child, so they might be providing applied behavior analysis. There's another acronym ABA. And they might be providing the supervisory component of that and the parent training component that goes along with those things. If they put everything on one invoice and they don't separate out ABA, from parent training, from BCBA supervision, the DOE will send it back and they say, "You have to compartmentalize this." There is a separate mandate of hours for ABA and a separate mandate of hours for parent training. You can't put them all together. They won't do the separation, we have to do the separation in advance. They'll just bounce it back.

So there are a number of conditions that we look for. You know that expression, the devil's in the details. We look through those details because we know that the IU is going to look through those details with a fine-tooth comb, and we want to make sure that the information that's on the form is accurate, that it's in the right place, that it's not intermixed with other information that shouldn't be there.

That all the signatures that have to be in place are in place. Not just, as I mentioned before, on the tuition affidavit in the enrollment contract, but if there's like a related service provider, they fill out their invoicing form. That has to be signed off on by the parent, if the service is provided at home, by the school principal, if it's provided at the school. All the signatures have to be in place. Missing information, mismatched information. Those elements are crucial to getting the documents approved and paid. Adam Dayan: We're going to wrap up the conversation here for this episode. We'll be back next month for part two of this conversation with Janice Deutsch about implementation. Speaker 1: Thanks for listening to Curious Incident, a podcast for special needs families. Don't forget to subscribe for a new episode every month. For more resources and helpful information, check out our website and blog at

This podcast provides general information which is not intended to and does not constitute legal advice. You should not rely on this information for any purpose. For legal counsel, you should consult with an attorney to discuss your specific circumstances. Your listening to this podcast does not create an attorney-client relationship between you and the law offices of Adam Dayan, PLLC. No attorney-client relationship is established unless a retainer agreement has been executed between the client and the law offices of Adam Dayan. This podcast may constitute attorney advertising. Prior results do not guarantee a similar outcome. Any guests featured or resources mentioned on this podcast are for information purposes and are not endorsed by the law offices of Adam Dayan PLLC.


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