Manifestation Determination:
Requirements and Procedures,
and Suggested Activities
• Understand the basic principles of
Individuals with Disabilities Education Act
(IDEA) Manifestation Determination
Review (MDR) requirements
IDEIA 2004 [§300.530(e)]
• Be able to apply the basic rules of IDEA
MDR requirements
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Overview
• Authority of school personnel
• General Rules of Discipline
• Manifestation determination process
• FBA and BIP
• Mechanisms for documentation
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• A MDR is mandated when considering longterm disciplinary removal of students with
disabilities (SWD)
– Requires schools to treat SWD differently than
those without disabilities
– Has evolved to ensure
• Safe and orderly schools
• Ongoing and active participation of parents and
families
• Ability of SWD to access FAPE
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• Honig v. Doe (1988) – unilateral expulsion of SWD
constitute a change of placement & are not allowed and is
subject to IDEA procedural requirements (began as Doe v.
Mather, 1986)
• S-1 v. Turlington (1981) – knowledgeable individuals must
make determination of the relationship of a SWD’s
misconduct to his/her disability
• School Board of County of Prince William, VA v. Malone
(1985) – special education services cannot be discontinued
as a result of an expulsion/suspension
• 16 published MDR decisions 1980-1997 – 63% no
relationship
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General Authority of School Personnel
School personnel may remove a child to an appropriate
interim alternative educational setting (IAES), another setting,
or suspension for not more than 10 school days in a row—to
the extent those alternatives are applied to children without
disabilities. You may hear this referred to as “the 10-day
rule.”
To further clarify, let's ask a few questions.
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General Authority of School Personnel
Frequently Asked Questions
1) Where do school personnel have the authority to remove a child?
(appropriate IAES, another setting, or suspension)
2) Another setting from what? (The child's current placement)
For how long? (Not more than 10 consecutive school days, to the
extent those alternatives are applied to children without disabilities)
3) Is Day 10 counted in that length of time? (Yes)
4) How does disciplining children without disabilities relate to this
provision? (The alternatives mentioned by IDEA—IAES, another
setting, suspension—may only be applied to children with
disabilities to the extent those disciplinary actions are applied to
children without disabilities.)
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General Authority of School Personnel
Does the student continue to receive special education
services during the time of removal?
It's important to know that schools do not have to provide
students with disabilities with special education services
during a removal of up to 10 school days in one school
year—as long as they also do not provide educational
services to children without disabilities who are similarly
removed. [§300.530(d)(3)]
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General Authority of School Personnel
Additional Violations. What if the child violates a code of
conduct more than one time in the same school year? Can
school personnel remove that child again for up to and
including 10 school days in a row?
Yes—and for each separate incident of student misconduct—
under two conditions.
Those conditions are:
1) Additional removals from the current educational placement
may occur as long as they are for not more than 10 school
days in a row in a school year and they do not constitute a
“change of placement” in the disciplinary context under
§300.536. [§300.530(b)(1)]
We will talk about “Change in
Placement” in a minute.
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General Authority of School Personnel
What's a Change of Placement?
A change of placement occurs if:
1) the removal is for more than 10
consecutive school days; or
1) the child has been subjected to a series of
removals that constitute a pattern.
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General Authority of School Personnel
Factors to be considered in determining if the series
of removals constitutes a pattern
IDEA states that a pattern would exist— (§300.536)
1) when the series of removals total more than 10 school days
in a school year;
2) when the child's behavior is substantially similar to the
child's behavior in previous incidents that resulted in the series
of removals; and
3) when additional factors exist such as the length of each
removal, the total amount of time the child has been removed,
and the proximity of the removals to one another.
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General Authority of School Personnel
The school system determines on a case-by-case basis
whether a pattern of removals constitutes a change of
placement.
This determination is subject to review through due process
and judicial proceedings.
Let's look at two illustrations
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General Authority of School Personnel
Case 1
If a child with a disability is suspended from school for 6 days in
October and then another 3 days in February and then 1 day in May,
does that constitute a pattern of removals that amount to a change of
placement?
(No, that's only 10 school days total. IDEA states that a pattern is “a series of
removals that total more than 10 school days in a school year.”) §300.536(a)(2)(i)
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General Authority of School Personnel
Case 2
How about this situation with a child with a disability named
Robert?
1—Two separate incidents of throwing food at children in the
cafeteria, each time resulting in a suspension of one day in
September and October.
2—Pulling the fire alarm in November. A five-day suspension.
3—Fighting in class in December. Two days removal.
4—Setting off the sprinkler system in the school with a lighter in
February. Two days removal.
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General Authority of School Personnel
Could the school system determine that Robert's removals constitute
a pattern and, thus, a change of placement? - Yes
A pattern is “a series of removals that total more than 10 school
days in a school year.” In this case, Robert has been removed from
his current placement for a total of 11 days. School systems cannot
use repeated short-term removals as a way of avoiding the Act's
change in placement provisions.
§300.536(a)(2)(i)
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General Authority of School Personnel
Therefore, the school system would need to consider whether this
series of removals constitutes a pattern and, thus, a change of
placement, including considering:
(a)whether Robert's behavior was substantially similar to that of
previous incidents, and
(b)any additional factors or relevant information regarding Robert's
behaviors, including, where appropriate, any information in his IEP.
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In-school suspensions do not count as a
day of suspension if the student is:
• afforded the opportunity to progress in the
general education curriculum
• provided his/her special education and related
services
• allowed to participate with nondisabled peers
to the same extent as in the regular
placement
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• “The length of removal, the total time of
removal, and the proximity of removals to
each other may all affect whether a
disciplinary action is, upon review,
determined to be a change of placement.”
Kubick, Jr., 2010
• What can tools can a district use to assist
in making decisions about a pattern of
removals?
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• Always give parents notice of procedural
safeguards.
• All students are entitled to certain rights.
• Agreement of parties supersedes rules.
• Students with disabilities are treated like
all other children until the end of the tenth
day of suspension.
• Always take into consideration how many
days the student has been removed
previously.
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• Document in written form all discussions
related to discipline as well as all
disciplinary actions taken.
• Ensure school personnel evaluate the
effectiveness of disciplinary policies and
procedures and make changes and
adjustments as needed.
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• Know which students are receiving special
education services.
• Know which students have Section 504 plans.
• Know which students are in the pipeline for
evaluation for possible IDEA eligibility.
• Keep track of days of removal.
• Include brief notes of what happened.
• Determine who will do what.
• Determine where records will be kept.
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• Be mindful of the approaching 10 day
threshold as components of an MDR is
likely to include completion of a current
functional behavioral assessment (FBI)
and development of a behavior
intervention plan (BIP).
• An FBA is difficult, if not impossible, to
complete if the student is outside of the
educational setting.
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Discipline Dispositions Chart
Student: _____________________________
School:_______________________________
Infraction
Date
Description Administrative # of Days
of
Disposition
Suspended
Infraction
ISS/OSS
Grade:_______________________
School Term:____________ _____
Cumulative
Days of ISS
and/or OSS
Recommendation
Proximity
of Referrals
1. Conduct TST/IEP
Tier
(days,
Placement Meeting to Discuss
weeks,
General student behavior
months
(Education) 2. Justify reason for
since last
not conducting a
referral)
1 2 3 TST/IEP meeting
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Authority In Special Circumstances
Definition of Key Terms
1)“Dangerous weapon” is defined in 18 U.S.C. 930(g)(2) as follows:
- means a weapon, device, instrument, material, or substance, animate
or inanimate, that is used for, or is readily capable of, causing death or
serious bodily injury, except that such term does not include a pocket
knife with a blade of less than 2 ½ inches in length. (71 Fed. Reg.
46723)
Note: Student doesn’t have to use the weapon; he or she may merely possess it.
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Authority In Special Circumstances
• carries a weapon to or possesses a weapon at school, on
school premises, or at a school function;
• knowingly possesses or uses illegal drugs, or sells or
solicits the sale of a controlled substance, at school, on
school premises, or at a school function; or
• has inflicted serious bodily injury upon another person
while at school, on school premises, or at a school function
under the jurisdiction of a State educational agency (SEA)
or a local educational agency (LEA). [§300.530(g)]
In any of these circumstances, school personnel may remove a student to
an interim alternative educational setting (IAES) for not more than 45
school days without regard to whether the behavior is determined to be a
manifestation of the child's disability.
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Authority In Special Circumstances
2) Controlled substance means a drug or other substance identified
under schedules I, II, III, IV, or V in section 202(c) of the Controlled
Substances Act (21 U.S.C. 812(c)).
3) Illegal drug means a controlled substance; but does not include a
controlled substance that is legally possessed or used under the
supervision of a licensed health-care professional or that is legally
possessed or used under any other authority under that Act or under
any other provision of Federal law.
Note: The student only knowingly has to possess an illegal drug; he/she doesn’t have to be caught
using the drug. However, for controlled substances, IDEA means that the child must sell or solicit the
sale of a controlled substance.
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Authority In Special Circumstances
4) Serious Bodily Injury means bodily injury that involves—
1. A substantial risk of death;
2. Extreme physical pain;
3. Protracted and obvious disfigurement; or
4. Protracted loss or impairment of the function of a bodily
member, organ, or mental faculty. (71 Fed. Reg. 46723)
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Authority In Special Circumstances
Other provisions of IDEA's discipline procedures
apply under special circumstances
•conducting the manifestation determination under §300.530(e);
•notifying parents under §300.530(h); and
•determining the extent of services that must be provided to the
child under §300.530(d)(1).
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Mississippi's Response to SWD Discipline Issues
Establish Positive Behavior Supports (PBS)
While the focus of RtI is on intervening with students who have not
yet been identified as a child with a disability, the benefits to SWD
are increased when the focus is school-wide.
Positive reform efforts achieved through the implementation of
Mississippi's RtI process affects all students, not just the general
education students.
There is no way to separate the benefits to SWD when school-wide
positive behavior efforts are implemented for all students.
A plan for students with disabilities and
eligible young children who require
specific intervention(s) to address
behavior that interferes with learning
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• All students should be disciplined the same,
unless an alternate discipline plan is
included in the student's IEP or 504 plan.
• Written notice followed by a formal hearing
is required for long-term suspensions.
• Remember a new MDR must be held for
each subsequent incident once the 10 days
has been reached in a school year, so
prevention is an excellent strategy.
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Challenging behaviors must be addressed
in the IEP, regardless of the student's
disability category (i.e., not just for students
labeled EmD) –
•Present Level of Performance
•Accommodations and Modifications
•Related Service
•Short Term Objectives
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• Develop and consistently implement a
detailed Behavior Intervention Plan (BIP)
based on a Functional Behavior
Assessment (FBA), regardless of student's
disability category.
• Develop and consistently implement
personnel policies, discipline policies and
code of student conduct policies and
procedures against bullying or harassing
behavior.
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DISCIPLINE: STUDENTS WITH DISABILITIES
Removals
In-School Suspension (ISS)
1. A student with disabilities should not be assigned to ISS for more
than three (3) consecutive days. School administrators must
ensure Exceptional Education Services are provided daily to all students
with disabilities assigned to ISS.
2. Following two (2) incidents of behavior(s) that result in assignment
to ISS, the IEP Committee must review the IEP and develop a
behavior plan to address the student‘s behavior subject to the
disciplinary action or if a behavior plan is in place, the behavior plan
must be reviewed/revised to address the specific behavior.
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Removal of Ten (10) Days or Less Per Incident
School personnel may consider any unique circumstances on a
case-by-case basis when deciding to order a change in
placement for a child with a disability who violates the code of
student conduct.
A change in placement occurs when a series of removals are
made that constitute a pattern due to the child being removed
for more than ten (10) schools days in a school year, and
because of factors such as length of each removal, the total
amount of time the child is removed, and the proximity of the
removals to one another.
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School personnel may order the removal of a child for not more than
ten (10) consecutive schools days* to the extent that such removals
would be applied to children without a disability for the same offense or
when the child’s behavior is deemed to be dangerous behavior**.
Additional removals of not more than ten (10) consecutive school days
in that same school year for separate incidents of misconduct may be
ordered as long as those removals do not constitute a change in
placement.
*School day is defined as any day, including a partial day that children are in attendance at school for
instructional purposes. This term has the same meaning for all children in school, including children
with and without disabilities.
**Dangerous behavior is defined as behavior of a student that poses a threat of imminent, serious
physical injury to the student or others, or behavior that results in serious physical injury to the
student or others.
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Services must be provided during such removals as follows:
A. If a child is removed for more than ten (10) consecutive school
days for a violation of school rules, services must be provided
following day ten (10) of the removal. Services are not required for
removals of less than ten (10) cumulative days;
B. After a child has been removed from his or her current placement
for more than ten (10) cumulative school days in the same school
year, during any subsequent days of removal, the local school district
must provide services;
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C. In any case where a child is removed for a violation of school
rules for more than ten (10) consecutive school days or has been
removed for more than ten (10) cumulative school days, and such
removal constitutes a change in placement, services must
be provided. After the child has been suspended for a total of
twenty (20) days for school rule violations, the school will provide
services within the school district, unless the child represents a
danger to himself or others; and
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D. Services will be provided to the extent necessary to enable the
child to appropriately progress in the general curriculum and
appropriately advance toward achieving the goals set out in the
child’s IEP. School personnel, in consultation with the child’s
special education teacher, will determine the extent of services
necessary to enable the child to appropriately progress in the
general curriculum and appropriately advance toward achieving the
goals set in the child’s IEP. Schools must provide all services that
can be reasonably provided outside the school setting.
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Using Available Information to
Make Informed Decisions
Regarding the Manifestation
Determination
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• The MDR Team must meet within 10 days
from the decision of removal to an interim
alternative education setting (IAES)
• Membership of review team
– Streamlined to district representative, parent,
and “relevant members” of the IEP team
• Other individuals with unique insights into the
student or the incident of misconduct
– No guidance is provided as to who these
relevant individuals shall be
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• The review team must review any relevant
information to determine:
– If the conduct question was caused by, or had a
direct and substantial relationship to the
student’s disability,
– If the conduct in question was the direct result of
the school’s failure to implement the IEP
[§300.530(e)(1(ii)]
• If such a finding is made, the regulations
require the school to take immediate steps to
remedy those deficiencies.
[§300.530(e)(3)]
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Manifestation Determination
To make these determinations, the group will review:
1. Student's IEP
2. Teacher observations
3. Relevant information provided by the parents
Note: No guidance is provided as to how these determinations
will be completed or the relevant information that is to
be reviewed
The link between the child's conduct violation and his or her disability
is important. The Federal Register - (71 Fed. Reg. 46720)
We believe the Act recognizes that a child with a disability may display
disruptive behaviors characteristic of the child's disability and the
child should not be punished for behaviors that are a result of the
child's disability.
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• There is little guidance from theory,
research, and legal issues.
• Examine:
– Student’s file
– Observations of student
– Parent information
– Circumstances of the incident and prior
incidents (if any)
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• What to look for:
– Patterns of attendance, discipline, grades
– Universal screening data (behavior and academic)
– Other behavior data (logs, graphs, etc.)
– FBA
– IEP
•
•
•
•
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Eligibility category
Appropriate to address needs
Documentation of services
Contains behavioral goals and a BIP
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• Was the IEP legally developed?
• Want the IEP implemented as written?
• Have the services been provided consistent with the
IEP?
• Is the student making educational progress?
• Did the IEP address all of the student’s needs?
• Are behavioral goals and objectives included in the IEP?
• Was there a developing pattern of conduct that should
have been detected and addressed?
• Has the IEP been modified over time to reflect changes
in the student?
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• Sources:
– Teachers, staff, parents, student report (e.g., ratings)
• Can be based upon observations
– Previous recent observation data
– Following the incident
– Is behavior similar to that of others with a similar disability?
• Recent changes in mood, behavior, frustration, etc.
• Understanding of consequences
• Ability to control behavior
– Previous socially acceptable behavior examples
– Previous self-control examples
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•
•
•
•
Are the student’s thought processes logical?
Did the student understand consequences for violation?
Did the student know the behavior was inappropriate?
Does the student know and understand the district code of
conduct?
• Has the student demonstrated the ability to follow school
rules?
• Has the student previously expressed that similar behavior
is wrong?
• Has the student expressed an understanding of
consequences of behavior?
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• Has the student previously followed school rules?
• What features of disability have been exhibited in
the past?
• What situations is the student able to control
behavior?
• Are there factors that explain the misconduct?
• Was the behavior premeditated?
• Would similarly situated students without
disabilities react in a similar manner?
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•
•
•
•
Recent changes
Medications
Family circumstances/environment
Outside evaluations
– Diagnosis and hospitalizations
• Behavior in home environment
• Consider cultural differences
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• Antecedents, behavior, consequences
• Relationship to eligibility category and/or existing or
suspected diagnosis
• Individual involved in incident
• History surrounding specifics within the incident
–
–
–
–
Behavior
Individuals
Environment
Other recent events
• Is there evidence that previous efforts have been
made to address the behavior?
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• If there is due process, documentation will
assist the district to be defensible
• Many districts may wish to use a form to
guide the review team through the process.
• http://www.ode.state.or.us/pubs/forms/schoolage/1279-p.pdf
• http://www.phila.k12.pa.us/offices/specialedcspd/forms/manif
_determ_22403.pdf
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Protections for students not yet
determined eligible for special
education and related services
Criteria for Basis of Knowledge
IDEA is specific about what qualifies as “basis of knowledge.” It
states the school system can be deemed to have such knowledge if the
statement below apply before the behavior occurred: §300.534(b)
(1)The parent of the child expressed concern in writing to supervisory
or administrative personnel of the appropriate educational agency, or
a teacher of the child, that the child is in need of special education and
related services;
(2) The parent of the child requested an evaluation of the child; or
(3) The teacher of the child, or other personnel of the LEA, expressed
specific concerns about a pattern of behavior demonstrated by the
child directly to the director of special education of the agency or to
other supervisory personnel of the agency.
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Protections for students not yet
determined eligible for special
education and related services
The Child Find Mechanism
These provisions presume that, if individuals express concerns to
other individuals (especially those in supervisory positions within
the school system) about a child's behavior or possible need for
special education and related services, the school has an affirmative
obligation to act upon those concerns and investigate the child's need
for special education and related services.
Federal Register - (71 Fed. Reg. 46727)
…the child find and special education referral system is an important
function of schools
... School personnel should refer children for evaluation through the
school referral system when the child's behavior or performance
indicates that they may have a disability covered under the Act…
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Review Questions:
A few questions –
1.Under what circumstances must a manifestation determination be
conducted? (Whenever a decision is made to change the placement of a
child with a disability because he or she has violated a code of student
conduct.)
2.What's the time frame for conducting a manifestation
determination? (The manifestation determination must occur within 10
school days of any decision to change the placement of a child with a
disability because of a violation of a code of student conduct.)
3.Who is involved in conducting a manifestation determination?
(The LEA, parent, and relevant members of the child's IEP Team.)
4.Who decides who's a “relevant member” of the Team? (The parent
and the school.)
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Manifestation Determination
If the Determination is Yes - two scenarios under which the
manifestation determination would be “yes”. The incident:
1.was a manifestation of the child's disability, or
2.the direct result of the LEA's failure to implement the child's IEP.
If either condition is met, the student's conduct must be determined to
be a manifestation of his or her disability.
[§300.530(e)(2)-(3) and (f)]
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Manifestation Determination
“Yes,” for failure to implement the IEP
If the group determines that the child's misconduct was the direct
result of the school's failure to implement the child's IEP, “the school
must take immediate steps to remedy those deficiencies.”
The Federal Register explains, if such a determination is made:
The school has an affirmative obligation to take immediate steps to
ensure that all services set forth in the child's IEP are provided,
consistent with the child's needs as identified in the IEP.
(71 Fed. Reg. 46721)
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Manifestation Determination
What about placement?
Unless the behavior involved one of the special circumstances—
weapons, drugs, or serious bodily injury—the child would be
returned to the placement from which he or she was removed as part
of the disciplinary action.
However, the parent and school can agree to a change of placement
as part of the modification of the behavioral intervention plan.
[§300.530(f)(2)]
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Manifestation Determination
“Yes,” for conduct directly related to disability
If the group finds that the child's misconduct had a direct and
substantial relationship to his or her disability, then the group must
also reach a manifestation determination of “yes.”
Such a determination carries with it two immediate considerations:
1.Functional behavioral assessment (FBA)—Has the child had one?
Does one need to be conducted?
2.Behavioral intervention plan (BIP)—Does the child have one? If
so, does it need to be reviewed and revised? Or if the child does not
have one, does one need to be written? [§300.530(f)]
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Manifestation Determination
FBA focus
1.Identifying the function or purpose behind a child's behavior.
Knowing why a child misbehaves is directly helpful to the IEP
Team in developing a BIP that will reduce or eliminate the
misbehavior.
2.The IEP team must also write a BIP for the student, unless one
already exists. If a plan does already exist, then the IEP team
will need to review and modify it, as necessary, to address the
behavior.
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Conduct Functional Behavioral
Assessment (FBA) within 10 days:
• For suspensions of more than 10 days
• When placed in an interim alternative
educational setting (IAES)
• If a change of placement occurs
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FBA provides the process for developing a
useful understanding of how behavior relates to
the environment. It incorporates the following:
• Interviews
• Observations
• Reports from teachers and other professionals
• Record reviews
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• Behavior Supports
• Proactive Strategies
• Positive Interventions
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A positive behavior support plan must:
• Be developed by the IEP Committee
• Be based on an FBA
• Become part of the individual eligible
young child's or student's IEP
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• Positive behavior support programs and plans
must be be based on a Functional Behavior
Assessment (FBA) and must utilize positive
behavior support techniques.
• When an intervention is needed to address
problem behavior, the types of intervention
chosen for a particular student or eligible young
child must be the least intrusive necessary.
§14.133(a), §711.46(a)
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Such plans must include methods that
utilize positive reinforcement and other
positive techniques to shape a student's
behavior, ranging from the use of positive
verbal statements as a reward for good
behavior to specific tangible rewards.
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Manifestation Determination
If the Determination is “No.”
1.Then the student's behavior was not caused by or did not have
a direct and substantial relationship to the their disability;
2.the behavior was not the direct result of the school's failure to
implement the IEP.
In either case of “no,” school personnel have the authority to
apply the relevant disciplinary procedures to the child with
disabilities in the same manner and for the same duration as the
procedures would be applied to a child without disabilities.
However, the student is to continue to receive all other
services outline in the IEP.
§300.530(d)
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Manifestation Determination
After a student with a disability has been removed from
their current placement for 10 school days in the same
school year, the school system must provide services to
the student during any subsequent days of removal.
§300.530(d)
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Additional Aspects
• Punishment alone generally will not solve
the problem.
• Develop consequences for unacceptable
behavior.
• Allow for individual needs and differences.
• Make the punishment fit the code of
conduct violation.
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LEAs may order a student with disabilities
be placed in an interim alternative
educational setting (IAES) for no more
than 45 school days if the student is
involved in matters involving weapons,
drugs or serious bodily injury regardless of
relationship to disability.
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• Hearing officer decides if behavior is
dangerous to self or others.
• IEP Committee determines the IAES
placement and services.
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Case Examples
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• Who should attend the MDR meeting?
– Is there a need for an additional individual(s) to
assist the team?
• What types of information should they
consider in the child’s file?
• What types of observation data is needed?
• What should be examined in the IEP?
• What information should the team encourage
the parents to share with the team?
• What else should be considered?
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Josey is an 8 year old first grader in special education
with a severe communication disorder that prevents her
from effectively interacting with her peers. She has few
friends and often plays by herself at recess. Sometimes
the other children tease her. One day in the bathroom,
she pushed another child who fell and hit her head on the
sink. The girls knocked two of her teeth out and severely
cut her lip. The other children said Josey was angry and
meant to push the other child.
The district has decided that Josey will be placed at the
alternative school for 45 days.
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Mary is a eighth grader who is served in special education under a
ruling of SLD. She was diagnosed with ADHD when she was 7
years old. She was walking to the bus when several other students
were standing close by. One of the students pointed and the group
laughed. Right at that moment a fifth grade boy walked by. Other
students reported Mary pushed the boy. The next day the younger
student asked to see the school nurse to get a band aid for his
shoulder. He told the nurse that a girl has injured him with a pencil
after school. Upon investigation, the district found that Mary
confessed to hitting the boy with a pencil. She said she did not
know why she did it, that she did not know the boy, and he did not
do anything to her.
The district has decided to place Mary at the Alternative School for
20 days.
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Austin is a 12 year old diagnosed with bipolar
disorder. Lately he has been not sleeping and
seems to be very active. He was caught running
through the halls of the schools with a can of spray
paint. Later it was discovered that he had painted
a four letter word on his teacher’s classroom door.
The district has decided to place him at the
alternative school for the rest of the year.
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Sam is a child diagnosed with Asperger’s. He takes a
number of medications and the doctor has recently
changed his medication. One day he suddenly
became enrage in his classroom and threatened his
teacher and another student with his father’s gun, tore
a television off the wall, and swept all the materials off
the teachers desk.
The district has a zero tolerance policy and has
decided to place Sam at the alternative school for one
year.
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Meloy, L.L.. (n.d.). Minimalist approach to manifestation determination:
Possible compromise of due process rights. In Research-based
practice . Retrieved June 3, 2013, from
http://www.nasponline.org/publications/cq/36/6/manifdeter.aspx.
Kubick, Jr., R.J. (2010). Best practices in making manifestation
determinations. In A. Thomas & J. Grimes (Eds.), Best Practices in
School Psychology V, vol. 3 (pp. 827-837).
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Valecia Davis
vdavis@mde.k12.ms.us
Desma McElveen
dmcelveen@mde.k12.ms.us
Tanya Bradley
tbradley@mde.k12.ms.us
Office of Special Education
Division of Technical Assistance
(601) 359-3498
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