Least restrictive environment is student-based (NASDSE, 2018).
The concept of least restrictive environment (LRE) is a foundational element of the Individuals with Disabilities Education Act (IDEA) for all students with disabilities. However, LRE can often be misunderstood for students who are deaf or hard of hearing (DHH). An article titled “Deaf Students Education Services” published in 1992 by the U.S. Department of Education Office of Civil Rights (OCR) provided guidance to the provision of free and appropriate public education (FAPE) and the LRE for students who are DHH as explained in IDEA and section 504 of the Rehabilitation Act of 1973 (section 504). The article states, “The disability of deafness often results in significant and unique educational needs for the individual child. The major barriers to learning associated with deafness relate to language and communication, which, in turn, profoundly affect most aspects of the educational process.” The article goes on to explain that teams developing an individual education plan (IEP) for a student who is DHH should consider certain factors:
When a student is DHH, consideration of these factors is not only warranted, but necessary, to ensure that the student receives FAPE in an environment that is least restrictive to them. The article continues to explain that LRE for students who are DHH may not always be the general education classroom:
The Secretary is concerned that some public agencies have misapplied the LRE provision by presuming that placements in or closer to the regular classroom are required for children who are deaf, without taking into consideration the range of communication and related needs that must be addressed in order to provide appropriate services. The Secretary recognizes that the regular classroom is an appropriate placement for some children who are deaf, but for others it is not. The decision as to what placement will provide FAPE for an individual deaf child — which includes a determination as to the LRE in which appropriate services can be made available to the child — must be made only after a full and complete IEP has been developed that addresses the full range of the child's needs…. The overriding rule regarding placement is that placement decisions must be made on an individual basis.
The overriding rule regarding placement is that placement decisions must be made on an individual basis.
(U.S. Department of Education, 1992)
What this means for students who are DHH is that the LRE must not only be least restrictive, but also language rich. In summary, the least restrictive environment for students who are DHH are as varied as the individuals themselves. The National Association of State Directors of Special Education (NASDSE) (2018) states, “Least restrictive environment is student-based” and “Each student is unique.” Therefore, each educational plan should be individualized to meet the unique needs of each student.
The least restrictive environment is sometimes impacted by the population size found in any district. A “critical mass” is integral to providing a language rich environment for students who are DHH, but what is “critical mass?”
The FLIPP is a multi-purpose data-based discussion tool that presents a ‘picture’ of standardized and functional assessments for children who are DHH. It helps determines a student’s needs of their educational programming, including placement in the least restrictive environment.
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