National Association of State Directors of Special Education, Inc.
225 Reinekers Lane, Suite 420, Alexandria, VA 22314
Tel: 703/519-3800 Fax: 703/519-3808 www.nasdse.org

February 6, 2018
The Honorable Betsy DeVos
Secretary, U.S. Department of Education
400 Maryland Avenue, SW
Washington, DC
Dear Secretary DeVos:
We write on behalf of the National Association of State Directors of Special Education
(NASDSE), the national nonprofit organization that represents the state directors of special
education in the states, the District of Columbia, the U.S. Department of Defense Education
Agency, the Bureau of Indian Education, the U.S. territories and Freely Associated States.
Your staff has indicated that the Department is considering postponing implementation of the
regulation on significant disproportionality in special education that was published in December,
2016. The regulation was designed to develop a uniform methodology for states to use in
identifying disproportionality and to take steps to address it.
Our members are the state personnel who are charged with implementation of this regulation.
While NASDSE members have had some concerns about the methodology proscribed in the
regulation, all states have been moving forward to implement the regulation. Postponing
implementation not only stops work already in motion, but it suggests that the identification and
redress of significant disproportionality can be put on hold.
NASDSE does not believe that addressing equity should ever be put on hold. Postponing
implementation leaves the states in limbo – should they move forward or stop what they doing?
We urge you to speak out and acknowledge the fundamental fact that equity for students with
disabilities in special education exists and should be addressed. Postponing implementation of
the regulation sends the wrong message at the wrong time.
NASDSE welcomes an opportunity to meet with you and members of your staff to discuss our
concerns.
Please feel free to contact NASDSE’s executive director, Bill East at bill.east@nasdse.org, (703)
3576 or NASDSE’s president, Santina Thibedeau at santina.thibedeau@doe.nh.gov or (603)
271-1099.
.
Sincerely,

Bill East
Executive Director

Santina Thibedeau
President