September 2025 – Special Educator e-Journal

Download a PDF Version of This e-Journal

● Special Education Legal Alert. By Perry A. Zirkel

● Buzz from the Hub

● Update from the US Department of Education

● Article: Enhancing Equity in Special Education By Dr. Sadia Warsi and Dr. Seema Imam

● Acknowledgements

Buzz from the Hub

https://www.parentcenterhub.org/buzz-august2025/

OSEP Fast Facts: Part B Exiting School

The Office of Special Education Programs (OSEP) has released a new OSEP Fast Fact: Students Served under IDEA Part B Exiting School. This is the first OSEP Fast Fact to focus specifically on how students with disabilities, ages 14-21, exit school—through graduation, dropout, reaching maximum age, and other exit reasons. This new OSEP Fast Fact uses data from the IDEA Section 618 Part B Exiting Data Collection to provide a national snapshot of the educational outcomes for students with disabilities as they transition out of school. Students who exited special education via moving and continuing special education or transferring to regular education are not considered in this Fast Fact.

Read the latest Fast Fact here.

An Age-By-Age Guide to Helping Kids Manage Emotions

When we teach kids to identify their emotions, we give them a framework that helps explain how they feel, which makes it easier for them to deal with those emotions in a socially appropriate way. This free printable from Quality Start LA shares simple tips to help young children, from infancy to preschool-age, manage their emotions.

Find the free printable here.

IRIS Modules on FBAs and BIPs

IRIS has released brand-new modules on functional behavioral assessments (FBAs) and Behavior Intervention Plans (BIPs)! These new IRIS Modules explore the importance of discovering the reasons that students engage in challenging behavior and outline steps for conducting an FBA and developing a BIP.

Check out the new modules on the IRIS website.

Adulting Shorts: Let’s Talk About Getting Your Teen Ready for a Job

This comic from UMass Chan’s Transitions to Adulthood Center highlights how the

Pre-employment Transition Services (Pre-ETS) help youth with disabilities ages 14–22 explore careers, build job-readiness skills, and prepare for life after school.

Read the comic here. Employment Connections

CPIR’s Employment Connections page guides families and educators through the steps of planning employment for youth with disabilities. It highlights the importance of identifying personal interests, leveraging supports like job coaches, and exploring opportunities for supported employment through networks like Vocational Rehabilitation.

Find all the resources on the Employment Connections page here.

The Power of Validation to Improve Meetings

“Validation doesn’t mean agreement—it means showing that you’re listening and that their experience makes sense from their point of view.” In this short, but insightful resource from CADRE, validation as a strategy to defuse tension and foster respect during emotionally charged conversations is discussed.

Read the one pager here.

Update from the U.S. Department of Education

(https://www.ed.gov/) Birth to Grade 12 Education-Reources

https://www.ed.gov/birth-to-grade-12-education

Available Grants

https://www.ed.gov/grants-and-programs/apply-grant/available-grants

U.S. Department of Education Encourages States to Maximize Opportunity to Improve Academic Achievement

The Department of Education sent a letter to all chief state school officers inviting them to implement existing statutory flexibilities and seek waivers from burdensome statutory and regulatory provisions by using the authority outlined in the ESEA.

U.S. Department of Education Approves Missouri to Pilot Innovative Statewide Assessment Program

Today, U.S. Secretary of Education Linda McMahon approved the Missouri Department of Elementary and Secondary Education request to pilot an innovative statewide assessment program focused on improving the existing statewide assessments.

Nicholas Kent Sworn in as 15th Under Secretary of Education

Nicholas Kent was sworn in after the United States Senate voted to confirm him as the 15th Under Secretary of Education.

U.S. Department of Education Initiates Title VI Investigation into Baltimore City Public Schools for Alleged Anti-Semitic Harassment

Today, the U.S. Department of Education’s Office for Civil Rights (OCR) opened an investigation into Baltimore City Public Schools in Baltimore, Maryland (BCPS) for allegedly violating Title VI of the Civil Rights Act of 1964 (Title VI).

U.S. Secretary of Education Linda McMahon Directs National Center for Education Statistics to Collect Universities’ Data on Race Discrimination in Admissions

Today, to fulfill President Trump’s memorandum directing the Department to promote transparency in higher education, U.S. Secretary of Education Linda McMahon directed NCES to collect universities’ data on race discrimination in admissions.

Secretary McMahon Announces “Returning Education to the States” 50-State Tour

U.S. Secretary of Education Linda McMahon today announced the “Returning Education to the States” Tour.

U.S. Secretary of Education Linda McMahon Joins Florida Education Leaders and Families for FAFSA Testing Event

Yesterday, U.S. Secretary of Education Linda McMahon attended a successful 2026-27 Free Application for Federal Student Aid (FAFSA®) beta testing event, marking the earliest successful test launch of the FAFSA form in history.

U.S. Department of Education Launches Investigations into Four Kansas School Districts For Alleged Title IX, FERPA Violations

The U.S. Department of Education’s Office for Civil Rights and Student Privacy Policy Office initiated investigations into four Kansas school districts.

U.S. Department of Education Issues Proposed Public Service Program Rules to Protect American Taxpayers

The Department issued a Notice of Proposed Rulemaking that would prevent benefits under the taxpayer-funded Public Service Loan Forgiveness program from being improperly provided to borrowers whose employers are are engaged in illegal activities.

U.S. Department of Education Prohibits Federal Funds from Supporting Political Activism on College Campuses

The U.S. Department of Education rescinded Biden-era guidance that allowed Federal Work Study (FWS) programs to pay students to engage in certain partisan and nonpartisan political activities.

U.S. Department of Education Places Five Northern Virginia School Districts on High-Risk Status and Reimbursement Payment Status for Violating Title IX

The U.S. Department of Education announced it is placing five Northern Virginia School Divisions on high-risk status with the condition that all federal funding flowing to these districts is done by reimbursement only due to their violations of Title IX.

U.S. Department of Education Initiates Title VI Investigation into Haverford College for Allegedly Tolerating Anti-Semitic Harassment

U.S. Department of Education’s Office for Civil Rights opened a directed investigation into Haverford College (Haverford) for allegedly violating Title VI of the Civil Rights Act of 1964.

U.S. Department of Education Issues Equitable Service School Choice Guidance

ED issued a Dear Colleague Letter to State and Local Education Agencies with additional guidance on how they might provide equitable services for students enrolled in private schools in more efficient and effective ways to best meet students’ needs.

U.S. Department of Education’s Office for Civil Rights Finds George Mason University Has Violated Title VI

Today, the U.S. Department of Education’s Office for Civil Rights (OCR) announced its finding that George Mason University (GMU) violated Title VI of the Civil Rights Act of 1964 (Title VI).

U.S. Department of Education Initiates Investigation into Burlington Public Schools for Allegedly Violating Parental Rights

The Department’s SPPO initiated an investigation into Burlington Public Schools in Massachusetts for allegedly failing to comply with parents’ requests to opt their children out of a survey that asked students questions about many sensitive topics.

U.S. Department of Education, Federal Partners Issue Guidance to Help Colleges and Universities Mitigate Foreign Threats to Research

Today, the U.S. Department of Education, alongside the Office of the Director of National Intelligence’s (ODNI) National Counterintelligence and Security Center (NCSC) and other federal partners issued new guidance in its Safeguarding Academia bulletin.

U.S. Secretary of Education Confirms On Time Launch of the 2026–27 FAFSA Form

Yesterday, U.S. Secretary of Education Linda McMahon sent a letter to Congress certifying that the 2026–2027 Free Application for Federal Student Aid (FAFSA®) form will be available on time this fall for students and families across the country.

U.S. Department of Education’s Office for Civil Rights Finds Denver Public Schools Violated Title IX

The U.S. Department of Education’s Office for Civil Rights found that Denver Public Schools violated Title IX of the Education Amendments of 1972 and its implementing regulations.

Special Education Legal Alert

By Perry A. Zirkel

© September 2025

This month’s update identifies two recent court decisions that respectively illustrate specialized ADA and IDEA issues. For related
publications and special supplements, see perryzirkel.com

On August 19, 2025, the Ninth Circuit Court of Appeals issued an unofficially published decision in *D.M. v. Oregon School Activities Association*, addressing the disability-discrimination challenge of a high school athlete’s challenge to the state’s interscholastic athletic association eligibility rule. The student in this case, who was starting his senior year, had a 504 plan for diagnoses that included ADHD, oppositional defiance disorder, and post-traumatic stress disorder. He was on the football team, which served for him as a motivational force for academic and behavioral advancement in school. Having attended a residential program, where he repeated tenth grade and played football, he had used his four years of eligibility upon enrolling in the district and completing his eleventh grade. As a result, he sought a waiver of the association’s “eight-semester rule,” which included an express exemption for students with IEPs (but not for those with 504 plans). The association denied his fifth-year hardship appeal. He quickly filed in federal court for an emergency temporary restraining order under the Americans with Disabilities Act (ADA), claiming that the requested waiver was a reasonable accommodation. The federal judge ruled against him, concluding that he failed to show the requisite likelihood of success on the merits of his claim. Two months later, the judge also denied his motion for a preliminary injunction. Although the football season was over, the student persisted in his lawsuit to seek the remaining potential remedy of money damages. Two years later the same judge issued a summary judgment for the athletic association. Undaunted, the student appealed the court’s decision to the Ninth Circuit. As is customary, a panel of three members of the appellate court made the decision.
First, the legal counsel on behalf of the plaintiff-student argued that the determination whether the requested waiver was a reasonable accommodation (in contrast with a fundamental alteration) requires a fact-specific individualized inquiry, thus reversing the summary judgment and moving to the trial stage.	The majority agreed, concluding that genuine issues of material fact remained as to whether in these specific circumstances the requested waiver was a reasonable accommodation and whether his disabilities were the “but-for” cause of his athletic ineligibility status, thus preserving the matter for a trial. The dissent disagreed on the alternative ground of the plaintiff’s failure to show deliberate indifference, which is required for money damages under the ADA.
Second, the plaintiff argued for reassignment to a different judge for the sought-for trial.	The three appellate judges unanimously ruled that in the absence here of proof of personal bias, the requested reassignment was not warranted.
Unless resulting in a settlement, this case is far from over, with the immediate alternatives being a decision either on reconsideration by the full Ninth Circuit or, more likely, via trial on remand to the lower court. Moreover, the issue more generally is unsettled, with two other circuits previously upholding the eight-semester rule without exemptions and a lower court in the Ninth Circuit establishing this interscholastic athletic association’s exemption for students with IEPs.

On April 21, 2025, a federal district court in Tennessee issued an unpublished decision in *William A. v. Clarksville/ Montgomery County School District, addressing implementation of the remedy that it ordered in its decision summarized in* the June 2024 update. In that earlier decision, the court upheld a hearing officer’s compensatory education award of 888 hours of dyslexia tutoring in the Wilson system, except that it removed the requirement for the tutor to be a “reading interventionist.” Next, the plaintiff-parent filed a motion with the court, seeking to modify the hearing officer’s order by specifically requiring the tutoring to be provided by the Dyslexia Center of Clarksville, which had previously served the student. The court denied the motion, reasoning that it could not conclude “at this stage” that the defendant-district was not capable of providing the specified Wilson-reading remedy. The court added this proviso: “If [the district] does prove to be wholly incapable of providing Wilson Reading and Language System instruction with its own personnel in a timely manner, then it will … have to look to an outside vendor.” The court also clarified that the tutoring should be 5 hourly sessions per week insofar as reasonably possible. The Sixth Circuit affirmed this decision. Next, the parents filed another motion with the lower court, contending that the district had failed to provide the ordered instruction “competently or expeditiously” and seeking an order to either convert the 888 hours into a compensatory education fund or have the defendant-district pay a private tutor directly.
The first reason that the parent gave for their latest request was that the district delayed the start of the instruction until a year after the hearing officer’s order and two months after the court’s affirmance.	Rejecting this basis and avoiding the finger-pointing as to which side was not sufficiently cooperative, the court concluded that “even if that gap caused the [student] harm and violated this Court’s order, the plaintiff has not argued that such harm would be remedied by the specific relief he seeks.”
The second reason is that the district’s tutor was merely trained, not certified, in the Wilson system.	In rejection, the court concluded that neither its order nor the hearing officer’s original award required certification, and no new evidence requires it.
Third, the parent contended that the district’s tutor failed to follow the Wilson System and otherwise lacks foundational literacy-teaching knowledge.	The court found the third contention insufficient to justify the requested revision, because even if the tutor’s instruction were deficient, “the district could cure this deficiency with a replacement tutor.”
The fourth basis was that the student had regressed in his reading skills during the tutoring.	Again, finding the basis insufficient, the court found that evidence showed initial regression but then significant progress during the 133 tutoring hours to date.
The final reason was that the tutoring had averaged 6.5 hours per month compared to 5 hours per week.	Without determining who was responsible for this lack of consistency and frequency, the court decided to order 5 hours per week on a set schedule.
This latest decision in the case of a student who graduated from high school with a 3.4 GPA and the inability to read illustrates the difficulty of the writing enforceable remedial orders that resolve the matter without becoming the subject of further costly litigation disputes between the parties. Given the congested schedule and generalist nature of federal courts, it also suggests that the state complaint process may have been a more effective alternative to address enforcement issues of the hearing officer’s remedial orders.

Enhancing Equity in Special Education: Integrating Cultural Responsiveness Through Universal Design for Learning

Dr. Sadia Warsi
National Louis University

Dr. Seema Imam
National Louis University

This practical guide translates research on integrating culturally responsive pedagogy with Universal Design for Learning (UDL) into actionable strategies for special education professors. Drawing from a course transformation that enhanced graduate students’ awareness of systemic barriers and improved their capacity for equitable practice, this article provides concrete tools including course activities, assignment templates, discussion facilitation strategies, and assessment rubrics. The guide addresses the urgent need for special education teacher preparation programs to address persistent disproportionality while maintaining focus on evidence-based practices. Professors will find immediately implementable resources designed to transform traditional special education coursework into more inclusive and equity-focused learning experiences.

Keywords: teacher preparation, culturally responsive pedagogy, Universal Design for Learning, special education, course design, practical implementation

The persistent overrepresentation of students of color in special education continues to represent one of the most pressing equity issues facing our field today. Black students are 1.4 times more likely to be identified for special education services than their peers and more than twice as likely to be labeled with emotional disturbance or intellectual disability according to recent

federal data (U.S. Department of Education, 2020). Yet despite decades of attention to this issue, the patterns persist, and perhaps more troubling, only 27% of special education teachers report feeling “very well prepared” to serve culturally and linguistically diverse learners with disabilities (National Center for Learning Disabilities, 2019). This preparation gap represents both a challenge and an opportunity for those of us working in special education teacher preparation programs. We have the responsibility and the power to prepare educators who not only understand evidence-based practices but also possess the cultural competence and critical consciousness necessary to serve all students equitably. What we’re sharing here comes from our own wrestling with these issues in our online asynchronous graduate course on differentiated instruction and curricular adaptations, where we found ourselves increasingly uncomfortable with the traditional approaches we were teaching while knowing we needed to do something different.

The integration of culturally responsive pedagogy with Universal Design for Learning principles offers what we’ve come to see as a promising framework for addressing these preparation needs while maintaining the scientific rigor that characterizes effective special education practice (Gay, 2018; CAST, 2018). This approach recognizes that effective special education must address both individual learning differences and systemic inequities that disproportionately affect students from marginalized communities (Annamma et al., 2013). What we didn’t anticipate when we began this work was how much it would challenge our own assumptions about teaching and learning, and how much we would need to confront our own biases and limitations as educators. This article emerges from the transformation of our graduate-level special education course over the course of one semester, where we observed changes in students’ awareness of systemic barriers, their comfort in discussing issues of race and equity, and their practical skills in

developing culturally responsive educational programs. We should note that this was not a smooth or linear process, and there were definitely moments when we questioned whether we were doing more harm than good.

The work we’re describing here goes beyond simply adding cultural content to existing courses, though we’ll admit that’s where we started before realizing how inadequate that approach was. As Fritzgerald (2020) reminds us, “antiracism must be active, not passive. Universal Design for Learning has to be intentionally implemented not just intended” (p. 8). It requires a fundamental examination of whose voices are centered in our curriculum, what perspectives are valued in our discussions, and how power operates within the educational systems we are preparing teachers to enter. This integration challenges us to move beyond color-blind approaches that ignore the reality of racial dynamics in education while maintaining the commitment to evidence-based practice that defines our field (DiAngelo, 2018). Most importantly, it requires sustained commitment to our own growth as culturally competent educators who can model the practices we expect from our students. We’re still very much in the process of this growth ourselves, and we’ve learned that admitting what we don’t know has been as important as sharing what we think we’ve figured out.

Theoretical Foundation and Course Design

The integration of UDL and culturally responsive pedagogy creates what we’ve begun to understand as synergies that address both individual learning differences and systemic inequities, though we didn’t see these connections clearly at first (Waitoller & King Thorius, 2016). UDL’s three principles of multiple means of engagement, representation, and action and expression align naturally with culturally responsive pedagogy’s emphasis on honoring diverse ways of

knowing and being (Meyer et al., 2014; Gay, 2018). When UDL’s focus on removing barriers combines with culturally responsive efforts to challenge systemic inequities, the result is a comprehensive framework that can serve all learners more effectively. However, we’ve learned that successful integration requires careful attention to how these frameworks complement and enhance each other rather than simply coexisting, and this took us longer to understand than we’d like to admit.

Traditional UDL implementation sometimes fails to address systemic inequities or the cultural factors that influence how students engage with learning environments (Kozleski & Waitoller, 2010). Similarly, culturally responsive approaches may lack the systematic framework for accessibility that UDL provides. When thoughtfully integrated, these frameworks address both limitations while maintaining the strengths of each approach (Fritzgerald, 2020), though we found that achieving this integration was messier and more challenging than the literature suggested it would be. The course design framework that emerged from our work follows a four-phase structure that allows students to build competence gradually while maintaining intellectual and emotional safety. We say “emerged” because honestly, we didn’t plan this structure from the beginning. It evolved as we watched students struggle with certain concepts and realized we needed to scaffold the learning more carefully than we originally thought.

The foundation-building phase establishes classroom community and introduces both frameworks side by side, helping students see connections from the beginning rather than treating them as separate concepts. During this phase, we begin the cultural autobiography work that helps students examine their own identities and assumptions while starting the literature component that provides emotional connection to the lived experiences of people with

disabilities. What surprised us was how difficult this phase was for many students, particularly those who had never been asked to examine their own cultural identities or consider how these might influence their professional practice. The critical analysis phase moves students into examining systemic inequities through data analysis, case study review, and discussions about the historical context of special education. This turned out to be the most challenging phase emotionally, as students confronted uncomfortable truths about disproportionality and their own potential complicity in maintaining inequitable systems. We learned that this phase requires especially careful facilitation to help students move through their discomfort toward productive action rather than becoming defensive or overwhelmed, and we’re still working to perfect this balance.

The practical application phase allows students to translate their growing understanding into concrete strategies for their professional practice. During this phase, they redesign existing curricula, develop culturally responsive IEPs, and create assessment alternatives that honor diverse ways of demonstrating competence. The final integration phase synthesizes learning through comprehensive projects and helps students develop action plans for continued growth beyond the course. Looking back, we realize that we were probably too ambitious with what we expected students to accomplish in a single semester, and we’ve been adjusting these expectations as we continue to refine the course.

Course Activities That Transform Understanding

One of the activities we’ve developed involves cultural identity mapping combined with professional reflection, though we should mention that the first time we tried this, it fell completely flat because we hadn’t prepared students adequately for the vulnerability it required.

This work begins with recognizing, as Fritzgerald (2020) notes, that “the teacher cannot be the only expert in the classroom. To deny students their own expert knowledge is to disempower them” (p. 5). Students begin by completing a cultural identity wheel that includes not only race and ethnicity but also language, religion, socioeconomic background, family structure, geographic region, and educational experiences. The reflection process that follows asks them to examine how these factors influenced their own learning experiences and how they might influence their expectations for students and families. This activity requires careful facilitation because it involves personal vulnerability, and we’ve learned that we need to model this vulnerability ourselves if we expect students to engage authentically.

We’ve found that the sharing process is as important as the individual reflection, though getting this right took several attempts and some awkward class sessions where students were clearly uncomfortable. Students work in pairs to share one significant insight from their mapping, then move to small groups to discuss how their cultural backgrounds might influence their professional practice. The whole group debrief focuses specifically on implications for special education, helping students make connections between personal experience and professional responsibility. What emerges from these discussions often surprises students who have never considered how their own cultural lenses influence their work with children and families. We’re consistently amazed by the insights that come from these conversations, even though we sometimes worry that we’re not facilitating them as skillfully as we should be.

The literature component has proven to be an important element of the course, though we initially underestimated how much time and discussion these books would require. We use novels featuring characters with disabilities from diverse backgrounds, with Out of My Mind by

Sharon Draper serving as the primary text. This novel centers on Melody Brooks, an eleven-year-old African American girl with cerebral palsy who cannot speak but possesses

exceptional intelligence. The first-person narration provides direct access to Melody’s thoughts and experiences, challenging common assumptions about intellectual ability and communication while highlighting how educational environments can either support or constrain student potential. What we didn’t expect was how emotionally challenging many students would find these readings, and we’ve had to build in more processing time than we originally planned.

To supplement this literature work, we developed a comprehensive Padlet resource titled “Building Equity in Teacher Preparation Programs” that curates picture books about social justice, childhood trauma, and refugee experiences, providing students with accessible texts that address complex equity issues across diverse populations .

Students often struggle initially with implementing these concepts in practice, particularly in content areas that seem more rigid, and we’ll admit that some of our early attempts to help them with this were less successful than we hoped. One mathematics teacher reflected, “This all sounds great, but putting it into practice seems more than challenging to me right now. Math is very concrete, there is a right answer and a wrong answer. There are also standards that have to be taught and graded along with the curriculum. I am not sure how to implement these strategies in my classroom yet.” However, as the course progresses, students begin to discover practical applications, often in ways that surprise us: “I have had students verbalize how to do a problem (because they had trouble putting it on paper) and they are 100% correct and they get full points of course. That is one way to incorporate these methods. I have also created hands-on labs for the

kids to ‘discover’ a theorem without me teaching it.” These moments of discovery remind us why this work is worth the struggle, even when it doesn’t go as smoothly as we’d like.

The importance of building trust and relationships as foundational to culturally responsive UDL emerges consistently in student reflections, though we’re still learning how to help students understand this in practice rather than just theory. As Fritzgerald (2020) notes, “trust is essential in all learning environments but particularly in urban classrooms. Reducing stress with trust is the foundational building block to a dynamic learning environment” (p. 36). Students begin to understand this principle in practice, with one noting, “I have always felt strongly that building connections with each student is the best way to build trust with them as well. If trust is not present, I don’t believe true learning can happen.” What we’ve learned is that modeling this trust-building in our graduate classroom is essential, and we continue to work on creating the kind of environment we want our students to create for their own students.

The discussions reveal assumptions and biases that students bring to their work, and facilitating these conversations continues to challenge us as instructors. Many students initially focus on Melody’s disability without recognizing how her race and cultural background also influence her educational experiences. Through guided discussion, they begin to see how multiple identity factors interact to shape individual experiences in ways that cannot be understood by examining any single characteristic in isolation. These insights prove helpful for later work on assessment practices and IEP development. As one student reflection noted in our course, “reading Out of My Mind completely changed how I think about non-verbal students. It has made me reconsider how I approach communication in my adaptations and IEPs. I am now much more focused on

finding ways to give these students a voice.” Moments like these make us feel like we’re onto something important, even when we’re not sure we’re doing everything right.

The transformative potential of this integrated approach becomes evident in students’ evolving understanding of their professional identity, though we’ve noticed that this transformation happens at different rates and in different ways for different students. One student wrote, “I used to think teaching was ‘teacher knows best’ and my classroom was structured in a way that was very rigid. I prepared each lesson, presented it, students took notes, completed homework, and repeated it all the next day. Fast forward 16 years, I aim to make my classroom interactive; it is student-centered instead of teacher-directed, at least as often as I can. When I show a student that they can teach me or that they can teach their classmate, it empowers them and makes them want to learn as well as teach others.” This shift from teacher-centered to student-centered approaches reflects the deeper understanding of how UDL and culturally responsive pedagogy can work together to honor student expertise and cultural knowledge. We find ourselves constantly inspired by these reflections, even as we recognize that not all students reach this level of insight, and we’re still trying to figure out how to support those who struggle with these concepts.

Another essential activity involves systematic analysis of disproportionality data combined with case study examination, and we’ll be honest that this is one of the most difficult parts of the course for us to facilitate well. Students begin by exploring local and state data on special education identification patterns by race and ethnicity, noting disparities and discussing potential contributing factors. We then provide carefully selected case studies representing diverse student populations at various stages of the referral and identification process. Working in small groups, students identify potential bias points in assessment and decision-making while considering how

culturally responsive practices might change student outcomes. This assignment often produces emotional responses from students as they confront the reality of systemic inequities in their own professional contexts, and we’re still learning how to support them through these reactions.

White students frequently experience what DiAngelo (2018) describes as “White fragility” when confronting concepts of privilege and systemic racism, while students of color may feel validated in their previous observations but also frustrated about the persistence of these patterns. As one student reflected, “I have been teaching for 20 years, and I thought I knew everything about adapting curriculum for students with disabilities. But this course has opened my eyes to how race intersects with disability in ways I never considered before. It is humbling and motivating at the same time.” We’ve learned to anticipate these reactions and provide structured opportunities for processing emotions while maintaining focus on productive action, though we don’t always get the balance right and sometimes worry that we’re pushing too hard or not hard enough.

The Padlet resource became particularly valuable for helping students understand the intersections between different forms of marginalization. The resource includes teacher candidate reflections on antiracism and Universal Design for Learning, which serve as models for the kind of critical thinking we expect from our students. One reflection featured on the Padlet noted how UDL “supports antiracism because it is student centered and it does not use assignments as oppressive tools that tell students they’re not good enough,” helping our students see concrete connections between the frameworks. The Padlet also addresses structural inequities in early childhood and elementary education, providing data and perspectives that students reference in their own analysis work. The IEP redesign workshop provides hands-on practice in applying integrated frameworks to practical special education tasks, and this has become one of our

favorite activities even though it took several iterations to get it working well. Working with partners, they redesign goals and services to incorporate both frameworks, paying particular attention to how cultural factors might influence goal relevance and measurement strategies. This practice embodies Fritzgerald’s (2020) principle that “we have to make room for learners to struggle and use resources that they know to figure out problems that they don’t know the answer to yet” (p. 19-20), applying this not only to K-12 students but to the adult learners in our teacher preparation programs.

The workshop includes a family perspective component where students role-play IEP meetings, with some taking on family member perspectives based on provided cultural background information. This role-playing consistently produces important insights about power dynamics in IEP meetings and the importance of truly listening to family perspectives rather than simply seeking their agreement with predetermined recommendations. Students often report that this experience fundamentally changes how they approach family engagement in their professional practice, though we’ve also learned that some students find this role-playing uncomfortable and we’re still working on ways to make it more accessible while maintaining its power to generate insight.

Discussion Facilitation Strategies

Facilitating discussions about race, culture, and disability requires skills that many of us in special education were never explicitly taught, and we continue to feel like we’re learning as we go. The concept of “brave spaces” rather than “safe spaces” has proven helpful in framing our approach, though we borrowed this idea from colleagues in other fields who were more experienced with this work than we were. We acknowledge that meaningful learning often

involves discomfort while emphasizing our collective responsibility to support each other through difficult conversations. This framing helps students understand that their discomfort is normal and productive rather than something to be avoided, though we sometimes struggle with knowing when discomfort is productive and when it’s becoming harmful. The asynchronous online format of our course initially concerned us when it came to these discussions, but we found that adding weekly synchronous Zoom sessions specifically for what we called “brave conversations” created the space students needed to process challenging concepts and engage with each other around difficult topics.

We’ve adopted Glenn Singleton’s Courageous Conversations protocol as our primary structure for discussing race and equity (Singleton, 2021), though we had to practice using this approach several times before we felt competent with it. The four agreements include staying engaged morally, emotionally, intellectually, and socially; speaking your truth by sharing authentic thoughts and feelings; experiencing discomfort as a natural part of growth; and expecting and accepting non-closure since some conversations will remain unresolved. This protocol provides safety through structure while encouraging authentic engagement with challenging topics. We’ve found that referring back to these agreements throughout difficult conversations helps keep us grounded, though there have definitely been times when we’ve had to remind ourselves of them as much as our students. The weekly Zoom sessions became crucial spaces where students could practice these brave conversations in real time, building the skills they would need to facilitate similar discussions in their own professional contexts.

Our discussion prompts are carefully scaffolded to build complexity over time, though we learned this through trial and error rather than careful planning initially. During the foundation

phase, we might ask students to describe a time when their cultural background influenced their learning experience and consider how this might inform their approach to teaching students with disabilities. Students also engage with our curated Padlet resource, which includes definitions of equity that emphasize how “equitable outcomes often require differential treatment and resource redistribution so as to achieve a level playing field among all individuals and communities,” helping them understand the theoretical foundations before moving into more challenging applications. In the critical analysis phase, prompts become more challenging: “Given what we know about disproportionality, how might we explain the overrepresentation of Black students in certain disability categories?” By the application phase, students are ready to tackle questions like “How would you explain the importance of culturally responsive IEP development to a colleague who says ‘disability is disability, culture doesn’t matter’?” We’ve learned that rushing this progression or skipping steps usually leads to unproductive conversations or student resistance. The synchronous Zoom sessions proved particularly valuable for these more challenging discussions, as students could read facial expressions and body language that helped them navigate the emotional complexity of these conversations in ways that weren’t possible through discussion boards alone.

Managing resistance requires patience and skill that we’re still developing, and we’ve made mistakes along the way that taught us important lessons. Common sources of resistance include fear of making mistakes or saying something offensive, belief that focusing on culture diminishes focus on disability, discomfort with discussions about privilege and systemic inequity, and concern about “lowering standards” or being “too political.” As Fritzgerald (2020) challenges us to consider, “are you willing to reconsider your own power, privilege, and practice to truly honor the students you serve?” (p. 8). We’ve learned to acknowledge these fears and

concerns without dismissing them, connecting cultural responsiveness to improved student outcomes through research and examples (Ford, 2012; Harry & Klingner, 2014). When resistance becomes more pronounced, we provide opportunities for private reflection and processing while using small group discussions before moving to large group sharing, though we’re still refining our ability to read when students need more support versus when they need gentle challenging. The brave conversations in our weekly Zoom sessions often became the places where the most resistant students began to open up, perhaps because the real-time nature of the discussion allowed for immediate clarification and support that wasn’t possible in asynchronous formats.

When difficult moments arise, and they inevitably do, we address problematic comments directly but respectfully, redirecting toward learning rather than blame (hooks, 1994). We follow up privately with students as needed and use mistakes as learning opportunities for the entire class. We’ve found that our own vulnerability and willingness to share our learning processes helps create an environment where students feel safer taking risks and making mistakes, though we continue to work on the balance between sharing our own experience and centering the learning that needs to happen for students. The online format actually proved beneficial for some of these follow-up conversations, as students who might have been embarrassed to discuss their mistakes in front of the whole class were more willing to engage in private video calls or email exchanges where they could process their learning without the pressure of public scrutiny.

Practical Assignments and Assessment Strategies

Cultural Autobiography and Professional Identity Development

The cultural autobiography and professional reflection assignment serves as the foundation for all other course work, though we underestimated how challenging this would be for some students when we first developed it. Students write a comprehensive reflective essay examining their cultural identity and its influence on their approach to special education. The assignment includes three distinct components, each building on the previous one. The personal reflection section requires students to complete a detailed cultural identity wheel encompassing race, ethnicity, language, religion, socioeconomic background, family structure, geographic region, educational experiences, and ability status. Students then write 3-4 pages analyzing how these intersecting identities shaped their worldview, learning preferences, and educational experiences. This section also asks them to examine significant experiences that influenced their understanding of difference and diversity, including any messages they received about disability, learning, and academic success from family, school, and community contexts.

The professional implications section asks students to connect their cultural identity analysis to their teaching practice in 2-3 pages, examining how their background might influence their expectations for students and families, their communication styles with diverse populations, and their comfort level with various cultural practices and family structures. Students must identify at least three potential biases they bring to their work and explain how these might impact their professional decision-making. This section often produces the most resistance, as many students have never been asked to critically examine their own assumptions or consider how their privilege might influence their work with marginalized communities.

This assignment often produces insights that students report as fundamental to their professional growth, though the quality varies significantly and we’re still working on how to support

struggling students. Many students note that they had never systematically examined their cultural identity or considered its influence on their professional practice (Sleeter, 2017). The action planning component requires students to develop specific strategies for ongoing cultural competence development in a detailed 2-page plan that includes concrete areas for growth, specific approaches for learning about different cultures represented in their school communities, resources for continued learning beyond the course, and accountability measures for ensuring continued progress. Students must identify at least five specific actions they will take in the next year, with timelines and measurable outcomes. We assess this assignment using a detailed rubric that evaluates depth of self-reflection, honest examination of biases, clear connections between personal experience and professional practice, specificity of growth plans, and evidence of genuine commitment to ongoing development. The assignment typically ranges from 7-9 pages total and requires students to cite at least three scholarly sources on cultural competence in special education.

Curricular Transformation Project

The curricular adaptation redesign project asks students to transform an existing curriculum unit using both UDL principles and culturally responsive pedagogy frameworks, and this assignment has evolved significantly since we first developed it. Students begin by selecting a curriculum unit from their current teaching context or student teaching placement, typically representing 2-3 weeks of instruction in any subject area. They conduct a comprehensive analysis using provided frameworks, examining how the current curriculum addresses or fails to address diverse learning needs, whose perspectives are represented or marginalized in the content, what cultural assumptions underlie the instructional approaches, and where barriers exist for students with

disabilities or from non-dominant cultural backgrounds. This analysis, typically 4-5 pages, must be supported by specific examples from the curriculum materials and connections to course readings on cultural responsiveness and UDL.

The redesign process requires students to fundamentally reconceptualize their unit while maintaining academic rigor and ensuring accessibility. Students must demonstrate how they will incorporate diverse perspectives throughout rather than as add-ons, provide multiple options for engagement that connect to various cultural ways of knowing and being, offer representation through multiple formats that accommodate diverse perceptual abilities and languages, and create expression opportunities that honor different cultural communication styles and abilities. The redesigned unit includes daily lesson plans with explicit UDL and cultural responsiveness indicators, modified materials that reflect diverse perspectives, and assessment alternatives that maintain high expectations while providing culturally responsive options. The implementation and reflection component asks students to pilot at least one lesson from their redesigned unit (when possible), gather feedback from students, colleagues, or families, document challenges and successes, and develop strategies for ongoing refinement. Students submit a final portfolio including their original unit analysis, complete redesigned unit with lesson plans and materials, implementation reflection, and a presentation for sharing with peers. We’ve found that providing examples of successful redesigns helps, though we worry sometimes that this constrains student creativity rather than inspiring it. This assignment challenges students to move beyond

surface-level modifications to fundamental reconceptualization of how curriculum can be designed to serve all learners, and many students initially struggle with this level of transformation.

Many students initially struggle with this assignment because it requires them to examine not only what they are teaching but also how they are teaching and whose perspectives are being centered, which can be overwhelming for those new to this work. The work reflects Fritzgerald’s (2020) insight that “UDL helps us create learning environments that not only prepare us for students’ differences but welcomes them” (p. 11).

Culturally Responsive IEP Development Workshop

The culturally responsive IEP development assignment demonstrates students’ ability to integrate both frameworks into one of the most important practical tasks they will perform as special educators, and this has become a signature assignment that we’re particularly proud of even though it took several iterations to get right. Students work with carefully constructed case studies representing diverse cultural backgrounds, disability categories, and age ranges from elementary through transition-age youth. Each case study includes comprehensive information about student demographics, detailed cultural background including family immigration history or community connections, current academic and functional performance data, family perspectives gathered through culturally responsive interviewing techniques, previous educational experiences including any trauma or discrimination, and community resources and cultural assets. We provide 4-5 case studies per semester, allowing students to choose one that challenges them to work outside their comfort zone or cultural familiarity.

The IEP components students develop must demonstrate sophisticated integration of both frameworks. The present levels of performance section must incorporate family perspectives and cultural factors using strength-based language that acknowledges cultural assets, identify how cultural factors may influence current performance without deficit-based assumptions, address

the intersection of disability and cultural identity, and include information about cultural communication styles, learning preferences, and family values. Students must write goals and objectives that address identified needs while building on cultural strengths, incorporate UDL principles in structure and measurement allowing for multiple demonstration methods, include opportunities for cultural expression and connection to community knowledge, specify accommodations that honor cultural communication styles rather than viewing difference as deficit, and ensure that progress monitoring respects cultural ways of demonstrating knowledge. The service specifications require detailed descriptions of special education and related services with explicit cultural considerations, supplementary aids and services using UDL frameworks that accommodate diverse learning and communication styles, assessment accommodations that honor cultural communication patterns and avoid cultural bias, transition services that connect to cultural values and community resources rather than imposing dominant culture expectations, and family engagement strategies that respect cultural hierarchy, communication patterns, and decision-making processes. Students must also develop a cultural responsiveness plan that outlines how they will continue learning about the student’s cultural background, build relationships with cultural community resources, and ensure ongoing family engagement throughout IEP implementation. This assignment challenges students to think beyond traditional special education approaches while maintaining focus on meaningful outcomes, though we’ve learned that some students need more scaffolding than others to be successful with this level of integration. We assess this work using a comprehensive rubric that evaluates cultural responsiveness, UDL implementation, family-centeredness, strength-based language, and practical feasibility.

Collaborative Unit Design Capstone Project

The final integrated unit design project requires students to synthesize their learning by creating comprehensive interdisciplinary units suitable for inclusive classrooms serving students with diverse abilities and cultural backgrounds, and this is where we see the most growth in student thinking though also the most variation in quality. Working in teams of 3-4 students with diverse backgrounds and teaching contexts, students design comprehensive 2-3 week interdisciplinary units that demonstrate seamless integration of UDL and culturally responsive principles across all components. The collaborative nature of this assignment intentionally brings together students from different cultural backgrounds, grade levels, and subject areas to mirror the collaborative work they will need to do in inclusive school settings. Teams must demonstrate shared

decision-making processes that honor different cultural perspectives and teaching philosophies while maintaining academic rigor and accessibility.

The units must connect meaningfully to academic standards while addressing diverse learning needs, demonstrate clear theoretical frameworks explaining the integration of both approaches with explicit citations to course readings, include 10-15 detailed lesson plans showing daily implementation with cultural responsiveness woven throughout content selection, instructional methods, and assessment approaches, and incorporate technology tools and community resources that reflect and support diverse cultural perspectives. Each unit must include a cultural responsiveness map showing how different cultural perspectives are integrated throughout rather than isolated in specific lessons, and a UDL implementation guide demonstrating multiple means of engagement, representation, and action/expression across all lessons. Assessment strategies must align with UDL principles while maintaining cultural responsiveness in design and implementation, providing multiple assessment options that honor different cultural communication styles while including accommodations and modifications that maintain rigor.

Teams must develop both formative and summative assessments that allow students to demonstrate knowledge through various modalities including visual, auditory, kinesthetic, and technology-enhanced methods. The assessment plan must include options for individual, partner, and group demonstrations of learning, with explicit attention to how cultural factors might influence student performance and engagement with different assessment formats.

The culminating requirement involves teams presenting their units to the class in a 20-minute presentation that includes a brief teaching demonstration, explanation of their integration approach, discussion of challenges and solutions, and facilitation of peer feedback. Teams must also submit a detailed implementation guide for other educators, including materials lists, technology requirements, community resource contacts, and troubleshooting suggestions for common challenges. This capstone project synthesizes all course learning while providing practical resources that students can immediately implement in their professional contexts.

Assessment and Evaluation Tools

We’ve developed assessment approaches that measure both individual framework implementation and the quality of integration between UDL and culturally responsive approaches, though we should acknowledge that creating these rubrics was an iterative process and they continue to evolve. Our cultural responsiveness assessment examines how curricula integrate multiple cultural perspectives throughout content, with attention to whether diverse voices are centered rather than marginalized and whether cultural representation goes beyond surface-level examples to meaningful integration. We also assess how curricula build on students’ cultural knowledge and experiences as resources for learning, connecting academic content to community wisdom and practices. The critical consciousness development component

of our rubric evaluates whether curricula encourage students to think critically about social issues, examine multiple perspectives, and consider their role in creating positive change. This criterion has proven essential because it distinguishes between approaches that simply include diverse content and those that actually challenge students to think critically about equity and justice.

UDL Implementation Assessment Rubric

Criteria	Beginning (1)	Developing (2)	Proficient (3)	Exemplary (4)
Multiple Means of Engagement	Limited engagement options with minimal attention to learner variability. Activities lack connection to student interests or cultural backgrounds.	Sometimes provides engagement variety but inconsistently addresses diverse motivational needs. Occasional connections to student interests or cultural backgrounds.	Usually provides multiple engagement options with clear attention to diverse interests and cultural backgrounds. Most activities offer appropriate challenge levels.	Consistently provides varied ways to motivate learners that authentically connect to diverse individual interests and cultural backgrounds. Offers appropriately challenging

				content that sustains motivation.
Multiple Means of Representation	Information presented primarily in single format with minimal accommodatio n for diverse learners. No consideration of cultural ways of knowing.	Some variety in information presentation but inconsistent attention to diverse learning needs. Limited consideration of cultural contexts.	Information presented in multiple formats with attention to diverse learning needs and some cultural considerations. Background knowledge often activated appropriately.	Information consistently presented in multiple formats accommodatin g diverse perceptual abilities, languages, and cultural ways of knowing. Background knowledge explicitly activated and cultural references meaningfully integrated.

Multiple Means of Action/Expressio n	Students have minimal options for demonstrating learning, primarily through traditional formats. No accommodatio n for diverse communication styles.	Students have some choice in demonstration methods but options limited. Minimal attention to cultural communication styles or diverse abilities.	Students have several meaningful options for demonstrating learning with attention to cultural and ability differences. Some authentic assessment approaches used.	Students have multiple authentic options for demonstrating knowledge that honor different cultural communication styles and abilities. Assessment is culturally responsive and provides ongoing feedback.
Cultural Asset Integration	Curriculum content reflects dominant cultural perspectives only. Student	Occasional acknowledgment of diverse cultural perspectives. Limited efforts	Regular integration of diverse cultural perspectives into curriculum content. Clear	Curriculum consistently builds on students’ cultural knowledge and

	cultural knowledge viewed as irrelevant or not addressed.	to connect academic content to student cultural experiences.	efforts to build on student cultural knowledge and experiences.	experiences as resources for learning. Academic content authentically connected to community wisdom and practices.
Critical Consciousness Development	Curriculum focuses solely on academic content without addressing social contexts or multiple perspectives.	Limited opportunities for critical thinking about social issues. Minimal attention to multiple perspectives or social justice themes.	Regular opportunities for critical thinking about social issues and examination of multiple perspectives. Some attention to equity and justice themes.	Curriculum consistently encourages students to think critically about social issues, examine multiple perspectives, and consider their role in creating

				positive change.
Accessibility and Inclusion	Learning environment assumes one way of learning and being. Barriers present for students with disabilities or from non-dominant cultural backgrounds.	Some efforts to remove barriers and provide accommodations . Inconsistent attention to diverse learning needs and cultural differences.	Learning environment designed to accommodate diverse learners with appropriate supports and accommodations . Regular attention to accessibility and inclusion.	Learning environment proactively designed for diverse learners from the outset. Barriers systematically identified and removed. Universal accessibility principles embedded throughout.

Our UDL implementation rubric examines the quality of implementation across all three principles, though we’re still refining the criteria as we learn more about what effective implementation looks like in practice. For engagement, we look for consistent provision of varied ways to motivate learners that connect to individual interests and cultural backgrounds, offer appropriate challenge levels, and sustain motivation throughout learning. The representation criterion examines whether information is presented in multiple formats that

accommodate diverse perceptual abilities, languages, and cultural ways of knowing, with particular attention to how background knowledge is activated and connected. For action and expression, we assess whether students have multiple meaningful options for demonstrating knowledge that honor different cultural communication styles and abilities, with emphasis on authentic and culturally responsive assessment.

The integration and synthesis assessment measures how seamlessly students integrate UDL and culturally responsive principles throughout all aspects of their work, with attention to clear understanding of how the frameworks complement each other rather than treating them as separate requirements. We also assess practical application by examining whether designs are immediately implementable with clear, specific strategies that teachers can adapt for their contexts, showing deep understanding of classroom realities. We continue to learn that assessing this kind of integration is more complex than we initially realized, and we’re working to develop more nuanced ways of recognizing and supporting student growth in this area.

Moving Forward

The work we’ve described in this article represents just the beginning of what is possible when we commit to transforming special education teacher preparation through the integration of culturally responsive pedagogy and UDL, though we want to be clear that this is an ongoing process rather than a finished product. The activities, assignments, assessment strategies, and curated resources like our Padlet on “Building Equity in Teacher Preparation Programs” presented here have been implemented in one context with one group of students, and we believe they can be adapted for various institutional settings and student populations, though we also

recognize that what works in our context may not work in others without significant modification.

The most important insight from our experience is that this work requires sustained commitment to our own growth as culturally competent educators, and we continue to learn just how much we don’t know. We cannot prepare teachers to engage in culturally responsive practice if we are not doing that work ourselves, and this means examining our own biases and assumptions, developing relationships with communities different from our own, and continuously learning about the cultural backgrounds of our students and the families they will serve. We also recognize that individual course transformation, while necessary, is insufficient for addressing the systemic nature of the challenges we face. Teacher preparation programs must commit to integration across courses rather than isolating cultural responsiveness to standalone diversity requirements, and field experience placements must provide opportunities for students to implement these approaches in authentic settings with ongoing support and mentorship.

The responses we’ve encountered, both from students and from institutional systems, remind us that this work involves challenging systems and structures that have operated in particular ways for decades, and change can create discomfort that not everyone is ready to embrace. Our role as teacher educators includes preparing students to navigate various environments while maintaining their commitment to equitable practice, though we’re still learning how to do this effectively ourselves. Perhaps most importantly, we must center the voices and experiences of the communities most affected by special education practices. Our work must be accountable to students with disabilities from diverse backgrounds and their families, not just to academic standards or institutional requirements (Yosso, 2005). This means creating ongoing opportunities

for community input, regularly examining our practices for unintended consequences, and maintaining humility about what we do not know.

As Fritzgerald (2020) reminds us, “when a learning environment is truly antiracist, then all learners will be empowered beyond bias to make decisions about their learning and leading because the environment is welcoming and safe” (p. 5). The changes we’ve observed in our students offer hope for the future of special education, though we recognize that not all students reach the same level of transformation and we continue to struggle with how to support those who find this work more challenging. When teachers leave our programs with both the technical skills and the critical consciousness necessary for equitable practice, they have the potential to disrupt patterns of inequity that have persisted for far too long. As one student reflected, “this course has not just changed how I teach. It has changed how I see the world and my role in it. I understand now that being a special educator means being an advocate for equity and justice, not just providing accommodations.” The tools provided in this article represent one contribution to that larger project, offered with the hope that others will adapt, improve, and extend this work in their own contexts, while recognizing that we all have much more to learn.

About the Authors:

First Author: Dr. Sadia Warsi

Dr. Sadia Warsi is a tenured Associate Professor in the Special Education Program at National Louis University who teaches Special Education courses including SPE 508 Literacy across the Curriculum for Students with Disabilities, SPE 509 Literacy Instruction for Diverse Learners, and SPE 527 Curriculum Adaptations in the Least Restrictive Environment. Her research centers on early childhood development in diverse environments, emergent literacy in multicultural

settings, experiences of children in homeless shelters, and minority parent involvement in special education, with expertise in qualitative methodology. She has a forthcoming book “Beyond labels: Understanding refugee students with disabilities in educational contexts” (2025).

Second Author: Dr. Seema Imam

Dr. Seema Imam is a tenured Professor in the School of Teacher Preparation at National Louis University who teaches in the Elementary, Special Education and Middle level Master of Arts in Teaching Programs. Her teaching focuses on preparing teachers to use educational technology in their practice and preparing teachers to meet the needs of multicultural students focusing on belonging and inclusion. She has developed expertise in teacher preparation through supervision of teacher candidates’ lesson preparation and in curriculum design through her work with Islamic school professionals, having taught an international online course titled “Integrating, Infusing, Initiating: Designing Curriculum for Islamic School” to educators worldwide. Her research and teaching interests center on inclusive teacher preparation that addresses the diverse needs of all students, informed by her extensive background in both traditional public school and Islamic school settings.

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