Before The
State Of Wisconsin
DIVISION OF HEARINGS AND APPEALS

In the Matter of Neenah School District
v.
[Student]

DECISION
Case No.: LEA-04-011

The Parties to this proceeding are:

[Student], by [Parents]
[address]
Neenah, WI 54956

Neenah School District, by

Attorney Lori M. Lubinsky
Axley Brynelson, LLP
One Park Plaza, Suite 500
P O BOX 1767
Madison, WI 53701-1767
PROCEDURAL HISTORY

On April 26, 2004, the Department of Public Instruction received a request for a due process hearing under Wis. Stats. Chapter 115, and the federal Individuals with Disabilities Education Act (IDEA) from Attorney Lori Lubinsky on behalf of the Neenah School District (District) and referred the matter to this Division for hearing. The due process hearing was held on June 1, 7, and 21, 2004. Eric Hjortness (Parent) appeared on behalf on the Student at the hearing, except for the afternoon of the third hearing day when Attorney David Winkel represented the Student.

Attorney Lubinsky and Mr. Hjortness filed post-hearing briefs, and the record closed on July 7, 2004. At the request of both parties, the deadline for issuance of a decision in this matter was extended to July 23, 2004.

ISSUE

The District seeks a determination that its March 2004 evaluation of the Student was appropriate and that, consequently, the Student's Parents are not entitled to an independent educational evaluation (IEE) at public expense.

FINDINGS OF FACT

  1. The Student is a 12-year-old child who attended kindergarten through fifth grade in the District at Spring Road Elementary School. (Ex. 1, Tr. I:14)

  2. In April 2001, the Student was diagnosed with attention deficit hyperactivity disorder-inattentive type (ADHD). (Ex. 9) In December 2001 and November 2002, the Student was diagnosed as having Tourette's spectrum disorder, ADHD, generalized anxiety, and obsessive compulsive disorder (OCD). (Ex. 10 and Ex. 7)

  3. In October 2001, when the Student was in fourth grade, the District met with the Parents and developed an Accommodation/Intervention Plan for the Student in response to concerns about her self-esteem, off-task behavior, and social-emotional maturation/peer relationships. (Ex. 20)

  4. In December 2001, the District determined that the Student had or was perceived as having an impairment that substantially limited her learning and work, as defined by Section 504 of the Rehabilitation Act of 1973. (Ex. 21) The basis for the determination was the Student's clinical diagnoses. (Id.) At a meeting with the Parents, the District developed a Section 504 Accommodation/Intervention Plan for the Student to address concerns about her self-esteem, academic performance, off-task behavior, and social-emotional maturation/peer relationships. (Id., Tr. I:13)

  5. The Student's Section 504 Plan was reviewed and updated in May 2002. (Ex. 1, p. 14) The Student's progress was again reviewed in October 2002, at the beginning of the 2002-2003 school year. At that time, her teachers and Parents reported satisfactory progress and no need for active case management, and the Student's fifth grade teachers were to be informed about her Section 504 Plan. (Id.)

  6. Prior to the start of the 2003-2004 school year, the Student's Parents enrolled her in sixth grade at Seton Middle School (Seton), a private parochial school in Neenah. (Ex. 1, Tr. Vol. I, p. 14, hereinafter I:14)

  7. On January 7, 2004, the Parents requested that the District conduct a "reevaluation" of the Student. (Ex. 27) The Student had not been previously evaluated by the District for special education services under the IDEA. (Tr. I:13) Following the request, the District's school psychologist met with the Parents to discuss and determine the scope of the evaluation. (Tr. I:15) It was determined that the District would conduct an initial special education evaluation of the Student, focusing on three areas of suspected impairment - speech and language, autism, and other health impairment (OHI). (Tr. I:16) These areas were selected for evaluation based upon the parents' stated concerns and the Student's clinical diagnoses. (Tr. I:16-20) The District began testing upon receipt of the evaluation consent form signed by the Parents. (Tr. I:22)

  8. After testing of the Student had begun, the Parents requested that the District hold an individualized education program (IEP) team meeting to discuss the testing. (Tr. I:22-23) At the meeting, the Parents requested that the District also conduct occupational therapy and physical therapy assessments of the Student and add two CESA-6 employees to the IEP team to conduct the autism and OHI assessments, rather than have District staff perform those portions of the evaluation. (Tr. I:23-25) The District agreed to add OT and PT assessments and additional evaluators; however, the autism consultant from CESA-6 was unable to participate as an evaluator because her schedule was full. (Id., Tr. I:108-109 and 269)

  9. The members of the Student's IEP team who conducted assessments of the Student included the following District employees: the school psychologist, the autism resource consultant, and the speech and language pathologist. (Ex. 1) Other evaluators on the IEP team included an OHI consultant employed by CESA-6, and a physical therapist (PT) and occupational therapist (OT), both employed by Theda Care, with whom the District contracts for PT and OT services. (Id., Tr. II:17, Tr. III:142-143) The evaluators on the IEP team were experienced, trained and knowledgeable in their respective fields. (Tr. I:147-150 and 250-256, Tr. II:18-22, Tr. III:142-144, 164-168, and 171-173) Other members of the IEP team were the Parents, one of the Student's core academic regular education teachers at Seton, Seton's guidance counselor and principal, and the District's Director of Special Education. (Id.)

  10. In the course of her evaluation of the Student, the speech and language pathologist met with the Student one-on-one on seven occasions, observed the Student for 60 minutes in the classroom, reviewed the Student's records, had the Student's teachers and Parents fill out questionnaires regarding her social skills, and administered six formal tests. (Ex. 1, Tr. I:151-154) Those tests assessed various areas of speech and language, including vocabulary, language competence, pragmatic language, and problem solving. (Ex. 1, p. 21) On the test of pragmatic language for adolescents, which assessed the Student's responses to social situations, the Student scored "exactly average" in the 50th percentile rank. (Tr. I:155) To qualify for speech and language services on that test, a Student must score in the 4th percentile rank. (Tr. I:156)

  11. During her evaluation of the Student, the autism resource consultant reviewed the Student's educational records and medical records submitted by the Parents, interviewed some of the Student's past and present teachers and the Seton guidance counselor, observed the Student in school, had the Student's parents, teachers and guidance counselor complete written assessment scales, and interviewed the Student. (Ex. 1, Tr. III:174-183)

  12. As part of her evaluation of the Student, the OHI consultant reviewed the Student's educational and medical records, interviewed the Student, interviewed the Seton guidance counselor, principal and some of the Student's teachers, and observed the Student for approximately three and a half hours in various settings and classrooms at school. (Ex. 1, Tr. I:257-260)

  13. In his evaluation of the Student, the school psychologist reviewed the Student's medical and educational records, interviewed the Student and the Parents, interviewed Seton staff, and administered the Achenbach behavior checklists to the Student, Parents and teachers. (Ex. 1, Tr.I:26-27)

  14. An IEP team meeting was held on March 29, 2004 to complete the Student's evaluation and to determine whether she was eligible for special education services. (Ex. 1) The Parents attended and participated in the meeting. All of the evaluators completed individual written evaluation reports that were provided to all of the IEP team participants, including the Parents, at the March 29 meeting. (Tr. I:28, II:291) The Student's father asked to stop the March 29 IEP team meeting at one point, but the Student's mother wanted the meeting to continue in order to hear the autism consultant's report. (Tr. II:359)

  15. All members of the IEP team, except for the Parents, concluded that the Student does not meet the eligibility criteria for autism, speech and language impairment, and OHI. (Ex. 1, Tr. I:31-32, I:159-162, I:203-204, I:237, I:262 and 264, Tr. II:32-33, II:109-110, Tr. III:152, III:187-192)

  16. The District's eligibility criteria for autism, speech and language, and OHI that were utilized for the Student's evaluation are the same as the eligibility criteria set forth in the Wisconsin Administrative Code. (Ex. 1)

  17. The District sent the Parents written notice, dated March 30, 2004, of the IEP team findings/determination that the Student is not a child with a disability, as well as the required recommendations for a child found not to be a child with a disability. (Ex. 35)

  18. By letter dated March 30, 2004, the Parents informed the District that they disagreed with the District's evaluation of the Student and asked the District to arrange and pay for an independent educational evaluation (IEE) of the Student. The Parents also requested another meeting with the District to further discuss the District's evaluation. (Ex. 2)

  19. On April 5, 2004, the Parents took the Student to the Department of Neurology at the University of Wisconsin Hospital and Clinics for consultation, testing and diagnoses by Dr. E. Ryann Watson. (Ex. 3) Dr. Watson met with the Student, reviewed the Student's medical and educational records, received behavior checklists from some of the Student's teachers, had the Student complete various neuropsychological tests and intelligence/IQ tests, and met with the Student's mother. (Tr. III:252-254) Dr. Watson's "diagnostic impression was that [the Student] had an autism spectrum disorder." (Tr. III:254) Dr. Watson's diagnosis was based upon the medical diagnostic criteria, DSM-IV TR. (Tr. III:254)

  20. By letter dated April 13, 2004, the District's Director of Special Education responded to the Parents' request for an IEE, requesting an explanation of why the Parents disagreed with the District's evaluation. The District requested a response by April 20, 2004, "[i]n order to make a determination regarding this matter within 20 business days of your request." (Ex. 15) The District was unaware at this time that the Parents had taken the Student to Dr. Watson for testing. (Tr. II:117) In the letter, the District also agreed to hold another meeting with the Parents to further discuss the District's evaluation of the Student. (Ex. 15)

  21. On April 14, 2004, the District received an invoice from UW Hospitals and Clinics for in the amount of $1,740.00 for Dr. Watson's psychological testing of the Student. (Ex. 16)

  22. By letter dated April 15, 2004, the Parents informed the District that they had obtained an IEE of the Student at the Waisman Center (at UW Hospitals and Clinics) in Madison because the District had "refused" their request for an IEE. (Ex. 17)

  23. By letter dated April 22, 2004, the District denied the Parents' request for an IEE on the grounds that its evaluation of the Student was appropriate and informed the Parents that the District would be filing a due process hearing request. (Ex. 18)

  24. On April 26, 2004, Attorney Lubinsky filed a due process hearing request with the Department of Public Instruction on behalf of the District, seeking a determination that the District's evaluation of the Student was appropriate and that the Parents were not entitled to an IEE at public expense.

  25. On April 27, 2004, Attorney David Winkel, on behalf of the Parents, sent the District a copy of Dr. Watson's report regarding the Student and suggested that the District pay the bill of $1,740.00 from the UW Hospital and Clinics. (Ex. 36) Attorney Winkel also requested that the District meet with the Parents to reconsider whether the Student needs special education services based on Dr. Watson's diagnosis. (Id.)

  26. By letter dated May 3, 2004, the District denied Attorney Winkel's request to reimburse the Parents for the UW Hospital and Clinics bill and agreed to reconvene the IEP team to consider the information in Dr. Watson's report. (Ex. 19)

  27. On May 17, 2004, the District held an IEP team meeting, including the Parents and their attorney, to review Dr. Watson's report and to consider whether it changed the IEP team's determination regarding the Student's eligibility for special education services. (Tr. I:36-37 and 265) For approximately two and a half hours, the IEP team discussed Dr. Watson's report, including concerns they had about the report and information contained therein. (Tr. I:265-268, Tr. II:27, II:163-164, II:173 and II:296, Tr. III:195-196)

  28. Except for the Parents, all members of the IEP team concluded that Dr. Watson's diagnosis of the Student and the information contained in her report did not change their determination that the Student does not meet the special education eligibility criteria for autism, OHI, and speech and language and is not a child with a disability under state and federal special education law. (Tr. I:37, I:165, I:268, Tr. II:35, Tr. III:196)

  29. On May 18, 2004, the District sent the Parents written notice of the District's refusal to amend the IEP team's evaluation and determination to find that the Student meets the special education criteria for an autism impairment. (Ex. 13)

DISCUSSION

The District filed a due process hearing request seeking a determination that its evaluation of the Student was appropriate and that the Parents are not entitled to an IEE at public expense. Upon the Parents' request for an IEE, state and federal law required the District either to initiate the IEE or to request a due process hearing. Wis. Stat. § 115.80(1)(b); 34 CFR § 300.502(b)(2). The District met its burden of establishing at the due process hearing that its evaluation of the Student was appropriate.

School districts are obligated by state and federal law to conduct an initial evaluation to determine whether a student is a child with a disability1 before providing special education2 and related services to the student. 34 CFR § 300.531, Wis. Stat. § 115.782. In order to conduct an initial evaluation of a child, a District must first appoint an IEP team of qualified individuals. Section 115.78(1m), Wis. Stats., directs districts to appoint IEP team participants as follows:

(1m) Appointment of Team. The local educational agency shall appoint an individualized education program team for each child referred to it under s. 115.777. Each team shall consist of all of the following:
(a) The parents of the child.
(b) At least one regular education teacher of the child if the child is, or may be, participating in a regular educational environment.
(c) At least one special education teacher who has extensive and recent training and experience related to the child's known or suspected disability as specified in s. 115.76 (5) (a) or, where appropriate, at least one special education provider of the child.
(d) A representative of the local educational agency who is qualified to provide, or supervise the provision of, special education, is knowledgeable about the general curriculum and is knowledgeable about and authorized to commit the available resources of the local educational agency.
(e) An individual who can interpret the instructional implications of evaluation results, who may be a team participant under pars. (b) to (d) or (f).
(f) At the discretion of the parent or the local educational agency, other individuals who have knowledge or special expertise about the child, including related services personnel as appropriate.
(g) Whenever appropriate, the child.

Here, the District appointed an IEP team for the Student that contained all of the required participants and more. The evaluators on the IEP team were experienced, trained and knowledgeable in their respective fields, in accordance with legal requirements. Despite the Parents' arguments to the contrary, there is no evidence that the IEP team members were unqualified and lacked the knowledge or recent training and experience necessary to appropriately evaluate the Student and participate on the IEP team.

Once a proper IEP team has been appointed, districts must adhere to the following requirements when conducting an evaluation to determine a child's eligibility for special education:

(2) Conduct of evaluation.
(a) In conducting the evaluation, the individualized education program team shall not use any single procedure as the sole criterion for determining whether a child is a child with a disability or for determining an appropriate educational program for the child. The individualized education program team shall do all of the following:
1. Use a variety of assessment tools and strategies to gather relevant functional and developmental information, including information provided by the child's parent, that may assist in determining whether the child is a child with a disability and the content of the child's individualized education program, including information related to enabling the child to be involved in and progress in the general curriculum or, for preschool children, to participate in appropriate activities.
2. Use technically sound instruments that may assess the relative contribution of cognitive and behavioral factors, in addition to physical or developmental factors.
3. Ensure all of the following:
a. That tests and other evaluation materials used to assess a child under this section are selected and administered so as not to be racially or culturally discriminatory and are provided and administered in the child's native language or other mode of communication, unless it is clearly not feasible to do so.
b. That any standardized tests that are given to the child have been validated for the specific purpose for which they are used, are administered by trained and knowledgeable personnel and are administered in accordance with any instructions provided by the producer of such tests.
c. That the child is assessed in all areas of suspected disability.
d. That assessment tools and strategies that provide relevant information that directly assists persons in determining the educational needs of the child are used.
(b) As part of an initial evaluation of a child and as part of any reevaluation of a child under sub. (4), the individualized education program team and other qualified professionals, as determined by the local educational agency, shall do all of the following:
1. Review existing evaluation data on the child, including evaluations and information provided by the child's parents, previous interventions and the effects of those interventions, current classroom-based assessments and observations, and observations by teachers and related services providers.
2. On the basis of that review and information provided by the child's parents, identify the additional data, if any, that are needed, and the qualifications of the evaluators that are needed, to determine all of the following:
a. Whether the child has a particular category of disability or, in case of a reevaluation of a child, whether the child continues to have such a disability.
b. The present levels of performance and educational needs of the child.
c. Whether the child needs special education and related services, or in the case of a reevaluation of a child, whether the child continues to need special education and related services.
d. Whether any additions or modifications to the special education and related services are needed to enable the child to meet the measurable, annual goals specified in the child's individualized education program and to participate, as appropriate, in the general curriculum.
(c) The local educational agency shall administer such tests and other evaluation materials as may be needed to produce the data identified under par. (b)2.
(d) If a child is attending a public school in a nonresident school district under s. 118.51 or 121.84 (1)(a) or (4), when the individualized education program team conducts its initial evaluation of the child or any reevaluation of the child under sub. (4), the team shall include at least one person designated by the school board of the child's school district of residence who has knowledge or special expertise about the child.
(e) Each individualized education program team participant who administers tests, assessments or other evaluation materials as part of an evaluation or reevaluation of a child under this section shall prepare and make available to all team participants at a team meeting a written summary of the participant's findings that will assist with program planning.

(3) Determination of eligibility for special education.
(a) Upon the completion of the administration of tests and other evaluation materials, the individualized education program team shall determine whether the child is a child with a disability. The individualized education program team may not determine that a child is a child with a disability solely because the child has received insufficient instruction in reading or math or because the child has limited proficiency in English.

(c) If the individualized education program team determines that a child is not a child with a disability, the team shall prepare an evaluation report. The report shall identify any educational needs of the child and any services offered by the local educational agency from which the child may benefit and shall include information about any programs and services, other than those offered by the local educational agency, that may benefit the child. The local educational agency shall give a copy of the evaluation report to the child's parents with the notice under s. 115.792 (1) (b).

Wis. Stat. §§ 115.782(2) and (3).

The District has established that its conduct of the Student's evaluation met the applicable legal standard. The District assessed the Student in all areas of suspected disability and conducted OT and PT assessments at the Parents' request. Based upon the Parents' concerns and previous clinical diagnoses, the Student was evaluated for suspected disabilities in the areas of autism, speech and language, and OHI. The District's eligibility criteria for autismi, speech and languageii, and OHIiii are the same as that set forth in the Wisconsin Administrative Code. The Student's IEP team utilized and reasonably applied the proper eligibility criteria in its evaluation of the Student.

As required by law, the IEP team used a variety of assessment tools, and tests were administered by trained, qualified individuals. The IEP team did not use any single procedure or rely on any single source of information. It received and considered information from the Parents, including medical and clinical records of the Student's. The IEP team reviewed the Student's educational records and considered information from past teachers of the Student's in the District and from current staff at Seton, including teachers, the principal, and the guidance counselor.

All of the IEP team members who assessed the Student completed individual written evaluation reports. Their reports were provided to all of the IEP team participants, including the Parents, at the March 29 meeting. The law does not require that the individual evaluation reports be provided to the IEP team participants prior to the IEP team meeting, as alleged by the Parents.

All members of the IEP team, except for the Parents, concluded that the Student does not meet the eligibility criteria for autism, speech and language impairment, and OHI. The IEP team's determination was reasonably and appropriately based upon all of the considerable information and data reviewed, obtained, and learned about the Student during the evaluation process.

The testimony of one of the Parent's experts offered support to the IEP team's determination. Dr. Inglese testified that the Student's disorders have not, heretofore, affected her ability to learn. (Tr. III:69) He further indicated that, over time, her disturbances might negatively impact her learning, but that thus far the evidence indicates that she is succeeding in school. (Tr. III:70)

Under the IDEA, when parents disagree with a school district's evaluation of their child, they have the right to an IEE at public expense, unless the district proves at a due process hearing that its evaluation was appropriate. See Letter to Young, 39 IDELR 98 (OSEP 2003). Here, the District has met its burden of proof and has shown that its evaluation of the Student was appropriate. Therefore, the Parents are not entitled to an IEE of the Student at public expense.

There was considerable testimony and argument by the parties as to whether Dr. Watson's testing of the Student constituted an IEE and whether the Parents and the District complied with the law and District policy regarding IEE procedures. Based upon my conclusion that the District's evaluation was appropriate, it is not necessary to address those arguments.

CONCLUSIONS OF LAW

The District's evaluation of the Student was appropriate; therefore, the Parents are not entitled to an IEE of the Student at public expense.

ORDER

The Parents are not entitled to an IEE of the Student at public expense, and the District is not required to reimburse the Parents for the cost of Dr. Watson's assessment of the Student.

Dated at Madison, Wisconsin on July 23, 2004.

STATE OF WISCONSIN
DIVISION OF HEARINGS AND APPEALS
5005 University Avenue, Suite 201
Madison, Wisconsin 53705-5400
Telephone: (608) 266-7709
FAX: (608) 264-9885
By:__________________________________
Sally Pederson
Administrative Law Judge
NOTICE OF APPEAL RIGHTS

APPEAL TO COURT: Within 45 days after the decision of the administrative law judge has been issued, either party may appeal the decision to the circuit court for the county in which the child resides under §115.80(7), Wis. Stats., or to federal district court pursuant to U.S.C. §1415 and 34 C.F.R. §300.512.

A copy of the appeal should also be sent to the Division of Hearings and Appeals, 5005 University Avenue, Suite 201, Madison, WI 53705-5400.

The Division will prepare and file the record with the court only upon receipt of a copy of the appeal. It is the responsibility of the appealing party to send a copy of the appeal to the Division of Hearings and Appeals. The record will be filed with the court within 30 days of the date the Division of Hearings and Appeals receives the appeal.

_________________
1The term "child with a disability" is defined in 20 U.S.C. § 1401 as: (3) CHILD WITH A DISABILITY
(A) IN GENERAL The term 'child with a disability' means a child
(i) with mental retardation, hearing impairments …, speech or language impairments, visual impairments …, serious emotional disturbance …, orthopedic impairments, autism, traumatic brain injury, other health impairments, or specific learning disabilities; and
(ii) who, by reason thereof, needs special education and related services.
See also Wis. Stat. § 115.76(5); 34 C.F.R. § 300.7(a)(1).

2The term "special education" is defined in 34 CFR § 300.26, which provides in pertinent part as follows:

(a) General. (1) As used in this part, the term special education means specially designed instruction … to meet the unique needs of a child with a disability …
* * * *
(3) Specially-designed instruction means adapting, as appropriate to the needs of an eligible child under this part, the content, methodology, or delivery of instruction-
(i) To address the unique needs of the child that result from the child's disability; and
(ii) To ensure access of the child to the general curriculum, so that he or she can meet the educational standards within the jurisdiction of the public agency that apply to all children.
See also 20 U.S.C. § 1401(25); Wis. Stat. § 115.76(15).
iAUTISM. (a) Autism means a developmental disability significantly affecting a child's social interaction and verbal and non-verbal communication, generally evident before age 3, that adversely affects learning and educational performance. Other characteristics often associated with autism are engagement in repetitive activities and stereotyped movements, resistance to environmental change or change in daily routines, and unusual responses to sensory experiences. The term does not apply if a child's educational performance is adversely affected primarily because the child has an emotional disturbance, as defined in sub.(7).
(b) The results of standardized or norm-referenced instruments used to evaluate and identify a child under this paragraph may not be reliable or valid. Therefore, alternative means of evaluation, such as criterion-referenced assessments, achievement assessments, observation, and work samples, shall be considered to identify a child under this paragraph. Augmentative communication strategies, such as facilitated communication, picture boards, or signing shall be considered when evaluating a child under this paragraph. To identify a child under this paragraph, the criteria under subd. 1. and 2. and one or more criteria under subd. 3. through 6. shall be met.
1. The child displays difficulties or differences or both in interacting with people and events. The child may be unable to establish and maintain reciprocal relationships with people. The child may seek consistency in environmental events to the point of exhibiting rigidity in routines.
2. The child displays problems which extend beyond speech and language to other aspects of social communication, both receptively and expressively. The child's verbal language may be absent or, if present, lacks the usual communicative form which may involve deviance or delay or both. The child may have a speech or language disorder or both in addition to communication difficulties associated with autism.
3. The child exhibits delays, arrests, or regressions in motor, sensory, social or learning skills. The child may exhibit precocious or advanced skill development, while other skills may develop at normal or extremely depressed rates. The child may not follow normal developmental patterns in the acquisition of skills.
4. The child exhibits abnormalities in the thinking process and in generalizing. The child exhibits strengths in concrete thinking while difficulties are demonstrated in abstract thinking, awareness and judgment. Perseverant thinking and impaired ability to process symbolic information may be present.
5. The child exhibits unusual, inconsistent, repetitive or unconventional responses to sounds, sights, smells, tastes, touch or movement. The child may have a visual or hearing impairment or both in addition to sensory processing difficulties associated with autism.
6. The child displays marked distress over changes, insistence on following routines, and a persistent preoccupation with or attachment to objects. The child's capacity to use objects in an age-appropriate or functional manner may be absent, arrested or delayed. The child may have difficulty displaying a range of interests or imaginative activities or both. The child may exhibit stereotyped body movements.

Wis. Admin. Code § PI 11.36(8).

iiSPEECH OR LANGUAGE IMPAIRMENT. (a) Speech or language impairment means an impairment of speech or sound production, voice, fluency, or language that significantly affects educational performance or social, emotional or vocational development.
(b) The IEP team may identify a child as having a speech or language impairment if the child meets the definition under par. (a) and meets any of the following criteria:
1. The child's conversational intelligibility is significantly affected and the child displays at least one of the following:
a. The child performs on a norm referenced test of articulation or phonology at least 1.75 standard deviations below the mean for his or her chronological age.
b. Demonstrates consistent errors in speech sound production beyond the time when 90% of typically developing children have acquired the sound.
2. One or more of the child's phonological patterns of sound are at least 40% disordered or the child scores in the moderate to profound range of phonological process use in formal testing and the child's conversational intelligibility is significantly affected.
3. The child's voice is impaired in the absence of an acute, respiratory virus or infection and not due to temporary physical factors such as allergies, short term vocal abuse, or puberty. The child exhibits atypical loudness, pitch, quality or resonance for his or her age and gender.
4. The child exhibits behaviors characteristic of a fluency disorder.
5. The child's oral communication or, for a child who cannot communicate orally, his or her primary mode of communication, is inadequate, as documented by all of the following:
a. Performance on norm referenced measures that is at least 1.75 standard deviations below the mean for chronological age.
b. Performance in activities is impaired as documented by informal assessment such as language sampling, observations in structured and unstructured settings, interviews, or checklists.
c. The child's receptive or expressive language interferes with oral communication or his or her primary mode of communication. When technically adequate norm referenced language measures are not appropriate as determined by the IEP team to provide evidence of a deficit of 1.75 standard deviations below the mean in the area of oral communication, then 2 measurement procedures shall be used to document a significant difference from what would be expected given consideration to chronological age, developmental level, and method of communication such as oral, manual, and augmentative. These procedures may include additional language samples, criterion referenced instruments, observations in natural environments and parent reports.
(c) The IEP team may not identify a child who exhibits any of the following as having a speech or language impairment:
1. Mild, transitory or developmentally appropriate speech or language difficulties that children experience at various times and to various degrees.
2. Speech or language performance that is consistent with developmental levels as documented by formal and informal assessment data unless the child requires speech or language services in order to benefit from his or her educational programs in school, home, and community environments.
3. Speech or language difficulties resulting from dialectical differences or from learning English as a second language, unless the child has a language impairment in his or her native language.
4. Difficulties with auditory processing without a concomitant documented oral speech or language impairment.
5. A tongue thrust which exists in the absence of a concomitant impairment in speech sound production.
6. Elective or selective mutism or school phobia without a documented oral speech or language impairment.
(d) The IEP team shall substantiate a speech or language impairment by considering all of the following:
1. Formal measures using normative data or informal measures using criterion referenced data.
2. Some form of speech or language measures such as developmental checklists, intelligibility ratio, language sample analysis, minimal core competency.
3. Information about the child's oral communication in natural environments.
4. Information about the child's augmentative or assistive communication needs.
(e) An IEP team shall include a department-licensed speech or language pathologist and information from the most recent assessment to document a speech or language impairment and the need for speech or language services.

Wis. Admin. Code § PI 11.36(6).

iiiOther health impairment means having limited strength, vitality or alertness, due to chronic or acute health problems. The term includes but is not limited to a heart condition, tuberculosis, rheumatic fever, nephritis, asthma, sickle cell anemia, hemophilia, epilepsy, lead poisoning, leukemia, diabetes, or acquired injuries to the brain caused by internal occurrences or degenerative conditions, which adversely affects a child's educational performance. Wis. Admin. Code § PI 11.36(10), See also 34 C.F.R. § 300.7.