Third Circuit Denies Reimbursement when Medical Needs Can be Separated from Educational Needs

In the case of Mary Courtney T. v. School District of Philadelphia, in which a decision was issued July 31, 2009, the Third Circuit Court of Appeals has held that where medical and other needs of a special education student can be separated out from the educational problems and needs of the student, the school district is not responsible for payment of those services which are not educational. 

In Mary Courtney T., the student was placed in a long-term residential psychiatric treatment center, which did not have educational accreditations and had no on-site school, special education teachers or school affiliations.  The evidence in the case, according to the Court, showed that the student's treatment at this facility was medical, despite the fact that it contained what could arguably be classified as educational components.  

The Court emphasized that it was not the tools used, but the goals of the program that are to be used to determine if the program was educational or medical.  The Court further explained that because the student's education was impeded by a complex and acute medical condition, and not a lack of educational services or a specific kind of placement, it was not the responsibility of the school district to address this need.  The Court distinguished this case from other cases where a simple change in placement, without the need for more extensive medical intervention, would allow a student to access his or her education.        

The Court explained that there must be a link between the treatment provided and the child's learning needs to qualify for reimbursement under the IDEA.  Put another way, the Court explained it "must consider whether the residential placement ... was necessary to provide [the student] with special education."  The Court looked at the program provided to the student and found that it was related to her medical needs, not her learning needs, and found that it did not qualify for reimbursement.  

Finally, the Court took an interesting approach on the issue of reimbursement, by skipping the normal first step of determining whether the school district provided an appropriate placement and only looked at whether the placement chosen by the parents, the psychiatric treatment center, was educationally appropriate.   

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