Wednesday, August 5, 2009
District failure to properly serve appeal papers results in SRO affirmance of reimbursement award
SRO 09-062 and 09-075: Parents prevailed at hearing on private school reimbursement claim. NYC attorneys served appeal papers on parent’s attorney despite requirment that papers be personally served upon the parent. SRO held that service was improper and thus, refused to consider the district’s appeals.
Monday, August 3, 2009
U.S signs the U.N. Convention on the rights of persons with disabilities
On July 30, 2009, the United States became one of 142 countries that have signed the UN Convention on the Rights of Persons with Disabilities. The purpose of this convention is “to promote, protect and ensure the full and equal enjoyment of all human rights and fundamental freedoms by all persons with disabilities, and to promote respect for their inherent dignity.” Notable with respect to the rights of students with disabilities is the following:
*In all actions concerning children with disabilities, the best interests of the child shall be a primary consideration. Article 7, §2.
*States Parties shall ensure an inclusive education system at all levels and lifelong learning directed to “the full development of human potential and sense of dignity and self-worth, and the strengthening of respect for human rights, fundamental freedoms and human diversity” and
the “development by persons with disabilities of their personality, talents and creativity, as well as their mental and physical abilities, to their fullest potential.” Article 24, §1.
*Effective individualized support measures are provided in environments that maximize academic and social development, consistent with the goal of full inclusion. Article 24, §2.
*Signatory nations (i.e. the U.S. and others) agree to “adopt all appropriate legislative, administrative and other measures for the implementation of the rights recognized in the present Convention” and “to take all appropriate measures, including legislation, to modify or abolish existing laws, regulations, customs and practices that constitute discrimination against persons with disabilities”
Thus, our country has made a commitment to the world at large that we will engage in a course of conduct that, inter alia, maximizes the academic development of children with disabilities. Therefore, arguably, any decision made, subsequent to the signing of this convention, that enforces the traditional, overly restrictive, access only interpretation of Rowley, would be at odds with this commitment that we as a nation have made to maximize, rather than to merely provide an opportunity to acquire meaningful benefit.
*In all actions concerning children with disabilities, the best interests of the child shall be a primary consideration. Article 7, §2.
*States Parties shall ensure an inclusive education system at all levels and lifelong learning directed to “the full development of human potential and sense of dignity and self-worth, and the strengthening of respect for human rights, fundamental freedoms and human diversity” and
the “development by persons with disabilities of their personality, talents and creativity, as well as their mental and physical abilities, to their fullest potential.” Article 24, §1.
*Effective individualized support measures are provided in environments that maximize academic and social development, consistent with the goal of full inclusion. Article 24, §2.
*Signatory nations (i.e. the U.S. and others) agree to “adopt all appropriate legislative, administrative and other measures for the implementation of the rights recognized in the present Convention” and “to take all appropriate measures, including legislation, to modify or abolish existing laws, regulations, customs and practices that constitute discrimination against persons with disabilities”
Thus, our country has made a commitment to the world at large that we will engage in a course of conduct that, inter alia, maximizes the academic development of children with disabilities. Therefore, arguably, any decision made, subsequent to the signing of this convention, that enforces the traditional, overly restrictive, access only interpretation of Rowley, would be at odds with this commitment that we as a nation have made to maximize, rather than to merely provide an opportunity to acquire meaningful benefit.
Friday, July 31, 2009
Assessment of whether offer was more favorable than results obtained at hearing
Hawkins v. Berkeley: A school district can limit its ultimate exposure to attorney fees by making a settlement offer that exceeds that which the parent ultimately obtains after all legal proceedings have been completed. The evaluation of whether the district’s offer is more favorable than the relief obtained can be quite complex. There is a very helpful discussion in this case. Although the case is a California case, the Court cites to the 2nd Circuit.
fn 8: That the burden is appropriately placed on the District is also
supported by the legislative history for the Handicapped
Children's Protection Act, the IDEA's predecessor. See 132 Cong.
Rec. S. 9277 (1986) (co-sponsor Sen. Simon) (stating that a
"court should not ... enter into difficult attempts to make
complex or arbitrary comparisons of different forms of relief"
and that, "[f]or a court to deny an award of fees on the basis of
a rejection of an offer, it must be manifestly clear that the
relief offered was as favorable as that obtained") (emphasis
added).
To be sure, the difference between the kinds of relief obtained
and offered is like comparing apples and oranges, and so there is
some difficulty in evaluating whether this aspect of the
settlement agreement was more or less favorable. Therefore, the
Court must determine who bears the burden of proof — i.e., is it
the District's burden to show that the agreement was less
favorable or Mr. Hawkins's burden to show that the agreement was
more favorable? In the context of Rule 68, courts have held that
it is the burden on the defendant to show that the settlement
offer was more favorable than the judgment. See Reiter v. MTA
N.Y. City Transit Auth., 457 F.3d 224, 231 (2d Cir. 2005) (stating
that, "[i]n determining the value of the relief, the defendant
bears the burden of showing that the Rule 68 offer was more
favorable than the judgment"); Milton v. Rosicki, Rosicki &
Assocs., P.C., No. 02 CV 3052 (NG), 2007 U.S. Dist. LEXIS 56872,
at *8-9 (E.D.N.Y. Aug. 3, 2007) (noting the same); Jankey v.
Beach Hut, CV 05-3856 SVW (JTLx), 2006 U.S. Dist. LEXIS 96365, at
*23 (C.D. Cal. Dec. 19, 2006) (noting the same). As explained in
one legal treatise, it is often difficult to compare nonmonetary
forms of relief but,
[a]s a guiding principle ..., it would be best to
view the defendant as having the burden of
demonstrating that the offer was superior. Although it
is true that the rule itself makes the cost-shifting
consequences apply unless the judgment is more
favorable, suggesting that the burden to show that the
judgment is more favorable should be on the plaintiff,
that wording assumes the comparison is not difficult to
make. Rule 68 is actually a tool for defendant to use,
and defendant alone determines the provisions of the
offer. Since defendant has drafted those provisions,
the courts generally interpret the offer against
defendant. Consistent with that, the burden should be
on defendant to demonstrate that those provisions are
in fact more favorable than what plaintiff obtained by
judgment.
Wright, et al., 12 Fed. Prac. & Proc. Civ. 2d § 3006.1. The
settlement offer provision in the IDEA is modeled on Rule 68, and
therefore the Court concludes that the burden is on the District,
as the defendant in the case, to show that the settlement
agreement was less favorable. In light of the discussion above,
the District has failed to meet that burden.[fn8]
fn 8: That the burden is appropriately placed on the District is also
supported by the legislative history for the Handicapped
Children's Protection Act, the IDEA's predecessor. See 132 Cong.
Rec. S. 9277 (1986) (co-sponsor Sen. Simon) (stating that a
"court should not ... enter into difficult attempts to make
complex or arbitrary comparisons of different forms of relief"
and that, "[f]or a court to deny an award of fees on the basis of
a rejection of an offer, it must be manifestly clear that the
relief offered was as favorable as that obtained") (emphasis
added).
Parent justified in rejecting settlement offer for failure to include reasonable attorney fees
Hawkins v. Berkeley: In this California district court case, the Court held that the parent was substantially justified in rejecting a prehearing district settlement offer for failure to include adequate attorney fees.
Thursday, July 16, 2009
Pendency determined by state complaint process
Millay v. Surry, 584 F. Supp. 2d 219 (D.C. Maine 2008): A Maine District Court held that a decision rendered by the State of Maine Education Department in response to a complaint filed by the parent through the complaint resolution process established the child’s pendency placement during subsequent proceedings.
10th Circuit rules that eligibility under IDEA does not necessarily make a student eligible under 504
Ellenberg v. New Mexico Military Institute, 2009 WL 1977486 (10th Cir. 2009): According to the 10th Circuit Court of Appeals, eligibility for special education and having an individualized education program under the IDEA demonstrates a child's disability, but not necessarily that the disability “substantially limits” the major life activity of learning. Therefore, IDEA eligibility does not necessarily yield 504 eligibility.
Friday, July 10, 2009
Thursday, July 9, 2009
4th Circuit allows parent to proceed on unreasonable restraint claim
H.H. ex rel. H.F. v. Moffett, 2009 WL 1931203 (4th Cir. 2009): Parent alleged that school district personnel “maliciously kept [her child] restrained in her wheelchair for hours at a time during the school day, while they ignored her, verbally abused her, and schemed to deprive her of educational services.” This case is in the preliminary stages. The Circuit Court found that the evidence demonstrated that the alleged conduct violated the child's clearly established right to freedom from undue restraint under the Fourteenth Amendment, and that therefore, the teacher was not entitled to qualified immunity as a matter of law.
Tuesday, June 30, 2009
Impact of legislative stalemate on special education law in New York State
As those of us in New York State are aware, legislative activity in Albany appears to have ground to a halt. Unfortunately, many state laws governing special education expired today. There is no indication that the legislature took action to extend these provisions. Of particular note, Education Law §4404(3)(a) expressly provided a 4 month statute of limitations for appealing an adverse State Review Office decision. This section expired today. In its stead is a provision that does not include a period of time during which an appeal must be commenced, thus adding an element of uncertainty as to whether the 4 month period contemplated by Article 78 or the 3 month Statute of Limitations provided by the IDEA would apply.
Next, students with IEPs who attend private schools are presently entitled to special education services from the district of location of the private school. As of July 1, it appears that the district of residence will be the responsible district.
Next, students with IEPs who attend private schools are presently entitled to special education services from the district of location of the private school. As of July 1, it appears that the district of residence will be the responsible district.
Thursday, June 25, 2009
SRO orders provision of ESY services and test accommodations
SRO 09-052: CSE recommended ESY services for 06-07 and 07-08 school years. The March 14, 2008 CSE removed ESY services from the student's IEP for the 2008-09 school year. SRO Paul Kelly stated that “[n]either the March 14, 2008 IEP nor the testimony and evaluations presented at the impartial hearing demonstrated that the student's needs changed such that he was no longer at risk of substantial regression during the summer months. Based on the above, I find that the district did not provide sufficient evidence to meet its burden to support the March 2008 CSE's determination to remove ESY services from the student's 2008-09 program proposed in the March 2008 IEP. Accordingly, the hearing record does not demonstrate that ESY services were properly removed from the student's program, thereby denying the student a FAPE.”
Kelly also rejected the district’s effort to remove testing accommodations, Kelly stated similarly that “ the district did not present sufficient evidence to support its decision to change the student's testing accommodations.”
Kelly also rejected the district’s effort to remove testing accommodations, Kelly stated similarly that “ the district did not present sufficient evidence to support its decision to change the student's testing accommodations.”
Monday, June 22, 2009
Supreme Court finds for parents in Forest Grove Case
Forest Grove v. T.A. : The following is a summary prepared by the Supreme Court’s reporter of decisions.
After a private specialist diagnosed respondent with learning disabilities, his parents unilaterally removed him from petitioner public school district (School District), enrolled him in a private academy, and requested an administrative hearing on his eligibility for special-education services under the Individuals with Disabilities Education Act (IDEA), 20 U. S. C. §1400 et seq. The School District found respondent ineligible for such services and declined to offer him an individualized education program (IEP). Concluding that the School District had failed to provide respondent a “free appropriate public education” as required by IDEA, §1412(a)(1)(A), and that respondent’s private-school placement was appropriate, the hearing officer ordered the School District to reimburse his parents for his private-school tuition. The District Court set aside the award, holding that the IDEA Amendments of 1997 (Amendments) categorically bar reimbursement unless a child has “previously received special education or related services under the [school’s] authority.” §1412(a)(10)(C)(ii). Reversing, the Ninth Circuit concluded that the Amendments did not diminish the authority of courts to grant reimbursement as “appropriate” relief pursuant to §1415(i)(2)(C)(iii). See School Comm. of Burlington v. Department of Ed. of Mass., 471 U. S. 359, 370.
Held: IDEA authorizes reimbursement for private special-education services when a public school fails to provide a FAPE and the private-school placement is appropriate, regardless of whether the child previously received special-education services through the public school. Pp. 6-17.
(a) This Court held in Burlington and Florence County School Dist. Four v. Carter, 510 U. S. 7, that §1415(i)(2)(C)(iii) authorizes courts to reimburse parents for the cost of private-school tuition when a school district fails to provide a child a FAPE and the private-school placement is appropriate. That Burlington and Carter involved the deficiency of a proposed IEP does not distinguish this case, nor does the fact that the children in Burlington and Carter had previously received special-education services; the Court’s decision in those cases depended on the Act’s language and purpose rather than the particular facts involved. Thus, the reasoning of Burlington and Carter applies unless the 1997 Amendments require a different result. Pp. 6-8.
(b) The 1997 Amendments do not impose a categorical bar to reimbursement. The Amendments made no change to the central purpose of IDEA or the text of §1415(i)(2)(C)(iii). Because Congress is presumed to be aware of, and to adopt, a judicial interpretation of a statute when it reenacts that law without change, Lorillard v. Pons, 434 U. S. 575, 580, this Court will continue to read §1415(i)(2)(C)(iii) to authorize reimbursement absent a clear indication that Congress intended to repeal the provision or abrogate Burlington and Carter. The School District’s argument that §1412(a)(10)(C)(ii) limits reimbursement to children who have previously received public special-education services is unpersuasive for several reasons: It is not supported by IDEA’s text, as the 1997 Amendments do not expressly prohibit reimbursement in this case and the School District offers no evidence that Congress intended to supersede Burlington and Carter; it is at odds with IDEA’s remedial purpose of “ensur[ing] that all children with disabilities have available to them a [FAPE] that emphasizes special education … designed to meet their unique needs,” §1400(d)(1)(A); and it would produce a rule bordering on the irrational by providing a remedy when a school offers a child inadequate special-education services but leaving parents remediless when the school unreasonably denies access to such services altogether. Pp. 8-15.
(c) The School District’s argument that any conditions on accepting IDEA funds must be stated unambiguously is clearly satisfied here, as States have been on notice at least since Burlington that IDEA authorizes courts to order reimbursement. The School District’s claims that respondent’s reading will impose a heavy financial burden on public schools and encourage parents to enroll their children in private school without first trying to cooperate with public-school authorities are also unpersuasive in light of the restrictions on reimbursement awards identified in Burlington and the fact that parents unilaterally change their child’s placement at their own financial risk. See , e.g., Carter, 510 U. S., at 15 . Pp. 15-16.
523 F. 3d 1078, affirmed.
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT
Stevens, J., delivered the opinion of the Court, in which Roberts, C. J., and Kennedy, Ginsburg, Breyer, and Alito, JJ., joined. Souter, J., filed a dissenting opinion, in which Scalia and Thomas, JJ., joined.
After a private specialist diagnosed respondent with learning disabilities, his parents unilaterally removed him from petitioner public school district (School District), enrolled him in a private academy, and requested an administrative hearing on his eligibility for special-education services under the Individuals with Disabilities Education Act (IDEA), 20 U. S. C. §1400 et seq. The School District found respondent ineligible for such services and declined to offer him an individualized education program (IEP). Concluding that the School District had failed to provide respondent a “free appropriate public education” as required by IDEA, §1412(a)(1)(A), and that respondent’s private-school placement was appropriate, the hearing officer ordered the School District to reimburse his parents for his private-school tuition. The District Court set aside the award, holding that the IDEA Amendments of 1997 (Amendments) categorically bar reimbursement unless a child has “previously received special education or related services under the [school’s] authority.” §1412(a)(10)(C)(ii). Reversing, the Ninth Circuit concluded that the Amendments did not diminish the authority of courts to grant reimbursement as “appropriate” relief pursuant to §1415(i)(2)(C)(iii). See School Comm. of Burlington v. Department of Ed. of Mass., 471 U. S. 359, 370.
Held: IDEA authorizes reimbursement for private special-education services when a public school fails to provide a FAPE and the private-school placement is appropriate, regardless of whether the child previously received special-education services through the public school. Pp. 6-17.
(a) This Court held in Burlington and Florence County School Dist. Four v. Carter, 510 U. S. 7, that §1415(i)(2)(C)(iii) authorizes courts to reimburse parents for the cost of private-school tuition when a school district fails to provide a child a FAPE and the private-school placement is appropriate. That Burlington and Carter involved the deficiency of a proposed IEP does not distinguish this case, nor does the fact that the children in Burlington and Carter had previously received special-education services; the Court’s decision in those cases depended on the Act’s language and purpose rather than the particular facts involved. Thus, the reasoning of Burlington and Carter applies unless the 1997 Amendments require a different result. Pp. 6-8.
(b) The 1997 Amendments do not impose a categorical bar to reimbursement. The Amendments made no change to the central purpose of IDEA or the text of §1415(i)(2)(C)(iii). Because Congress is presumed to be aware of, and to adopt, a judicial interpretation of a statute when it reenacts that law without change, Lorillard v. Pons, 434 U. S. 575, 580, this Court will continue to read §1415(i)(2)(C)(iii) to authorize reimbursement absent a clear indication that Congress intended to repeal the provision or abrogate Burlington and Carter. The School District’s argument that §1412(a)(10)(C)(ii) limits reimbursement to children who have previously received public special-education services is unpersuasive for several reasons: It is not supported by IDEA’s text, as the 1997 Amendments do not expressly prohibit reimbursement in this case and the School District offers no evidence that Congress intended to supersede Burlington and Carter; it is at odds with IDEA’s remedial purpose of “ensur[ing] that all children with disabilities have available to them a [FAPE] that emphasizes special education … designed to meet their unique needs,” §1400(d)(1)(A); and it would produce a rule bordering on the irrational by providing a remedy when a school offers a child inadequate special-education services but leaving parents remediless when the school unreasonably denies access to such services altogether. Pp. 8-15.
(c) The School District’s argument that any conditions on accepting IDEA funds must be stated unambiguously is clearly satisfied here, as States have been on notice at least since Burlington that IDEA authorizes courts to order reimbursement. The School District’s claims that respondent’s reading will impose a heavy financial burden on public schools and encourage parents to enroll their children in private school without first trying to cooperate with public-school authorities are also unpersuasive in light of the restrictions on reimbursement awards identified in Burlington and the fact that parents unilaterally change their child’s placement at their own financial risk. See , e.g., Carter, 510 U. S., at 15 . Pp. 15-16.
523 F. 3d 1078, affirmed.
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT
Stevens, J., delivered the opinion of the Court, in which Roberts, C. J., and Kennedy, Ginsburg, Breyer, and Alito, JJ., joined. Souter, J., filed a dissenting opinion, in which Scalia and Thomas, JJ., joined.
Saturday, June 13, 2009
SRO encourages use of video conferencing instead of home instruction
SRO 09-054: This case is interesting in good part because of a footnote in which SRO Paul Kelly states:
I note that the use of videoconferencing between the school and the student's home may enhance the student's academic program, eliminate the need for the district to maintain home instructors for the student in each
academic content area, and allow the student and his classmates to share a common learning environment. Therefore, I encourage the district to consider providing this form of assistive technology to the student when
the CSE next convenes.
This footnote could be of significance in future home schooling cases as it appears to embrace modern technology in a way that could result in a win/win situation for students and school districts.
I note that the use of videoconferencing between the school and the student's home may enhance the student's academic program, eliminate the need for the district to maintain home instructors for the student in each
academic content area, and allow the student and his classmates to share a common learning environment. Therefore, I encourage the district to consider providing this form of assistive technology to the student when
the CSE next convenes.
This footnote could be of significance in future home schooling cases as it appears to embrace modern technology in a way that could result in a win/win situation for students and school districts.
Thursday, June 4, 2009
SRO upholds IHO decision despite no answer from district on appeal
SRO 09-049: The parent appealed; the district failed to answer. The SRO upheld the IHO determination for the district. In SRO 09-048, the SRO considered a cross-appeal by a parent despite the failure by the parent to file an answer to the district's cross-appeal. The SRO cited to Arlington Cent. Sch. Dist. v. State Review Officer, 293 A.D.2d 671 [2d Dep't 2002], for the proposition that the SRO is required examine the entire hearing record and make an independent decision based on the entire hearing record.
Saturday, May 30, 2009
NYS: legislative developments
http://assembly.state.ny.us/leg/?bn=A08398(memo); http://assembly.state.ny.us/leg/?bn=A08398&sh=t(text)
A bill has been introduced that includes a number of significant changes affecting the rights of parents of kids in special education. The following are highlights:
1. Section 8 would amend S 4404(1)(a) of the Education Law to create an exception to the two year statute of limitations for due process for tuition reimbursement claims for unilateral parental placements. The bill would require that a complaint seeking tuition reimbursement for the unilateral parental placement of a student in a private school be presented not more than one hundred and eighty days from the unilateral placement by the parent or person in parental relation in the private school. This section would take effect September 1, 2009.
2. elimination of the separate consent requirement for the initial provision of the summer component of a 12 month program
The following proposed changes affect privately placed kids and their parents:
1. the Education Law 3602-c deadline for written request for services would be changed to April 1 for parents of kids who have already had an IEP developed and implemented
2. mandatory mediation prior to hearing; where a due process complaint involveschild find requirements, the federal rules would apply and mediation would continue to be optional.
3. school district of location would now be able to provide a 12 month program(privately placed kids)
4. This bill would also add language to clarify, both for July and August services and services provided during the regular school year, that a student parentally placed in a nonpublic school has no entitlement under S 3602-c to the provision of a special class or integrated co-teaching services. Section 3602-c is intended to authorize the provision of special education programs and services to supplement the regular educa- tion instruction provided by the nonpublic school. Unlike related services, resource room services, consultant teacher services and supplementary aids and services, which are designed to supplement regu- lar education instruction, a special class or integrated co-teaching services necessarily involves a teacher providing a portion of the core regular educational program of the student. Such core instruction should be provided by the nonpublic school, and would be both costly and burdensome for the school district of location to provide.
5. S4402(4)(d) of the Education Law would be amended to provide thatwhere the board of education of a student’s school district of residence provides transportation up to a distance of fifty miles to and from a nonpublic school which a student identified with a disability attends for the purpose of receiving services or programs from the nonpublic school which are similar to special education programs and services recommended for the student by the district of residence, the student would not be entitled to special education programs and services from the school district of location pursuant to S 3602-c of the Education Law . As a condition of eligibility for such transportation, the parent or person in parental relation to the student would be required to consent to the provision of notice by the school district of residence to the chairperson of the committee on special education of the school district in which the nonpublic school is located. Such notice must be provided by the district of residence no later than thirty days after commencing transportation services.
Unless otherwise indicated in the statute, the changes would take effect on June 30, 2009. Some of the changes to 3602-c would take effect in 2010.
A bill has been introduced that includes a number of significant changes affecting the rights of parents of kids in special education. The following are highlights:
1. Section 8 would amend S 4404(1)(a) of the Education Law to create an exception to the two year statute of limitations for due process for tuition reimbursement claims for unilateral parental placements. The bill would require that a complaint seeking tuition reimbursement for the unilateral parental placement of a student in a private school be presented not more than one hundred and eighty days from the unilateral placement by the parent or person in parental relation in the private school. This section would take effect September 1, 2009.
2. elimination of the separate consent requirement for the initial provision of the summer component of a 12 month program
The following proposed changes affect privately placed kids and their parents:
1. the Education Law 3602-c deadline for written request for services would be changed to April 1 for parents of kids who have already had an IEP developed and implemented
2. mandatory mediation prior to hearing; where a due process complaint involveschild find requirements, the federal rules would apply and mediation would continue to be optional.
3. school district of location would now be able to provide a 12 month program(privately placed kids)
4. This bill would also add language to clarify, both for July and August services and services provided during the regular school year, that a student parentally placed in a nonpublic school has no entitlement under S 3602-c to the provision of a special class or integrated co-teaching services. Section 3602-c is intended to authorize the provision of special education programs and services to supplement the regular educa- tion instruction provided by the nonpublic school. Unlike related services, resource room services, consultant teacher services and supplementary aids and services, which are designed to supplement regu- lar education instruction, a special class or integrated co-teaching services necessarily involves a teacher providing a portion of the core regular educational program of the student. Such core instruction should be provided by the nonpublic school, and would be both costly and burdensome for the school district of location to provide.
5. S4402(4)(d) of the Education Law would be amended to provide thatwhere the board of education of a student’s school district of residence provides transportation up to a distance of fifty miles to and from a nonpublic school which a student identified with a disability attends for the purpose of receiving services or programs from the nonpublic school which are similar to special education programs and services recommended for the student by the district of residence, the student would not be entitled to special education programs and services from the school district of location pursuant to S 3602-c of the Education Law . As a condition of eligibility for such transportation, the parent or person in parental relation to the student would be required to consent to the provision of notice by the school district of residence to the chairperson of the committee on special education of the school district in which the nonpublic school is located. Such notice must be provided by the district of residence no later than thirty days after commencing transportation services.
Unless otherwise indicated in the statute, the changes would take effect on June 30, 2009. Some of the changes to 3602-c would take effect in 2010.
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