Episode 94 The ESY Puzzle: Putting the Pieces Together for IEP Success

Extended School Year (ESY) services can raise nuanced questions for IEP teams and special education professionals. On this episode of the Lozano Smith Podcast, host Aly R. Bivins talks with Roxana E. Khan and Erin Frazor about how ESY differs from summer school, the legal requirements under the IDEA, and how to make sound, individualized decisions. They round out the conversation by highlighting common pitfalls and offering practical tips to ensure compliance, including the importance of clear documentation. Show Notes & References 2:10 – ESY (Extended School Year services) vs. Summer School 2:52 – FAPE (Free Appropriate Public Education) and ESY 3:40 – Endrew F. v. Douglas County School District Re-1, 137 S. Ct. 988 ( Client News Brief 12 – March 2017 ) 5:54 – Common ESY issues and questions 8:18 – How to determine eligibility for ESY 8:45 – Regression/Recoupment Analysis applied in California 10:14 – Three other standards determined by the courts 14:08 – What to provide during ESY 21:21 – When to make ESY determination 25:10 – Determining ESY eligibility for incoming students with less available information 28:01 – Litigation regarding ESY 34:17 – Does ESY only apply during the summer? 37:14 – Does the IDEA speak to Least Restrictive Environment (LRE) in relation to ESY? 38:45 – M.C. by & through S.B. v. Los Angeles Unified School District (C.D. Cal., Aug. 9, 2023) Case No. 2:20-CV-09127-CBM-E, 2023 WL 11066079 40:07 – Continuum of ESY placement options   For more information on the topics discussed in this podcast, please visit our website at:   Disclaimer: As the information contained herein is necessarily general, its application to a particular set of facts and circumstances may vary. For this reason, this podcast episode does not constitute legal advice. We recommend that you consult with your counsel prior to acting on the information contained herein.

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Episode 94 The ESY Puzzle: Putting the Pieces Together for IEP Success is an episode from Let’s Talk - Lozano Smith Podcast by Lozano Smith.

This episode is 43:40 long.

This episode was published on May 28, 2025.

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