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As discussed throughout this book, the Individuals with Disabilities Education Act (IDEA) (2005) is designed to afford parents and school officials opportunities to work together to develop individualized educational programs (IEPs) for students with disabilities. Yet, in recognizing that parents and educators may not agree in all situations, Congress included dispute resolution provisions in the IDEA (20 U.S.C. § 1415). Parents of students with disabilities may request mediation (20 U.S.C. § 1415(e)) or due process hearings (20 U.S.C. § 1415(f)) if they disagree with any actions of school boards regarding proposed IEPs or of the provision of a free appropriate public education (FAPE) for their children. After having exhausted administrative remedies, parents may seek judicial review in federal or state courts (20 U.S.C. § 1415(i)(2)(A)). Courts can waive the exhaustion requirement only when it clearly is futile to pursue additional administrative remedies (Honig v. Doe, 1988). Students must remain in their then-current placements while administrative or judicial actions are pending unless school officials and parents agree to other arrangements (20 U.S.C. § 1415(j)), hearing officers order changes (20 U.S.C. § 1415(k)(3)(B)), or judicial decrees call for new placements (Honig v. Doe, 1988). The IDEA empo