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The report argues that the Carter framework, originally meant to safeguard students denied Free Appropriate Public Education (FAPE), has expanded beyond its purpose. Policy changes that settle previously won cases and reduce annual adjudications may allow private placements to persist without confirming district capacity, leaving program outcomes largely unknown.",{"@graph":69,"@context":123},[70,84,106],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/reassessing-carter-case-spending-for-students-with-disabilities-in-new-york-city-schools-executive-summary/585236/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/reassessing-carter-case-spending-for-students-with-disabilities-in-new-york-city-schools-executive-summary/585236.png","ImageObject",300,407,{"name":92,"@type":93},"Aria Callaghan","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-11-11","2026-10-15",true,{"@type":102,"interactionType":103,"userInteractionCount":105},"InteractionCounter",{"@type":104},"ViewAction",12,{"@type":107,"mainEntity":108},"FAQPage",[109,115,119],{"name":110,"@type":111,"acceptedAnswer":112},"What is the Carter-Case tuition reimbursement framework?","Question",{"text":113,"@type":114},"Carter cases are legal proceedings where families seek tuition reimbursement from the state for private school placements after believing the district failed to provide FAPE.","Answer",{"name":116,"@type":111,"acceptedAnswer":117},"How does the report describe the growth and impact of Carter-case spending in New York City?",{"text":118,"@type":114},"For the 2026 fiscal year, 2.15% of the DOE budget was approved for Carter-case tuition reimbursement, and spending increased significantly as filings rose, even though outcomes for many private programs remain unknown.",{"name":120,"@type":111,"acceptedAnswer":121},"Why does the report argue NYC’s approach matters to other states and districts?",{"text":122,"@type":114},"It warns that deviations from IDEA’s annual accountability structure can reshape incentives, obscure program quality, and create inequities in access to services.","https://schema.org",{"og:url":83,"og:type":125,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":127,"canonical":83},"index,follow",{"doc_id":129,"site_id":62},585236,1792209450,{"code":4,"msg":5,"data":132},{"doc_id":129,"user_id":133,"nickname":92,"user_avatar":134,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":135,"file_id":136,"file_url":137,"file_type":138,"file_size":139,"view_count":105,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":46,"language":140,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":67,"update_tm":144,"read_time":31,"preview_page_count":4},962084926284,"https://ap-avatar.wpscdn.com/davatar_29158cc5080c5b710cf443261637dec0","Report  \nAbout Us  \nThe Manhattan Institute is a community of scholars, journalists, activists, and civic leaders committed to advancing economic opportunity, individual liberty, and the rule of law in America and its great cities.  \nFebruary 2026  \nReassessing “Carter-Case”Spending for Students with Disabilities in New York City Schools  \nJennifer Weber  \nFellow  \nManhattan Institute  \nExecutive Summary  \nNew York City’s special-education system looks very different today from the way it did a decade ago. For the 2026 fiscal year, 2.15% of the Department of Education’s entire budget was approved for “Carter-case” tuition reimbursement. Originally meant as a safeguard for students denied a Free Appropriate Public Education (FAPE),1 the Carter framework has expanded far beyond its intended purpose. Policy decisions such as the shift to settling previously won cases and reducing annual FAPE adjudications have allowed private placements to continue year after year without determining whether the district can meet students’needs in NYC. As filings increased, the city’s spending on tuition reimbursement also increased significantly, even as outcomes for many private programs remain unknown.  \nNYC’s experience serves as a warning for states and large districts nationwide. With shifting more authority to states, NYC shows how deviations from the annual accountability structure of the Individuals with Disabilities Education Act (IDEA) can reshape incentives, obscure program quality, and create inequities in access to services. Reassessing Carter cases in NYC is essential to restore IDEA’s accountability structure, rebuild the nation’s largest public school system’s capacity, and ensure that students receive appropriate services in their least restrictive environment (LRE),2 without relying on litigation.  \nReassessing “Carter-Case” Spending for Students with Disabilities in New York City Schools  \nOverview of Individuals with Disabilities Education Act  \nThe Individuals with Disabilities Education Act (IDEA) is federal legislation that guarantees students with a disability a special education and other related services. Initially enacted in 1975 as the Education for All Handicapped Children Act (EHA), it was designed to ensure that children with disabilities received an adequate public education and had legally enforceable protections.3 Congress reauthorized and renamed it IDEA in 1990, and again in 2004.4 In 1990, the law established disability categories and a framework for parents’rights. In 2004, Congress aligned special education with No Child Left Behind (NCLB) by adding an accountability system and procedural reforms.5  \nUnder IDEA, every student with a disability is guaranteed the right to Free Appropriate Public Education (FAPE) through an Individualized Education Program (IEP) .6 School districts are required to write their own IEPs, but those plans must implement the services that IDEA mandates, and the IEP for each individual child must be reviewed annually. When an IEP is not fully implemented, the school district is denying a child FAPE. IDEA established a due-process system that allows parents to challenge a district’s failure to provide FAPE,7 and, furthermore, the school district must revisit the question of whether it can adequately provide FAPE at least once a school year.8  \nUnder IDEA, FAPE consists of special education and related services provided at public expense, under public supervision, in correspondence with the student’s IEP and in accordance with state standards.9 The least restrictive environment (LRE) is also an essential component of FAPE.10 Under IDEA, districts must educate students with disabilities in the LRE appropriate to their needs. This means that children with disabilities should be served alongside students without disabilities whenever possible. LRE is part of the district’s core FAPE obligation and is supposed to be evaluated each year through the IEP process.  \nOrigin of Carter Cases  \nF","cbCaihweYbGsaO7J","https://ap.wps.com/l/cbCaihweYbGsaO7J","pdf",1830145,"English","# Executive Summary\n## Overview of Individuals with Disabilities Education Act\n## Origin of Carter Cases","[{\"question\":\"What is the Carter-Case tuition reimbursement framework?\",\"answer\":\"Carter cases are legal proceedings where families seek tuition reimbursement from the state for private school placements after believing the district failed to provide FAPE.\"},{\"question\":\"How does the report describe the growth and impact of Carter-case spending in New York City?\",\"answer\":\"For the 2026 fiscal year, 2.15% of the DOE budget was approved for Carter-case tuition reimbursement, and spending increased significantly as filings rose, even though outcomes for many private programs remain unknown.\"},{\"question\":\"Why does the report argue NYC’s approach matters to other states and districts?\",\"answer\":\"It warns that deviations from IDEA’s annual accountability structure can reshape incentives, obscure program quality, and create inequities in access to services.\"}]","Reassessing “Carter-Case” Spending for Students with Disabilities in New York City Schools - Executive Summary | PDF",1792054127]