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1 | COLUMBIA SOCIAL WORK REVIEW, VOL. 18 

THE IMPLICATIONS OF DISPROPORTIONATE 
INDIVIDUALIZED EDUCATION PLAN 
CLASSIFICATIONS IN NEW YORK CITY SCHOOLS

AMANDA CORDELL
CSWR Prize Winner

ABSTRACT 
Over- and under-representation of students of color within disability 

classifications is a nationwide phenomenon that has a major impact on 
students’ ability to thrive in school and is especially prevalent in New York 
City Department of Education schools. The present paper uses a Dis/Crit 
framework to analyze this phenomenon, revealing that disproportionality 
of disability classification is a symptom of underlying racism and ableism 
in the education system. Despite the relatively recent addition of policy to 
address both racial and disability discrimination in schools, students continue 
to experience inequitable educational opportunity both because of their race 
and their ability.

INTRODUCTION 
There are widely-documented disparities in how special education 

services are provided in New York City (The Research Alliance for New 
York City Schools, 2019). These disparities can be seen in an over- and 
under-representation of the way students are labeled, or “classified” on 
their Individualized Education Plan (IEP), and are arguably a symptom of 
White supremacist and ableist values embedded in an education system 
that structurally oppresses both race and disability across all social systems 
(Connor, Ferri, & Annamma, 2016). 

This paper seeks to show that the legacy of White supremacist values 
embedded in the US education system continues to use race and ability 
to disadvantage students of color, specifically students of color who are 
identified as needing special education services, by using DisCrit as a 
grounding theory. DisCrit is a theory that combines Critical Race Theory 
and Disability Studies to examine the ways in which race and ability are 
intertwined in widespread issues across education (Connor, Ferri, & 
Annamma, 2016). 

The first part (“Background”) gives an overview of how the special 
education system functions, specifically in New York City (NYC).  NYC’s 
school system provides a compelling example of the way structural inequities 
inherent in the education system are disproportionately impacting students 
of color, students with disabilities, and students of color who are being 
labeled as having disabilities. The lessons learned from NYC’s experience 
are especially valuable because NYC is the largest school district in the 
country and also has the highest percentage of students identified as needing 



COLUMBIA SOCIAL WORK REVIEW, VOL. 18 | 2 

special education services (Mirakhur et al., 2018)  
Part two provides a theoretical framework for how federal and NYC 

Department of Education (DOE) policies affect both students of color and 
students with disabilities (SWDs).  Notable federal and NYC-specific policies 
created to afford educational rights for SWDs as well as educational rights 
for students regardless of race or ethnicity are examined chronologically, 
as well as some of their shortcomings. Part three will discuss the need for 
structural reform and propose ways of initiating broad structural reform.

PART ONE: BACKGROUND 
The IEP is essentially a legal contract between the school, the school 

district, and the students’ legal guardian(s). It outlines the educational needs 
of the student and what accommodations and services will be provided to the 
student to meet those needs (Stanberry, n.d.). Students must be evaluated 
to receive services, regardless of whether their challenges in school are 
behavioral or academic, then they are classified and often placed into special 
classrooms and sometimes different buildings, removing them both from 
the shared physical spaces with their peers and from the statistics of how 
the full student body is achieving. Federal law dictates that IEPs should be 
classified in different categories that, in theory, should help educators and 
schools provide appropriate support. There are thirteen different federal 
classifications that can be named on the student’s IEP; some examples 
include “Autism,” “Specific Learning Disability,” or “Emotional Disturbance” 
(Individuals with Disabilities Education Act, 2004). 

In New York City, the overall rate of classification for “Emotional 
Disturbance” (ED) for White, Asian, and Latinx students is 2-5%, while 
the rate of classification for Emotional Disturbance for Black students is 
11% (The Research Alliance For New York City Schools, 2019).  This data 
demonstrates that there is a gross overrepresentation of Black students 
classified with Emotional Disturbance, in comparison to their peers in 
other racial groups. Moreover, students with ED classifications also have 
the highest rates of discipline, suspension, absenteeism in comparison to 
other types of IEP classifications (The Research Alliance for New York 
City Schools, 2019). For these students, it is conceivable, and arguably even 
likely, that externalizing behavior in schools is more likely to be met with 
disciplinary responses instead of evaluation for an underlying learning 
difference. 

Asian and Latinx students in NYC DOE schools are more likely to be 
labeled with a “Speech and Language Impairment.” More than 35 percent 
of Asian and Latino students with IEPs are classified as having speech or 
language impairments, compared with 26 and 29 percent, respectively, for 
Black and White students (The Research Alliance For New York City Schools, 
2019). These data likely demonstrate that students who are in the process 
of learning English are being mislabeled as having a speech and language 
impairment instead of being provided with the appropriate instruction for 



3 | COLUMBIA SOCIAL WORK REVIEW, VOL. 18 

language learners (The Research Alliance for New York City Schools, 2019).
While these disparities are a well-documented phenomenon nationwide 

(National Education Association, 2007), NYC’s public school system is 
an especially relevant case study for the implications of inequity in IEP 
classifications. As the largest school district in the country (Mirakhur et 
al., 2018), there are over one million students in NYC’s public school system, 
and about 20% of those students have an IEP (The Research Alliance for 
New York City Schools, 2019). This percentage of the population being 
identified as needing special education services is also disproportionately 
high in comparison to the other three largest school districts in the country: 
Los Angeles, Chicago, and Houston. In those cities, the numbers of students 
identified as needing special education services is 12%, 14%, and 7% 
respectively (Mirakhur et al., 2018) In other words, there are more students 
identified as needing special education services in New York City than there 
are in LA, Chicago, and Houston combined, by a margin approaching 100,000 
(Mirakhur et al., 2018).

PART TWO: APPLYING A DIS/CRIT THEORY LENS 
Approaching the issue of disproportionality of IEP classifications 

through a Dis/Crit framework, it is apparent that the correlation between 
IEP classification and race in New York City Schools is not incidental. 
Marginalized identities of non-White students with disabilities are negtively 
compounded in the education system, and the function of that structural 
oppression is to maintain the privileges inherent in a White supremacist 
and ableist structure. 

An integral component of DisCrit theory is acknowledging the ways 
in which both race and ability have been socially constructed to create a 
norm that propagates White supremacy in the infrastructure of the United 
States’ social systems. The political and social systems were initially 
designed only to accommodate property-owning or rich, White men (Carlin, 
2002). Therefore, large social infrastructure was never intended to serve or 
accommodate participants who are not White. 

Dividing students into different IEP classifications divides the student 
population and reduces the visibility of the larger issue that roughly 20% 
of the NYC DOE student population is being segregated from general 
education. Looking at the overall issue illuminates that the special education 
system labels are being utilized to segregate students, particularly students 
of color, who are recognized as needing academic support (The Research 
Alliance for New York City Schools, 2019). 

When critically examining the disproportionate use of IEP 
classifications for students of color in schools, the question is raised of which 
metrics are being used to evaluate students for IEP classification and who 
created those metrics. Black students exhibiting the same externalizing 
behavior that their White peers present in schools are more likely to be 
met with an evaluation for emotional disturbance classification instead of 



COLUMBIA SOCIAL WORK REVIEW, VOL. 18 | 4 

evaluating for an underlying learning difference (Colker, 2013). As these 
students are more likely to be perceived as having a mental health concern 
versus a learning disability, this could lead to an overrepresentation of 
ED classifications and an underrepresentation of learning disability 
classifications. Moreover, students with ED classifications are more likely 
to be assigned to specialized classrooms and schools, instead of being 
educated in inclusive settings with their general education peers (The 
Research Alliance for New York City Schools, 2019). Disproportionately 
classifying Black students with ED classifications ultimately segregates 
them into isolated education settings.  Some would say IEP classifications 
enable students to receive supportive services, but others may argue IEP 
classifications operate to map a student’s trajectory of lesser academic 
achievement.  

PART THREE: POLICY ANALYSIS 
Disproportionately referring students of color for special education 

services, and misidentifying or mislabeling their needs within the special 
education system, is having a major impact on those students’ ability to 
thrive in school. Broadly, students identified as needing special education in 
NYC DOE schools are far less likely to graduate high school than their general 
education peers, even after receiving services that should have improved 
their ability to succeed academically (Advocates for Children of New York 
2019). More specifically, New York University’s Research Alliance for New 
York City Schools (2019) found that students in NYC DOE schools with an 
ED IEP classification are likelier to be segregated into separate classrooms 
and schools than their general education peers, likelier to be suspended or 
meet harsh disciplinary outcomes than other IEP classifications, and likelier 
to be chronically absent from school. As stated above, in NYC DOE schools, 
Black students are twice as likely as other students to be classified with ED 
(The Research Alliance For New York City Schools, 2019), and so Black 
students are also experiencing the brunt of these negative impacts. 

However, the US education system, as with all US social and political 
systems, was never intended to serve populations of students of color or 
students with disabilities. It wasn’t until relatively recently that policy has 
been enacted in an attempt to amend the education system and to afford 
educational rights and opportunity specifically for students of color and 
students with disabilities. As will be discussed below, the policies that were 
created essentially acted as a bandage and could not address the deeper 
structural flaws necessary to truly envision a more equitable system. An 
analogy would be changing a motorcycle into a four-person vehicle. The 
motorcycle was designed just for one person, and in order to change the 
basic design, additional pieces like a series of sidecars could be welded onto 
the sides. Those who are relegated to sitting in the sidecars will always be in 
a less safe and less comfortable position and will not be able to speak loud 
enough for the driver of the motorcycle to hear their needs and requests 



5 | COLUMBIA SOCIAL WORK REVIEW, VOL. 18 

while the motorcycle is on the road. Arguably, the policy reforms address 
symptoms of a structural issue rather than provide large structural change 
are inadequate to meet the needs of the people most affected. 

Most think of Brown v. Board of Education in 1954 as the first example 
of the courts addressing race in schools. However, state courts considered 
racial inequity in schools even earlier. The court in Mendez v. Westminster 
(Mendez v. Westminster School Dist., 1946) was the first to hold that 
separate-but-equal public institutions are inherently unconstitutional 
because of the 14th Amendment (Mendez v. Westminster School Dist., 1946). 
While Mendez v. Westminster was ultimately overturned on appeal (on 
grounds not pertaining to the 14th Amendment),  the lower court’s decision 
was influential because it recognized the principle of equal educational 
opportunity for all students regardless of lineage (United States Courts, n.d.).

The first statement on racial desegregation in schools by a federal court 
was in Brown v. Board of Education (1954). This Supreme Court decision 
was a join of five different cases from five different states or U.S. territories 
that were being argued on the same grounds, namely that separate but 
equal education is unconstitutional. Despite this supreme court decision, 
desegregating schools was never successfully enforced (Legal Defense and 
Educational Fund, n.d.). In fact, more recent Supreme Court decisions such 
as Milliken v. Bradley (1974), which removed the burden from states to 
redistrict in the interest of desegregation (Nadworny& Turner, 2019), have 
further impeded efforts to desegregate. Schools now are more “more racially 
isolated” at any point in the past forty years (Legal Defense and Educational 
Fund, n.d.). 

The Elementary and Secondary Education Act (ESEA), the first federal 
legislation specifically focused on creating educational rights for students, 
was passed by President Johnson in 1965 (Brewer & Picus, 2014). The ESEA 
is notable because it outlined affirmative rights for students, as opposed to 
prohibitions on schools. The legislation originally had six sections, which 
detailed how the funding would be distributed amongst different programs 
and students, with the largest allocation for low-income families (Brewer 
& Picus, 2014). Since then, the ESEA has been amended and reauthorized 
many times. However, while this act was intended to regulate public schools 
on a national level, some of the reauthorizations have been publicly criticized 
as having profoundly negative effects on the school system. For example, 
the No Child Left Behind reauthorization under the Bush administration 
is largely blamed for dramatically increasing the amount of standardized 
testing in schools (Klein, 2015), which is an assessment system that is widely 
recognized as racially biased (Rosales, 2018). 

While certain opportunities were afforded to SWDs in the ESEA 
in 1965, the Individuals with Disabilities Education Act (IDEA), passed 
in 1975, is the federal law that most shapes the way SWDs experience 
U.S. public schools. Most notably, the IDEA introduced the terms “free 
and appropriate public education” and “least restrictive environment” 



COLUMBIA SOCIAL WORK REVIEW, VOL. 18 | 6 

(Individuals with Disabilities Education Act, n.d.). These two terms have 
been interpreted in different ways over the past forty years, and the law does 
not provide clear guidelines for implementation (Zirkel, 2013).  Since the 
IDEA’s inception, SWDs have argued in courts all over the country about 
the correct construction of the word “appropriate” when it comes to the 
allocation of services by schools that are intended to support SWDs to 
have access to the same level of education as their peers. The term “least 
restrictive environment” is vague and ambiguous, and can be interpreted  by 
schools to segregate SWDs, whether different classrooms in the same school 
or in different schools altogether. In New York, the range of environments a 
student can be placed in to receive services is called the Special Education 
Continuum (Advocates for Children of New York, 2016).

The concept of educating special education and general education 
students together in the same classroom did not become common practice 
in New York City until the early 2000s, and still has many flaws in its 
implementation (Stiefel et al., 2017, p.6). This type of setting is called an 
“inclusive setting” and is one of the least restrictive settings available 
for students on the special education continuum of services (Advocates 
for Children of New York, 2016). The type of IEP classifications listed on 
a student’s IEP is highly correlated to what type of setting the student is 
placed in. In NYC schools, students classified with Emotional Disturbance 
and Intellectual Disability are less likely to be referred for inclusive settings, 
and because Black students are likelier to have these IEP classifications, this 
means that these students are less likely to be educated in classrooms with 
their general education peers (The Research Alliance For New York City 
Schools, 2019). Analyzing this outcome of increased segregation for Black 
students through a historical and systematic lens of oppression that the Dis/
Crit framework suggests provides an argument that the inherent biases in 
the system continue to exclude Black students from partaking inequitable 
educational opportunity as their non-Black and non-disabled peers (Connor, 
Ferri, & Annamma, 2016). 

Most recently, in New York City, to address the shortcomings of these 
federal laws in NYC schools, the NYC Department of Education created a 
three-year strategic plan called “A Shared Plan to Success.” This plan had 
four main goals: “(1) provide SWDs with greater exposure to the general 
education curriculum, (2) provide SWDs with greater exposure to GEN 
students, (3) build school capacity to support SWDs, and (4) improve the 
academic performance of SWDs (NYCDOE, 2012 as quoted by Stiefel et 
al., 2017, p. 6).”  These goals were guided by the principle that SWDs should 
access the same services and spend time in classrooms with their general 
education peers to the greatest extent possible  (Stiefel et al., 2017, p. 6). 
Providing greater access for SWDs to general education settings and peers 
is beneficial because not only does the IDEA mandate that students are 
educated in the least restrictive environment, but research shows that 
integration of students with disabilities is advantageous to both students 



7 | COLUMBIA SOCIAL WORK REVIEW, VOL. 18 

with disabilities and general education students (The Research Alliance 
For New York City Schools, 2019). In many ways, these four outcomes are 
reminiscent of the arguments that students, families, and lawyers argued 
about racial inequality in Mendez vs. Westminster and Brown vs. Board of 
Education. “Separate but equal” education for SWDs is unacceptable. 

There are two other federal laws that afford students additional rights 
in schools and that are overseen by the Office of Civil Rights. These are 
the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 
1990 Title II rights for IDEA-eligible SWDs (Individuals with Disabilities 
Education Act, n.d.). Instead of affording specific rights to students with 
disabilities, these two acts are used to prevent discrimination against 
students because of their rights to additional services as SWDs (Individuals 
with Disabilities Education Act, n.d.). 

Despite being entitled to “Free and Appropriate Public Education” in the 
“Least Restrictive Environment,” segregating SWDs from general education 
students inherently changes the quality of education those students are 
receiving. While the mechanisms for segregation of students because of race 
and disability have been obscured by purportedly helpful IEP classifications 
and special education law, the historical legacy of racism and ableism still 
functions in the American education system. Arguably, “Separate but 
equal” education for SWDs may be  unlawful in the same manner that 
segregating students because of race has been found to be unlawful. The 
current education system structurally oppresses both race and disability; 
the oppression at the intersection of those identities is compounded. The 
function of that structural oppression is to maintain the privileges inherent 
in a White supremacist structure.

PART FOUR: OPPORTUNITIES FOR REFORM 
As with most social issues in the US, disparities in IEP classifications 

are hidden in a complex web of bureaucratic systems that obscure the 
larger reality of how policy is impacting large groups of students.  In the 
U.S., “special education law is a conservative, individualistic approach 
that requires each of us to put forward enormous energy to help one child 
at a time in a resource-starved context” (Colker, 2013). While individual 
advocacy for students and families remains key, the only way of addressing 
the disproportionately negative impact of the special education system on 
students of color is reconfiguring the policies and practices that shape the 
system. Policy reform that promotes the creation of safe and affordable 
housing, healthcare, and employment that pays a living wage equitably 
across race and ability lines, will lift up our education system and everyone 
who participates in it (Colker, 2013). Additionally, funding structures on 
federal, state, and city levels need to be adjusted to allocate more funds 
to under-resourced districts and schools; and decoupled from punitive 
standardized testing measures. 

In envisioning and creating this policy change, the voices and 



COLUMBIA SOCIAL WORK REVIEW, VOL. 18 | 8 

perspectives that were initially excluded in the creation of social systems 
need to be centered. Centering the voices of those who are most impacted by 
policy is taking a liberatory approach to school desegregation (Love, 2013). 
It is crucial for the families, students, and teachers who are most affected 
by education policy to be integrally involved at every step of the decision-
making process. Integrating student, family, and teacher voices is the only 
way to truly envision the changes necessary to create an equitable education 
system. 

Specific to the integration of students with disabilities, the NYC DOE 
should eliminate the requirement of IEP classifications as they segregate 
populations further and categorize students in unnecessary ways. IEP 
classification labels are abstract and unspecific, and do not give guidance 
about what types of support students who have them should receive. Just 
as race is socially constructed as a way to use language which organizes 
people into groups for the purpose of affording some rights and privileges to 
some and denying them others (SpearIt, 2012), so are the labels assigned to 
students regarding their needs in a classroom.  Also important, as not talking 
about race or appearing to be “colorblind” isn’t an answer to addressing 
issues of race in the US (SpearIt, 2012), neither is ignoring disability and 
that some students need additional educational services and support 
in school to access the same educational opportunities as their peers. 
Moreover, as a society, the temptation to replace using IEP classifications 
with medical diagnoses as a catch-all replacement for IEP classifications 
needs to be avoided. Instead, this paper is a call to recognize the ways that 
both race and disability are socially constructed, and use direct and specific 
language about which interventions and services students need in the 
classroom and school building to remove barriers students experience in 
accessing education opportunity because of developmental delays, cognitive 
processing differences, and socioemotional challenges.

CONCLUSION 
If students continue to be separated from their peers and the burden 

of providing support is placed on individual families, teachers, and school 
administrators, the problematic systems that perpetuate a structural 
disparity in IEP classifications will remain. Further, the more students 
are referred to by their IEP classifications, the less the trends of racial and 
disability segregation are visible. IEP classifications are not necessarily 
correlated to physical or mental disability diagnosis and have no bearing 
over what services students receive. Instead, IEP classifications serve the 
purpose of labeling students and segregating them from their peers. They 
should be removed from IEPs.

 In implementing the structural change necessary to reform the 
education system, it is critical to center the voices of the stakeholders in 
the system that are most impacted and least likely to be heard: students, 
families, and teachers, especially Black, Latinx, and low-income students, 



9 | COLUMBIA SOCIAL WORK REVIEW, VOL. 18 

families, and teachers. Integrating student, family, and teacher voices is 
the only way to truly envision the changes necessary to create an equitable 
education system. As a current high school student who is also part of the 
Teens Take Charge student-led group wrote, “This stigma surrounding 
special education or needing extra help needs to stop. Because the more we 
focus on our weakness, the less we see our strengths, and the more we’re left 
behind” (Mejia, 2018).

ABOUT THE AUTHOR 

AMANDA CORDELL is originally from Northern California and holds a 
BA from Humbolt State University. Over the past 10 years, she has worked 
in education in the San Francisco Bay Area and New York City. Amanda is 
currently enrolled in the dual degree program at Columbia School of Social 
Work and Bank Street College of Education. 

 
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