Present Levels of Academic Achievement and Functional Performance: Unravelling the Narratives

In this qualitative study, we analyzed the language used by professionals within iep documents for students with disabilities. Viewing the iep as a narrative


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the skills that were reported, the data that were reported, and problems located in the student rather in the environment. Implications for policy, practice, and research are provided.

Keywords
individualized education programs -extensive support needs -positioning theory Individualized Education Plans (iep s) have been a central component of the special education process in the United States since P.L. 94-142 granted all students with disabilities access to a free and appropriate public education (Christle & Yell, 2010). Agreed upon by educators and parents, the iep offers students with disabilities a written plan which should guarantee an education based on annual goals, and describing needed supports. These goals and supports are reasonably calculated based on the student's present levels of academic achievement and functional performance (plaafp). In 2017-2018, approximately seven million students received special education services under the Individuals with Disabilities Education Improvement Act (idea; National Center for Education Statistics, 2019) indicating at least seven million annual iep s are written each year in the United States (U.S.). Additionally, many other countries have adopted some or all of the iep process in their educational systems, although it is not always a legal requirement.1 According to idea (2004), a student must meet eligibility criteria for one of 13 different types of disabilities, and require specially designed instruction due to disability, in order to receive an iep. With identification comes a host of federal protections, as well as implicit and explicit procedures aimed at acknowledging and addressing the student's educational needs in order to justify special education services (Christle & Yell, 2010). The entire process of special education, therefore, is built on a presumption of student difference. Educators must follow specific procedures which are meant to specify the student's deficits and the extent to which a student differs from a typical student, resulting in the need for a "special" education.
Aware of the weighty legal implications of their actions, educational teams and researchers have focused on meeting the procedural requirements of iep s (Voulgarides, 2018;Yell et al., 1998). These requirements include ensuring that 7 the narrative of a student's education, which is reproduced through everyday written and verbal communication about and to the student (Harré, 2012).

The iep as a Narrative
Gough (2010) suggested that all stories in education could be understood as "stories fashioned for particular purposes -especially those that most resolutely proclaim that they are 'factual ' ." (p. 46) This point of view is particularly relevant to the study of iep s. With their legal implications in the U.S., iep s are required to be developed using observational data and other quantitative evidence of learning, and any promised educational services must be based on evidence-based practices as identified through scientific inquiry. Thus, there is an underlying assumption that the information contained in the iep is fact. However, in telling the iep story, a narrative is created which is neither "fact" nor "fiction," but the outcome of a collective narrative, written by teachers and other educators, about a disabled student in school. Taken together, all iep s constitute a collective narrative about disabled students in school overall. This exemplifies Clandinin and Connelly's assertion that narratives create knowledge in education (2000). Therefore, iep s can be seen as one form of knowledge creation in education.
As a document, the iep is a way of communicating information about the student to school staff, the student's parents, and to the student. Passed among staff members, it becomes the physical and legally sanctioned version of the student's educational narrative. More narrowly, it functions as a narrative about the student's disability as it is expressed in school. Cherney (2011) notes, "ableist culture sustains and perpetuates itself via rhetoric; the ways of interpreting disability and assumptions about bodies that produce ableism are learned. The previous generation teaches it to the next and cultures spread it to each other through modes of intercultural exchange" (para. 2). In this way, ableism is apparent in rhetoric, including in narrative documents such as iep s.
As Mitchell and Snyder (2000) explain, common narratives about disability follow a predictable structure: A simple schematic of narrative structure might run: first, a deviance or marked difference is exposed to a reader; second, a narrative consolidates the need for its own existence by calling for an explanation for the deviation's origins and formative consequences; third, the deviance is brought from the periphery of concerns to the center stage of the story to come; and fourth, the remainder of the story seeks to rehabilitate or fix the deviance in some manner, shape, or form (p. 20).

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Similarly, Goggin and Newell (2005) explain that rhetoric about disability has certain common characteristics. First, the tragedy of disability is portrayed to achieve maximum effect, achieved by highlighting the differences and problems of the individual affected by the disability. Second, a particular solution is proposed as a way to alleviate the disability. Finally, when the solution has been obtained, the disability has been 'dealt with.' This implies that there is no more appeal to emotion, and the solution is a rational response to the problem. Cortazzi (1993), drawing from Labov (1972), explains that teachers report narratives in a six-part structure. The abstract and orientation set up the narrative, identifying the who, what, when, and where of the narrative. Next, the complication explains the problem in the narrative. The evaluation and result describe how the problem was addressed and resolved, and the coda closes the story. This mirrors the narrative structure of the iep. The iep (a) exposes the student's deviance or difference; (b) explains the basis for the determination of difference or deviance (i.e., an evaluation process); (c) explains the specific forms of deviance and difference which require rehabilitation (i.e., the plaafp); and (d) describe how the difference or deviance will be rehabilitated, and how progress toward rectifying the difference or deviance will be measured (i.e., the goals and supplementary aids and services). The narrative is expressed by a team of educators and is reproduced through the everyday processes of schooling. Slee (2010) notes that this narrative pattern is similar to Bordieu's (2014) description of collective stories which are "recognized by belief and thereby become real" (Bordieu, 2014, p. 37;cited in Slee, 2010).

Present Levels of Academic Achievement and Functional Performance and Positioning
The iep, as a document and as a process, is a social forum in which professionals make and communicate decisions about students with disabilities. Positioning theory (Maghaddam & Harré, 2010) can be applied to this process as a way of explaining how narratives about students with disabilities vîs-a-vîs the iep process can afford or restrict their educational opportunities. Positioning theory relies on social moves and language within social contexts (Harré, 2012), relating to stories -created and re-iterated -which individuals tell themselves and other people about relationships. Positioning can variously lead to positive or negative consequences for an individual, depending on how ruppar et al.

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the individual is positioned. The ways in which individuals position each other and themselves have consequences for later actions.
As Moghaddam and Harré explain, positioning describes "how people use words (and discourse of all types) to locate themselves and others" (2010, p. 3). Words allow individuals to claim and ascribe rights, and also provide justification for duties (e.g., special education) (Moghaddam & Harré, 2010, p. 3). Because positioning is about stories, it can go hand-in-hand with narrative analysis in understanding how stories are created and sustained in schools. Once a person is positioned, subsequent stories are told which tend to complement the original position. Narratives about a person over time become the lived experience of the person, telling the storyline of their education.
idea (2004) requires each iep team to provide, in the iep document, a "statement of the child's plaafp, including -(i) How the child's disability affects the child's involvement and progress in the general education curriculum (i.e., the same curriculum as for nondisabled children)" (idea, 2004). The description of the student's plaafp is a collaborative task to which each member of the multi-disciplinary team contributes. The statements justify the need for specially designed instruction and supplementary aids and services. Any need identified in the plaafp must be reflected elsewhere in the document (Tehachapi Unified School District v. Markham, 2017). Sabat (2003) specifically described the ways that positioning can ascribe negative attributes, leading to diminished opportunities. Malignant positioning, as Sabat describes, can have negative effects on (a) the way an individual is seen by others; (b) the ways an individual is treated; and (c) the way a person may come to see themselves. Malignant positioning can be explicit; for example, a person in power might make a directly negative comment such as "she doesn't know anything" or "she can't do that." More commonly, however, malignant positioning is implicit. This can be seen, for example, when an observer is "amazed" that a person's behavior does not conform to low expectations. As with other types of positioning, malignant positioning re-iterates and validates storylines based on individual observers' interpretations, leading to concrete outcomes for how individuals are treated, given access to space, and given access to information (Sabat, 2003). Malignant positioning affects the ways in which persons are seen by others and how they are treated, as well as how they understand their own self-worth. Finally, Sabat et al. (2004) contend that malignant positioning is rooted in labels (i.e., having Down syndrome) which lead to stereotypical and often deficit-oriented positioning by others.

Purpose
While talking and writing about students is a part of educators' everyday work, little attention has been given to the ways that students are talked and written about, and how those narratives about students form the overall expression of students' educational experience. This might be related to the underlying assumption that an iep is a technical document, written by dispassionate professionals who are legally encumbered with the task of 'dealing with' disability in a rational manner. In reality, iep documents are co-written by teachers, therapists, parents, and administrators who are all invested in the processes outlined in the document and beholden to achieving the outcomes it proposes. Authors of iep s often have an emotional and professional stake in the document; however, the organization, purpose, and political (legal) situation in which the document is created imbues a techno-rational approach which might not be aligned with the human service it requires. In producing and reproducing these narratives, educators unwittingly position themselves and their students. As positioning theory suggests, the positions of students in iep narratives are likely to be consequential to their educational experiences and outcomes.

Method
The purpose of the current study was to examine how narratives about students with disabilities, as characterized through their iep s, position students in educational contexts. We included statements of plaafp for students whose multiple and complex access needs included specially designed instruction, health care supports, and communication supports. In addition, their curriculum was adapted in depth and breadth and augmented with communication and daily living instruction. Most students were taught in segregated classes for 40% of the day or more (see Authors et al. (2019) for a description of the iep demographics). We chose to examine these iep s because they are written for students who are the most likely to experience exclusion in school (Kleinert et al., 2015) and to experience stigma related to their disability label (Werner et al., 2012). Following the university approved human subjects procedures, 88 iep s were collected from teachers for students who met the inclusionary criteria from the following U.S. states: Wisconsin, Kansas, Missouri, California, Colorado, and Florida. The iep s represented a variety of placements, ages, and disability categories.

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We chose to examine plaafp statements because these statements are situated in the "complication" stage of the iep narrative (Cortazzi, 1993). This lens allows us to uncover the ways that iep team members understand students with disabilities within the overarching cultural narrative of special education, disability, and human difference. The following research question guided our study: How are students with disabilities who require multiple and complex supports in schools positioned in statements of plaafp?

Initial Coding
Using a multi-stage coding process (Miles et al., 2013), we first applied structural codes to the plaafp statements to identify the major categories of skill areas reported (see Table 1 for a list of these categories and definitions). This allowed us to examine the frequencies of various skill areas reported across students. We also took note of any quantitative data reported, the type of data (e.g., testing, observation), as well as other types of additional evidence team members reported (e.g., what they believed the student required, or any description of his current set of services). During this stage of coding, we noted emerging ideas for discussion -for example, we noticed that some statements reflected what the teachers provided rather than what the student could demonstrate. We also noticed that language could illustrate a positive, neutral, or negative picture of a student. Finally, we noticed that some statements seemed to implicitly justify a service or support -for example, some statements identified things that the student "needed" or "required" (e.g., requiring hand over hand assistance for a task, or needing constant redirection to stay on task). As we discussed, we began to consider the ways that students were positioned in iep documents.

Pattern Coding
Based on our initial observations, we engaged in pattern coding to identify relationships among codes. We identified examples of interactive positioning of students in the iep s through the use of language and data across the initial categories of codes. According to Harré (2007), interactive positioning occurs when one person positions another person through language. It is important to note that positioning is a bidirectional, and that in positioning another person, one positions themselves. In our analytic process, we recognized that the iep team is situated as more powerful in the special education process than the student. The iep team, in positioning students, also positioned themselves. We looked for evidence of this in the data.
For each set of initial categories, we used magnitude coding (Saldaña, 2016) to identify examples of language and data which positioned students in  (Sabat et al., 2004). We applied pattern coding to identify uses of language and data which aligned with malignant positioning.

Focused Coding
Based on the pattern codes, we used focused coding (Saldaña, 2016) to further refine and cluster the codes into three themes which we understood to explain how students with extensive support needs were positioned in plaafp statements. First, we found that the descriptions of students' skills positioned them as capable or incapable of learning, particularly in general education settings. Second, we found that data and "pseudo-data" implied particular expectations as well as generalizations about student skills which, through context or lack of context, positioned students as capable or incapable. Finally, we found that the source of the "complication" to the students' learning was variously located within the student or within the environment and teaching. These themes revealed how teams constructed students' abilities within the plfaap statements in order to justify educational decisions within the iep.

Category
Number of codes Positionality and Trustworthiness Two associate professors of special education, two assistant professors of special education, one assistant professor of speech-language pathology, and one current doctoral student of special education comprised our research team. All research team members formerly taught or provided related services to students with extensive support needs in K-12 schools. We are aligned in our commitment to promoting equitable educational experiences and outcomes for students with extensive support needs, including exposing ableist policy and structures which prevent students with extensive support needs from fully participating in their schools and communities. We initiated this research due to our shared experiences as iep team members, as well as our recognition that iep s for students with extensive support needs are a powerful, yet underexamined tool that can lead to exclusion and inequity.
We engaged in several activities suggested by Brantlinger et al. (2006) to establish trustworthiness. First, our research activities were collaborative in several ways. We established reliability in our pattern coding by dividing iep s into three sets coded by two researchers independently. Disagreements were discussed among the researchers and consensus was reached either between the two coders, or with the entire group. During and following initial coding, we independently engaged in memoing about emerging themes and brought our memos to the group for discussion. During focused coding, we utilized researcher pairs to identify inductive codes, which we discussed as a group. We identified exemplars for each code and verified the saturation of codes by noting instances of repetition. These exemplars were discussed by the group. We considered disconfirming evidence (i.e., examples of data which contradicted our findings) and considered coding for positive positioning. As we coded, however, we noticed that these categories did not reach saturation, and we turned our analysis to specifically identifying patterns of malignant positioning. Researcher triangulation was complemented by theoretical triangulation as we applied narrative and positioning theory to the data set.

Findings
We identified nine types of implicit and explicit malignant positioning in three categories. In the following paragraphs, we will describe the types of skills reported, as well as how the reporting of skills, data, and location of the problem positioned students in ways that diminished their capacities. ruppar et al.

Skills Reported
Students' plaafp were reported in 17 different areas across the 88 iep s we analyzed (see Table 1). However, each category was not present in every iep. Communication was the most commonly reported skill area, mentioned in a total of 304 statements across 78 (88.6%) iep s. Least common were social studies (n = 2 statements; n = 2 iep s, 2% of iep s); and science (n = 5 statements; n = 5 iep s, 5.6% of iep s). We found the categories of reported skills could position students in implicit and explicit ways.

Implicit Positioning: Arbitrary Skill Reporting
To understand how plfaap statements positioned students, we examined the language used to describe the students' skills, and noted instances of implicit and explicit positioning. We noted that the types of skills reported did not follow a predictable pattern, especially in relation to functioning in school. Instead, the skills reported reflected a smattering of casual observations. For example, iep 78 stated: [Student] has difficultly displaying rules.
[Student] struggles with classroom mechanics (using school supplies), displaying appropriate leisure skills (playing interactive games with others, has conversations with peers), social awareness and manners as well as social skills which impacts his ability to participate in the general education setting on grade level curriculum.
Many skills were not related to the general curriculum, and skills reported were not reflective of expectations for students without disabilities. For example, "He enjoys managing the soccer teams and being a social butterfly in social skills class (iep 37)" or "[Student] was a pleasure to work with although simple in nature (iep 38)." Both statements employ implicit positioning to frame students as unable to perform socially normative skills. In this situation, the writer positions themselves in a cavalier approach to assessment, suggesting that the skills are so far from typical as to be simple and unimportant to them.

Explicit Positioning: Basic and Simple
Using explicit positioning, we noted that skills, as reported, created a narrative of students with extensive support needs as incapable of engaging in age-appropriate activities. Often, the skills reported were deficit-based or norm-focused. Deficit-based skills referred to things the child could not do or suggested the student was only capable of limited skills (e.g., "basic" or "simple"). Deficit-based phrases pertained to the type of content presented to the student. For example, students' levels were reported based on age inappropriate skills. iep 72, written for an 11-year-old student, stated: "[Student] is able to identify basic shapes, basic colors, coins, and dollars." Statements also communicated assumptions about the student's abilities or actions, and characterized student responses as irrational or simple: "He comforts himself by rocking body, making noises and other simple ways" (iep 54) or "Not motivated to complete any type of fine motor activity and will rush through task to be finished, completing it in a messy and incorrect manner" (iep 41). Described as "rocking," "making noises," "simple," "not motivated" and "messy," the students are positioned as unable to participate in age-appropriate activities and as potentially disruptive to the school environment. Moreover, in positioning students as unable, the writer's position reflects a passive approach to teaching and lack of agency to teach the student new skills.

Explicit Positioning: Norm-Referencing
Norm-referenced skills compared the student to peers without disabilities. For example, iep 64 stated: "For her Units of Study writing probe, she scored a 0. Her second-grade peers were expected to score a 10." Some iep s explicitly stated the skills not met, rather than what the was capable of demonstrating. iep 56 stated: "Skills not met: Attempts to imitate novel babbling sounds, repeats 4 words in correct sequence, describes familiar objects by 1 or 2 of their characteristics, moves own complex body parts, rote counts to 100, states full name, address, and phone number." Additionally, norm-referenced intelligence, academic, and adaptive behavior assessments were completed to demonstrate the significant difference between the student being assessed and thier peers. For example, iep 39 stated, "[the student was re-evaluated] and The Weschsler Non-Verbal Scale of Ability (wnv) yielded a full-scale iq of 33. The Adaptive Behavior Assessment System (abas) had a composite score of 45-49. Both the wnv and abas scores are significantly below his same age peers." Using norm-referenced assessment criteria illustrates the writer's reliance on a narrow amount of data, which is given outsized weight in guiding educational decisions. The writer relies on clinically-validated psychological instruments to bring authority to their recommendations. ruppar et al.

Explicit Positioning: Deficits Contraindicate Access
Finally, we noticed instances in which students' deficits clearly delimited the types of supports they would be afforded. iep 38 indicated: "[Student] does not have adequate upper extremity strength and function to access communication systems." Similarly, iep 48 indicated: [Student's] significant communication challenges affect his ability to function and communicate with all peers and staff at school. His communication disorder interferes with his ability to access the curriculum and perform in the classroom." In these cases, upper body strength was a barrier for access to communication, and ability to communicate with all staff and peers in the school was identified barrier to inclusion. These deficits delimited the student's access to fundamental educational experiences (i.e., communication and inclusion). In this way, explicit positioning was directly related to students' access to educational opportunities. At the same time, educators are positioned as gatekeepers to access, determining that sufficient tools or time were not available to address the students' access needs.

Data Reporting
Our analysis of plaafp statements revealed four types of data: (a) casual observations, (b) pseudo-data, (c) norm-referenced data, and (d) statements with both implicit and explicit reference to student deficit. Twenty-five percent (n = 22) of iep s reported no measurable data.

Implicit Positioning: Casual Observations
Observational data relied on the non-replicable, subjective views of the reporter. For example, iep 17 stated, "In social studies, [student] can usually (75% of the time) tell me the main points of a reading." As another example, iep 5, reads: "An adult meets [student] at the specialized transportation meeting spot. When getting off the bus/van, [student] needs physical assistance. He has difficulty switching his feet and keeping his balance on the steps." Both of these statements report information that was presumably gathered from repeated observation of the student's reading and motor skills. However, procedures for data collection, summarization, and evaluation is not provided. Instead, the iep, in which significant decisions about the student are communicated, is based on the casual observations of a single reporter. For example, the paraprofessional might routinely push the child in their wheelchair off the bus, and was asked to assist him one time for this observation. As written, there is insufficient information to evaluate the validity of the information.

Implicit Positioning: Pseudo-Data
In the iep s, we observed instances in which data were presented which appeared objective, but were not measurable data. We called this "pseudo-data." The use of pseudo-data is an example of implicit positioning because it reports adult responses to student behavior, rather than students' skills. As such, pseudo-data "look" like data about the student, but actually report adult responses to student deficits. For example, in iep 56, the team wrote "When it was [student's] turn to respond, the adult navigated the device to the appropriate screen and used full physical prompts to facilitate selection of the correct response on 9/9 opportunities." Some data are certainly presented, but it appears the data report adult behaviors rather than student skills. Likewise, pseudo data position adults as necessary and central to the data collection, rather than the student.
Pseudo-data were also noted when a skill was reported without any clear context. For example, iep 21 states that the student "taps a drum on 60% of opportunities." It was unclear where or for what purpose the student was being asked to tap a drum. Similarly, iep 54 cryptically reported: "He will orient to sauce but is not dipping at this time." This focus on seeming minutiae of participation in everyday activities, which are generally not an area of focus for students without identified disabilities, paints a picture of a student for whom dipping something in sauce, or tapping on a drum, makes up an important part of their day -and implicates their disabilities as causing this limited scope of activities. In both of these examples, the lack of context makes it difficult to understand how the students' demonstration of these skills is contextually relevant, or the extent to which the student might be motivated to perform these skills. This suggests that even the most circumscribed student deficits are of primary importance. In this way, decontextualized pseudo-data implicitly positioned students as incapable of completing simple tasks and needing extensive adult supports. Adults, here, are positioned as necessary, and as a result the system of special education sustains itself.
Reporting students' dispositions was another form of implicit positioning using pseudo-data. For example, iep 10 notes, "[Student] can be obedient and follow directions, however, at times [student] becomes willful and will do what she wants." In this case, no measurable or objective data are reported, and more, the student is positioned as having vacillating willingness to participate in learning activities. This is explained as a student deficit, in that sometimes the student chooses to participate in whatever is asked of her, and other times not. Another iep reported, "[Student] is very sweet, and has a happy disposition." Again, no useful data are reported to document the student's baseline skills, and yet the student is positioned as somewhat of a compliant pet for the teacher. These descriptions of students' dispositions are cast as skills, suggesting that a personality trait might be something that the student could improve upon.
Finally, positioning was noted when students' skills were reported in relation to the level of assistance they required to complete a particular task. The terms "maximal assistance" or "maximum assistance" signaled this type of positioning. For example, iep 77 states: "[Student] continues to require maximal assistance to get in and out of the gait trainer." iep 31 states: "[Student] will follow some simple one-step directions with maximum prompting and physical assistance as needed, depending on activity." iep 68 simply states: "She requires maximum assistance to complete all activities." The focus on assistance positions students and their teachers in two key ways. First, it describes the behaviors of the professional, rather than the student. Second, in these statements the professionals' reporting of the student's skills reflects their own assessment of how much the student needs them.

Implicit Positioning: Data to Highlight Deficits
Other iep s similarly identified students' deficits in an implicit way. For example, iep 73 reports, " [Student] needs to have mastered 20 workboxes and 3 steps in a task strip.
[Student] has mastered 13 workboxes at 80% accuracy and 4 at 50% accuracy. He has not yet mastered a step task completion activity." The inability to complete a fairly specific and questionably valid task is held against the student, with the student's lack of skill or commitment to the task implied throughout the statement. Similarly, in iep 24, written for a 17-year-old student, read "The Pragmatic judgement subtest of the casl was administered in order to assess social language skills. Her standard score was 40 which is below average. A conversational sample was also obtained. While there were no norms in the database for students her age, she was compared to students between the ages of 10 years, 9 months and 13 years, 3 months." In this case, an age inappropriate assessment was completed, and reported as though it were valid and meaningful, and used to position the student as having significant communication deficits.
In our review of plaafp statements, we noted those that explicitly referred to student deficits. These statements directly called attention to the tasks or skills students were unable to complete, even though these tasks were often idiosyncratic and lacking validity. For example, iep 80 noted, "This school year, [student] was scoring 0% independence on her oatmeal preparation as her parent report was that she was eating breakfast at home and refusing to make the oatmeal at school." In other words, the student was not hungry and making 20 oatmeal was not a socially valid task for her to complete, yet the iep team still felt it important to note that she was never successful in making oatmeal independently at school, even though eating breakfast at home acted as an abolishing operation. Similarly, iep 72 explicitly states the student's inability to write legibly without context: [Student's] handwriting is typically illegible. He is able to write his name within one inch boxes but is unable to write his name on a line. It is difficult for him to trace and/or write letters that are not in his name.
[ Student] is able to write better with a thick marker on a whiteboard instead of a thin pencil or pen on a paper. He has poor fine motor skills to grip the writing utensil and hold the paper, which contributes to his illegible handwriting.
In these examples, the students' deficits were assumed and manufactured based on age inappropriate or socially invalid activities.

Location of the Problem
Based on Harré's (2012) conceptualization of positioning theory, an iep is a justification for special education services and must include a description of a "complication." That is, the iep team must describe the student support needs which necessitate the services they propose. Although disability can be conceptualized as the mismatch between the support needs of a person and their environment (Thompson et al., 2009), we found many plaafp statements did not address the impact of the environment on student success, instead locating student failure as a problem within the student.

Explicit Positioning: Disability Causes Problems
We noted a particular structure which signaled explicit positioning of the student as a cause of problems. The structure can be understood in a logical sequence: (Student's) + (disability characteristic) + (problem caused by student characteristic) = student's position. For example, iep 73 states: "His high energy level and difficulty focusing also may decrease his progress in speech and his communication ability throughout the day." Similarly, "[Student's] identification of Intellectual Disability affects her functional math, functional writing, functional reading and basic life skills (iep 58)" and "[Student] is unable to structure his leisure time and does not follow traditional routines at this time without adult support (iep 74)." In each, the the location of the problem is situated within the student's disability, and environmental or instructional factors that contribute to student difficulty are wholly disregarded.

Implicit Positioning: What the Student "Requires"
Students' perceived needs and willfulness implicitly positioned students. For example, iep 68 states "[Student's] fine motor skills are limited" and "She requires maximum assistance to complete all activities. She tends to lose interest or become non-compliant with directions/steps and will push paper away… [Student] needs to continue to work on following directions within the given task until completed." It is unclear from the statement if the iep team considered environmental factors that may increase accessibility and enjoyment. The educational problem is situated within the student and does not encourage the student's future teachers to analyze the environments for barriers to learning before providing invasive physical supports.

Discussion
Kannen (2008) argues that 'social order is maintained through the constructed categorizations of privilege and power that we deem certain bodies to have, which then demarcate what is possible for those bodies and for bodies that are then considered to be Other' (p. 150). As our findings suggest, the iep process, and specifically the plaafp, can be used as a tool to create narratives which position a student as too needy, deviant, or different to achieve in school -thus restricting possibilities and positioning students as outsiders. We observed that the use of data and rhetorical devices implicitly and explicitly positioned students as not worthy of formal assessment, as being basic or simple, as deviant from the norm, as having deficits that specifically disallow access to supports or services, as the cause of problems, and as requiring extraordinary services. In contrast, adults or educators were positioned as necessary, authoritative, and gatekeepers to access, yet were passive with regards to agency for teaching. In the following sections, we will discuss the ways that students' positions, as described through data and rhetorical devices, can reinforce ableist systems and narratives about disabled students. Then, we propose ways to improve plaafp statements.

Uses and Sources of Data
No measurable or objective information was reported in 25% of the iep s. Yet, state and federal guidance in the U.S. suggest plaafp statements should unravelling the narratives Journal of Disability Studies in Education 3 (2023) 4-28 22 contain baseline data from which goals and services are developed and subsequent progress is measured. Data-based decision making is central to effective special education (Jimenez et al., 2012), and without these data, decisions related to goals, supports, services, and placement lack transparency and objectivity. We observed reporting which resembled casual observations, suggesting that rigorous assessment is not a priority for students with extensive support needs. Further, lack of data or quality data risks malignant positioning of students, in which iep decisions are based on anecdotal information, reputation, or student disability labels.
Positioning someone as incompetent relative to others is a device to remove rights from less powerful individuals (Harré, 2012). Norm-referenced assessments, which appear objective, often spotlight students' deficits. The story that continues from this deficit-based complication in a narrative must be to resolve the deficit in order to overcome it (Mitchell & Snyder, 2000). This approach to understanding a student's disability characteristics as a problem that needs to be fixed ignores the school environment's complicity in creating the context in which the students' characteristics are disabling. This is not to say that students who requre multiple and complex supports do not need specially designed instruction to access general curriculum content; however, highlighting the extent to which their needs differ from the norm does little to support a person-centered, strengths-based curriculum. As a result, the student's differences remain the center of the problem, suggesting remediation to a "normal" level of functioning and stripping away an aspect of their identity is the most appropriate option.

Uses and Sources of Rhetorical Devices
As norm-referenced assessment data give the impression of a deep chasm of difference in need of rectification, the use of those data -and the patterns of anguage that accompany the data -obscures the capacities and potential of students and creates conditions to exclude them. For example, reporting on circumscribed or age-inappropriate skills positions students as alienated from the general population of students due to their inability to fully participate in normal activities. This use of rhetoric perpetuates ableism -most apparent in the implication that, due to the extent of students' differences, their neediness is self-evident. As Cherney (2011) explains, "ableism is that most insidious form of rhetoric that has become reified and so widely accepted as common sense that it denies its own rhetoricity -it "goes without saying." To fully address ableism, we must name its presence, for cultural assumptions accepted ruppar et al.
Journal of Disability Studies in Education 3 (2023) 4-28 uncritically adopt the mantle of "simple truth" and become extremely difficult to rebut" (para. 2). Similarly, to disrupt ableism in special education, we must name it and critically examine assumptions.
While the use of rhetoric is important to examine, the sources of the rhetoric can reveal the most promising strategies for naming and disrupting ableist assumptions. Taylor (2013) explains that social and political forces "categorize people according to particular social norms effectively produce subjects as particular kinds of people" (para. 2). In this way, rhetoric acts as a narrative which defines individual identities in the eyes of others -in effect, positioning students. In the case of special education, systems include schools, policies, and ableist cultures. For example, school employees might feel that it is necessary to have strongly deficit-oriented wording in iep s in order to justify their funding needs. Similarly, describing a student as needing "maximal assistance" positions students as passive participants requiring the most extensive educational accommodations and adaptations, even though the data says nothing about the student's skills. This results in a system which leads to deficit-oriented narratives about students, put in writing and passed among professionals, thus perpetuating low expectations and exclusion.

Implications for Practice
iep team members should be cognizant of their role in positioning students, and the potential consequences of malignant positioning, as they craft iep documents. Harré (2012) explained that positions can be determined through explicit rules, as well as "tacit, existing as only immanent features of unchallenged patterns of action" (p. 196). Educators should be aware of the ways that their language, as well as the systems in which their language functions, can unintentionally create barriers to educational opportunities. As Pearl (1997) notes, the most common consequence of deficit-based assumptions is segregation, suggesting that educators' malignant positioning of students can lead to more restrictive educational placements.
On the other hand, iep team members should recognize that their words have power to position students in positive ways, leading to increased educational opportunities. For example, incorporating students' voices into statements of present levels of academic achievement and functional achievement can position them as competent and having agency over their own learning. Providing examples of success, describing what the students are capable of doing without comparing them to peers, and choosing age-appropriate and academic skills to assess and report are likely to position a student as a unravelling the narratives Journal of Disability Studies in Education 3 (2023) 4-28 participating community member who has the potential to make a meaningful contribution, rather than a deviant, needy, and special student.

Implications for Policy
Slee (2019) explains that rhetoric and practice can never be disentangled and, together, are part of the policy-making practice. In the U.S., idea (2004) requires plaafp statements to describe how a student's disability affects access to the general curriculum. At the outset of the iep, the team is required to argue that the disability is the primary limitation to student's access to curriculum, suggesting a medical approach to remediating disability. This orientation dismisses the role of the curriculum in limiting the student's involvement and progress in school, predisposing teams to convey narratives of deficit.
Special education policy should reflect the perspectives of individuals with disabilities, and should promote positive positioning of students. iep teams for students who require multiple and complex supports consist of a variety of professionals. Their collective reports resemble a bricolage of information about students which reduces students to a sum of their parts rather than presenting a holistic picture of a child for whom special education is necessary due to the disabling context of school (Authors, 2011). This encourages teams to highlight the ways students' deficits limit their progress, rather than describe the ways that the school might be are disabling. As a result, the readers and authors of these statements see students' differences and deviance as central to their educational narrative. Centering voices of people with disabilities in special education processes is essential to moving special education beyond a predominantly deficit-driven field which operates to sustain itself and, as Skrtic (2004) described it, "function as a legitimizing device" (p. 117).
A primary function of the iep is to ensure education is accessible to students with disabilities; as such, iep s can be re-imagined to first identify environmental and educational barriers for students, and to create a plan to eliminate barriers prior to establishing goals. Rather than focusing heavily on the students' goals, which center student deficits, iep s should give more attention to the specially designed instruction that the school will provide to ensure students with various learning needs can be successful. Rather than remediating deficits in the students, iep s might be conceptualized as a way to remediate deficits in educational environments that limit access and progress for individual students with disabilities.

Future Research
Future research in this area should continue to examine how rhetoric and data position students with disabilities in schools. Positioning theory and narrative analysis can be applied to professionals' speech in schools, such as casual hallway conversations, collaboration, or iep meetings. Another line of research could examine how professionals position themselves in relation to students. Emerging evidence suggests that administrators, in particular, might misunderstand special educators' roles and position special educators as caregivers, cheerleaders, or "miracle workers" rather than professionals with a learned skill set (Author, 2017). In turn, students with disabilities are positioned as in need of caring and control rather than education. Because 25% of the iep s reported no data at all, research is needed to investigate ways to support iep team members to report measurable data in iep s. Finally, research is needed about constructing iep documents in ways that position students in a positive way.

Limitations
Due to the difficulty in obtaining iep documents as well as the small size of the population under study (i.e., <1% of students receiving special education services) our sample was limited by its size. We did not have an opportunity to discuss the iep documents with team members, which might have provided additional insights into their motivation or reasoning for writing the statements. We did not observe the students, so we cannot verify that the observations reported by team members were accurate. Finally, 25% of the iep s lacked quantitative data, limiting our conclusions related to data reporting.

Conclusion
Describing ableism in special education, Brantlinger (1997) noted, "Disability is a social construct that can be illogical, damaging, and imbued with others' vested interests" (p. 431). The current study explains how disability is constructed through the language professionals use to position students. Professional interests intersect with the system of special education and, as observed in this study, can unwittingly collude to create a narrative of difference and deviance for students, resulting in educational affordances and barriers as powerful consequences. iep processes and professional communication unravelling the narratives Journal of Disability Studies in Education 3 (2023) 4-28 vary in different contexts. The findings from the current study highlight ways that iep processes situated in a medical or deficit model can reproduce inequality by positioning students as limited in potential and the source of problems. Instead, iep processes might be reconceptualized to situate the need for remediation in the school environment, placing responsibility on the school for removing barriers and improving student learning.