Required Training
Module 2 - Effective Communication
2026 - 27 School Year�
This training must be completed by
September 4, 2026 by all district employees who have not completed it previously
Telluride R-1 School District
Under Title II, what must the District do to provide effective communication to students with hearing, vision, or speech disabilities?
The District must provide appropriate “auxiliary aids and services” where necessary to provide effective communication, so that students with disabilities have an equal opportunity to participate in, and enjoy the benefits of, the services, programs, and activities of the District. In selecting the auxiliary aids and services to be provided, Title II requires the District to give “primary consideration” to the auxiliary aid or service requested by the student with the disability when determining what is appropriate for that student. See Q&A 3 below. If the District can prove that providing a particular auxiliary aid or service would be a fundamental alteration in the nature of a service, program, or activity, or be an undue financial and administrative burden, the school does not need to provide that auxiliary aid or service. See Q&A 6 below. However, the school still has an obligation to provide, to the maximum extent possible, an effective auxiliary aid or service.
What are examples of auxiliary aids and services for students with hearing, vision, and speech disabilities?
Auxiliary aids and services include a wide range of services, devices, technologies, and methods which make aurally or visually delivered information available to students with hearing, vision, or speech disabilities so that they can receive information from, and convey information to, others as effectively as students without disabilities, as well as services needed for the acquisition or modification of equipment or devices.
What does it mean for the District to give “primary consideration” to the request of the student with a disability when making the decision to provide a particular auxiliary aid or service?
When determining what is appropriate for that student, the District must provide an opportunity for the person with the disability (or an appropriate family member, such as a parent or guardian) to request the particular aid or service the student with a disability thinks is needed to provide effective communication. It is the person with the disability (or his or her appropriate family member) who is most familiar with his or her disability and can provide relevant information about which aids or services will be most effective.
For example, if a high school student was deaf at birth or lost his or her hearing before learning language, that person may use American Sign Language (ASL) as his or her primary form of communication and may be uncomfortable or not proficient with other forms of communication. A high school student who lost his or her hearing later in life and who uses a cochlear implant may not be as familiar with sign language and may feel most comfortable and proficient with an oral interpreter or with the use of a computer or other technology. A young student who is nonverbal and is fluent in ASL but cannot read yet may not be able to use a computer with written text and may be most comfortable and proficient communicating with a sign language interpreter.
The District must honor the choice of the student with the disability (or appropriate family member) unless the District can prove that an alternative auxiliary aid or service provides communication that is as effective as that provided to students without disabilities. If the District can show that the alternative auxiliary aid or service is as effective and affords the person with a disability an equal opportunity to participate in and benefit from the service, program, or activity, then the district may provide the alternative.
What factors should the District consider in determining what auxiliary aids or services are necessary to afford qualified students with disabilities an equal opportunity to participate in, and enjoy the benefits of, the public school's services, programs, or activities?
The determination of what auxiliary aids or services will provide effective communication must be made on a case-by-case basis, considering the communication used by the student, the nature, length, and complexity of the communication involved, and the context in which the communication is taking place. When determining the appropriate method of communication, schools must make an individualized determination and cannot assume, for example, that simply because a student is deaf, the student is fluent in ASL. In addition to giving primary consideration to the particular auxiliary aid or service requested by the student with a disability, the public school should also consider, for example, the number of people involved in the communication, the expected or actual length of time of the interaction(s), and the content and context of the communication. For example, will the communication with a deaf student be fairly simple so that handwritten or typed notes would suffice; or is the information being exchanged important, somewhat complex, technical, extensive, or emotionally charged, in which case, a qualified interpreter may be necessary. The Title II regulations’ requirements apply to all of a student’s school-related communications, not just those with teachers or school personnel. Therefore, given the ongoing exchanges students experience with teachers, students, coaches, and school officials, any student who requires a sign language interpreter in order to receive effective communication in an academic class would likely need interpreter services throughout the day and may also need them to participate in school-sponsored extracurricular activities. For a deaf or hard of hearing student, a sign language interpreter or CART may be appropriate where student comments and discussions are part of the class experience for all students, i.e., to enable the student to understand comments and discussions from classmates that all students are exposed to, in addition to what is being said by the teacher, and to enable the student to express himself or herself in a manner that permits the teacher and classmates to fully understand and respond to the student. Likewise, a student with cerebral palsy who is nonverbal may need a computer that produces text or speech in order to communicate with the teacher and his or her classmates. For a blind student, that student’s textbooks and handouts must be accessible for that student, and all written information used in the classroom should also be read aloud or presented in other accessible formats. In determining which auxiliary aid or service to provide, the District should be mindful that communications evolve depending on the circumstances, and should reassess the effectiveness of communication regularly as a situation changes. For example, what may begin as a simple request by a student to check out a book from the school library, where an exchange of written notes would be sufficient, can evolve into a more complex communication concerning assistance in completing a research paper, where an exchange of written notes might not be sufficient to ensure effective communication.
What does it mean for auxiliary aids and services to be provided in "accessible formats, in a timely manner, and in such a way as to protect the privacy and independence" of a student with a disability?
This regulatory provision has several requirements:
What happens if the District thinks that providing a particular auxiliary aid or service would result in a fundamental alteration in the nature of a service, program, or activity, or an undue financial and administrative burden?
The District Superintendent or designee (i.e., another school official with authority to make budgetary and spending decisions) may make the determination that a particular auxiliary aid or service would result in a fundamental alteration in the nature of the service, program, or activity or in undue financial and administrative burdens after considering all resources available for use by District in the funding and operation of the service, program, or activity. Such a determination must be accompanied by the decision maker’s written statement of the reasons for concluding that a requested auxiliary aid or service would cause such alteration or burdens. In those circumstances, the District has the burden of proving that providing the requested auxiliary aid or service would result in such alteration or burdens. In situations where the District decides not to provide a particular aid or service and can prove that doing so would result in a fundamental alteration or undue burdens, the District must take other steps that would not result in such an alteration or such burdens but would nevertheless ensure that, to the maximum extent possible, the individual with a hearing, vision, or speech disability can participate in, and receive the benefits or services provided by, the District’s program or activity. Generally, this would involve the provision of an auxiliary aid or service that would not result in a fundamental alteration or undue burden.
Under what circumstances is a public school required to provide auxiliary aids and services to persons with a hearing, vision, or speech disability who are not students, such as parents, other relatives, and members of the public, who seek to participate in or benefit from a district's services, programs, or activities?
Title II’s effective communication obligations are not limited just to students – the District is obligated to provide effective communication to all individuals who seek to participate in or benefit from the District’s services, programs, or activities such as student registration, parent-teacher conferences, meetings, ceremonies, performances, open houses, and field trips. All of the same Title II requirements and considerations discussed in the context of students with hearing, vision, or speech disabilities apply to other individuals with disabilities who are covered by this requirement.
May the District require an individual with a hearing, vision, or speech disability to bring another person to interpret or facilitate communication, or to rely on a person who accompanies an individual with such a disability?
Title II regulations expressly prohibit a public school from requiring an individual with a disability to bring another person to interpret for him or her, except in an emergency involving an imminent threat to the safety or welfare of an individual or the public where there is no interpreter available. In that case, the school may ask either a minor child or an adult to interpret or facilitate communication. In no other circumstances may a school rely on a minor child to interpret or facilitate communication. Also, where the individual with the hearing, vision, or speech disability specifically makes the request, an accompanying adult may interpret or facilitate communication if the accompanying adult voluntarily agrees to provide the assistance and the school’s reliance on the accompanying adult is appropriate under the circumstances.
Can the District charge for the provision of auxiliary aids or services?
No. The District must provide auxiliary aids and services at no cost for such aids or services.
How do the IDEA FAPE and the Title II effective communication requirements differ with regard to the obligation to provide communication for students with disabilities attending public elementary and secondary schools?
The Title II regulations explicitly require that the District take appropriate steps to ensure that communications with persons with disabilities are “as effective as” communications with other persons. They further require that District provide appropriate auxiliary aids and services where necessary to afford a person with a disability an “equal opportunity” to participate in and enjoy the benefits of the district’s services, programs, or activities. Under the IDEA, FAPE must be individually designed to provide meaningful educational benefit to the child. The IDEA does not require that a district compare the effectiveness of communications with a student with a disability to the effectiveness of communications with students without disabilities. For a student with a disability who is covered under both laws -- such as all IDEA-eligible students with hearing, vision, or speech disabilities -- the District must ensure that both sets of legal obligations are met, and that none of the student’s rights under either law are diminished or ignored. For many students, the special education and related services that they receive under the IDEA will also ensure that communication with those students is as effective as communication with other persons. In other instances, the services, devices, technologies and methods for providing effective communication that are provided to a particular student as “auxiliary aids and services” under Title II may not necessarily be the same as those determined under the IDEA. Further, if the special education and related services provided under the IDEA are not sufficient to ensure that communication with the student is as effective as communication with other persons, the Title II obligations have not been met. Thus, depending on the circumstances, the services and aids that a student receives under the IDEA may be the same as or greater than the services and aids that would be provided under Title II; in other circumstances, a student may receive more services and aids under Title II than those provided under the IDEA. A student with a disability does not, and cannot be asked to, give up his or her rights under Title II in exchange for, or because he or she already receives, special education and related services under the IDEA. That is, the provision of FAPE under the IDEA does not limit a student’s right to effective communication under Title II.
How does a parent request auxiliary aids and services for a child under Title II?
Title II requires the District to provide notice about Title II and its applicability to the Districts’ services, programs, or activities. Currently, the District Superintendent is the designated ADA and Section 504 coordinator for the District. Teachers and other staff members who receive inquiries about auxiliary aids and services will refer the inquiry to the Superintendent or the Superintendent’s authorized designee. If a child has a 504 Plan or an IEP, a request for auxiliary aids and services under Title II can be made to the child’s 504 committee or IEP team. Please refer to Q&A 15 for additional information regarding the role of the IEP Team or 504 committee. As discussed below, a parent does not need to make a specific request under Title II before a school considers its responsibilities to provide auxiliary aids and services.
For children who are already receiving special education and related services under the IDEA or accommodations pursuant to a 504 Plan, do parents have to make specific requests for different or additional auxiliary aids and services to trigger the Title II obligations for effective communication? Also, once the decision is made to provide a particular auxiliary aid or service to a student with a hearing, vision, or speech disability, does the District have any obligation under either Title II or the IDEA to revisit that decision? If so, when?
Parents do not have to make a specific request for different or additional auxiliary aids. When the District knows that a student needs assistance with communication because, for example, he or she has a hearing, vision, or speech disability, the District has an affirmative obligation to provide effective communication under Title II, whether or not a parent requests specific auxiliary aids and services under Title II. This obligation is in addition to the requirement that the District make FAPE available if the student is eligible under the IDEA, and may also be in addition to accommodations implemented under a 504 Plan. Under Title II, the public school has a continuing obligation to assess the auxiliary aids and services it is providing to students with hearing, vision, or speech disabilities to ensure that these students are receiving effective communication. For information on what parents can do if they disagree with the District’s decision on what Title II’s effective communication provisions require for their child, please refer to Slide 18.
Who in the District participates in the determinations about the provision of auxiliary aids and services under Title II? Does the ultimate decision maker differ depending upon whether the student is covered by the IDEA, Title II, or both?
The Title II regulations do not designate a particular responsible person or group of people to make the determinations about the provision of auxiliary aids and services under Title II. The District’s ADA Coordinator (currently the Superintendent) has the responsibility of making decisions about the auxiliary aids and services required under Title II. The ADA Coordinator may participate in Title II effective communication decisions and in 504 Plan reviews. If a student is IDEA-eligible, a parent’s request under Title II for a child will be addressed at least initially by the IEP team. See Q&A 15. The Uncompahgre BOCES (the “UnBOCES”) serves as the Administrative Unit for special education in the District, and IEP teams work under the direction of the UnBOCES’ Director of Special Education.
Under what circumstances may the IEP Team make decisions about the provision of auxiliary aids and services required under Title II?
Under the IDEA, the school must ensure that the child’s educational program, as part of FAPE, is based on the individual needs of the child and is reasonably calculated to enable the child to receive meaningful educational benefit. The District designates the IEP Team as having the responsibility of making decisions about the auxiliary aids and services required under Title II, under the direction of the UnBOCES Director of Special Education. In making such decisions, the IEP Team will apply the effective communication standards of Title II rather than the standards that apply to a FAPE determination under the IDEA.
Is the IDEA evaluation process different than the analysis used when considering an individual's request for a particular auxiliary aid or service under Title II?
Under the IDEA, the District must conduct a full and individual initial evaluation before the initial provision of special education and related services to a child with a disability. The evaluation must use a variety of assessment tools and strategies to gather relevant functional, developmental, and academic information about the child, including information provided by the parent that may assist in determining whether the child is a child with a disability and needs special education and related services. Evaluations also must be provided and administered in a student’s native language or other mode of communication. If the District has already completed a child’s evaluation under the IDEA, it may rely on information obtained from that evaluation when determining the need for effective communication under Title II. However, the District must analyze the child’s needs and how to meet those needs based on the Title II standard, and this includes giving primary consideration to a request for a specific auxiliary aid or service. The District may not ignore information obtained through the IDEA evaluation procedures, but may implement its own procedures to determine whether a child needs a particular auxiliary aid or service to ensure effective communication under Title II. Similarly, as explained above in Q&A 5, the District must provide the auxiliary aids or services in a timely manner and cannot wait for the IEP process to run its course before providing necessary auxiliary aids and services under Title II. The IDEA does not prohibit the District from providing the needed auxiliary aids and services under Title II while the IDEA evaluation is pending. In this situation, the District must first address the child’s needs for auxiliary aids and services based on the Title II standard while proceeding with the IDEA evaluation process, meaning the District must provide those aids and services that ensure communication with the child is as effective as communication with students without disabilities and give primary consideration to the parent’s or child’s request for specific auxiliary aids and services, if any. Once the IDEA evaluation is complete, the District may need to reassess whether the child needs different auxiliary aids or services to ensure effective communication under Title II if the results of the IDEA evaluation provide additional information regarding the child’s needs or the effectiveness of the auxiliary aids and services being used.
May the District determine that, under Title II, all children with a hearing, vision, or speech disability will receive the same auxiliary aid or service as others with that kind of disability?
No. The decision what auxiliary aids or services to provide is made on an individualized, case-by-case basis. Because students with disabilities experience varying levels and types of limitations from hearing, vision, or speech disabilities, and because the District must give primary consideration to the requests of the individual, these determinations must be made on an individual basis. For examples of appropriate auxiliary aids and services in individual cases, see Slide 3.
What dispute resolution mechanisms are available if a parent believes that the District has improperly denied or limited his or her child's access to a particular auxiliary aid or service under Title II or has not made FAPE available under the IDEA?
Under the IDEA, a parent challenging the provision of FAPE may request mediation, may file a complaint with the State educational agency, or may request an impartial administrative hearing by filing a due process complaint and participating in the prescribed resolution process. The administrative hearing procedures vary by state and may include one or two levels of administrative review. An administrative hearing decision may be appealed to a State or Federal court empowered to hear such cases. In general, IDEA’s administrative hearing procedures must be utilized before seeking relief in State or Federal court. Regardless of whether or not the student also is eligible under the IDEA, a parent of a student with a disability can file a Title II complaint regarding the denial or limitation of a particular auxiliary aid or service with the United States Department of Education’s Office for Civil Rights or with the United States Department of Justice’s Civil Rights Division, or file a Title II complaint under District policy AC-R1. A parent may also choose to file a civil action alleging a violation of Title II in Federal court. However, parents and guardians should be aware that the IDEA requires that, before filing a Federal case under other laws, such as Title II of the ADA, seeking a remedy that is also available under the IDEA, the parent or guardian generally must exhaust the administrative hearing procedures of the IDEA, which means obtaining a final decision under the IDEA’s impartial due process hearing procedures.
Under what circumstances may the District use IDEA funds to pay for auxiliary aids or services for IDEA-eligible students to ensure effective communication as required by Title II?
The IDEA provides that grant funds must be used only in accordance with the applicable provisions of the IDEA and to pay the excess costs of providing special education and related services to children with disabilities. Therefore, IDEA funds may be used only to pay for auxiliary aids and services under Title II that also are required to be provided under the IDEA, such as assistive technology or interpreter services that are included in the student’s IEP. If a child receives auxiliary aids and services under Title II that are not included in the child’s IEP, IDEA funds may not be used to pay for those services.
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Certificate of Completion, Module 2
Please complete this training module and form by September 4, 2026
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