Full opinion text
MEMORANDUM OPINION & ORDER PAUL G. GARDEPHE, District Judge: Plaintiff L.O. brings this action—on behalf of herself and her son, K.T.—against the New York City Department of Education (the “DOE”) for relief pursuant to the Individuals with Disabilities Education Act (the “IDEA”), 20 U.S.C. §§ 1400 et seq. Plaintiff seeks to overturn a State Review Officer’s decision affirming an Impartial Hearing Officer’s finding that the educational program and services that the DOE’s Committee on Special Education (“CSE”) recommended for Plaintiffs son were appropriate. The parties have cross-moved for summary judgment. For the reasons stated below, Defendant’s motion will be granted and Plaintiffs motion will be denied. BACKGROUND I STATUTORY BACKGROUND “Under the IDEA, states receiving federal funds are required to provide ‘all children with disabilities’ a ‘free appropriate public education.’ ” Gagliardo v. Arlington Cent Sch. Dist., 489 F.3d 105, 107 (2d Cir.2007) (quoting 20 U.S.C. § 1412(a)(1)(A)); see also Walczak v. Florida Union Free Sch. Dist., 142 F.3d 119, 122 (2d Cir.1998). A “free appropriate public education” (“FAPE”) must include “ ‘special education and related services’ tailored to meet the unique needs of a particular child, ... and be ‘reasonably calculated to enable the child to receive educational benefits....’” Walczak, 142 F.3d at 122 (quoting Bd. of Educ. v. Rowley, 458 U.S. 176, 207, 102 S.Ct. 3034, 73 L.Ed.2d 690 (1982)) (internal citations omitted). Special education and related services under the IDEA are provided by a school district pursuant to an annual individualized education program (“IEP”). Walczak, 142 F.3d at 122; see also 20 U.S.C. § 1414(d). In New York, local committees on special education (“CSE”) are responsible for developing appropriate IEPs. Walczak, 142 F.3d at 123. “In developing a particular child’s IEP, a CSE is required to consider four factors: (1) academic achievement and learning characteristics, (2) social development, (3) physical development, and (4) managerial or behavioral needs.” Gagliardo, 489 F.3d at 107-08 (citing N.Y. Comp.Codes R. & Regs. (“NYCRR”) tit. 8, § 200.1(ww)(3)(i)). Parents who wish to challenge the adequacy of an IEP developed by their local CSE may request an impartial due process hearing before an impartial hearing officer (“IHO”) appointed by the local school board. Id. at 108 (citing 20 U.S.C. § 1415(f) and N.Y. Educ. Law § 4404(1)). An aggrieved party may appeal an IHO’s decision to a state review officer (“SRO”), and the SRO’s decision may be challenged in either federal or state court. Id. (citing 20 U.S.C. §§ 1415(g), (i)(2)(A) and N.Y. Educ. Law § 4404(2)). II. FACTS A. KT.’s Background K.T. is a nineteen-year-old boy who was diagnosed with autism at age four. (Impartial Hearing Transcript (“Tr.”) (Dkt. No. 29) 652-53) He has also been diagnosed with pervasive developmental disorder, mild mental retardation, obsessive compulsive disorder, mood disorder, asthma, and pica. (Def. R. 56.1 Stmt. (Dkt. No. 20) ¶ 6) In 2009, K.T. began attending New York City Public School 811X. (Tr. 653; Pltf. Ex. 27 (Dkt. No. 29) at 3) He was placed in the school’s “6:1:1 program,” which provides for a class consisting of six students, a teacher, and a paraprofessional. (Tr. 99; Pltf. Exs. 3 at 1, 5 at 1, 6 at 1 (Dkt. No. 29)) K.T. received special services, including counseling as well as speech, physical, and occupational therapy. (Pltf. Exs. 3 at 10; 5 at 12; 6 at 12 (Dkt. No. 29)) In September 2010 — when K.T. was assigned a new teacher and moved to a new classroom — he began to engage in self-abusive behavior and to physically and verbally abuse others at school. (Tr. 131, 655; Pltf. R. 56.1 Stmt. (Dkt. No. 15) ¶ 8) His self-abusive behaviors include “hitting himself on the head, hitting the table and scratching himself.” (Pltf. Ex. 3 (Dkt. No. 29) at 4) He also often “puts staples in his mouth, which he finds comforting.” (Pltf. Ex. 25 (Dkt. No. 29) at 2) In the fall of 2010, K.T. began expressing reluctance to attend school (Tr. 630-631), and by November 2011, K.T. refused to attend school (Pltf. R. 56.1 Stmt. (Dkt. No. 15) ¶ 3; Tr. 630). B. The IEPs Developed by the CSE 1. December 2009 IEP On December 2, 2009, the DOE convened a CSE meeting for the purpose of developing an IEP for K.T. for 2010. (Def. R. 56.1 Stmt. (Dkt. No. 20) ¶ 13; Pltf. Ex. 6 (Dkt. No. 29)) Plaintiff L.O. attended the meeting, along with a DOE representative, a special education teacher, a physical therapist, an occupational therapist, a speech therapist, and a counselor. (Pltf. Ex. 6 (Dkt. No. 29) at 2) At this meeting, the CSE considered recommending K.T. for placement in a general education program in a state-supported public or private school, but determined that “[g]eneral education with the assistance of supplementary aids and services will not provide enough support for [K.T.] to meet his needs.” {Id. at 14) Accordingly, the CSE recommended that K.T. be placed in a “[sjpecial class in a specialized school with related services” for a twelve-month school year. {Id. at 1) The CSE found that a classroom with a 6:1:1 student-teacher-paraprofessional ratio would be appropriate. {Id.) With respect to academic management and emotional needs, the IEP notes that K.T. “benefits from a small [and] highly structured class setting” and “forms of positive reinforcement.” {Id. at 3) The IEP also states that, although K.T. “is a friendly young man” and has “improve[d] his social and communication skills” by “learning under the TEACCH methodology,” his behavior “seriously interferes with instruction and requires additional adult support.” {Id. at 4) The IEP recommends that K.T. participate in an “Alternative Assessment” program due to the severity of his “deficits in cognitive, communication, and social development.” (Id. at 12) It also recommends that K.T. continue to receive a number of related services, including speech, physical, and occupational therapy. (Id.) The CSE decided to terminate K.T.’s counseling program, however. (Id. at 2) The December 2009 IEP sets forth nine annual goals and 26 short-term objectives for K.T. during 2010. (Id. at 6-11) The annual goals include improving his skills in a number of areas, including community awareness, reading, math, handwriting, social interaction, and physical fitness. (Id.) The short-term objectives provide methods for K.T. to achieve his goals. For example, the IEP states that K.T. “will read and identify items he likes from a fast food menu 8/10 times over a two week period,” in order to develop his reading skills. (Id. at 6) Finally, the IEP includes (1) a plan for K.T. to transition to adult living; and (2) a behavioral intervention plan (“BIP”), which describes KT.’s interference behaviors and provides strategies for changing those behaviors. (Id. at 15-16) 2. December 2010 IEP KT. continued to attend his 6:1:1 special class throughout 2010. See Tr. 97-99. On December 20, 2010, the CSE convened for the purpose of developing an IEP for K.T. for 2011. (Pltf. Ex. 5 (Dkt. No. 29); Def. R. 56.1 Stmt. (Dkt. No. 20) ¶28) Plaintiff L.O., a DOE representative, a special education teacher, and a speech pathologist attended the meeting. (Pltf. Ex. 5 (Dkt. No. 29) at 2) The CSE recommended that KT.’s services remain the same as the previous year. (Id. at 1-2) The CSE again considered — and rejected — a general education program for K.T.,- and recommended that he continue to receive speech, physical, and occupational therapy. (Id. at 11-12) The December 2010 IEP notes that K.T. “is currently following an alternate assessment curriculum,” and recommends that he continue with this program. (Id. at 3, 12) The IEP reports that K.T. “can complete work tasks independently with assistance needed only for redirection and/or task completion,” but again comments that KT.’s behavior “seriously interferes with instruction.” (Id. at 3-1). The December 2010 IEP lists new annual goals and short-term objectives, including that “[wjithin one year, [K.T.] will be able to use the keyboard on a computer to type his name with minimal assistance.... ” (Id. at 7) The IEP also includes a transition plan and a BIP. (Id. at 13-14) 3. March 2011 IEP In a January 18, 2011 letter, Plaintiff requested that the DOE re-evaluate K.T. “to ensure [that he] is receiving the appropriate services and is in the appropriate educational setting.” (Pltf. Ex. 12 (Dkt. No. 29)) The next day, the school’s related services coordinator made a referral to the CSE for a re-evaluation of KT.’s program (Pltf. Ex. 11 (Dkt. No. 29)), and requested updated speech, language, and physical therapy evaluations (Tr. 569-72). On March 7, 2011, the CSE convened for a review .of KT.’s IEP. (Tr. 115-16; Pltf. Ex. 3 (Dkt. No. 29)) Those present for this meeting included Plaintiff, a DOE representative, a school psychologist, and a special education teacher. (Pltf. Ex. 3 (Dkt. No. 29) at 2) The March 2011 review resulted in no significant changes to KT.’s educational program. (Compare id. at 1-11 with Pltf. Ex. 5 (Dkt. No. 29) at 1-14) The March 2011 IEP notes that the CSE considered placing K.T. in a(l) general education program, (2) 12:1:1 class in a special school, or (3)12:1:4 class in a special school, but rejected all of those options “because they would not meet [K.T.’s] significant academic and social needs.” (Pltf. Ex. 5 (Dkt. No. 29) at 9) The March 2011 IEP also continues to recommend that K.T. participate in the Alternative Assessment program, and that he receive speech, physical, and occupational therapy. (Id. at 10) The March 2011 IEP includes a transition plan that is identical to the plan in the previous IEP. Although the March 2011 IEP indicates that a new BIP was developed for K.T., the new BIP is not attached to the IEP. (Id. at 4,11) K.T. continued to attend the 6:1:1 special class through most of 2011. See Pltf. Ex. 43 (Dkt. No. 29) at 9 (report card indicating that K.T. received a progress update in June 2011). On November 18, 2011, however, K.T. began refusing to attend school. (Pltf. R. 56.1 Stmt. (Dkt. No. 15) ¶ 3; Tr. 630) III. ADMINISTRATIVE PROCEEDINGS A. Plaintiff’s Due Process Complaint On December 9, 2011, Plaintiff filed a due process complaint requesting an impartial hearing. (Pltf. Ex. 1 (“Due Process Cmplt.”) (Dkt. No. 29); Pltf. R. 56.1 Stmt. (Dkt. No. 15) ¶ 35) Plaintiff asserted that the school district’s CSE did not provide K.T. with a FAPE for 2009, 2010, and 2011. (Due Process Cmplt. Notice (Dkt. No. 29) at 5) Plaintiff alleged, inter alia, that (1) the CSE did not appropriately evaluate K.T., and the IEPs “do not reflect reliance on any evaluations or assessments of the student”; (2) the IEPs indicated that KT.’s progress would be monitored using the Brigance assessment, and that he would be evaluated with a “data-folio,” but these evaluations did not occur; (3) the DOE did not conduct evaluations “necessary to develop meaningful present levels of performance”; (4)' the CSE did not develop “meaningful and measurable annual goals”; (5) the DOE deprived K.T. of “mandated services for students with autism”; (6) the IEPs “identified no instructional methodologies appropriate for a child with [K.T.’s] particular needs”; (7) the IEPs “provided neither social skills training nor appropriate goals related to such training”; (8) “no functional behavior assessment has ever been conducted, and no behavioral plan has been developed”; (9)the DOE “failed to provide adequate speech/language services”; (10) the “annual goals do not adequately address the student’s particular needs”; (11) the CSE did not develop an “appropriate transition plan” to adult living; (12) the DOE did not provide appropriately certified or licensed service personnel to work with K.T.; (13) the DOE did not provide the parent with “meaningful reports on [K.T.’s] progress”; (14) the March 2011 IEP did not include any behavioral goals; (15) the December 2010 IEP did not identify “any of the accommodations” that the DOE was to provide K.T. during “alternative assessments”; (16) a “Vineland-II assessment” conducted on March 7, 2011 was improperly administered; and (17) KT.’s significant deterioration as a result of inappropriate programming had led to the need for a residential placement. (Id. at 5-9) In her complaint, Plaintiff sought, inter alia, annulment of the March 2011 IEP; prompt completion of a number of evaluations and a functional behavior assessment; the immediate development of an appropriate IEP; provision of intensive speech-language therapy services at least four times per week; review of K.T.’s medical and education records for purposes of placing him in a residential school designed for students with autism; compensatory services; and payment of attorney’s fees and costs. (Id. at 9-10) B. The Impartial Hearing and the Hearing Officer’s Decision The impartial hearing began on January 10, 2012, and concluded on March 6, 2012, after five days of hearings. The DOE offered testimony from five employees at KT.’s school, including '(1) Myrna Qui-nones, [KT.’s] special education teacher; (2) Eleyna Rivas, the assistant principal; (3) Charlene Torres, a speech teacher; (4) Kim McPherson, an occupational therapist; and (5) Chárito Labay, a physical therapist. See Tr. 93-553. Plaintiff testified and also offered testimony from (1) Carol Búfano, a former DOE related services coordinator; (2) Gracie President, the program manager for Service for the Under-served; and (3) Peter Doran, the Medicaid Services Coordinator for Services for the Developmentally Challenged. See Tr. 553-718. On April 18, 2012, the IHO issued a decision rejecting Plaintiffs challenge to the appropriateness of KT.’s 2009, 2010, and 2011 IEPs, and denying Plaintiffs claim for compensatory additional services. (April 18, 2012 IHO Final Decision (Dkt. No. 29) at 25) The IHO found that “the CSE has offered [K.T.] a FAPE and implemented the program and services called for in [KT.’s] IEPs [for 2009, 2010, and 2011],” and thus K.T. “is [not] entitled to compensatory additional services.” (Id. at 18) The IHO rejected all of Plaintiffs objections to the IEPs. He found that (1) “the CSE had adequate evaluative information [concerning KT.’s] functional, developmental and academic needs upon which to premise its programs for the student” for all three school years, and that the “evidence offered into the hearing record demonstrates that [KT.’s] cognitive functioning, educational functioning, mental health needs and adaptive behavior skills were regularly assessed by the CSE since 2006” (id. at 19); (2) KT.’s “IEPs for the last three academic years established annual goals and short-term instructional objectives which were reasonably related to his educational deficits” (id. at 20); (3) “the absence of specific instructional methodologies from [KT.’s] IEPs for the last three academic years did not impede [his] right to a FAPE” (id. at 20-21); (4) the “CSE has consistently developed transition plans for [K.T.] over the last three ... academic years” (id. at 22); (5) “the CSE’s recommended program provided [K.T.] with sufficient instructional services to meet his individual speech/language needs” (id.); (6) the IEPs’ failure to “indicate when periodic reports on [KT.’s] progress toward his annual goals would be provided to the parent ... did not impede [his] right to a FAPE” (id. at 23); (7) “where, as here, the [behavioral intervention plans] document a child’s interfering behaviors and propose strategies ... to address those behaviors, the failure to also conduct [a functional behavior assessment] does not amount to a denial of FAPE” (id. at 24); and (8)although “the provision of parent counseling and training was not memorialized on any of the student’s last three ... IEPs ..., [this failure] did not result in a denial of a FAPE” because “parent counseling and training was available at the assigned school” (id.). C. State Review Officer’s Decision Plaintiff appealed the IHO’s decision, arguing that — with respect to each of the three IEPs — (1) there is no evidence that any of K.T.’s evaluations were reviewed by the CSE; (2) the IEPs set forth inappropriate academic and functional goals; (3) the IEPs do not adequately address [K.T.’s] speech-language needs; (4) the CSE did not conduct functional behavior assessments in developing KT.’s IEPs and did not adequately address KT.’s behavioral issues; and (5) the IEPs do not indicate the extent to which counseling and training will be provided to K.T.’s parents. (L.O. Petition to SRO (Dkt. No. 29) ¶¶ 52-92) Plaintiff also argued that “the IHO simply ignored the fact that the CSE and the [DOE] never addressed [K.T.’s] refusal to attend school.” (Id. ¶ 85) On March 15, 2013, the SRO affirmed, finding that all three IEPs were properly designed to address KT.’s educational needs. (Sterne Decl. (Dkt. No. 13), Ex. 1 (“SRO Decision”) at 33) As to Plaintiffs contention that there was no evidence in the IEPs that the CSE had reviewed KT.’s evaluations, the SRO concluded that “the hearing record contains evaluative materials that, based on their date, existed at the time of each of the CSE meetings.” (Id. at 11) With respect to the December 2009 IEP, the SRO noted that the IEP is consistent with several evaluative reports conducted prior to the CSE meeting, including (1) an “October 2008 psychoeducational evaluation report,” (2) a “September 2009 comprehensive psychosocial evaluation report,” (3) a “December 1, 2009 counseling report,” and (4) “reports which document [HT.’s] participation and progress from summer 2009 through January 2010.” (Id. at 11-13 (citing Pltf. Exs. 26-28, 49)) The SRO concluded that “[although the [DOE] did not show which evaluative information was reviewed during the course of the CSE meeting, the evidence in the hearing record nevertheless supports the IHO’s ultimate conclusions.” (Id. at 15) The SRO also found that the December 2010 IEP is consistent with a number of evaluative reports, including (1) comprehensive psychological evaluations of K.T. completed on January 20, 2010 and April 21, 2010; (2) a June 18, 2010 physical therapy progress report; (3) an August 13, 2010 report card; (4) a September 17, 2010 “Student’s Strengths-Based Profile”; (5) a Brigance Inventory of Early Development-II test administered on September 21, 2010; (6) a “Student Communication Profile” dated October 8, 2010; (7) a November 1, 2010 report card; (8) an “instructional priority data collection sheet”; and (9) the minutes from a December 3, 2010 “trans-disciplinary meeting [concerning K.T.].” (Id. at 21-24 (citing Pltf. Exs. 16, 21, 24-25, 43, 45^7, 50)) The SRO similarly found that the March 2011 IEP is consistent with a March 1, 2011 teacher evaluation and a March 7, 2011 “VABS-II survey interview report.” (Id. at 29-31 (citing Pltf. Exs. 22-23)) As to Plaintiffs contention that the IEPs contained inappropriate goals for K.T., the SRO found that the goals and short-term objectives in the December 2009 and December 2010 IEPs contained “sufficient specificity by which to guide instruction and intervention, evaluate the student’s progress, and gauge the need for continuation or revision, and [that] they contained adequate evaluative criteria.” (Id. at 16; see also id. at 27) He also concluded that the March 2011 IEP “carried over [certain] goals from the December 2010 IEP” and that “[t]hese goals continued to be appropriately linked to the information reflected in the March 2011 IEP.” (Id. at 31) The SRO also rejected Plaintiffs argument that the IEPs did not adequately address KT.’s speech-language needs. The SRO explained that the December 2009 and December 2010 IEPs recommend continuation of KT.’s 30-minute speech-language therapy sessions, and that both IEPs include several goals focusing on KT.’s social communication and language skills. (Id. at 17, 28) The SRO found that the CSE appropriately modeled the December 2010 IEP after the December 2009 IEP based on indications that K.T. had made progress under the December 2009 IEP. (Id. at 28) Similarly, with respect to the March 2011 IEP, the SRO concluded that “it was reasonable in March 2011 to continue the student’s speech language services from his December 2010 IEP.” (Id. at 31) As to Plaintiffs contention that the CSE did not consider special factors and interfering behaviors in developing K.T.’s IEPs, the SRO noted that — although the CSE did not develop a functional behavior assessment for K.T. during any of the three school years at issue — “the lack of an FBA does not automatically result in a denial of a FAPE.” (Id. at 20) The SRO found that the IEPs “adequately identify] the problem behavior and prescribe! ] ways to manage it,” and that both the December 2009 and December 2010 IEPs include “adequate and appropriate” behavioral intervention plans for K.T. (Id. at 20, 29) The SRO noted that, although the March 2011 IEP does not attach the behavioral intervention plan referenced in that IEP, “the description of the student in the present level of social/emotional performance section of the IEP remained unchanged from the previous IEP.” (Id. at 32) The SRO also concluded that KT.’s refusal to attend school — which began eight months after the March 2011 IEP was formulated — is “not relevant to this proceeding for the purpose of determining whether the preceding March 2011 IEP was appropriate at the time it was formulated.” (Id. at 32 n. 41) Finally, as to Plaintiffs complaint that the IEPs do not contain provisions concerning parent counseling and training, the SRO found that the DOE’s “failure to incorporate parent counseling and training into [all three] IEP[s] was a violation of State regulation, but it did not rise to the level of a denial of a FAPE to the student.” (Id. at 21; see also id. at 29, 32-33) Accordingly, the SRO denied Plaintiffs appeal. (Id. at 33) D. The Instant Action Plaintiff filed the instant action on June 10, 2013. (Dkt. No. 1) Plaintiff alleges procedural and substantive violations of the IDEA that amount to a deprivation of a FAPE for K.T. Plaintiff also requests that this Court award compensatory education based on the alleged deprivation of a FAPE. (Id. at 7) The parties have cross-moved for summary judgment. (Dkt. Nos. 12,19) DISCUSSION I. STANDARD OF REVIEW “ ‘The responsibility for determining whether a challenged IEP will provide a child with an appropriate public education rests in the first instance with administrative hearing and review officers. Their rulings are then subject to independent’judicial review.’ ” M.H. v. New York City Dep’t of Educ., 685 F.3d 217, 240 (2d Cir.2012) (quoting Walczak, 142 F.3d at 129) (internal quotation marks omitted). “In considering an IDEA claim, a district court ‘must engage in an independent review of the administrative record and make a determination based on a preponderance of the evidence.’ ” C.L. v. Scarsdale Union Free Sch. Dist., 744 F.3d 826, 837-38 (2d Cir.2014) (quoting Gagliardo, 489 F.3d at 112); see also 20 U.S.C. § 1415(i)(2)(C)(iii). However, ‘“[t]he role of the federal courts in reviewing state educational decisions under the IDEA is circumscribed.’ ” C.F. ex rel. R.F. v. New York City Dep’t of Educ., 746 F.3d 68, 77 (2d Cir.2014) (quoting Gagliardo, 489 F.3d at 112-13 (internal quotation marks omitted)). “[C]ourts are ‘restrained by [their] lack of specialized knowledge and educational expertise; [they] must defer to the administrative decision particularly where the state officer’s review has been thorough and careful.’ ” N.S. v. New York City Dep’t of Educ., No. 13 Civ. 7819(VEC), 2014 WL 2722967, at *6 (S.D.N.Y. June 16, 2014) (quoting M.W. ex rel. S.W. v. New York City Dep’t of Educ., 725 F.3d 131, 138-39 (2d Cir.2013) (internal quotation marks and alteration omitted)). “The deference owed depends on both the quality of the [administrative] opinion and the court’s institutional competence.” C.F., 746 F.3d at 77 (citing M.H., 685 F.3d at 244) (alteration added and footnote omitted). To determine the quality of an opinion, “ ‘courts must look to the factors that normally determine whether any particular judgment is persuasive, for example, whether the decision being reviewed is well-reasoned, and whether it was based on substantially greater familiarity with the evidence and the witnesses than the reviewing court.'’ ” M.W., 725 F.3d at 139 (quoting R.E. v. New York City Dep’t of Educ., 694 F.3d 167, 189 (2d Cir.2012)) (internal quotation marks and citation omitted). The institutional competence question hinges on whether a matter involves “persistent and difficult questions of educational policy,” C.L., 744 F.3d at 838 (quotation marks and citation omitted), or “‘issues of law, such as the proper interpretation of the federal statute and its requirements.’ ” N.S., 2014 WL 2722967, at *6 (quoting Lillbask ex rel. Mauclaire v. State of Conn. Dep’t of Educ., 397 F.3d 77, 82 (2d Cir.2005) (alteration omitted)) (internal quotation marks and citation omitted). “[W]here an SRO decision ‘is reasoned and supported by the record,’ the district court should not disturb it.” Weaver v. Millbrook Cent. Sch. Dist., 812 F.Supp.2d 514, 521 (S.D.N.Y.2011) (quoting Gagliardo, 489 F.3d at 114). II. WHETHER K.T. WAS PROVIDED WITH A FREE AND APPROPRIATE PUBLIC EDUCATION “In determining whether an IEP complies with the IDEA, courts make a two-part inquiry that is, first, procedural, and second, substantive. At the first step, courts examine whether there were procedural violations of the IDEA, namely, “whether the state has complied with the procedures set forth in the IDEA.’ ” R.E., 694 F.3d at 189-90 (quoting Cerra v. Pawling Cent. Sch. Dist., 427 F.3d 186, 192 (2d Cir.2005)). “The statute is clear, however, that not every violation of the IDEA’[s] procedural requirements will result in the denial of a FAPE.” R.B. v. New York City Dep’t of Educ., No. 12 Civ. 3763(AJN), 2013 WL 5438605, at *8 (S.D.N.Y. Sept. 27, 2013), aff'd, 589 Fed.Appx. 572 (2d Cir.2014). “Rather, a procedural violation will constitute a denial of a FAPE ‘only if the procedural inadequacies (i) impeded the child’s right to a free appropriate public education; (ii) significantly impeded the parents’ opportunity to participate in the decisionmaking process regarding the provision of a free appropriate public education to the parents’ child; or (iii) caused a deprivation of educational benefits.’ ” D.B. v. New York City Dep’t of Educ., 966 F.Supp.2d 315, 329 (S.D.N.Y.2013) (quoting 20 U.S.C. § 1415(f)(3)(E)(ii)). “Multiple procedural violations may cumulatively result in the denial of a FAPE[, however,] even if the violations considered individually do not.” R.E., 694 F.3d at 190 (citing Werner v. Clarkstown Cent. Sch. Dist., 363 F.Supp.2d 656, 659 (S.D.N.Y.2005)). “Courts then examine whether the IEP was substantively adequate, namely, whether it was ‘reasonably calculated to enable the child to receive educational benefit[].”’ R.E., 694 F.3d at 190 (quoting Cerra, 427 F.3d at 192) (quotation marks and citation omitted). “Pursuant to Second Circuit precedent, an IEP is substantively adequate if it is ‘likely to produce progress, not regression and affords the student ... an opportunity greater than mere trial advancement.’ ” R.B., 2013 WL 5438605, at *12 (quoting E.S. ex rel. B.S. v. Katonah-Lewisboro Sch. Dist., 487 Fed.Appx. 619, 621 (2d Cir.2012)) (internal quotation marks and citation omitted). “Any substantive inadequacy in a student’s IEP results in the denial of a FAPE.” Id. (citing M.W., 725 F.3d at 131). Here, Plaintiff argues that the December 2009, December 2010, and March 2011 IEPs denied K.T. a FAPE because (1) the CSE did not actually rely on the evaluative data it had before it in formulating these IEPs (Pltf. Br. (Dkt. No. 16) at 5-8,13-15,18); (2) the goals listed in the IEPs were not appropriate to address KT.’s educational needs (id. at 8,15,19); (3) the IEPs did not adequately address KT.’s speech and language needs (id. at 8-9,15-17,19-20); (4) the CSE did not conduct functional behavior assessments to address KT.’s interfering behaviors and refusal to attend school (id. at 10-12, 20-23); and (5) the IEPs did not offer parental training and counseling as required by New York regulations (id. at 12-13,17-18, 20). Courts have classified all of these alleged violations as procedural. See, e.g., F.B. v. New York City Dep’t of Educ., 923 F.Supp.2d 570, 581-82 (S.D.N.Y.2013) (treating as possible procedural violation claim that CSE had not considered evaluative material) (quoting Grim v. Rhinebeck Cent. Sch. Dist., 346 F.3d 377, 381 (2d Cir.2003)); E.F. v. New York City Dep’t of Educ., No. 12-cv-2217 (MKB), 2013 WL 4495676, at *18-19 (E.D.N.Y. Aug. 19, 2013) (determining whether alleged deficiencies in IEP’s goals constituted a procedural violation of the IDEA); R.E., 694 F.3d at 194 (finding that an IEP was procedurally inadequate because, inter alia, it did not include “statutorily mandated speech and language therapy”); A.C. ex rel. M.C. v. Bd. of Educ. of The Chappaqua Cent. Sch. Dist., 553 F.3d 165, 172-73 (2d Cir.2009) (considering whether the DOE’s failure to conduct a functional behavior assessment constituted a procedural violation of the IDEA); R.E., 694 F.3d at 192-93 (finding that the “failure to include parent training in the IEP” constituted a procedural violation of the IDEA, but did not deny the student a FAPE). Although all of the violations alleged by Plaintiff can be classified as procedural, this Court has considered whether the deficiencies cited by Plaintiff demonstrate either procedural or substantive inadequacy under the IDEA. A. The CSE’s Consideration of Evaluative Materials Plaintiff argues that “[n]o evidence in the record establishes that the CSE reviewed any evaluations in developing [the December 2009, December 2010, and March 2011 IEPs].” (Pltf. Br. (Dkt. No. 16) at 5, 13, 18) The DOE responds, however, that “[t]he mere fact that the IEP did not record a report’s recommendations verbatim cannot be said to mean that the report was not considered,” and that “information contained within the reports provided to the CSE exists in the IEPs.” (Def. Br. (Dkt. No. 22) at 7) “In developing an IEP, a CSE is required to ‘review existing evaluation data on the child, including (i) evaluations and information provided by the parents of the child; (ii) current classroom-based, local, or state assessments, and classroom-based observations; and (iii) observations by-teachers and related service provid-ers" T.G. ex rel. R.P. v. New York City Dep’t of Educ., 973 F.Supp.2d 320, 340 (S.D.N.Y.2013) (quoting 20 U.S.C. § 1414(c)(1)(A)); see also id. (“The CSE must consider ‘the results of the initial evaluation or most recent evaluation of the child [in developing a student’s IEP].”) (quoting 20 U.S.C. § 1414(d)(3)(A)(iii)); E.A.M. v. New York City Dep’t of Educ., No. 11 Civ. 3730(LAP), 2012 WL 4571794, at *9 (S.D.N.Y. Sept. 29, 2012) (“New York state regulations also provide that the CSE ‘must consider the results of the initial or most recent evaluation’ in developing a student’s IEP.”) (quoting 8 NYCRR § 200.4(d)(2)). Here, the SRO found that “[t]here was ample evidence that evaluations had been conducted to identify the student’s special education needs from which the student’s IEP could be developed,” and that “the hearing record contains evaluative materials that, based on their date, existed at the. time of each of the CSE meetings.” (SRO Decision (Dkt. No. 13) at 11, 15) The SRO further concluded that all three IEPs were “prepared in a manner consistent with information included in the evaluative materials that had been conducted at the time” of the CSE meetings. (Id. at 15; see also id. at 26, 30) The SRO thus concluded that the IEPs sufficiently incorporated evaluative data so as not to deny K.T. a FAPE. (Id. at 15, 26, 30-31) While, as the SRO acknowledged, the record does not indicate what particular evaluative data the CSE considered at each of the IEP meetings at issue, see id. at 15, this Court agrees with the SRO that the absence of these details does not foreclose a finding that the DOE provided K.T. with a FAPE. See F.B., 923 F.Supp.2d at 581 (although the most recent evaluative report of the student “was not physically present at the CSE meeting ... the fact of the update’s absence at the meeting does not carry the day”; deferring to the SRO’s conclusion that the absence of the report was “of little moment, given [a doctor’s] testimony that she ‘must have’ reviewed the update, and, more important, given the substantial materials in the case supporting the CSE’s conclusion”). Accordingly, this Court will review the IEPs at issue to determine whether they demonstrate that the CSE considered sufficient evaluative material to satisfy the requirements of the IDEA. 1. December 2009 IEP The SRO listed a number of reports and evaluations concerning K.T. that were available to the CSE at the time of the December 2009 IEP meeting, including (1) an October 2008 psycho-educational report (Pltf. Ex. 28 (Dkt. No. 29)); (2) a September 2009 comprehensive psychosocial evaluation (Ptlf. Ex. 27 (Dkt. No. 29)); (3) a December 1, 2009 counseling report (Pltf. Ex. 26 (Dkt. No. 29)); and (4) a series of student progress reports (Pltf. Exs. 49, 51, 52 (Dkt. No. 29)). Plaintiff complains, however, that (1) “the information relied upon by the SRO to show that the December 2009 IEP was consistent with the existing evaluations is generic descriptive materials about the student”; and (2) that the December 2009 IEP lacks certain “important evaluative information” contained in the reports listed by the SRO. (Pltf. Br. (Dkt. No. 16) at 6-7) Having reviewed the December 2009 IEP and the evaluative reports cited by the SRO, this Court finds ample evidence that these reports are reflected in the IEP. The December 1, 2009 counseling report — which was prepared the day before the December 2, 2009 CSE meeting — recommends that “[wjeekly counseling sessions are counter-indicated, as they increase [K.T.’s] emotional discomfort and he receives limited benefit.” (Pltf. Ex. 26 (Dkt. No. 29) at 1) The December 2009 IEP reflects this recommendation, as it terminates KT.’s counseling services. (Pltf. Ex. 6 (Dkt. No. 29) at 2) The December 2009 IEP’s description of KT.’s social and emotional performance also tracks the findings of the October 2008 psycho-educational report; both documents state that KT.’s moods change frequently, that he is very restless, that he often becomes verbally and physically aggressive, and that he engages in self-abusive behavior. Compare Pltf. Ex. 6 (Dkt. No. 29) at 4 with Pltf. Ex. 28 (Dkt. No. 29) at 1. With respect to KT.’s academic performance, the December 2009 IEP reflects the October 2008 report’s conclusions that K.T. “can count and write numbers 1-10”; that he “has difficulty with basic arithmetic facts”; that he is “able to name colors”; that he can “follow some single verbal commands”; that he “struggles greatly to maintain attention and concentration in order to complete work;” and that he “is resistant to sitting for long periods of time.” Compare Pltf. Ex. 6 (Dkt. No. 29) at 3 with Pltf. Ex. 28 (Dkt. No. 29) at 3-4. The December 2009 IEP also reflects the October 2008 report’s findings that K.T. has autism, and that he takes medication to decrease hyperactivity and assist with sleep. Compare Pltf. Ex. 6 (Dkt. No. 29) at 3, 5 with Pltf. Ex. 28 (Dkt. No. 29) at 1. Plaintiff argues, however, that the December 2009 IEP does not incorporate important evaluative information from the October 2008 psycho-educational report. First, she contends that the December 2009 IEP does not contain information concerning KT.’s scores on a number of psychological tests, all of which were administered in 2006 and reported in the October 2008 report. (Pltf. Br. (Dkt. No. 16) at 7) While the December 2009 IEP does not include the specific scores, it does reflect the substantive results of the tests. For example, the October 2008 report states that these tests “revealed [that K.T.] was functioning in the Profoundly Deficient range in all areas,” and that “[significant support in self-care and daily supervision were recommended.” (Pltf. Ex. 28 (Dkt. No. 29) at 3) The December 2009 IEP notes that “[K.T.] must be observed consistently,” that his behavior “requires additional adult support,” and that teachers must consistently assess and observe him due to his “[sjeverity of deficits in cognitive, communication, and social development.” (Pltf. Ex. 6 (Dkt. No. 29) at 4, 12) The October 2008 report also states that the Stanford-Binet test revealed that K.T. “was able to name colors,” that his “[vocabulary skills were ... equivalent to age 3,” and that “[w]hen attentive, he was able to follow some single verbal commands.” (Pltf. Ex. 28 (Dkt. No. 29) at 3) As discussed above, these' findings correspond with the IEP’s descriptions of KT.’s academic performance. See Pltf. Ex. 6 (Dkt. No. 29) at 3. In sum, although the December 2009 IEP does not recite KT.’s specific scores on these tests, it does convey the substantive results of these tests. Plaintiff also argues that the December 2009 IEP does not incorporate the October 2008 report’s statement that K.T. “would benefit from á 1:1 paraprofessional.” (Pltf. Br. (Dkt. No. 16) at 7; Pltf. Ex. 28 (Dkt. No. 29) at 1) Although the 2009 IEP provides that K.T. will remain in a 6:1:1 classroom, it also indicates that K.T. “works best with one on one instruction[.]” (Pltf. Ex. 6 (Dkt. No. 29) at 3) Accordingly, the 2009 IEP reflects the finding in the October 2008 report that K.T. would benefit from one-on-one instruction. Plaintiffs last argument with respect to the October 2008 report is that KT.’s teacher provided the information about K.T.’s academic performance, and that “the teacher ... may have independently provided the information to the CSE.” (Pltf. Br. (Dkt. No. 16) at 6) The fact that K.T.’s teacher provided the same information to the author of the October 2008 report and to the CSE merely confirms, however, that the CSE relied on accurate evaluative data concerning KT.’s behavioral issues in formulating the December 2009 IEP. The December 2009 IEP also tracks information in the September 2009 psychosocial evaluation. The 2009 IEP reflects the psychosocial report’s description of K.T.’s psychiatric history and behavioral issues, including that he puts staples in his mouth, is autistic, has gastrointestinal problems, demonstrates self-abusive behaviors, and takes medication for his anxiety and sleeplessness. Compare Pltf. Ex. 6 (Dkt. No. 29) at 3-5 with Pltf. Ex. 27 (Dkt. No. 29) at 4-5. Plaintiff asserts, however, that the December 2009 IEP does not incorporate two pieces of information that are set forth in the September 2009 report: “that K.T. has difficulty in maintaining eye contacts, and has failed to develop peer relationships appropriate to developmental level.” (Pltf. Br. (Dkt. No. 16) at 7) Both of these issues are reflected in the 2009 IEP’s annual goals and short-term objectives, however. One of the annual goals the IEP sets for K.T. is that, within one year, he “will be able to initiate social conversation with peers, family members or other staff members in his environment.” (Pltf. Ex. 6 (Dkt. No. 29) at 11) Similarly, a short-term objective in the 2009 IEP states that “[i]n a year [K.T.] will give eye contact with familiar peers while transitioning from one place to the other four out of five times over a three week period.”; (Id.) These goals reflect the CSE’s consideration of information contained in the September 2009 psychosocial report. Plaintiff contends, however, that the September 2009 report “notes that K.T. requires assistance in' ‘cleaning himself after using the toilet[,]’ an important management need that is not recorded in the December 2009 IEP.” (Pltf. Br. (Dkt. No. 16) at 7 (quoting Pltf. Ex. 27 (Dkt. No. 29) at 3))) Plaintiff adds that she testified at the impartial hearing that K.T. was not independent with his toileting, but that the DOE’s occupational therapist “was not even aware that K.T. has difficulties in toileting.” (Id. (citing Tr. 680 (L.O. testimony); Tr. 457 (McPherson testimony)) The failure of the December 2009 IEP to include a reference to K.T.’s toileting issues did not deny K.T. a FAPE, however. The IEP provides an annual goal for K.T. that reflects his need to improve his daily living skills: “Within a year, [K.T.] will improve fine motor skills necessary for performing [activities of daily living] and [s]chool activities as evidenced by demonstrating his ability to tie his shoe laces [..., and he will] develop a mature grasp pattern....” (Pltf. Ex. 6 (Dkt. No. 29) at 10) Although the IEP does not mention toileting as an area that requires improvement, the IEP as a whole reflects the evaluative information available to the CSE at the time of the December 2009 meeting. See F.B., 923 F.Supp.2d at 582 (“[The IDEA] does not require that the [CSE] team review every single item of data available, nor has case law interpreted it to mean such.”). This Court concludes that the December 2009 IEP was based on sufficient evaluative data. Although the CSE did not list each report and evaluation it relied on in formulating KT.’s December 2009 IEP, there is ample evidence that the 2009 IEP reflects the available evaluations and reports. Accordingly, this Court will not disturb the SRO’s finding with respect to the sufficiency of the evaluative data relied on by the CSE in formulating K.T.’s December 2009 IEP. 2. December 2010 IEP The SRO likewise listed a number of reports that were available to the CSE at the time it prepared the December 2010 IEP, and explained how that IEP is consistent with the information in those reports. (SRO Decision (Dkt. No. 13) at 21-26) These reports include: (1) results from a comprehensive psychological evaluation that was performed in January and April 2010 (Pltf. Ex. No. 25 (Dkt. No. 29)); (2) a June 18, 2010 physical therapy progress report (Pltf. Ex. 50 (Dkt. No. 29)); (3) an August 13, 2010 report card (Pltf. Ex. 47 (Dkt. No. 29)); (4) a September 17, 2010 strengths-based profile (Pltf. Ex. 46 (Dkt. No. 46)); (5) a September 21, 2010 Bri-gance diagnostic inventory (Pltf. Ex. 21 (Dkt. No. 29)); (6) an October 8, 2010 student communication profile (Pltf. Ex. 24 (Dkt. No. 29)); (7) a November 2010 report card (Pltf. Ex. 45 (Dkt. No. 29)); (8) an instructional priority data collection sheet from November and December 2010 (Pltf. Ex. 43 (Dkt. No. 29)); (9) minutes from a December 3, 2010 trans-disciplinary meeting concerning K.T. (Pltf. Ex. 16 (Dkt. No. 29)); and (10) a New York State Alternative Assessment report (Pltf. Ex. 48 (Dkt. No. 29)). These reports indicate that K.T. continued to exhibit the same behavior and conditions documented in the previous year’s IEP and evaluations. The reports state that K.T. suffers from autism, moderate mental retardation, and self-abusive behaviors (Pltf. Ex. 25 (Dkt. No. 29) at 1-2, 5; Pltf. Ex. 46 (Dkt. No. 29)); that he has difficulty concentrating and maintaining eye contact (Pltf. Ex. 25 (Dkt. No. 29) at 2); that he can usually follow one-step commands (id. at 2, 4); and that he lacks coordination and muscle strength (Pltf. Ex. 50 (Dkt. No. 29) at 1-2). The reports also describe KT.’s then-current language skills, indicating ‘that he responds to gestures but requires high-level prompts, and that he understands objects, manual signs, and spoken sentences. (Pltf. Ex. 24 (Dkt. No. 29) at 1) With respect to KT.’s expressive language skills, the reports indicate that K.T. is aggressive and bangs on the table, but can “purposefully communicate[ ] with others” using spoken words or symbols. (Id. at 1-2)'The record also includes a report card — which is signed by both K.T.’s mother and his teacher — that assesses KT.’s performance with respect to the goals included in the December 2009 IEP. (Pltf. Ex. 45 (Dkt. No. 29) at 1-10) The report card indicates that K.T. made progress on all of his goals between January and August 2010, but that he made little to no progress during November 2010. (Id.) An “instructional priority data collection sheet” indicates, however, that K.T. made some progress during November and December 2010 towards reaching certain goals relating to his language, math, social studies, communication, and gross motor skills. (Pltf. Ex. 48 (Dkt. No. 29) at 1-2) The record also reflects a December 3, 2010 meeting of KT.’s teacher, physical therapist, and occupational therapists at which KT.’s goals for the new year were discussed. (Pltf. Ex. 16 (Dkt. No. 29); Tr. 178-79) The meeting minutes indicate that KT.’s previous goals were aimed at increasing his communication and socialization skills. The meeting attendees agreed that the upcoming IEP should focus on vocational goals and “work task activities.” (Pltf. Ex. 16 (Dkt. No. 29) at 1) The minutes also state that there is no need for a change in KT.’s overall program. (Id.) The December 2010 IEP reflects the information contained in these materials. For example, the December 2010 IEP states that K.T. “communicates using short sentences and phrases”; that he “can follow 1 and 2 step directions, however he requires close supervision to redirect his attention and remain focused”; that he “sometimes displays anger and/or negative behavior and may become verbally abusive and/or self-abusive”; and that he often “bang[s] [his] fists on tables.” (Pltf. Ex. 5 (Dkt. No. 29) at 3-5, 14) The December 2010 IEP also contains goals that reflect the concerns described in the reports. Several of the goals are directed towards improving KT.’s social and communication skills, including: “When shown a picture of a classmate, during a group activity, [K.T.] will go over to that student and greet them by shaking their hand, with prompting and verbal cues.... ” (Id. at 6) The goals also focus on K.T.’s fíne motor skills; for example, the IEP provides that K.T. will be able to “use the keyboard on a computer to type his name with minimal assistance” within one year, and that he “will be able to tie his shoes performing the last two steps ... with 2-3 verbal cues and gesture cues.... ” (Id. at 8) The December 2010 IEP also challenges K.T. to “develop his overall aerobic fitness level,” and to “comply and cooperate in [occupational therapy] activities with [the] use of self-calming and relaxation techniques.” (Id. at 8-9) Finally, the “transition plan” included in the 2010 IEP focuses on vocational goals, including that K.T. “will learn community signs for use in the community with adult supports”; that he “will participate in functional skills activities such as setting the table, [and] washing/drying dishes”; and that he “will learn various work task activities such as sorting and matching.” (Id. at 13) Plaintiff argues, however, that “the information cited by the SRO is generally generic information about the student that could have simply been carried over from the prior IEP,” and that accordingly the SRO erred in finding that the December 2010 IEP was based on sufficient evaluative information. (Pltf. Br. (Dkt. No. 16) at 13-14) Plaintiff notes, for example, that the “IEP lacks any reference to the scores on the Stanford-Binet and the Vineland Adaptive Behavior Scales set forth in the 2010 psychoeducational evaluation, and makes no reference to [KT.’s] diagnosis of obsessive-compulsive disorder.” (Id. at 14) The results from the Stanford-Binet test — which measures cognitive functioning — indicate, in part, that K.T. has difficulty “identifying absurd or missing details in pictorial material”; “solving simple addition and subtraction problems”; and “using his short-term memory to immediately recall ... short sentences with few errors.” (Pltf. Ex. 25 (Dkt. No. 29) at 3) The results from the Vineland Adaptive test— which measures adaptive behavior functioning — indicate, in part, that K.T. “sometimes has difficulty following two-step directions”; that he “can ... identify some letters from the alphabet”; that he “can dress himself[, but] he requires assistance when brushing his teeth, washing his face and showering”; that he “will clear his own place from the table, but he does not wash dishes”; that he “does not show interest in others his age and does not demonstrate friendship seeking behaviors”; and that he “does not respond appropriately to reasonable changes in routine.” (Id. at 3-4) Although the December 2010 IEP does not list KT.’s scores on the Stanford-Binet or Vineland Adaptive tests, the IEP reflects the substantive results of those tests. The December 2010 IEP states, for example, that K.T. “communicates using short sentences and phrases to express his wants and needs”; “can identify colors, shapes, and numbers up to 10”; “can follow 1 and 2 step directions, however he requires close supervision to redirect his attention and remain focused”; can improve his cognitive deficiencies by “sort[ing] pictures of food and clothing in the proper category”; can “follow a daily picture schedule with verbal prompting”; requires “instruction/reinforcement of social skills and modeling of social skills”; and “displays anger and/or negative behavior and may become verbally abusive and/or self-abusive when he becomes frustrated, irritated or when he is ‘caught’ doing something.” (Pltf. Ex. 5 (Dkt. No. 29) at 3-4, 6) Although the December 2010 IEP does not incorporate every piece of information from the evaluative reports— including' KT.’s diagnosis of obsessive compulsive disorder — it does reference much of the information in those reports. Plaintiff next argues that the December 2010 IEP “simply carries over all the services recommended by [the December 2009 IEP],” which “was not reasonably calculated to allow K.T. to actually achieve any of his IEP goals.” (Pltf. Br. (Dkt. No. 16) at 14 (emphasis in original) (pointing out that the progress reports in the record indicate that K.T. had not achieved any of his goals by December 2010)) Although the December 2010 IEP does not modify KT.’s overall program — and adopts several of the goals set forth in the December 2009 IEP — it makes a number of changes that reflect the DOE’s commitment to improving KT.’s vocational skills for 2011. The December 2010 IEP does not repeat the 2009 IEP’s goals relating to KT.’s math, reading, and handwriting skills, but instead sets goals that address functional activities that will prepare K.T. for life after graduation, such as “set[ting] the table in preparation for a snack,” “us[ing] the keyboard on a computer to type his name,” tying his shoes, and “developing] his overall aerobic fitness level.” (Pltf. Ex. 5 (Dkt. No. 29) at 6-8) This transition to functional goals is consistent with the testimony of K.T.’s teacher, who stated that many students “reach a plateau” in their academic skills, and that although the teachers “continue to work with them as much as possible academically,” they also “do many functional activities to prepare them for independence when they eventually graduate and leave the program.” (Tr. 109) In sum, although the overall program recommended in the December 2010 IEP is similar to the program in the December 2009 IEP, the December 2010 IEP includes a number of significant changes that reflect KT.’s evolving needs. Moreover, the fact that K.T. did not meet all of the goals outlined in the December 2009 IEP does not demonstrate that the 2009 IEP was inappropriate. The student progress reports in the record indicate that K.T. had achieved a number of goals and was making significant progress towards achieving others, despite his slight regression in December 2010. See Pltf. Ex. 45 (Dkt. No. 29). KT.’s overall progress in 2010 indicates the appropriateness of the goals reflected in the December 2009 IEP, and the CSE appears to have taken these results into account in developing the December 2010 IEP. As discussed above, the December 2010 IEP sets new goals that focus more on functional activities than on academic improvement. Finally, Plaintiff argues that the December 2010 IEP is deficient because it does not document K.T.’s then-current functional academic level, and because the hearing record does not indicate whether a vocational assessment of K.T. was completed prior to the development of the 2010 IEP. (Pltf. Br. (Dkt. No. 29) at 14) These deficiencies did not deny K.T. a FAPE, however. While the IEP does not list K.T.’s functional academic level, it notes that he “is currently following an alternate assessment curriculum,” and describes the tasks he can perform, including that he “can identify colors, shapes and numbers up to 10”; “can follow 1 and 2 step directions”; “can complete many work task activities throughout the day”; “can recognize many pictures and symbols”; and “has the ability to complete a color, cut and paste activity independently.” (Pltf. Ex. 5 (Dkt. No. 29) at 3) With respect to the absence of a vocational assessment, it appears that the DOE performed such an assessment during the 2009-10 period. (Tr. 690 (Plaintiff’s testimony indicating that she “vaguely remember[s] filling out a form ... that was sent home [regarding a vocational assessment] at least once, maybe twice” between 2009 and 2010)) More importantly, the December 2010 IEP’s focus on the need to improve K.T.’s functional abilities — and its description of his current abilities — indicates that the CSE took his vocational skills into account in preparing the IEP. Several of the reports in the record — including the Vine-land Adaptive test results and the student strengths-based profile, see Pltf. Exs. 25, 46 (Dkt. No. 29) — provide sufficient information about K.T.’s functional skills for the CSE to set appropriate vocational goals. Accordingly, this Court concludes that the record supports the SRO’s finding that the “statement of [KT.’s] special education needs in the December 2010 IEP was consistent overall with information that was reflected in evaluative materials that had been completed at the time of the December 2010 CSE meeting.” (SRO Decision (Dkt. No. 13) at 26) 3. March 2011 IEP With respect to the March 7, 2011 IEP, K.T.’s teacher testified that the school psychologist “gave [K.T.] a battery of tests and those [tests] were discussed at the [March 2011 CSE meeting].” (Tr. 136-37) Although only two of those tests are included in the record — a March 1, 2011 teacher evaluation (Pltf. Ex. 23 (Dkt. No. 29) and a March 7, 2011 Vineland-II Adaptive Behavior Scales survey interview report (Pltf. Ex. 22 (Dkt. No. 29) — other documents reflecting KT.’s progress towards the goals listed in the December 2010 IEP are part of the record. For example, a February 2011 progress report indicates that KT. had made “little progress” towards meeting the December 2010 IEP’s annual goals. (Pltf. Ex. 38 (Dkt. No. 29) at 3-4) This report explains that K.T. needs more time to meet these goals, and that his teacher anticipates that he will achieve these goals. (Id.) Another progress report indicates that — with respect to K.T.’s language, math, social studies, science, community development, gross motor, and fine motor skills — K.T. has “made progress” but has not yet met his goals as of February 2011. (Pltf. Ex. 43 (Dkt. No. 29) at 3-5) The March 1, 2011 teacher evaluation describes K.T.’s (1) language and communication skills; (2) general strengths, weaknesses, and needs; and (3) daily living skills. (Pltf. Ex. 23 (Dkt. No. 29) at 1) The teacher reports that K.T. “communicates using short sentences and phrases to express exactly what he wants”; “can follow 2 step directions with minimal prompting”; “can recognize and match many pictures and symbols”; and “can identify color, shapes, and numbers up to 10.” {Id.) With respect to KT.’s weaknesses and needs, the report indicates that he “requires close supervision to redirect his attention and remain focused on his tasks,” and that he “benefits most when lessons are presented using visual cues and verbal prompting when addressing his academic needs and daily needs.” {Id.) With respect to his daily living skills, the report states that K.T. “is independent in [performing] all [daily living] skills,” including eating, drinking, using the bathroom, and washing his hands. {Id.) The March 7, 2011 survey interview report describes the results of K.T.’s Vine-land-II Adaptive Behavior Scales test, which measures “an individual’s typical performance of the day-to-day activities required for personal and social sufficiency.” (Pltf. Ex. 22 (Dkt. No. 29) at 3) The report indicates that KT.’s adaptive level is in the low range of functioning — i.e., his percentile rank is less than one — for all domains assessed, including communication, daily living skills, and socialization. {Id. at 2) The survey did not test K.T.’s gross or fine motor skills. {Id.) The progress reports, teacher evaluation, and Vineland-II survey interview report all indicate — not surprisingly — that KT.’s skills and needs did not change substantially between the preparation of the December 10, 2010 IEP and the March 7, 2011 CSE meeting. Moreover, the March 2011 IEP tracks the information set forth in these reports and evaluations. The March 2011 IEP notes that K.T. “can iden-ti[f]y colors, shapes and numbers up to 10”; that he “can follow 1 and 2 step directions”; that he “benefits from a small and highly structured class setting” and from the use of “prompts and [cues] to alert his attention]”; and that he has “severe cognitive and social deficits.” (Pltf. Ex. 3 (Dkt. No. 29) at 3, 10) The March 2011 IEP provides that K.T. will continue to receive speech, physical, and occupational therapy with the same frequency and duration set forth in the December 2010 IEP, and the March 2011 IEP carries over many of the same goals listed in the December 2010 IEP. Compare id. at 6-7, 10 with Pltf. Ex. 5 (Dkt. No. 29) at 6-9, 12. Plaintiff points out, however, that KT.’s teacher “testified that she could recall no evaluative material being reviewed at the March 7, 2011 IEP meeting.” (Pltf. Br. (Dkt. No. 16) at 18) At the impartial hearing, K.T.’s teacher — Myrna Quinones — testified that she could not recall discussing K.T.’s expressive skills, adaptive functioning, daily living skills, or socialization skills at the March 2011 CSE meeting. (Tr. 139-40) Quinones also testified, however, that the school psychologist “gave [K.T.] a battery of tests and those [test results] were discussed at the meeting.” (Tr. 137) Accordingly, although Quinones does not recall discussing particular skills of K.T. at the CSE meeting, she does recall discussing evaluative materials that addressed his skills. Plaintiff also contends that the March 1, 2011 teacher evaluation is “false,” because it indicates that K.T. is independent in all activities of daily living, including toileting and hand-washing, while testimony at the impartial hearing demonstrates that K.T. is not independent in toileting. (Pltf. Br. (Dkt. No. 16) at 18) Although Plaintiff testified that K.T. was not independent in toileting as of the March 6, 2012 hearing (Tr. 680), other documents in the record corroborate the March 1, 2011 teacher evaluation’s assessment of K.T. as being independent in his daily living skills between late 2010 and late 2011. For example, a September 2010 student strengths-based profile indicates that K.T. is independent in all activities of daily living, including toileting (Pltf. Ex. 46); and a December 2011 annual review plan states that K.T. “is independent with most [daily living] skills,” but that he has “some difficulty with shoe tying” (Pltf. Ex. 36 (Dkt. No. 29) at 1). Moreover, the hearing record suggests that K.T. was “regressing”— both with respect to his speech abilities and his overall behavi