On March 22, a Supreme Court ruling emphasized that schools that provide a free appropriate public education (FAPE) to students who have a disability now need to view "appropriate" more critically. What does Endrew F. v. Douglas County School District mean for special educators across the country?

The ruling stated that students must receive more than minimal benefit from their individualized education program (IEP). The plan must be ambitious, and teachers must plan for instruction that is rigorous. Schools and teachers must have high expectations, with the goal of providing the students with disabilities the opportunities provided to children without disabilities.

This is a good ruling. This will cause better instruction and better outcomes for our students. But this may cause growing pains for some teachers and schools.

While the ruling pointed to public schools as a whole, and did not point at special educators specifically, the special educators are often the case managers who plan the majority of the students' specialized education. Special educators are also part of an educational team that includes the student, parents, administrators, general educators and other professionals such as psychologists, social workers, speech pathologists, occupational and physical therapists.

Few IEPs are planned by one individual. The decisions for one IEP involve data collection, use of research-based curriculum and instructional methods; a team looking for progress and growth in the student from what has been presented in instruction and related services.

The IEP goals can, at any time, be adjusted if the decisions made by the team need to change — especially if they are no longer appropriate for the unique needs of the student or are not rigorous enough.

What does "appropriate" mean in FAPE? Who decides what is appropriate? How does a special educator determine if the plan is rigorous enough for the student?

The student receiving specialized education needs, as much as possible, to receive the same opportunity to learn the same information as a student who does not receive specialized education. Appropriate planning includes goals, objectives, accommodations, modifications and placement of services.

If a student is enrolled in a school that uses the Common Core State Standards, these are used to determine appropriate reading and math skills for each grade and should be used to formulate IEP goals and instructional plans. Schools use other standards as well, which should be used as the measure for what is considered appropriate.

The student's ability to reach these standards must be determined by assessment, observation, use of guided instruction and other explicit instruction. Each student has different abilities, and the best way to reach the standards must be considered by the special educator and modified as needed.

What is appropriate can also change multiple times with each new teaching and learning experience. The responsibility for determining what is appropriate is primarily that of the special educator, with input at any time from members of the special education team.

So what should special educators do to be sure they are choosing what is appropriate for their students? Seek more. Keep learning. Assess our craft and see what is lacking. Find ways to learn what is needed to improve instruction. Find mentors to teach what we don't know.

We must also ask questions of ourselves. Are we challenging our students? How much growth are they exhibiting? Are we providing the most appropriate program for each of our students?

Be vulnerable and be willing to change. This is what we ask of our students. We need to model that we are willing to do the same.