Office for Civil Rights Requires Williamson County Schools (TN) to Train Staff After FAPE Concerns for Student with Multiple Complex Medical Conditions
OCR identifies concerns district wouldn't serve student at school—even w/his private duty nurse—because student’s physician would provide written, not real-time oral, clarification of medical orders
April 16, 2026, U.S. Department of Education’s Office for Civil Rights (OCR) issued a letter of findings to Williamson County Schools (WCS) in Tennessee, after investigating a complaint filed by a parent on behalf of a student who has “multiple complex medical conditions.”
OCR investigated the following legal issue:
“Whether the District discriminated against the Student on the basis of disability, in violation of Section 504 and Title II.”
The parent alleged that in April 2025, the district “discontinued the Student’s services in the school setting due to his disabilities.” More specifically, the parent alleged the following:
“[T]he District required the Student’s physician to provide real time, oral responses to its questions about the Student’s disabilities and, because the physician will only provide written responses to the District’s questions, the Student’s individualized education program (IEP) team determined it will no longer serve the Student at his school.”
Before OCR issued findings, WCS expressed interest in resolving the complaint. April 14, 2026, WCS entered into a resolution agreement with OCR after OCR determined its investigation had identified concerns that could be addressed through a resolution agreement.
What Happened
During the 2023–2024 and 2024–2025 school years, the student attended a WCS school “until his IEP team placed him on homebound services April 21, 2025.”
OCR’s letter says the student’s primary care physician wrote a March 11, 2024, letter explaining that she manages a team of specialists for the student’s “multiple complex medical conditions.” The physician wrote that the student required “highly skilled, one-on-one nursing care by an RN” and that only “a one-on-one registered nurse” supervising the student “on a moment-to-moment basis” would allow him to safely access the education he was entitled to receive.
The student also had health care plans. OCR said the student had a Private Duty/Contract Nurse Individual Health Plan, signed by the school nurse April 29, 2024, stating that “only a private duty nurse would provide medical services” to the student at school.
The student’s January 16, 2025, IEP included services such as:
“adaptive art tools to increase engagement and independence in the academic setting”;
“adaptive seating throughout the classroom”;
“30 minutes of language therapy twice per week”; and
“20 minutes of occupational therapy twice per week.”
The IEP meeting minutes also showed that the parent raised the nursing issue directly. The parent told the team that because the school was not providing nursing, the student was only attending three days per week. The parent also stated that physicians had determined the student needed one-to-one medical supervision to attend school.
A district staff member responded that the student could still come to school, but that attending only three days was the parent’s choice. The parent responded that doctors wanted “RN eyes on him 24/7” and that the school was refusing to provide that nursing support.
Then, in February 2025, the parent sent district staff 49 “District Physician and Medication Authorization” forms completed by the student’s physician. These forms represented the procedures and medications the student needed on a daily basis.
