Historically, America's public schools largely have failed to provide disabled children with many educational opportunities. Up until the mid-twentieth century, state courts and legislatures determined the extent to which children with disabilities received an education. However, in 1965 the educational needs of over eight million children with disabilities coupled with the lack of appropriate resources needed to alleviate such needs spurred Congress to take action.
Students with complex health care needs, the schools they attend, their parents, nurses, and teachers have been uncertain as to which “related services” schools are required to provide and what constitutes a “medical service” exclusion. After the Supreme Court's decision in Cedar Rapids v. Garret F., school districts and public education at large struggle to deliver the promises of IDEA while containing the concommitant costs.
Cunningham M, 'Playing Doctor: Discerning What Medical Services School Districts Must Provide to Disabled Children under Cedar Rapids Community School District v. Garret F.' 52(1) Baylor L Rev 171 (2000).