Why IEP Accommodations Fail: The Working Memory

A student has extended time, preferential seating, and reduced assignments on their IEP. Six months later, they are still failing. The accommodations are being implemented. The problem is not fidelity. The problem is match.

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This distinction matters because the entire compliance infrastructure around IEP implementation focuses on fidelity: was the accommodation offered? Was it documented? Was it used? Almost no attention goes to the prior question: does this accommodation address the actual cognitive reason the student is struggling? When it does not, you can implement with perfect fidelity for a full school year and produce no change in outcomes.

The cognitive science behind this is not complicated, but it is rarely taught in special education preparation programmes or shared at IEP meetings. This article explains the mechanism, gives you a diagnostic framework, and shows you how to use assessment data you already have to select accommodations that are more likely to work.

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The Accommodation Mismatch Problem

IEP accommodation lists often come from disability reviews and standard options. Teams pick reasonable supports based on law, instinct, and past practice. They do not systematically analyse impaired cognitive processes, or which accommodations would help (Bettinger & Loeb, 2017).

Harrison et al. (2013) found teachers often pick accommodations by disability, not assessment. This means dyslexia learners get read-aloud and ADHD learners get extra time. These choices might not suit each learner's specific needs, though.

Fuchs et al. (2000) showed accommodations help learners differently. Cognitive skills matter more than disability labels. Text-to-speech helps a learner with phonological issues. Repeated reading practice assists another learner with reading fluency. Read-aloud only helps one of them.

IEP teams are often time-limited, and assessment data may not be interpreted at the level of the cognitive process that is blocking curriculum access. Harrison et al. (2013) note that the evidence base for many commonly recommended accommodations is limited, while Kennedy and Romig (2024) show how cognitive load theory can help special and general educators connect learning barriers to instructional design. Knowing how working memory impacts each learner is key (Alloway & Alloway, 2009; Gathercole & Alloway, 2008).

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How Working Memory Affects Everything

Working memory is the cognitive system that holds and manipulates information during active thinking. It is not the same as short-term memory, which is purely passive storage. Working memory is where you keep a sentence in mind while you figure out its meaning, where you hold the first three steps of a problem while executing the fourth, and where you track what you have already written while deciding what to write next.

Baddeley (2000) updated his working memory model, outlining four parts. The central executive controls attention and coordinates other areas. The phonological loop holds spoken and heard information (inner voice). The visuospatial sketchpad holds visual and spatial data. The episodic buffer combines information from sub-systems and long-term memory (Baddeley, 2000).

Cowan (2001) found adults hold four information chunks in working memory. This is under ideal circumstances. Children with learning difficulties may only hold two or three. A learner holding two chunks struggles with tasks needing more, like following multi-step instructions. Learners might also struggle with reading (Cowan, 2001). Writing tasks can also be difficult (Cowan, 2001).

Gathercole and Alloway (2008) showed learners with working memory problems struggled in primary school. Teachers commonly mistook their difficulties for lack of focus or drive. Learners themselves often did not know why (Gathercole & Alloway, 2008). This misunderstanding could cause unsuitable support. Inattentive learners might need simpler tasks, not behaviour plans.

Working memory affects writing and maths skills, plus reading and listening (Alloway, 2009). Learners find complex instructions hard to follow well. Retrieval effort hurts test scores (Cowan, 2010). Teachers can use this knowledge to support learners (Gathercole & Alloway, 2008).

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Extended Time: When It Helps and When It Does Not

Extended time is the most frequently listed accommodation in the United States. It is on nearly every IEP and 504 plan. It is also the accommodation most often applied without any analysis of whether it addresses the student's actual cognitive bottleneck.

Extended time helps when the bottleneck is processing speed. A student who understands the material but takes longer to decode text, generate written responses, or complete calculations benefits from more time because the constraint is temporal. Given enough time, they can demonstrate what they know.

Extended time does not automatically solve a working-memory barrier. Lewandowski, Lovett, Parolin, Gordon and Codding (2007) examined extended time on a speeded mathematics task and did not find a differential extended-time boost for students with ADHD compared with non-disabled peers. Fuchs et al. (2000) also showed why teams need objective accommodation data rather than relying only on judgement. The practical point is narrower and safer: if the main barrier is cognitive load or working-memory capacity, extra time should usually be paired with supports that externalise, chunk or simplify the information the student must hold at once.

This is a finding that most IEP teams have not systematically absorbed. When a student with extended time continues to fail, the typical response is to question fidelity: was the time actually offered? Did the student use it? A more productive question is: is this student's primary cognitive challenge a processing speed problem or a working-memory capacity problem? If it is the latter, adding time alone is likely to be mismatched unless the plan also reduces the amount of information the student must hold and manipulate.

What does help for working memory deficits? Reducing the number of items the student must hold in working memory at once. This means visual scaffolds that externalise information the student would otherwise have to track internally, chunked instructions delivered one step at a time, graphic organisers that hold partial information so the student does not have to, and worked examples that reduce the problem-solving load while the student is building procedural knowledge.

Extended time combined with these supports can be effective. Extended time alone, for a student whose bottleneck is capacity, is an accommodation that produces the appearance of support without changing the cognitive conditions that drive failure.

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Matching Accommodations to Cognitive Bottlenecks

IEP teams can solve accommodation mismatch. First, pinpoint each learner's cognitive bottleneck. Then, choose support that lessens pressure on that area. This method means using assessment data in new ways (Rose & Gravel, 2012).

Cognitive bottlenecks and common accommodations are linked in the table. It shows accommodations directly addressing the core learner challenge (Rose & Gravel, 2009).

The pattern across the table is consistent: common accommodations tend to address surface performance rather than the underlying process. They reduce the visible manifestation of the deficit without changing the cognitive conditions that produce it. The matched accommodations work because they reduce demand on the specific system that is failing, rather than simply giving the student more time or less work while the same system continues to be overwhelmed.

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Five Common Mismatches in Practice

Abstract principles become clearer through specific classroom examples. The five mismatches below appear regularly in IEP documentation across the country. Each one makes intuitive sense, which is why they persist. Each one also fails to address the actual cognitive bottleneck.

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Preferential Seating for Auditory Processing Disorder

A Year 4 student with an auditory processing disorder is seated at the front of the classroom, close to the teacher. The IEP team reasoned that proximity would improve the student's ability to hear instructions clearly.

Note: auditory processing disorder (APD) is a contested diagnostic category. The British Society of Audiology (2018) recognises it clinically, but researchers including Kamhi and Wallach (2012) argue its distinction from developmental language disorder and attention difficulties is unclear in children. Where APD appears on an EHCP, the analysis below still applies, because the working-memory bottleneck operates independently of the diagnostic label.

Auditory processing disorder is not a hearing problem. The student's ears receive the sound normally. The deficit is in the brain's ability to discriminate, sequence, and make meaning from the auditory signal. Moving a student closer to a speaker does not change how the auditory cortex processes the signal it receives.

Written instructions alongside spoken ones assist learners. Pre-teaching key vocabulary gives learners a processing scaffold. A sound-field system improves how well learners hear. Waiting after instructions allows learners to understand (Goodwin, 2016; Marzano, 2004; Hattie, 2009). Being near learners alone does not fix processing problems.

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Reduced Homework for a Student Who Cannot Read

Researchers have found that accommodations help learners. A Year 3 learner with reading difficulties gets less homework. The team thought fewer tasks would lower stress (Finn & Rotherham, 2005). This might encourage the learner to finish more work (Allington, 2014).

Homework quantity is not the problem. The student cannot access text-based homework regardless of how much of it there is. If the homework requires reading and the student decodes at a pre-primer level, three pages and one page are equally inaccessible.

What does help: homework in a format the student can access, whether that is audio, visual, or supported by a family member reading aloud, and direct reading instruction during the school day that builds the skill that makes homework accessible. Reducing quantity while leaving the access problem unsolved produces a student who completes less work but still cannot read.

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A Calculator for a Student Without Number Sense

A Year 5 student with dyscalculia is provided with a calculator for all mathematics tasks. The team reasoned that the calculation tool would remove the arithmetic barrier and allow the student to demonstrate understanding.

For a student whose deficit is in procedural calculation, a calculator can work well. But dyscalculia often involves a deeper difficulty: the intuitive understanding of quantity, magnitude, and the relationships between numbers. A student who does not know whether 37 is closer to 30 or 40, who cannot estimate whether an answer is reasonable, and who does not understand what multiplication represents will not become a mathematician by pressing the right buttons. The calculator outputs a number; it does not build the number sense required to use that number meaningfully.

Learners grasp quantity using concrete manipulatives. Number lines develop awareness of magnitude. Number sense teaching addresses concept gaps. Calculators improve fluency after learners understand (Geary, 1994; Griffin, 2003; Siegler, 2009).

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A Separate Testing Room for Test Anxiety

A Year 7 student with test anxiety receives testing in a separate, quiet room. The team reasoned that removing the student from the social pressure of the main classroom would reduce anxiety and improve performance.

A quiet room removes one anxiety stimulus. But test anxiety is not caused by the presence of other students; it is a generalised threat response to evaluation situations. Moving the student to an empty room does not change the student's relationship to the evaluation itself. For many students with test anxiety, the separate room adds a layer of stigma and heightened awareness of their difficulties without providing any cognitive or regulatory support.

Breathing techniques and cognitive reframing help learners manage anxiety before and during exams. Teach these strategies explicitly. Gradual exposure to supported evaluation situations is better than avoiding them. A counsellor-led programme reducing threat response is a real intervention. A separate room, as suggested by researchers (West et al., 2013), only bypasses the anxiety.

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Read-Aloud for a Student with Comprehension Deficits

A Year 6 student with reading comprehension difficulties receives read-aloud for all content-area tests. The team reasoned that removing the decoding burden would allow the student to demonstrate content knowledge.

This accommodation is correct for one type of comprehension difficulty: the student who decodes poorly but comprehends well when listening. But for a student whose comprehension deficit is a genuine language comprehension problem, rather than a decoding problem, hearing the text does not help. The student struggles to build a mental model of what text means, whether they encounter it visually or aurally. The words come in; the meaning does not cohere.

Choose the right help by spotting decoding or understanding problems. Gough and Tunmer's (1986) Simple View says reading is decoding times language skills. Learners struggling in one area need different support than those struggling in both. Reading help should fix the specific problem, not just overall performance.

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A Better Framework: Diagnose, Match, Monitor

A three-step process offers an alternative to accommodation lists. It begins with assessment data and concludes with monitoring measurable learner outcomes. (Marzano, 2003; Hattie, 2012)

Find the learner's main cognitive challenge using assessment data before the IEP. Check the psychoeducational report for working memory and processing speed. WISC-V gives Working Memory Index and Processing Speed Index scores. CTOPP-2 gives phonological profiles. BRIEF-2 gives executive function profiles (Gioia et al., 2015) in key areas. What exact cognitive process is most hindering this learner's curriculum access?

Choose accommodations that lessen the bottleneck load. Use the table as a starting point. Ask: which thinking skill does each accommodation help? If you cannot answer, it may not be right. You do not need to make a new diagnosis to ask this question, but the team should use existing assessment data, structured observation and specialist input when the profile is unclear.

Step 3: Monitor whether the accommodation changes outcomes, not just whether it is being used. Accommodation monitoring typically focuses on implementation: was the extended time offered? Did the student use the separate room? The question that matters for students is different: is the student's performance on the targeted task improving? If a student has had a working memory scaffold for two months and their performance on multi-step tasks has not changed, the scaffold is either mismatched, insufficiently intensive, or being applied inconsistently. Progress monitoring with curriculum-based measurement gives you the data to answer this question with precision rather than impression.

The cycle then repeats. New data informs revised accommodation decisions. This is closer to what the MTSS and RTI framework describes in theory: assess, intervene, monitor, adjust. In practice, IEP accommodation monitoring rarely reaches this standard.

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What the Assessment Data Tells You

Most psychoeducational assessments include more information about cognitive processes than most IEP teams use. Here is how to read the scores that are most relevant to accommodation design.

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The WISC-V Working Memory Index

The Working Memory Index (WMI) comprises two subtests: Digit Span and Picture Span. Digit Span asks the student to repeat sequences of numbers forwards, backwards, and in ascending order. Picture Span asks the student to remember pictures in sequence. A standard score below 85 on the WMI indicates a clinically significant working memory limitation.

Look beyond the composite score at the subtest profile. A student who scores significantly lower on Digit Span than Picture Span has a relative weakness in the phonological loop compared to the visuospatial sketchpad. This score pattern tells you to prioritise visual and spatial accommodations over verbal ones. Written instructions are more supportive than verbal instructions for this student. Diagrams and graphic organisers carry more load than oral explanations.

Learners scoring low on both subtests likely have working memory issues. Multi-step tasks become difficult, straining capacity (Alloway, 2009). Support should focus on getting information out of their heads using all senses (Rose & Meyer, 2002).

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The WISC-V Processing Speed Index

The Processing Speed Index (PSI) comprises Coding and Symbol Search. These subtests measure the speed and accuracy of simple visual-motor tasks under timed conditions. A score below 85 on the PSI indicates a processing speed deficit.

Here is the critical clinical distinction: a student with a low WMI but average PSI is a working memory case, not a processing speed case. Extended time will not help them significantly. A student with a low PSI but average WMI is a processing speed case. Extended time is the appropriate accommodation. A student with both low WMI and low PSI needs both capacity supports and time accommodations.

Many IEP teams treat extended time as a default for any student with a low overall cognitive ability score. The indices allow you to be more precise. Check whether the PSI is the driver before writing extended time into every accommodation box.

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The BRIEF-2 Executive Function Profiles

Teachers and parents use BRIEF-2 (Gioia et al., 2015) to rate learners. It measures executive function through nine scales. These include Inhibit, Self-Monitor, and Shift. The tool also covers Emotional Control, Initiate, and Working Memory. Plan/organise, Task-Monitor and Materials organisation are assessed too.

The BRIEF-2 Working Memory scale specifically assesses the functional use of working memory in everyday tasks: holding instructions in mind, tracking where one is in a task, keeping track of completed work. When this scale is elevated (T-score above 65), it confirms that working memory is a functional barrier in the student's actual school life, not just a psychometric deficit in a testing room.

Plan/Organise scales identify learners with executive function difficulties, (Goldstein & Naglieri, 2016). High scores suggest problems in planning and organisation, not working memory. Tailor support to meet specific needs. Templates help learners struggling with planning. Colour-coded folders and structured storage address organisation, (Dawson & Guare, 2018). Extended time may not always be the best answer.

Executive function knowledge helps teachers create effective IEPs, not just paperwork. This understanding lets learners make real progress (Diamond & Lee, 2011). Teachers need to apply findings from researchers like Meltzer (2007) and Gioia et al (2002).

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Cognitive Load Theory in the IEP

Sweller (1988) created cognitive load theory. It explains effective learning designs and those that overwhelm learners. Sweller (2011) significantly extended and refined the theory. Kennedy and Romig (2024) applied it to special education accommodation design.

Cognitive load theory distinguishes three types of load. Extraneous load is the cognitive effort required by the format of the task: poorly organised instructions, irrelevant information, distracting visual elements. It does not contribute to learning. Intrinsic load is the inherent complexity of the content itself: the number of interacting elements the student must understand. Germane load is the effort devoted to understanding and schema formation: the productive struggle that produces learning.

Sweller (1988) found that accommodation design helps learners by reducing distractions and managing tasks. Mayer & Moreno (2003) noted the importance of engagement with core content. Chandler & Sweller (1991) suggested avoiding burdens to keep learners productive.

Each of these three principles translates directly to accommodation decisions.

Clear task presentation reduces extraneous load. Sweller, van Merrienboer and Paas (1998) explain how instructional design can reduce unnecessary working-memory demands, including demands created by poorly organised formats or avoidable search. Use consistent formatting and remove extra information. Support learners with visual aids that organise content (Mayer, 2009). For phonological loop weaknesses, avoid only verbal instructions (Baddeley, 2003). Written instructions given at the same time help lessen load.

Managing intrinsic load means chunking content so the student encounters a manageable number of interacting elements at once. A student who cannot hold three things in working memory cannot follow a five-step process presented as a single block of text. Breaking that process into five discrete, sequential steps presented one at a time reduces intrinsic load to a level the system can manage. This is not dumbing down the task; it is presenting the task in a form the student's working memory can process. Differentiation strategies based on cognitive load principles use chunking and sequencing to manage intrinsic load without reducing the cognitive demands of the content itself.

Supporting germane load means ensuring the student has enough cognitive capacity left to actually learn, rather than using all available capacity on task management. A student with dysgraphia who spends their entire writing class managing the motor demands of letter formation has no capacity left for composition. Allowing that student to dictate removes the motor load and frees capacity for the thinking work. This is an accommodation that increases germane load by reducing extraneous load, which is exactly the goal.

Kennedy and Romig (2024) argue that special and general educators can use cognitive load theory to understand overwhelmed capacity and shape instruction for students with disabilities. Teams can improve accommodation choices by explicitly using this framework. This process reduces guesswork, moving beyond disability category associations.

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Using the Framework at IEP Meetings

The diagnostic framework above requires a change in the sequence of the IEP conversation. Most IEP meetings begin with the accommodation list: here are the things we will put in place. The framework requires starting earlier: here is what the assessment data tells us about this student's cognitive profile, and here are the accommodations that directly address that profile.

This change in sequence encounters two practical barriers. The first is time. IEP meetings are constrained, and walking a team through a psychoeducational assessment profile takes longer than reviewing a pre-populated accommodation list. The second is expertise. General education teachers, who implement most accommodations, are not typically trained in cognitive science, and asking them to reason from working memory indices to classroom accommodations requires bridging a knowledge gap that most pre-service programmes never build.

These barriers exist, but aren't reasons to choose ineffective help. For time, pre-meeting work is key. Special education teachers review assessments, find bottlenecks, and plan targeted support (Cook & Rao, 2018). For knowledge gaps, professional development linking cognitive science to real choices is needed (Willingham, 2009; Christodoulou, 2017).

IEP goals need good support. Learners struggle with problem-solving goals if memory is weak. Plan goals and support together. Base everything on the same diagnostic insights.

IEP monitoring shows if support works when matched to realistic goals. (Burns & Gibbons, 2008). Identify a learning barrier, add targeted support, and measure progress. (Daly et al., 2005). If support is wrong, monitoring shows only lack of progress. (Shinn, 2007).

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What Functional Behaviour Assessment Adds

Accommodation plans may fail if they don't match learners' needs. A learner avoiding writing may have weak executive function (Witzel, 2018). However, past failure and shame also cause writing avoidance (Dweck, 2006; Seligman, 1975).

Functional behaviour assessment can help teams identify the antecedents, consequences and likely function of avoidance behaviour. The IRIS Center at Vanderbilt describes FBA as a way to determine why a student is engaging in a behaviour before selecting a response. When learners avoid tasks because of cognitive overload, redesign the task and reduce load until it is manageable. When avoidance is maintained by fear, failure history or escape from evaluation, combine task redesign with confidence-building and behaviour support. FBA does not replace academic assessment, but it stops teams treating every avoidance pattern as the same behaviour problem.

Accommodation issues cause behaviour challenges (Hawkins et al., 2020). Teachers must address the mismatch instead of just behaviour. Ignoring the real problem means no lasting change (Willingham, 2017).

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The Difference Between a 504 Plan and an IEP Accommodation

Accommodation design uses cognitive science for both 504 plans and IEPs. However, diagnostic tools differ. IEPs use psychoeducational assessments such as the WISC-V. These assessments measure working memory and processing speed. This data allows IEP teams to match learners to appropriate accommodations.

504 plans are often developed without full psychological testing, relying instead on medical documentation of a disability. A student with an ADHD diagnosis and a 504 plan may never have had working memory formally assessed. The team knows the diagnostic label but not the cognitive profile. In this situation, the 504 plan for ADHD may default to standard ADHD accommodations without analysis of which specific executive functions are most impaired for this student.

Where assessment data is absent, request it. Where it cannot be obtained, use structured teacher observation to build a functional profile: what types of tasks does this student fail on, and what is the pattern of failure? A student who consistently fails on tasks requiring the simultaneous integration of multiple pieces of information but succeeds on single-step tasks has a working memory profile. A student who consistently fails on timed tasks but performs well with unlimited time has a processing speed profile. Functional observation, systematically conducted, provides the diagnostic information needed to match accommodations, even in the absence of standardised assessment.

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When Accommodations Are Correctly Matched

Correctly matched accommodations produce a specific change in the pattern of a student's performance. The student does not simply do better on everything; they do better on the specific tasks that were creating the cognitive bottleneck.

Learners with working memory deficits may improve with graphic organisers and chunked instructions on complex tasks. Simpler tasks should show no change. General improvement or no improvement overall do not confirm correct accommodation matching. (Alloway and Alloway, 2009; Sweller, 1988; Paas et al., 2003)

A student with a processing speed deficit who receives extended time should show improvement on timed tasks relative to untimed tasks, and should close the gap between their performance with and without time limits. If performance is equally low regardless of time, the bottleneck is not processing speed.

Most schools don't routinely track accommodation outcomes that closely. However, it's doable using curriculum data and simple tracking, (Deno, 1985). Does the learner's performance on the task improve after accommodation?

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Using Accommodation Data at the Annual Review

IEP reviews must check if accommodations work, not just if you use them. For each accommodation, ask: "Does evidence show this changed a learner's outcome?".

Teachers need stronger evidence than "learners found it helpful". Instead, use curriculum-based and formative data to ask whether the accommodation changes performance on the targeted task. Deno (1985) describes curriculum-based measurement as a practical way to monitor progress, and Fuchs and Fuchs (1986) found that systematic formative evaluation can improve student achievement when data are used to adjust instruction. For a working-memory accommodation, the most useful pattern is improvement on the complex task that created the bottleneck, not a general impression that everything feels easier.

Endrew F. (2017) clarified that an IEP must be reasonably calculated to enable progress appropriate in light of the child's circumstances. IDEA regulations also require IEP teams to describe how progress toward annual goals will be measured and when progress reports will be provided. If an accommodation is implemented correctly but the expected progress is not occurring, the safer conclusion is that the IEP team should review and revise the plan as appropriate, not simply keep the same support because it appears on the list.

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Frequently Asked Questions

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Further Reading

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References

Baddeley, A. D. (2000). The episodic buffer: A new component of working memory? Trends in Cognitive Sciences, 4(11), 417-423.

Cowan, N. (2001). The magical number 4 in short-term memory: A reconsideration of mental storage capacity. Behavioral and Brain Sciences, 24(1), 87-114.

Deno, S. L. (1985). Curriculum-based measurement: The emerging alternative. Exceptional Children, 52(3), 219-232.

Fuchs, L. S. and Fuchs, D. (1986). Effects of systematic formative evaluation: A meta-analysis. Exceptional Children, 53(3), 199-208.

Fuchs, L. S., Fuchs, D., Eaton, S. B., Hamlett, C. L. and Karns, K. M. (2000). Supplementing teacher judgments of mathematics test accommodations with objective data sources. School Psychology Review, 29(1), 65-85.

Gathercole, S. E. and Alloway, T. P. (2008). Working Memory and Learning: A Practical Guide for Teachers. SAGE Publications.

Gough, P. B. and Tunmer, W. E. (1986). Decoding, reading, and reading disability. Remedial and Special Education, 7(1), 6-10.

Harrison, J. R., Bunford, N., Evans, S. W. and Owens, J. S. (2013). Educational accommodations for students with behavioral challenges: A systematic review of the literature. Review of Educational Research, 83(4), 551-597.

Kennedy, M. J. and Romig, J. E. (2024 issue; first published online 2021). Cognitive load theory: An applied reintroduction for special and general educators. TEACHING Exceptional Children, 56(6), 440-451.

Lewandowski, L. J., Lovett, B. J., Parolin, R., Gordon, M. and Codding, R. S. (2007). Extended time accommodations and the mathematics performance of students with and without ADHD. Journal of Psychoeducational Assessment, 25(1), 17-28.

Sweller, J. (1988). Cognitive load during problem solving: Effects on learning. Cognitive Science, 12(2), 257-285.

Sweller, J. (2011). Cognitive load theory. In J. P. Mestre and B. H. Ross (Eds.), Psychology of Learning and Motivation, Volume 55 (pp. 37-76). Academic Press.

Sweller, J., van Merrienboer, J. J. G. and Paas, F. G. W. C. (1998). Cognitive architecture and instructional design. Educational Psychology Review, 10(3), 251-296.