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Efficient injection of charge carriers from the contacts into the semiconductor layer is crucial for achieving high-performance organic devices. The potential drop necessary to accomplish this process yields a resistance associated with the contacts, namely the contact resistance. A large contact resistance can limit the operation of devices and even lead to inaccuracies in the extraction of the device parameters. Here, we demonstrate a simple and efficient strategy for reducing the contact resistance in organic thin-film transistors by more than an order of magnitude by creating high work function domains at the surface of the injecting electrodes to promote channels of enhanced injection. We find that the method is effective for both organic small molecule and polymer semiconductors, where we achieved a contact resistance as low as 200 Ωcm and device charge carrier mobilities as high as 20 cm2V−1s−1, independent of the applied gate voltage.
The promise to impact contemporary applications has sparked great interest in the study of organic electronic and optoelectronic devices. The rich chemistry of organic materials, low manufacturing cost, and compatibility with flexible and stretchable substrates provide an opportunity to incorporate electronics in non-traditional areas, such as clothing, paper, flexible and rollable displays, or bio-integrated applications1,2,3,4. The progress in this field has been significant, and recently developed solution-processable small molecule and polymer semiconductors have reached charge–carrier mobilities (μ) previously reserved for inorganic materials5,6,7,8,9. A direct consequence of enhancing the intrinsic mobility of the organic semiconductor layer is that the contributions of the contact effects to the device performance now can be significant. In organic field-effect transistors (OFETs), this issue becomes more severe as the channel dimensions are minimized, since the channel resistance decreases with shrinking channel length, while the contact resistance is independent of this variable. Additionally, the development of new materials hinges on a correct evaluation of mobility: the equations adopted from silicon-based metal-oxide semiconductor field-effect transistors (MOSFETs) for the characterization of OFET operation assume negligible contact resistance, and thus they fail when the devices are severely limited by contacts. In this case, it is impossible to access the intrinsic properties of materials and to provide meaningful feedback for material design10,11,12,13.
The impact of contacts was recognized by many research groups14,15,16,17,18,19,20,21,22,23, and recently Klauk identified it as the largest hurdle to overcome in the pursuit of high-frequency OFETs24. Contact resistance results from the fact that a fraction of the applied voltage is necessary to transfer the charges from the electrode surface to the semiconductor layer. The magnitude of this potential drop at the contact depends on the geometry of the device, with coplanar contacts typically exhibiting higher contact resistance than staggered structures22, and several intrinsic factors. The energetic mismatch between the electrode work function and the transport level of the organic semiconductor hampers the injection process; a solution to this problem is to chemically tailor the electrode surface with self-assembled monolayers (SAMs)25,26. Often, however, these modifications also alter the surface energy of the electrodes, therefore impacting the morphology of the films deposited on these surfaces26,27,28. Charge injection layers and contact dopants have been introduced to enhance injection by increasing the charge-carrier concentration at the electrodes16,20,29,30. For top-contact transistors, degradation of the semiconductor layer underneath the electrodes often occurs due to the high energy of the evaporated metal particles. Methods such as nanotransfer printing or flip-chip lamination, were successfully implemented to eliminate this effect31,32. Other proposed solutions to eliminate degradation include the use of organic electrode materials such as graphene, reduced graphene oxide, carbon nanotubes, or charge transfer salts33,34,35,36. Recently, Uemura, et al. found that contact annealing can minimize the contact resistance and eliminate the non-ideal current–voltage curves arising from gated Schottky contacts11. Contact resistances in the hundreds Ωcm range were obtained upon SAM treatment of the source/drain contacts26,37,38, and even below 100 Ωcm resulting from careful control of device structure and geometry39,40,41.
Here, we demonstrate that the contact resistance in bottom-contact OFETs can be significantly reduced by optimizing the metal deposition rate in conjunction with using a SAM treatment. This resulted in over fivefold improved field-effect mobility, compared with the best previously reported devices with identical composition and structure. The approach is effective for both small molecule and polymer OFETs, and we obtained contact resistances as low as 200 Ωcm, and field-effect mobilities of 19.2 cm2V−1s−1 for 2,8-difluoro-5,11-bis(triethylsilylethynyl) anthradithiophene (diF-TES ADT) and 10 cm2V−1s−1 for indacenodithiophene-co-benzothiadiazole copolymer (C16IDTBT), with minimal dependence on the gate voltage. This step change in mobility provides the impetus to propel the performance of organic electronic devices beyond the requirements of a range of commercial applications. To understand this drastic improvement in device performance, we performed grazing incidence X-ray diffraction (GIXD) and Near Edge X-Ray Absorption Fine Structure (NEXAFS) measurements on the organic semiconductor films to evaluate whether the modification in the contact deposition procedure results in variations in the film morphology and/or microstructure, and found no major differences in the structure of the semiconductor layer. This result suggests that the improvements in device performance originate primarily from the differences in the electrode properties. We find the metal grain size correlates negatively with the deposition rate, as confirmed by atomic force microscopy (AFM) measurements, thus creating different environments for the SAM attachment and also impacting its final structure. Evaluation of the SAM/Au surfaces using scanning Kelvin probe microscopy (SKPM) indicated that there exist local enhancement regions in the work function of the electrodes fabricated using a low deposition rate, pointing to the existence of regions with more efficient charge injection due to enhanced SAM order, a feature which is absent in the samples obtained via fast metal deposition.
The chemical structure of diF-TES ADT is shown in Fig. 1a, and the electrical characteristics of a device made using a Au deposition rate of 0.5 Ås−1, followed by treatment with pentafluorobenzene thiol (PFBT) is depicted in Fig. 1b, c. In Fig. 1b, we show the evolution of the drain current (ID) as a function of the gate-source voltage (VGS) in the saturation regime, with the drain-source voltage (VDS) held constant at −40 V. The blue line corresponds to ID on a log scale (right axis), and the black open circles correspond to the square root of ID (left axis). The red line serves as a visual aid to show that the square root of ID follows a linear relation with VGS, as expected from the gradual channel approximation, and indicates the section of the curve where the field-effect mobility was calculated. Fig. 1c shows the evolution of ID with VDS, where each curve is measured at a different VGS, and demonstrates linearity at low VDS and a clear transition from the linear to saturation regime. Both these features are emblematic for low contact resistances. This device exhibits a field-effect mobility of μsat = 19.2 cm2V−1s−1, a current on/off ratio of Ion/Ioff = 6 ∙ 103, and a threshold voltage of VTh = 3.3 V. The relatively modest on/off ratio originates from the fact that we have not patterned our device arrays. Larger Ion/Ioff ratios are possible, as shown for example in Supplementary Fig. 1, where Ion/Ioff = 107. A summary of on/off ratios obtained in diF-TES ADT OFETs fabricated on source drain contacts deposited at a rate of 0.5 Ås−1 is displayed in Supplementary Fig. 2. The value of on/off ratio is controlled by many factors, and it is quite common that a wide spread is obtained in OFETs38.
In order to confirm that the mobility is not overestimated, we evaluated its dependence on VGS. Mobility overestimation can occur in the case of gated Schottky contacts, where there is a large injection barrier at the contacts, which is overcome by an increasing VGS. This relation causes a peak in the apparent mobility when the injection barrier is eliminated, before decreasing to a more realistic value10,11,12. As can be observed in Supplementary Fig. 3, the mobility in our device first increases with increasing VGS, followed by a plateau at higher VGS. Such a dependence has been observed in other high mobility systems such as C10DNTT thin films or rubrene single crystals and was attributed to the presence of electronic traps in the organic semiconductor layers11,41,42. The field-effect mobility evaluated in the linear regime for the device presented in Fig. 1 was µlin = 16.0 cm2V−1s−1 (Supplementary Fig. 4). The contact resistance has a greater effect on the effective device mobility in the linear regime, and the close correspondence recorded between the linear and saturation mobilities suggest a low contact resistance, in agreement with the linear curves obtained in the low-VDS range of the output characteristics in Fig. 1c. A quantitative analysis of the contact resistance and its effect on device properties will be provided later.
Figure 2 shows the results of diF-TES ADT devices fabricated using varied contact deposition rates along with two device schematics for the bottom-contact, top-gate architecture. The evolution of the average field-effect mobility (i.e., the effective device mobility) with the contact deposition rate is depicted in Fig. 2a, where the error bars indicate standard deviation. This value was averaged over at least 5 devices, and the histograms for 30 devices are shown in Supplementary Fig. 5. The device architecture was identical in all samples (see Fig. 2c), and the only difference was the rate used for the deposition of the source and drain contacts. An average field-effect mobility of µsat,avg = 14.6 ± 3.3 cm2V−1s−1 was obtained when a rate of 0.5 Ås−1 was used, decreasing to an average field-effect mobility of µsat,avg = 3.24 ± 0.49 cm2V−1s−1 at a rate of 3.0 Ås−1. The lower values coincide with those reported using the same methods, materials, and device architecture, where devices fabricated with a contact deposition rate of 2 Ås−1 resulted in an average field-effect mobility of µsat,avg = 1.5 cm2V−1s−1 and a maximum field-effect mobility of µsat,max = 3.14 cm2V−1s−143.
To understand the reason behind the improvements in field-effect mobility, we first performed microbeam grazing incidence wide-angle X-ray scattering (μGIWAXS)44 measurements on patterned contacts of device substrates treated with PFBT and diF-TES ADT as organic semiconductor layer, but without Cytop, to assure correlation of the measurements to devices (the identification of commercial equipment or vendor is not intended to imply recommendation or endorsement by NIST, nor is it intended to imply that the materials or equipment identified are necessarily the best available for the purpose). The results for the rates of 0.5 Ås−1 and 2 Ås−1 are shown in Fig. 3a. In both cases, the mixed index peak series arising from (100) oriented crystallites can be distinguished45, confirming that the molecules are “edge-on” oriented, as illustrated in Supplementary Fig. 6. These findings are in agreement with earlier reports26,45,46. The dominant (001) orientation is a result of the PFBT-treated Au acting as a templating structure (Supplementary Fig. 7), with the fluorine atoms of the PFBT molecules interacting with the periphery of diF-TES ADT molecules26. This orientation is the most favorable for charge transport across the channel. Also shown in Fig. 3a is μGIWAXS from the center of long-channel devices where the PFBT templating is lost, as demonstrated by the appearance of diffraction features from the (111) crystal orientation. From Fig. 3a, it is clear that there is no significant variation in (111) fraction between the two electrodes. Additionally, there is no evidence for significant lattice strain that has been invoked as the origin of high mobility 6,13-bis(triisopropyl-silylethynyl) pentacene (TIPS-pentacene)47. Shown in Fig. 3b are NEXAFS results from PFBT-treated Au films deposited at 0.5 Ås−1 and 2 Ås−1, labeled as “slow” and “fast”, respectively. Partial electron-yield NEXAFS is sensitive only to the surface of the film, and thus it is most relevant to the channel of the top gate devices. The NEXAFS is remarkably similar for the different deposition rates, showing that the composition of the samples is not altered, and that the molecular orientation (predominantly “edge on” with the highest π* intensity at normal incidence) is similar at both slow and fast rates, consistent with the bulk μGIWAXS.
We evaluated the contact resistance for the devices corresponding to each contact deposition rate using the gated transmission line method (gated TLM), based on Equation (1), and the results are displayed in Fig. 2b. The gated TLM was based on the value of ID in the linear regime taken at an overdrive voltage of VGS – VTh = −40 V with VTh determined by the second-derivative method48. Details about this analysis are included in Supplementary Fig. 8. It is clear from Fig. 2a, b that the increase in the average field-effect mobility as a function of contact deposition rate is mirrored by the inverse trend in contact resistance. The devices obtained using a fast deposition rate of 3 Ås−1 exhibit large contact resistance, RC = 3.1 kΩcm, which yields a field-effect mobility of µsat,avg = 3.2 ± 0.5 cm2V−1s−1. By slowing down the deposition process to a rate of 0.5 Ås−1, we reduced the contact resistance by six times, to 500 Ωcm. Consequently, the effective mobility measured in these devices is very high. This outcome suggests, along with the identical GIXD and NEXAFS results, that the drastically improved device performance is a result of the enhanced charge injection provided by the lower deposition rates, which yields lower contact resistance. The resistance due to the distance between injection and the conduction channel, Rbulk, should be unchanged between our devices fabricated using various contact deposition rates because the semiconductor has been verified to have the same crystal structure. This indicates that the main improvement in our devices lies in the resistance of the interface between the contact and the semiconductor, Rint.
Through AFM measurements, shown in Fig. 4a, b, we found that the slow deposition rate (0.5 Ås−1 in this case) yields a larger metal grain size than the faster rates (here 2.5 Ås−1), as confirmed by the 2D fast Fourier transforms in Supplementary Fig 9a, b. Au readily migrates on a substrate, a process which is enhanced by temperature. When the Au film formation is slow (similar to a simultaneous deposition and annealing), enough time is allowed for Au to reorganize to a more favorable energy state before additional particles reach the substrates, effectively “trapping” those underneath. On the contrary, at higher rates, the comparatively large amount of material reaching the surface per unit time reduces the time in which underlying Au particles can migrate from the point of initial contact to a more energetically favorable position. This process resembles that of Uemura et al., but in that case the annealing step was performed postdeposition, while here the deposition and annealing are simultaneous11. Nevertheless, the result is the same: lowering of the contact resistance. Interestingly, the RMS roughness of the two films are very similar (0.64 ± 0.04 nm for 0.5 Ås−1, 0.69 ± 0.02 nm for 2.5 Ås−1), suggesting that the in-plane variation is the determining factor in the field-effect mobility improvements, rather than any change in the height variation. To determine if this in-plane variation had any impact on the work function of PFBT-treated Au films, and therefore on the injection barrier, we first conducted macroscale Kelvin probe measurements and found no difference in the work function of the treated Au, both 0.5 Ås−1 and 2.5 Ås−1 gave φAu,PFBT = 5.3 eV. Details on the determination of work function based on Kelvin probe measurements were provided elsewhere.
To examine the local features of the PFBT/Au surface potential, we performed SKPM measurements on the same samples, the results are displayed in Fig. 5. The surface potential of the PFBT-treated Au deposited at 0.5 Ås−1 (Fig. 5a) exhibited local peaks, a feature that does not appear in the sample obtained at a fast deposition rate (Fig. 5b). This observation indicates that while the average surface potential is very similar for all samples, variations exist on small length scales that are masked when macroscopic measurements are carried out. By combining these results with the AFM data, we conclude that the larger size of the Au grains characteristic for the films obtained at a deposition rate of 0.5 Ås−1 allows selected regions of the PFBT monolayer to achieve a higher degree of order (see Fig. 5c) than in the case of 2.5 Ås−1 deposition (Fig. 5d). Since the shift in the work function is dependent on the strength and direction of the internal dipole of the SAM, which in turn is given by the orientation and order of the SAM molecules on the surface, the local maxima correspond to a larger work function obtained in the regions where the net SAM internal dipole moment normal to the surface is maximum. The larger work function allows more efficient injection deeper into the highest occupied molecular orbital (HOMO) than the surrounding area, and thus providing lower local resistance to injection.
To evaluate if the enhanced hole injection from optimized contacts is effective for other semiconductors, we also evaluated FETs fabricated on polymer semiconductors. The data displayed in Supplementary Fig. 10 were obtained on the copolymer indacenodithiophene-co-benzothiadiazole (C16IDT-BT), the structure of which is displayed in Fig. 6a. C16IDT-BT has been incorporated as the semiconductor in many studies reaching a maximum field-effect mobility of µ = 3.6 cm2V−1s−149. It can be observed that the mobility and contact resistance dependence on the contact deposition rate mirrors that obtained in small molecule devices, with the best performance resulting from a deposition rate of 0.5 Ås−1. Figure 6b and c show the evolution of the drain current at constant drain-source voltage while varying the gate-source voltage, and the drain current as a function of drain-source voltage with VGS held constant, respectively. This device exhibited a field-effect mobility of 10 cm2V−1s−1, which is ~ 3x greater than the best mobility reported for this material in this geometry and with Cytop as dielectric49. Other device parameters include Ion/Ioff = 3 × 104, S = 2.9 Vdec−1, and VTh = 7.4 V. A histogram showing the results of 30 devices is included in Supplementary Fig. 11, and an optical micrograph of the polymer film prior to Cytop deposition is shown in Supplementary Fig. 12. These device properties are coupled with a low contact resistance of 200 Ωcm (Supplementary Fig. 13), similar to the case of the small molecule device. These results show that the reduced contact deposition rate has a strong positive effect on the device performance in polymer semiconductors as well.
In summary, we have enhanced the performance of our OFETs through modification of the contact deposition rate in both small molecule and polymer semiconductors. We fabricated a series of OFETs, where we varied the deposition rate for the bottom contacts between 0.5 Ås−1 and 3 Ås−1 and obtained massively improved field-effect mobility when using a rate of 0.5 Ås−1, reaching a value of 19.2 cm2V−1s−1 along with a precipitous drop in contact resistance. We conducted GIXD and NEXAFS measurements and found no noticeable difference in the microstructure of the films deposited over the substrates fabricated using the various contact deposition rates. AFM measurements confirmed a larger grain size in Au deposited at 0.5 Ås−1, and SKPM measurements on the same surfaces exhibited local maxima in the surface potential. We propose that these local maxima can provide regions of enhanced injection into the semiconductor, thus improving device performance, in particular for the cases when the HOMO is particularly deep compared with the work function of the electrode. Our results underline the importance of careful device fabrication in achieving high-performance organic devices. The proposed approach is efficient and robust, and it can be generally applied in all common processes and device architectures. In addition to allowing the demonstration of high-mobility transistors with near ideal current–voltage characteristics, the use of this method can also lead to accurate measurement of the charge-carrier mobility, a critical step in a rational material design, and thus providing a standardization across the field.
Bottom-contact, top-gate devices were fabricated on both glass and SiO2 achieving similar results, and all data presented here are obtained on SiO2. The substrates were cleaned by immersion in hot acetone for 10 min, then rinsed with fresh acetone and isopropyl alcohol (IPA), followed by immersion in hot IPA for 10 min and an additional rinse using fresh IPA and dried in a stream of nitrogen. Then they were exposed to a UV–Ozone treatment for 10 min, rinsed thoroughly using deionized water and dried in a stream of nitrogen. The source and drain contacts were patterned by shadow mask and consisted of a 5 nm titanium adhesion layer deposited by e-beam evaporation at a rate of 1 Ås−1, followed by 40 nm of thermally evaporated gold at varying deposition rates. These contacts were then treated for 30 min using a 30 mM solution of room-temperature PFBT in ethanol followed by a 3-min sonication in fresh ethanol and a thorough ethanol rinse and dried in a stream of nitrogen. The substrates were then brought into a nitrogen glovebox (<0.1ppm O2, <0.1ppm H2O), where the organic semiconductor layer was deposited immediately. A 16.5 mg mL−1 solution of diF-TES ADT in chlorobenzene was spin-coated at 104 rad s−1 (1000 RPM) for 80 s and placed under vacuum for 90 min to remove additional solvent. C16IDT-BT was spin-coated at 208 rad s−1 (2000 RPM) for 60 s from a 10 mg mL−1 solution in chlorobenzene before annealing at 100 °C for 10 min. Samples were then brought back into the glovebox to apply the Cytop 809-M top-gate dielectric (ε = 2.1) that was spin-coated at 208 rad s−1 (2000 RPM) for 60 s and then annealed at 55 °C overnight resulting in a 1.4 µm film. A 40 nm gold top gate electrode was then applied using electron beam evaporation at a rate of 1 Ås−1.
The transistor characterization measurements were carried out in the dark and under ambient conditions using an Agilent 4155 C Semiconductor Parameter Analyzer. AFM and SKPM measurements were taken using an Asylum MFP-3D Bio AFM (Asylum Research, USA) in ambient atmosphere (the identification of commercial equipment or vendor is not intended to imply recommendation or endorsement by NIST, nor is it intended to imply that the materials or equipment identified are necessarily the best available for the purpose). For AFM, a silicon cantilever (Nanosensors PPP-NCLR, force constant: 21–98 N m−1, resonance frequency: 146–236 kHz) was used in tapping mode with a feedback setpoint of 500 mV, and 1 µm × 1 µm images were taken at a rate of 0.5 Hz. SKPM measurements used a silicon cantilever with a Ti/Ir coating (Oxford Instruments ASYELEC.01-R2, force constant: 1.4–5.8 N m−1, resonance frequency: 58–97 kHz) at a nap height of 5 nm, and 20 µm × 20 µm images were taken at a rate of 1 Hz.
were performed at D-line, Cornell High Energy Synchrotron Source at Cornell University following procedures described earlier44. In brief, X-rays of 12 keV energy in a wide bandpass (1.47%) were focused by a single-bounce X-ray focusing capillary50 resulting in a nominally 15-µm transverse beam. Devices were placed on a 5-axis sample goniometer in the focal point of the capillary, with a grazing incident angle of 2° to ensure the X-ray beam projected length was less than the device electrode width. This angle of incidence exceeds the critical angle and thus the full depth of the film (and significant substrate) was probed. The devices were carefully rotated with respect to the beam footprint to enable highest spatial resolution. A Pilatus 200k image detector with a pixel size of 172 μm was placed at a distance of 180 mm from the devices. Data were reduced with the Nika software package51.
were conducted at the Soft X-ray beam line of the Australian Synchrotron52, part of Australian Nuclear Science and Technology Organization, using highly linearly polarized X-rays from an elliptical polarizing undulator. Data were collected using a Channeltron detector in partial electron yield mode (retarding grid bias set at ~ 200 eV), varying the angle of the sample normal relative to the polarization vector of the incident X-rays. NEXAFS was normalized and corrected using QANT53.
The experimental data from this study are available from the corresponding author upon reasonable request.
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The work at WFU was supported by the National Science Foundation (NSF ECCS- 1254757 and NSF DMR- 1627925). I.M. acknowledges funding from EC FP7 Project SC2 (610115), and EPSRC project EP/M005143/1. J.E.A. acknowledges NSF DMR-1627428 for support of organic semiconductor synthesis. L.J.R. acknowledges use of the D1 beam line at the Cornell High Energy Synchrotron Source supported by the National Science Foundation (NSF DMR-0225180) and NIH-NIGMS and thanks Detlef Smilgies for support with the μ GIWAXS measurements. MG acknowledges support from the North Carolina Biotechnology Center to purchase the Asylum AFM (grant 2014-IDG-1012).
Z.A.L. and O.D.J designed the project and analyzed the results. Z.A.L. and K.J.B. fabricated and characterized the OFET devices. Z.A.L., H.L, and M.G. performed AFM and SKPM measurements. H.C., I.M., and J.E.A. synthesized the organic semiconductors. L.J.R. and S.E. performed and analyzed GIXD. E.G. and D.M.D. performed and analyzed NEXAFS measurements. Z.A.L. and O.D.J. wrote the paper, and all authors provided their input.
Correspondence to Oana D. Jurchescu.

matches: V. V. V. V. V. V.


In 2009, Juilan Metter, Ph.D., a psychologist who practiced in State College, Pennsylvania signed a consent agreement and order under which he permanently surrendered his license to practice psychology. The state psychology board took action after Metter pleaded guilty to Medicare billing fraud after being charged with billing Medicare for more than $50,000 for approximately 200 psychotherapy sessions at his office in Centre County on dates when he was not in Centre County and could not have met with and treated patients. The consent agreement (shown below) also indicates that the board had evidence that Metter displaed "gross incompetence, negligence or misconduct" and "provided services outside the scope of his license to practice psychology," both generally and in his management of two families. In 2011, Metter was sentenced to five months in prison, to be followed by two years of supervised release, and was ordered to pay restitution of $13,423 to the agency that administers Medicare. One of the family members ("Mrs. P") sued Metter for malpractice and, in July 2012, received a jury award of $16.5 million.
The Commonwealth and Respondent stipulate as follows in settlement of the above-captioned case.
This matter is before the State Board of Psychology ("Board") pursuant to the Professional Psychologists Practice Act, Act of March 23, 1972, P.L. 136, No. 52, as amended, (Act), 63 P.S. §1201 et seq.
At all relevant and material times, Julian B. Metter, Ph.D. ("Respondent") held a license to practice psychology in the Commonwealth of Pennsylvania, License No. PS004700L, which was originally issued by the Board on April 11, 1986.
a. Respondent's license to practice psychology in the Commonwealth of Pennsylvania is active through November 30,2009, and barring any action by the Board, may be renewed thereafter upon the filing of the appropriate documentation and payment of the necessary fees.
b. Respondent's last known address on file with the Board is 313 Logan Avenue, State College, P A 16801.
c. Respondent last practiced in the State College, PA area.
b. Between 2001 and 2004, the P Family1 saw Respondent on a regular basis for individual, couples and family therapy.
c. In addition to individual, couples and family therapy, Respondent recommended and performed hyperbaric oxygen therapy2 on the father (E.P.) and the two children (Br.P. and K.P.).
d. During the course of the therapeutic relationship, Respondent permitted the entire P Family to use the energy bed, shower and hot tub at Respondent's home.
e. Between July 2003 and February 2004, Respondent performed carbon dioxide therapy on the father (E.P.), which consisted of E.P. breathing carbon dioxide through a mask and then reporting his thoughts to Respondent.
1The Commonwealth will identify the participants by initials only.
2Hyperbaric oxygen therapy (HBOT}involves the breathing of pure oxygen while in a sealed chamber that has been pressurized at 1 1/2 to 3 times normal atmospheric pressure.
f. On or about July 10, 2007, the Court of Common Pleas of Clearfield County, Pennsylvania issued an order in the matter K.M. v. C.M., No. 04-1342-CD directing that the father (C.M.) arrange to have the minor child (S.M.) evaluated by a pediatric psychiatrist solely for the purpose of assessing whether stimulant medication is appropriate to treat the conditions that have been diagnosed in the minor child.
g. Rather than having an evaluation performed by a pediatric psychiatrist as ordered by the Court, C.M. instead arranged for the minor child to be evaluated by Respondent, a licensed psychologist.
h. Respondent performed an extensive evaluation of the minor child (S.M.), and based thereon, made recommendations regarding S.M.'s need for prescription medication.
i. In his report, Respondent recommended that the use of medication as an intervention for this child should be considered premature and suspended until other important factors have been investigated and addressed. Respondent also recommended nutritional supplementation appropriate to support a healthy central nervous system should be considered as adjunctive support for S.M.
j. In his report, Respondent concurred with S.M.'s optometrist and recommended that treatment to address S.M.'s visual processing deficits, including light therapy, be instituted with an optometrist specializing in this field.
l. On or about May 28, 2009, in the U.S. District Court for the Middle District of Pennsylvania, Case No. 4:09-CR-00176-MM, a Criminal Information was filed charging Respondent with one felony count of knowingly and willfully making and causing to be made materially false, fictitious and fraudulent statements and representations, and falsifying, concealing and covering up by trick, scheme and device material facts in connection with the delivery of, and payment for, health care benefits by health care benefit programs for submitting claims for psychotherapy services allegedly provided to patients in Centre County, Pennsylvania on dates when Respondent was not in Centre County and could not have met with and treated patients, in violation of 18 U.S.C. §1035. A true and correct copy of the Criminal Information is attached hereto and incorporated by reference as Exhibit A.
m. On or about June 25, 2009, in the criminal matter referenced above, Respondent pleaded guilty to one felony count of Medicare billing fraud, in violation of 18 U.S.C. §1035.
n. Respondent is awaiting sentencing in the above referenced criminal matter.
o. Respondent is aware of his right to have formal charges filed against him and his right to an administrative hearing in this matter, and to the following rights related to that hearing: to be represented by counsel at the hearing; to present witnesses and testimony in defense or in mitigation of any sanction that may be imposed for a violation; to cross-examine witnesses and to challenge evidence presented by the Commonwealth; to present legal arguments by means of a brief; and to take an appeal from any final adverse decision. Nonetheless, Respondent knowingly and voluntarily waives these rights as set forth in paragraph 6 below.
p. Respondent has agreed to waive the aforementioned right to have an adjudicatory hearing before the Board in order to resolve this matter as quickly as possible.
d. 63 P.S. §1208(a)(9) by deviating from the American Psychological Association, Ethical Principles of Psychologists and Code of Conduct, Ethical Standard 2.01 by providing services outside the scope of his license to practice psychology and the boundaries of his competence, education, training, and experience as a psychologist, in violation of regulations promulgated by the Board at 49 Pa. Code §41.61, Ethical Principle 3(e).
e. 63 P.S. §208(a)(14) by intentionally submitting to a third-party payor a claim for a service or treatment provided when Respondent was absent from his office.
a. Respondent violated Section 8(a)( 4) of the Act, 63 P.S. §I208(a)( 4), by displaying gross incompetence, negligence or misconduct in carrying on the practice of psychology.
b. Respondent violated Section 8(a)(11) of the Act, 63 P.S. §1208(a)(11) by committing immoral or unprofessional conduct.
c. Respondent violated Section 8(a)(9) of the Act, 63 P.S. §1208(a)(9), by engaging in improper dual relationships with patients, in violation of regulations promulgated by the Board at 49 Pa. Code §41.61, Ethical Principle 6(b).
d. Respondent violated Section 8(a)(9) of the Act, 63 P .S. §1208(a)(9), by deviating from the American Psychological Association, Ethical Principles of Psychologists and Code of Conduct, Ethical Standard 2.01 by providing services outside the scope of his license to practice psychology and the boundaries of his competence, education, training, and experience as a psychologist, in violation of regulations promulgated by the Board at 49 Pa. Code §41.61, Ethical Principle 3(e).
e. Respondent violated Section 8(a)(14) of the Act, 63 P.S. §1208(a)(I4), by intentionally submitting to a third-party payor a claim for a service or treatment provided when Respondent was absent from his office.
f. Respondent agrees to the PERMANENT VOLUNTARY SURRENDER of his license to practice psychology in. the Commonwealth of Pennsylvania, License No. PS004700L.
g. Respondent knowingly permanently forfeits and relinquishes all right, title, and privilege to practice psychology in the Commonwealth of Pennsylvania.
h. Upon adoption of this Consent Agreement and Order, Respondent shall immediately cease and desist from the practice' of psychology in the Commonwealth of Pennsylvania. Respondent agrees that he will not represent himself as a psychologist, practice or purport to practice psychology in the Commonwealth of Pennsylvania, hold himself forth as authorized to practice psychology in the Commonwealth of Pennsylvania through the use of a title, or otherwise hold himself forth as authorized to practice psychology in the Commonwealth of Pennsylvania.
A statement that the licensee will assist patients in obtaining alternative professional resources and in transferring psychological records.
j. Respondent shall, within forty-five (45) days of the issuance of the Board's Order adopting and implementing this Consent Agreement, provide to the undersigned prosecuting attorney a notarized affidavit that he has fully complied with the notification to his clients provision set forth in subparagraph "i" above.
1. Respondent agrees that he will never apply for reactivation, renewal, reinstatement, or reissuance of his license to practice psychology in the Commonwealth of Pennsylvania.
m. In the event Respondent ever applies for reactivation, renewal, reinstatement, or reissuance of his license to practice psychology in the Commonwealth of Pennsylvania, any such application or petition will be denied without consideration by or a hearing before the Board.
n. Nothing in this Agreement shall preclude the prosecuting attorney for the Commonwealth from filing charges or the Board from imposing disciplinary action or corrective measures for violations or facts not contained in this Agreement.
j. This Agreement shall take effect immediately upon its approval and adoption by the Board.
7. Respondent knowingly and voluntarily waives the right to an administrative hearing in this matter, and to the following rights related to that hearing: to be represented by counsel at the hearing; to present witnesses and testimony in defense or in mitigation of any sanction that may be imposed for a violation; to cross-examine witnesses mid to challenge evidence presented by the Commonwealth; to present legal arguments by means of a brief; and to take an appeal from any final adverse decision.
8. Respondent agrees, as a condition of entering into this Agreement, not to seek modification of it at a later date without first obtaining the express written concurrence of the Prosecution Division of the Department of State Office of Chief Counsel.
9. This Agreement is between the prosecuting attorney and Respondent only. Except as otherwise noted, this Agreement is to have no legal effect unless and until the Office of General Counsel approves the contents as to form and legality and the Board approves and adopts the Agreement.
10. Should the Board not approve this Agreement, presentation to and consideration of it by the Board shall not prejudice the Board or any of its members from further participation in the adjudication of this matter. This paragraph is binding on the participants even if the Board does not. approve this Agreement.
11. This Agreement contains the whole agreement between the participants. There are no other terms, obligations, covenants, representations, statements or conditions, or otherwise, of any kind whatsoever concerning this Agreement.
12. Respondent verifies that the fats and statements set forth in this Agreement are true and correct to the best of Respondent's knowledge, information and belief. Respondent understands that statements in this Agreement are made subject to the criminal penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
1. The defendant, JULIAN METTER, was a health care provider who operated in Centre County, Pennsylvania providing psychotherapy services to individual patients.
2. In order to properly bill public and private health care benefit programs for these psychotherapy services, it was essential that METTER actually meet, see, treat and interact with these patients. METTER could not bill for services provided to patients if he did not actually see and treat them.
3. As part of his practice METTER billed, Medicare, Medicaid and other insurance programs for psychotherapy services which he allegedly provided to patients, these public and private health insurance programs were "health care benefit programs", as defined by Title 18, United States Code, Section 24(b) in that the programs were public plans, affecting commerce, under which medical benefits, items and services are provided to individuals.
4. In truth, and in fact, as METTER then well knew, on approximately 200 occasions between October 2002 and October 2005 METTER billed these health care benefit programs for more than $50,000 for psychotherapy sessions with individual patients at his office in Centre County Pennsylvania on dates when METTER was not in Centre County and could not have met with, and treated, patients.
5. The United States incorporates by reference as though fully set forth herein the Introduction to this Information.
did knowingly and willfully make and cause to be made materially false, fictitious and fraudulent statements and representation's, and falsify, conceal and cover up by trick, scheme and device material facts in connection with the delivery of, and payment for, health care benefits by health care benefit programs, in that METTER submitted claims for psychotherapy services provided to patients in Centre County Pennsylvania on dates when, in truth, and in fact, as METTER then well knew, METTER was not in Centre County and could not' have met with, and treated, patients.
All in violation of Title 18, United States Code, Section 1035 and 2.
AND NOW, this 2ih day of July, 2009, the State Board of Psychology approves and adopts the foregoing Consent Agreement and incorporates the terms of paragraph 6, which shall constitute the Board's Order and is now issued in resolution of this matter.
This page was updated on July 26, 2011.


(1) "Applicant" means a person who has filed a written application for assistance for herself/himself and her/his dependent child(ren). An applicant may be a parent or non parent caretaker relative.
(2) "Assistance" means cash and any other benefits provided pursuant to this chapter.
(3) "Assistance unit" means the assistance filing unit consisting of the group of persons, including the dependent child(ren), living together in a single household who must be included in the application for assistance and in the assistance payment if eligibility is established. An assistance unit may be the same as a family.
(4) "Benefits" shall mean assistance received pursuant to this chapter.
(5) "Community service programs" means structured programs and activities in which cash assistance recipients perform work for the direct benefit of the community under the auspices of public or nonprofit organizations. Community service programs are designed to improve the employability of recipients not otherwise able to obtain paid employment.
(6) "Department" means the department of human services.
(7) "Dependent child" means an individual, other than an individual with respect to whom foster care maintenance payments are made, who is: (A) under the age of eighteen (18); or (B) under the age of nineteen (19) and a full-time student in a secondary school (or in the equivalent level of vocational or educational training), if before he or she attains age nineteen (19), he or she may reasonably be expected to complete the program of such secondary school (or such training).
(8) "Director" means the director of the department of human services.
(9) "Earned income" means income in cash or the equivalent received by a person through the receipt of wages, salary, commissions, or profit from activities in which the person is self-employed or as an employee and before any deductions for taxes.
(10) "Earned income tax credit" means the credit against federal personal income tax liability under § 32 of the Internal Revenue Code of 1986, 26 U.S.C. § 32, or any successor section, the advanced payment of the earned income tax credit to an employee under § 3507 of the code, 26 U.S.C. § 3507, or any successor section and any refund received as a result of the earned income tax credit, as well as any refundable state earned income tax credit.
(11) "Education directly related to employment" means education, in the case of a participant who has not received a high school diploma or a certificate of high school equivalency, related to a specific occupation, job, or job offer.
(12) "Family" means: (A) a pregnant woman from and including the seventh month of her pregnancy; or (B) a child and the following eligible persons living in the same household as the child: (C) each biological, adoptive or stepparent of the child, or in the absence of a parent, any adult relative who is responsible, in fact, for the care of such child; and (D) the child's minor siblings (whether of the whole or half blood); provided, however, that the term "family" shall not include any person receiving benefits under title XVI of the Social Security Act, 42 U.S.C. § 1381 et seq. A family may be the same as the assistance unit.
(13) "Gross earnings" means earnings from employment and self-employment further described in the department of human services rules and regulations.
(14) "Individual employment plan" means a written, individualized plan for employment developed jointly by the applicant and the department of human services that specifies the steps the participant shall take toward long-term economic independence developed in accordance with subsection 40-5.2-10(e). A participant must comply with the terms of the individual employment plan as a condition of eligibility in accordance with subsection 40-5.2-10(e) of this chapter.
(15) "Job search and job readiness" means the mandatory act of seeking or obtaining employment by the participant, or the preparation to seek or obtain employment.
In accord with federal requirements, job search activities must be supervised by the department of labor and training and must be reported to the department of human services in accordance with TANF work verification requirements.
Except in the context of rehabilitation employment plans, and special services provided by the department of children, youth and families, job search and job readiness activities are limited to four (4) consecutive weeks, or for a total of six (6) weeks in a twelve (12) month period, with limited exceptions as defined by the department. The department of human services in consultation with the department of labor and training shall extend job search, and job readiness assistance for up to twelve (12) weeks in a fiscal year if a state has an unemployment rate at least fifty percent (50%) greater than the United States unemployment rate if the state meets the definition of a "needy state" under the contingency fund provisions of federal law.
Preparation to seek employment, or job readiness, may include, but may not be limited to, the participant obtaining life skills training, homelessness services, domestic violence services, special services for families provided by the department of children youth and families, substance abuse treatment, mental health treatment, or rehabilitation activities as appropriate for those who are otherwise employable. Such services, treatment or therapy must be determined to be necessary and certified by a qualified medical or mental health professional. Intensive work readiness services may include work-based literacy, numeracy, hands-on training, work experience and case management services. Nothing in this section shall be interpreted to mean that the department of labor and training shall be the sole provider of job readiness activities described herein.
(16) "Job skills training directly related to employment" means training or education for job skills required by an employer to provide an individual with the ability to obtain employment or to advance or adapt to the changing demands of the workplace. Job skills training directly related to employment must be supervised on an ongoing basis.
(17) "Net income" means the total gross income of the assistance unit less allowable disregards and deductions as described in subsection 40-5.2-10(g).
(18) "Minor parent" means a parent under the age of eighteen (18). A minor parent may be an applicant or recipient with his or her dependent child(ren) in his/her own case or a member of an assistance unit with his or her dependent child(ren) in a case established by the minor parent's parent.
(19) "On-the-job-training" means training in the public or private sector that is given to a paid employee while he or she is engaged in productive work and that provides knowledge and skills essential to the full and adequate performance of the job. On-the-job training must be supervised by an employer, work site sponsor, or other designee of the department of human services on an ongoing basis.
(20) "Participant" means a person who has been found eligible for assistance in accordance with this chapter and who must comply with all requirements of this chapter, and has entered into an individual employment plan. A participant may be a parent or non-parent caretaker relative included in the cash assistance payment.
(21) "Recipient" means a person who has been found eligible and receives cash assistance in accordance with this chapter.
(22) "Relative" means a parent, stepparent, grandparent, great grandparent, great-great grandparent, aunt, great aunt, great-great aunt, uncle, great-uncle, great-great uncle, sister, brother, stepbrother, stepsister, half-brother, half-sister, first cousin, first cousin once removed, niece, great niece, great-great niece, nephew, great nephew, or great-great nephew.
(23) "Resident" means a person who maintains residence by his or her continuous physical presence in the state.
(24) "Self-employment income" means the total profit from a business enterprise, farming, etc., resulting from a comparison of the gross receipts with the business expenses, i.e., expenses directly related to producing the goods or services and without which the goods or services could not be produced. However, items such as depreciation, personal business and entertainment expenses, and personal transportation are not considered business expenses for the purposes of determining eligibility for cash assistance in accordance with this chapter.
(25) "State" means the State of Rhode Island and Providence Plantations.
(26) "Subsidized employment" means employment in the private or public sectors for which the employer receives a subsidy from TANF or other public funds to offset some or all of the wages and costs of employing a recipient. It includes work in which all or a portion of the wages paid to the recipient are provided to the employer either as a reimbursement for the extra costs of training or as an incentive to hire the recipient, including, but not limited to, grant diversion.
(27) "Subsidized housing" means housing for a family whose rent is restricted to a percentage of its income.
(28) "Unsubsidized employment" means full or part-time employment in the public or private sector that is not subsidized by TANF or any other public program.
(29) "Vocational educational training" means organized educational programs, not to exceed twelve (12) months with respect to any participant, that are directly related to the preparation of participants for employment in current or emerging occupations. Vocational educational training must be supervised.
(30) "Work experience" means a work activity that provides a participant with an opportunity to acquire the general skills, training, knowledge, and work habits necessary to obtain employment. The purpose of work experience is to improve the employability of those who cannot find unsubsidized employment. An employer, work site sponsor, and/or other appropriate designee of the department must supervise this activity.
(31) "Work supplementation" also known as "grant diversion" means the use of all or a portion of a participant's cash assistance grant and food stamp grant as a wage supplement to an employer. Such a supplement shall be limited to a maximum period of twelve (12) months. An employer must agree to continue the employment of the participant as part of the regular work force, beyond the supplement period, if the participant demonstrates satisfactory performance.
(32) "Work activities" mean the specific work requirements which must be defined in the individual employment plan and must be complied with by the participant as a condition of eligibility for the receipt of cash assistance for single and two (2) family households outlined in § 40-5.2-12 of this chapter.


M.C., by and through his guardian ad litem M.N.; M. N., Plaintiffs - Appellants, v. ANTELOPE VALLEY UNION HIGH SCHOOL DISTRICT, Defendant - Appellee.
Before: REINHARDT, KOZINSKI, and WARDLAW, Circuit Judges.
The Individuals with Disabilities Education Act (“IDEA”) guarantees children with disabilities a free appropriate public education (“FAPE”). 20 U.S.C. § 1400(d)(1)(A). We consider the interplay between the IDEA's procedural and substantive safeguards.
M.N. then filed a due process complaint alleging that the Antelope Valley Union High School District (the “District”) committed procedural and substantive violations of the IDEA. The due process hearing took place before an Administrative Law Judge who denied all of M.C.'s claims and the district court affirmed.
The IDEA's “primary goal is ‘to ensure that all children with disabilities have available to them a free appropriate public education that emphasizes special education and related services ․’ ” J.L. v. Mercer Island Sch. Dist., 592 F.3d 938, 947 (9th Cir. 2010) (quoting 20 U.S.C. § 1400(d)(1)(A)). A FAPE must be “tailored to the unique needs of the handicapped child by means of an ‘individualized educational program’ (IEP).” Hendrick Hudson Cent. Sch. Dist. Bd. of Educ. v. Rowley, 458 U.S. 176, 181 (1982) (quoting 20 U.S.C. § 1401(18)). An IEP must contain, among other things, “a statement of the child's present levels of academic achievement,” “a statement of measurable annual goals” and “a statement of the special education and related services ․ to be provided to the child.” 20 U.S.C. § 1414(d)(1)(A)(i). When formulating an IEP, a school district “must comply both procedurally and substantively with the IDEA,” M.L. v. Fed. Way Sch. Dist., 394 F.3d 634, 644 (9th Cir. 2005) (citing Rowley, 458 U.S. at 206–07), so that the process “will be informed not only by the expertise of school officials, but also by the input of the child's parents or guardians,” Endrew F. v. Douglas Cty. Sch. Dist., 580 U.S. __, slip op. at 11 (Mar. 22, 2017).
Judicial review in IDEA cases “differs substantially from judicial review of other agency actions, in which courts are generally confined to the administrative record and are held to a highly deferential standard of review.” Ojai Unified Sch. Dist. v. Jackson, 4 F.3d 1467, 1471 (9th Cir. 1993). We review whether the state has provided a FAPE de novo. Union Sch. Dist. v. Smith, 15 F.3d 1519, 1524 (9th Cir. 1994). We can accord some deference to the ALJ's factual findings, but only where they are “thorough and careful,” and “the extent of deference to be given is within our discretion.” Id. (citations omitted).
The district court accorded the ALJ's findings substantial deference because the ALJ “questioned witnesses during a three-day hearing” and “wrote a 21-page opinion that reviewed the qualifications of witnesses and culled relevant details from the record.” But neither the duration of the hearing, nor the ALJ's active involvement, nor the length of the ALJ's opinion can ensure that the ALJ was “thorough and careful.”1 J.W. ex rel. J.E.W. v. Fresno Unified Sch. Dist., 626 F.3d 431, 440 (9th Cir. 2010). And, in this case, the ALJ was neither thorough nor careful. As plaintiffs point out, the ALJ didn't address all issues and disregarded some of the evidence presented at the hearing. Even the district court recognized that the ALJ's analysis “is not entirely satisfying.” Accordingly, the district court erred in deferring to the ALJ's findings.
The IDEA contains numerous procedural safeguards that are designed to protect the rights of disabled children and their parents. See 20 U.S.C. § 1415. These safeguards are a central feature of the IDEA process, not a mere afterthought: “Congress placed every bit as much emphasis upon compliance with procedures giving parents and guardians a large measure of participation at every stage of the administrative process as it did upon the measurement of the resulting IEP against a substantive standard.” Rowley, 458 U.S. at 205. Because disabled children and their parents are generally not represented by counsel during the IEP process, procedural errors at that stage are particularly likely to be prejudicial and cause the loss of educational benefits.
Therefore, compliance with the IDEA's procedural safeguards “is essential to ensuring that every eligible child receives a FAPE, and those procedures which provide for meaningful parent participation are particularly important.” Amanda J. v. Clark Cty. Sch. Dist., 267 F.3d 877, 891 (9th Cir. 2001). “Procedural violations that interfere with parental participation in the IEP formulation process undermine the very essence of the IDEA.” Id. at 892.
Plaintiffs allege that the District violated the IDEA by (1) failing to adequately document the services provided by a teacher of the visually impaired (“TVI”), (2) failing to specify the assistive technology (“AT”) devices provided and (3) failing to file a response to the due process complaint.
Plaintiffs claim that the District didn't provide a “ ‘written record of reasonable expectations' to hold the District accountable for the provision of vision services to M.C.” (quoting Amanda J., 267 F.3d at 891). A brief history of the District's shifting offer of TVI services is necessary: The IEP document signed by M.N. and the District included an offer of 240 minutes of TVI services per month. According to the District, it realized a week later this was a mistake. But the District did nothing to notify M.N. More than a month later, the District purported to unilaterally amend the IEP by changing the offer of TVI services to 240 minutes per week. The District didn't send M.N. a copy of the revised IEP or otherwise notify her of this change. In fact, she didn't learn of it until the first day of the due process hearing, a month later. Moreover, at the hearing, District witnesses testified that the District offered M.C. 300 minutes of TVI services per week.
Plaintiffs claim that the District's failure to accurately document the offer of TVI services denied M.C. a FAPE by precluding M.N. from meaningfully participating in the IEP process. Before discussing the merits of this claim we must address the District's argument that the claim is waived.
1. The district judge recognized that plaintiffs' due process complaint “arguably encompassed Plaintiffs' argument that the provision of TVI services was inadequate.” The judge nevertheless found that plaintiffs “waived any argument that the District's failure to specify the frequency of TVI services in the August 2, 2012 IEP resulted in an actual denial of an educational benefit to M.C.” because the due process complaint was superseded by the ALJ's restatement of issues, which omitted the adequacy of TVI services.
The district judge held that plaintiffs waived the issue by failing to object to this omission.2 But plaintiffs weren't aware that the District had unilaterally changed the IEP until after the ALJ had restated the issues, so they could hardly have raised that as a procedural violation. And it turns out that the amendment didn't even provide an accurate statement of the services that M.C. was offered. District witnesses later testified that the District intended to offer M.C. 300 minutes of TVI services per week.
The district judge purported to understand the difficult position that plaintiffs were in due to this sequence of events but still found that “there [was] no indication in the record that Plaintiffs ever sought during the administrative hearing to amend the issues to be addressed to include the District's failure to provide M.C. with adequate TVI services.” But we generally treat issues as if they were raised in the complaint if they are tried by consent. Rule 15 of the Federal Rules of Civil Procedure provides that an issue “tried by the parties' express or implied consent ․ must be treated in all respects as if raised in the pleadings.” Fed. R. Civ. P. 15(b)(2); see 6A Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure § 1491 (3d ed.). While we haven't previously recognized this practice in IDEA cases, it's often been applied in a variety of other agency adjudications: before the IRS, Lysek v. C.I.R., 583 F.2d 1088, 1091–92 (9th Cir. 1978), the Department of Labor, 20 C.F.R. § 901.40; Pierce County v. U.S. ex rel. Dep't of Labor, 699 F.2d 1001, 1004 (9th Cir. 1983), and the Patent and Trademark Office, US PTO Stip. § 507.03. We see no reason IDEA cases should be treated differently.
2. The IEP is a “formal, written offer [that] creates a clear record that will do much to eliminate troublesome factual disputes ․ about when placements were offered, what placements were offered, and what additional education assistance was offered to supplement a placement, if any.” Union Sch. Dist., 15 F.3d at 1526. The IEP must specify “the anticipated frequency, location, and duration of [education] services.” 20 U.S.C § 1414(d)(1)(A)(i)(VII). Such “a formal, specific offer from a school district will greatly assist parents in ‘present[ing] complaints with respect to any matter relating to the ․ educational placement of the child.’ ” Union Sch. Dist., 15 F.3d at 1526 (quoting 20 U.S.C. § 1415(b)(1)(E)).
The district judge agreed with the ALJ's finding “that the September 17, 2012 Amendment merely corrected an unintentional error in the August 2, 2012 IEP.” We fail to see how this can be so. An IEP is a contract. It is signed by the child's parents and the school's representatives, and thus embodies a binding commitment. It also provides notice to both parties as to what services will be provided to the student during the period covered by the IEP. The school district is not entitled to make unilateral changes to an IEP document any more than may any other party to a contract. If the District discovered that the IEP did not reflect its understanding of the parties' agreement, it was required to notify M.N. and seek her consent for any amendment. See 20 U.S.C. § 1414(d)(3)(D), (F) (discussing amendments to the IEP). Absent such consent, the District was bound by the IEP as written unless it sought to re-open the IEP process and proposed a different IEP.
Because the District denied M.N. an opportunity to participate in the IEP drafting process by unilaterally revising the IEP, and because the IEP as initially drafted didn't provide M.N. with an accurate offer of the TVI services provided to M.C., the District committed two procedural violations of the IDEA. Union Sch. Dist., 15 F.3d at 1526. The district court nevertheless found that M.C. wasn't denied a FAPE, reasoning that “[a] procedural violation denies a child a FAPE when the violation seriously infringe[s] the parents' opportunity to participate in the IEP formation process.” (emphasis in original) (internal quotation and citation omitted). But, as explained above, M.N. was denied an opportunity to participate in the IEP drafting process. Moreover, in enacting the IDEA, Congress was as concerned with parental participation in the enforcement of the IEP as it was in its formation. See Rowley, 458 U.S. at 205 (discussing Congress's intent to “giv[e] parents and guardians a large measure of participation at every stage of the administrative process” (emphasis added)). Under the IDEA, parental participation doesn't end when the parent signs the IEP. Parents must be able to use the IEP to monitor and enforce the services that their child is to receive. When a parent is unaware of the services offered to the student—and, therefore, can't monitor how these services are provided—a FAPE has been denied, whether or not the parent had ample opportunity to participate in the formulation of the IEP.
Whether, and to what extent, M.C. was prejudiced by these procedural improprieties is a more difficult question. Assuming that M.C. was receiving 300 minutes of TVI services per week, as the District apparently intended to offer, M.C. may not have suffered any substantive harm. M.N. nevertheless suffered procedural harm by not being apprised of the actual status of the services being provided, causing her to incur legal fees in attempting to protect that right. Because any TVI services provided beyond what was specified in the written IEP would have been gratuitous, M.N. could not be sure that the District would continue to provide them. With only 240 minutes per month (about an hour a week) specified in the IEP, the District was entitled to cut back these services to that level. M.N. was amply justified in seeking the aid of counsel to clarify the amount of services provided. Incurring unnecessary legal fees is, of course, a form of prejudice that denies a student and his parents an educational benefit. See Parents on Behalf of Student v. Julian Charter Sch., OAH No. 2012100933, at 2 (Jan. 17, 2013) (order denying motion to dismiss). The fact that the District could have avoided the harm by promptly notifying M.N. that it was agreeing to provide far more services than specified in the IEP only makes matters worse.
When a student requires “a particular device or service” California requires that the IEP “include a statement to that effect.” Cal. Educ. Code § 56341.1(b)(5), (c). M.C.'s IEP initially indicated that M.C. didn't require AT devices or services. The District conceded that this was erroneous and issued an amendment that changed the checkbox for AT devices from “no” to “yes.” But neither the IEP nor the amendment specified the devices that M.C. required.
The district judge recognized that “the language of [section 56341.1] requires the District to identify the particular types of AT devices and services to be provided to M.C.” But the judge found that this procedural violation didn't “seriously infringe[ ] M.N.'s opportunity to participate in the IEP formulation process.” As we've made clear, however, parents must be able to participate in both the formulation and enforcement of the IEP. See supra at 13–14. Even if M.N. was able to participate in the IEP's formulation, the District's failure to identify the AT devices that M.C. required rendered the IEP useless as a blueprint for enforcement.
The district judge noted that the IEP team discussed “at least some of the AT services and equipment to be provided to M.C.” at the IEP meeting. But a discussion does not amount to an offer. M.N. could force the District to provide only those services and devices listed in the IEP, not those discussed at the IEP meeting but left out of the IEP document. See Union Sch. Dist., 15 F.3d at 1526 (requiring a “formal, written offer”). Indeed, items discussed at the IEP meeting but not included in the IEP document could be deemed to have been omitted on purpose.
Nor was this a case where “everyone involved in the individualized education team—including [the student's] parents—knew of the amounts [of services]” that were offered. J.L., 592 F.3d at 953. M.N. testified at the due process hearing that she didn't know which AT devices were offered to M.C. M.C.'s TVI services provider testified that M.C. received a laptop, a Book Port, software developed for the visually impaired, a screen reading program, a talking calculator and an Eye-Pal Solo. But M.N. was only aware that M.C. received a laptop, braille machine, braille calendar and a Book Port. M.N. also testified that the laptop didn't have the software that M.C. needed, but she didn't know which software was missing. Because the IEP didn't specify which AT devices were being offered, M.N. had no way of confirming whether they were actually being provided to M.C. The District's failure to specify the AT devices that were provided to M.C. thus infringed M.N.'s opportunity to participate in the IEP process and denied M.C. a FAPE. Id. at 953.
The IDEA requires a school district to respond to a parent's due process complaint within 10 days. 20 U.S.C. § 1415(c)(2)(B)(i)(I). The District failed to do this and plaintiffs argue that this violated the IDEA. To be clear, the District didn't just miss a deadline: It failed to ever respond to the complaint. The district court found that the failure to respond didn't infringe M.N.'s opportunity to participate in the IEP formulation process and, therefore, wasn't a denial of a FAPE. But this misses the mark. The District's failure to respond may not have denied plaintiffs a FAPE but it still violated the IDEA and due process.
An answer to a complaint serves an important dual purpose: It gives notice of the issues in dispute and binds the answering party to a position. See, e.g., United States v. All Assets Held at Bank Julius Baer & Co., 959 F. Supp. 2d 81, 116 n.21 (D.D.C. 2013) (noting that “one function of an answer” is to identify “points of disagreement”); Lopez v. U.S. Fidelity & Guaranty Co., 18 F.R.D. 59, 61 (D. Alaska 1955) (explaining that the purpose of rules governing answers to a complaint “is to prevent surprise”). Failure to file an answer puts the opposing party at a serious disadvantage in preparing for the hearing, as it must guess what defenses the opposing party will raise. The problem is particularly severe in IDEA cases because there is no discovery.
In order for M.C. to have received a FAPE, the IEP must have “(1) addresse[d] [his] unique needs, (2) provide[d] adequate support services so [M.C.] can take advantage of the educational opportunities, and (3) [been] in accord with the individualized education program.” Capistrano Unified Sch. Dist. v. Wartenberg, 59 F.3d 884, 893 (9th Cir. 1995) (citing Rowley, 458 U.S. at 188–89).
1. Plaintiffs argue that the District denied M.C. a FAPE by providing him with less than 300 minutes of TVI services per week. The District doesn't address the substance of plaintiffs' argument, arguing that the issue was waived. For the reasons explained above, plaintiffs haven't waived this issue. See supra at 7–10.
Both the ALJ and district judge placed the burden on M.N. to show that the services provided to M.C. were inadequate. Normally, the party alleging a violation of the IDEA bears the burden of showing that the services received amounted to a denial of a FAPE. See Schaffer ex rel. Schaffer v. Weast, 546 U.S. 49, 57–58 (2005). But here there was a procedural violation that deprived M.N. of the knowledge of what services were being offered to M.C. If parents don't know what services are offered to the student—in kind or in duration—it's impossible for them to assess the substantive reasonableness of those services. In such circumstances, the burden shifts to the school district to show that the services the student actually received were substantively reasonable. We remand so the District can have an opportunity to make such a showing before the district court.
2. Plaintiffs also claim that the District denied M.C. a FAPE by failing to develop measurable goals in all areas of need, including “the areas of life skills, residential travel, and business travel.” Additionally, plaintiffs argue that the District failed to provide adequate orientation and mobility services, as well as adequate social skills instruction. The district court found that plaintiffs failed to meet their burden of showing that the IEP wasn't “reasonably calculated to confer [M.C.] with a meaningful benefit.” J.W., 626 F.3d at 439. In doing so, it relied on the Supreme Court's comment in Rowley that, by “an ‘appropriate’ education, it is clear that [Congress] did not mean a potential-maximizing education.” 458 U.S. at 197 n.21. But Rowley “d[id] not attempt to establish any one test for determining the adequacy of educational benefits.” Id. at 202. Recently, the Supreme Court clarified Rowley and provided a more precise standard for evaluating whether a school district has complied substantively with the IDEA: “To meet its substantive obligation under the IDEA, a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances.” Endrew F., slip op. at 11. In other words, the school must implement an IEP that is reasonably calculated to remediate and, if appropriate, accommodate the child's disabilities so that the child can “make progress in the general education curriculum,” id. at 3 (citation omitted), commensurate with his non-disabled peers, taking into account the child's potential. We remand so the district court can consider plaintiffs' claims in light of this new guidance from the Supreme Court.
The IDEA provides that a “court, in its discretion, may award reasonable attorneys' fees as part of the costs to the parent or guardian of a child or youth with a disability who is a prevailing party.” 20 U.S.C. § 1415(i)(3)(B)(i)(I). A parent need not succeed on every issue in order to be a prevailing party. Park v. Anaheim Union High Sch. Dist., 464 F.3d 1025, 1035 (9th Cir. 2006). Rather, parents are prevailing parties if they “succeed [ ] on any significant issue in litigation which achieves some of the benefit [they] sought in bringing the suit.” Id. at 1034 (emphasis in original) (citation omitted). M.N. is the prevailing party in this appeal and is therefore entitled to attorneys' fees. See Ash v. Lake Oswego Sch. Dist., 980 F.2d 585, 590 (1992).
The District's failure to adequately document the TVI services and AT devices offered to M.C. violated the IDEA and denied M.C. a FAPE. These procedural violations deprived M.N. of her right to participate in the IEP process and made it impossible for her to enforce the IEP and evaluate whether the services M.C. received were adequate. At the very least, plaintiffs are entitled to have the District draft a proper IEP and receive compensatory education to “place [M.C.] in the same position [he] would have occupied but for the school district's violations of [the] IDEA.” R.P. ex rel. C.P. v. Prescott Unified Sch. Dist., 631 F.3d 1117, 1125 (9th Cir. 2011) (citations omitted). We remand the case to the district court for proceedings consistent with this opinion.
1. In Timothy O. v. Paso Robles Unified Sch. Dist., for example, we reversed a lengthy ALJ opinion with detailed findings that were unsupported by the record. 822 F.3d 1105, 1117, 1123 (9th Cir. 2016). The district court nevertheless had deferred to the ALJ's findings, apparently impressed by the length and superficial plausibility of the ALJ's opinion. Id. at Dist. Ct. Dkt. No. 78. Such blind deference is not appropriate. Rather, the district judge must actually examine the record to determine whether it supports the ALJ's opinion. See, e.g., J.G. ex rel. Jimenez v. Baldwin Park Unified Sch. Dist., 78 F. Supp. 3d 1268, 1281–82 (C.D. Cal. 2015) (Olguin, J.) (according “substantially less deference” where “the ALJ's decision ignore[d] and mischaracterize[d] key evidence”).
2. It is apparently common practice in IDEA cases is for ALJs to restate and reorganize the issues presented by the parties. See J.W., 626 F.3d at 442; Fordex rel. Ford v. Long Beach Unified Sch. Dist., 291 F.3d 1086, 1090 (9th Cir. 2002). We question the wisdom of such a procedure where the parents are represented by counsel and the complaint states the issues intelligibly, as was the case here. A party bringing a due process complaint is entitled to frame the issues it wishes to present and should not be put in the difficult position of contradicting the presiding official who will soon be the trier of fact. In such circumstances, failure to object will not be deemed a waiver of any claim fairly encompassed in the complaint.
3. The District also makes a separate waiver argument: It claims that plaintiffs waived their objection to the admission of the amendment into evidence. While plaintiffs did waive their objection to the admissibility of the amendment, for the reasons described above, see supra at 7–10, the waiver does not extend to its legal significance.
4. The District's purported amendment was also improper for a separate reason: The District presented no evidence supporting its claim that the parties agreed to 240 minutes of TVI services per week when the IEP was drafted. Indeed, it is unclear how the District came up with this figure given that its witnesses at the hearing testified that M.C. was actually provided 300 minutes of TVI services per week. Nevertheless, the ALJ and the district court accepted this as true. However, a party's mere allegations are not proof.
5. On remand, the district court shall determine whether this course of conduct was a deliberate attempt to mislead M.N. or mere bungling on the part of the District and its lawyers. If the district court determines that the former is the case, it shall impose a sanction sufficiently severe to deter any future misconduct.
6. Even if a motion to compel a response isn't brought, the ALJ should raise the issue sua sponte at the pre-hearing conference. This is imperative in IDEA cases where parents often proceed without the aid of counsel and may not be aware that the IDEA requires a school district to respond to the complaint within 10 days. See 20 U.S.C. § 1415(c)(2)(B)(i)(I).
7. We do not address the reverse situation where the due process case is brought by the school district and the parents fail to file a response. Different considerations may apply in such circumstances, especially if the parents are pro se. We leave that situation for a case that presents the issue.


Art15, sponsored by Citi Private Bank, further cements its position as the world's most global art fair with a focused presentation of 134 international galleries from 41 countries. Modern and contemporary artwork will be displayed from established and emerging galleries in Europe, the Middle East, Asia, Africa and America.
As the Fair moves into its third edition, there is an increased emphasis on curatorial rigour, with a reduced number of participants presenting more focused installations.
This year's Fair sees the highest number of solo artist presentations to date with new exhibitors ARNDT (Berlin/Singapore) showcasing the Filipino painter Rodel Tapaya; 10 Chancery Lane (Hong Kong), who are dedicating their space to Huang Rui, a Chinese artist known for his social and cultural criticism; Australian artist Kate Shaw will be creating work on site at Fehily Contemporary’s stand (Melbourne); Zipper Galleria (São Paolo) present one of Brazil’s rising stars James Kudo; Sulger-Buel Lovell (Cape Town/London) showcase the work of emerging sculptor Isabelle Grobler; and the prominent British painter Stella Vine presents new work at COB Gallery (London).
Over half the galleries attending Art15 have spaces outside of Europe, with several spanning multiple cities. There is a greater presence of Modern art, particularly Italian Modernism as seen in a presentation from new exhibitor, Switzerland's Cortesi Gallery. Contemporary photography remains a core component for Art15 with six solo photography displays including Cristina de Middel at La New Galeria, Spain.
The Fair also continues to explore new scenes within the ever-burgeoning Asian market. In response to an increased presence from Taiwanese collectors, this year nine galleries from Taiwan are participating including Lin & Lin Gallery, AKI Gallery and Yiri Arts.
Art15 continues its commitment to providing young galleries with a strong platform in London with the Emerge and London First sections. Spanning 19 countries, each section presents 14 exhibitors offering a truly global view of the emerging international gallery scene.
Jonathan Watkins, Director of Ikon Gallery in Birmingham and an ambassador for emerging artists is the curatorial advisor for Emerge. The section wholly encompasses the curatorial notion of emerging – from markets to galleries to artists. Graduating from last year's London First section, Sabrina Amrani from Madrid is a gallery that works with artists from the Middle East, North Africa and South Asia, demonstrating the global scope of today's art world reflected at Art15. Meanwhile Piper Gallery has an alternative focus on artists whose career spans more than 40 years, presenting work by Tess Jaray, RA.
Selected by curatorial advisor Aaron Cezar, Director of London's Delfina Foundation, London First provides unprecedented access to galleries who have never shown in London before. Amongst the galleries making their art fair debut are Blau Projects, São Paulo who inaugurated their gallery from a renovated shed two years ago; William Benington Gallery, London, who specialises in sculpture and Upfor Gallery, Portland, Oregon, who are pioneers in digital art.
Kate Bryan, Fair Director said, "Art15 offers a unique perspective as a truly global art Fair. Collectors have responded positively to the discoveries they have made at the last two editions. I am delighted to further cement our position as a Fair prepared to seek out new territory and promote a genuinely international platform in the world's most global city. Art15 will be an opportunity to celebrate artists from over 40 countries and our consolidated exhibitor numbers ensure a high standard of presentations across the board. Given its diverse and often unexpected content, everyone – from private museum owners and collectors to curators and art lovers – has the opportunity to explore something new."
Speaking at Art15's selection committee panel discussion on 23 January at Delfina Foundation, Tim Marlow, Director of Artistic Programmes at the Royal Academy of Arts and member of Art15's Selection Committee said "art fairs in different parts of the world have exposed western galleries to what is going on amongst collectors, critics, artists and galleries in new and different territories. What is interesting about Art15 is that they bring that global identity to a city like London, the most diverse city in the world."
Art15 has an extensive public programme again this year, with a dedicated series of talks integrating into the Fair's curatorial initiatives. These include Freedom Audit, an exhibition curated by Kathleen Soriano, independent curator and former Director of Exhibitions at the Royal Academy of Arts. The exhibition is a curatorial enquiry considering how artists from across the globe navigate the multifarious boundaries of sexual freedoms, political freedoms and freedom of speech.
A second curatorial initiative is the unpredictable digital art project, #IRL, curated by Valentina Fois and involving the creation of a large-scale digital commission by two artists – Emilie Gervais and Sara Ludy – in real-time during the Fair. Complementing this will be further curatorial initiatives, talks and projects, which will be announced in the coming weeks, as well as a section dedicated to non-profit institutions.


(a) Voluntary Dismissal; Dismissal for Want of Prosecution or Other Cause. Except as provided in §§707(a)(3), 707(b), 1208(b), and 1307(b) of the Code, and in Rule 1017(b), (c), and (e), a case shall not be dismissed on motion of the petitioner, for want of prosecution or other cause, or by consent of the parties, before a hearing on notice as provided in Rule 2002. For the purpose of the notice, the debtor shall file a list of creditors with their addresses within the time fixed by the court unless the list was previously filed. If the debtor fails to file the list, the court may order the debtor or another entity to prepare and file it.
(b) Dismissal for Failure To Pay Filing Fee.
(1) If any installment of the filing fee has not been paid, the court may, after a hearing on notice to the debtor and the trustee, dismiss the case.
(2) If the case is dismissed or closed without full payment of the filing fee, the installments collected shall be distributed in the same manner and proportions as if the filing fee had been paid in full.
(c) Dismissal of Voluntary Chapter 7 or Chapter 13 Case for Failure To Timely File List of Creditors, Schedules, and Statement of Financial Affairs. The court may dismiss a voluntary chapter 7 or chapter 13 case under §707(a)(3) or §1307(c)(9) after a hearing on notice served by the United States trustee on the debtor, the trustee, and any other entities as the court directs.
(d) Suspension. The court shall not dismiss a case or suspend proceedings under §305 before a hearing on notice as provided in Rule 2002(a).
(e) Dismissal of an Individual Debtor’s Chapter 7 Case, or Conversion to a Case Under Chapter 11 or 13, for Abuse. The court may dismiss or, with the debtor’s consent, convert an individual debtor’s case for abuse under §707(b) only on motion and after a hearing on notice to the debtor, the trustee, the United States trustee, and any other entity as the court directs.
(1) Except as otherwise provided in §704(b)(2), a motion to dismiss a case for abuse under §707(b) or (c) may be filed only within 60 days after the first date set for the meeting of creditors under §341(a), unless, on request filed before the time has expired, the court for cause extends the time for filing the motion to dismiss. The party filing the motion shall set forth in the motion all matters to be considered at the hearing. In addition, a motion to dismiss under §707(b)(1) and (3) shall state with particularity the circumstances alleged to constitute abuse.
(2) If the hearing is set on the court’s own motion, notice of the hearing shall be served on the debtor no later than 60 days after the first date set for the meeting of creditors under §341(a). The notice shall set forth all matters to be considered by the court at the hearing.
(f) Procedure for Dismissal, Conversion, or Suspension.
(1) Rule 9014 governs a proceeding to dismiss or suspend a case, or to convert a case to another chapter, except under §§706(a), 1112(a), 1208(a) or (b), or 1307(a) or (b).
(2) Conversion or dismissal under §§706(a), 1112(a), 1208(b), or 1307(b) shall be on motion filed and served as required by Rule 9013.
(3) A chapter 12 or chapter 13 case shall be converted without court order when the debtor files a notice of conversion under §§1208(a) or 1307(a). The filing date of the notice becomes the date of the conversion order for the purposes of applying §348(c) and Rule 1019. The clerk shall promptly transmit a copy of the notice to the United States trustee.