Parent Denied Reimbursement for Mother's Colorado Ski Trip to Visit Student at RTC

A parent sought full reimbursement of $3,047 in travel expenses for both parents to visit their son at an out-of-state residential treatment center in Colorado. The district refused to reimburse the mother's expenses because she missed the scheduled family therapy session and instead spent the weekend skiing in Vail. The ALJ ruled the district was not required to pay for the mother's trip but ordered partial reimbursement of $1,611 for the father's allowable expenses under the district's travel guidelines.

What Happened

Student is a 15-year-old with emotional disturbance who had been placed at Forest Heights Lodge, a residential treatment center (RTC) in Evergreen, Colorado, for nearly three years under his IEP. Because the school was out of state, the district had a written travel reimbursement policy allowing parents to be reimbursed for up to four trips per year to visit their child — but only for trips specifically tied to family therapy sessions at the RTC.

In February 2008, both parents planned to fly to Colorado for a scheduled family therapy session on February 15. A work emergency prevented the mother — a physician completing her residency — from traveling with the father on the original date. She was unable to make it to the therapy session in time. Rather than cancel the trip, the parents decided to spend the President's Day weekend with Student in Vail, Colorado, approximately 100 miles from the school. The father attended the therapy session as planned. The mother flew directly to Vail and spent the weekend with Student and the father, including time skiing, but never visited the RTC. Parents submitted a reimbursement claim of over $3,200. The district agreed to pay most of the father's expenses but refused to reimburse any of the mother's costs, arguing her trip was a family ski vacation, not a therapeutic visit.

What the ALJ Found

The ALJ sided with the district on the central issue. Under the IDEA, transportation and related expenses for parental visits to a residential placement can be reimbursable as a "related service" — but only when the student's IEP specifies that such visits are necessary, or when there is clear evidence that the student needed the visits in order to receive a free appropriate public education (FAPE).

Here, Student's IEP did not include any goals related to family visits or family therapy. There was no evidence from Student's therapist or any other professional that Student required in-person visits with his parents — outside of the formal therapy session — in order to make educational progress or receive a FAPE. The IEP simply stated that transportation would be reimbursed according to the district's September 2007 travel guidelines. Those guidelines explicitly limit reimbursement to trips made for the purpose of attending family therapy at the RTC. Because the mother did not attend the therapy session and did not visit the school at any point during the trip, the ALJ found her expenses were not covered.

The ALJ also resolved several disputed line items in the father's expenses. The district had underpaid on airport parking (two days instead of three) and applied an arbitrary $40/day cap on rental car costs that was not in its own written guidelines. The ALJ ordered the district to pay the father's actual pro-rated rental car costs and corrected the parking reimbursement.

What Was Ordered

The district was ordered to reimburse the father's allowable travel expenses totaling $1,611, broken down as: $1,029 for airfare; $280 for two nights of hotel; $96 for two days of meals; $36 for three days of airport parking; $140 for two days of rental car; and $30 for pro-rated gasoline costs.
The mother's airfare and all other expenses for her trip to Vail (February 15–17, 2008) were denied.
The father's claim for Alamo's refueling surcharge (charged because he returned the car without a full tank) was denied — the ALJ found no justification for passing that cost to the district.
Hotel valet parking charges were denied because the district's guidelines do not cover hotel parking, regardless of weather conditions.

Why This Matters for Parents

Your IEP must specifically support the visits you want reimbursed. Courts and hearing officers consistently look first at whether the IEP includes goals or language requiring parental visits. If your child's IEP doesn't mention family therapy visits or the need for in-person family contact, you have a much weaker case for reimbursement. Work with your IEP team to include this language explicitly if family visits are part of your child's therapeutic program.
Attending the therapy session is not optional if reimbursement depends on it. District travel policies that tie reimbursement to attendance at a specific therapy session will be enforced. If a parent misses the session due to an emergency, the district is not automatically required to cover the costs of an alternative visit — even a genuine family visit — unless the IEP or evidence shows the child needed it for FAPE.
District travel policies incorporated into an IEP become legally binding on both sides. When an IEP states that transportation will be reimbursed "per district guidelines," parents are agreeing to those guidelines' limitations. Read any travel policy carefully before signing an IEP that references it, and push back during the IEP meeting if the policy is too restrictive for your child's needs.
Districts must follow their own policies — vague caps can be challenged. The ALJ rejected the district's arbitrary $40/day rental car cap because it was not written into the guidelines. If a district denies or reduces your reimbursement based on a rule that doesn't appear in its written policy, you may be able to challenge that reduction through the IEP process or due process.

What Happened

What the ALJ Found

What Was Ordered

The district was ordered to reimburse the father's allowable travel expenses totaling $1,611, broken down as: $1,029 for airfare; $280 for two nights of hotel; $96 for two days of meals; $36 for three days of airport parking; $140 for two days of rental car; and $30 for pro-rated gasoline costs.
The mother's airfare and all other expenses for her trip to Vail (February 15–17, 2008) were denied.
The father's claim for Alamo's refueling surcharge (charged because he returned the car without a full tank) was denied — the ALJ found no justification for passing that cost to the district.
Hotel valet parking charges were denied because the district's guidelines do not cover hotel parking, regardless of weather conditions.

Why This Matters for Parents

Your IEP must specifically support the visits you want reimbursed. Courts and hearing officers consistently look first at whether the IEP includes goals or language requiring parental visits. If your child's IEP doesn't mention family therapy visits or the need for in-person family contact, you have a much weaker case for reimbursement. Work with your IEP team to include this language explicitly if family visits are part of your child's therapeutic program.
Attending the therapy session is not optional if reimbursement depends on it. District travel policies that tie reimbursement to attendance at a specific therapy session will be enforced. If a parent misses the session due to an emergency, the district is not automatically required to cover the costs of an alternative visit — even a genuine family visit — unless the IEP or evidence shows the child needed it for FAPE.
District travel policies incorporated into an IEP become legally binding on both sides. When an IEP states that transportation will be reimbursed "per district guidelines," parents are agreeing to those guidelines' limitations. Read any travel policy carefully before signing an IEP that references it, and push back during the IEP meeting if the policy is too restrictive for your child's needs.
Districts must follow their own policies — vague caps can be challenged. The ALJ rejected the district's arbitrary $40/day rental car cap because it was not written into the guidelines. If a district denies or reduces your reimbursement based on a rule that doesn't appear in its written policy, you may be able to challenge that reduction through the IEP process or due process.