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Not automatically. Distinguish an agency-arranged private placement, a parental private-school choice under equitable services, and a unilateral placement seeking reimbursement for denial of FAPE. Who made the decision and why reimbursement is sought affect the analysis.
Three different situations
When the agency places or refers a student privately, §300.146 requires IEP services at no parental cost and preserves applicable rights. Voluntary private enrollment under equitable services can involve a limited scope documented through a services plan.
With unilateral placement, the family acts without agency consent or referral and may bear financial risk while the claim is decided. A letter or complaint filing alone does not make the placement publicly funded.
What Burlington, Carter, and Forest Grove establish
Burlington, 471 U.S. 359, 369–374 (1985), recognizes reimbursement as a remedy and requires consideration of educational appropriateness and equitable factors. Unilateral choice does not itself eliminate reimbursement, but does not ensure recovery.
Carter, 510 U.S. 7, 12–16 (1993), explains that lack of State approval of a private school does not itself bar reimbursement. The public offer must violate IDEA and the private education must be appropriate; cost and equitable considerations still matter.
Forest Grove, 557 U.S. 230, 247 (2009), clarifies that never having received public special education is not an absolute reimbursement bar. The remedy’s requirements still must be established; the decision does not guarantee payment for every private-school student.
Useful evidence for review
Keep evaluations, unmet needs, IEPs, offers and notices, along with the private program, services, progress, and expenses. School preference or an isolated failure does not alone determine the outcome. We can compare the proposals and review notice before removal or expenditure.
Consult before signing a Services Plan or rejecting an offer
We recommend not signing a Services Plan without prior legal advice. If seeking FAPE, request an appropriate IEP and a written public offer before evaluating that change. Do not certify rejection of an appropriate offer or interest only in equitable services if that misstates your position. Read the Services Plan explanation for funding-related waiting risks and due process limits for equitable services, including exceptions.
The answer for your situation depends on the facts and records. An inquiry does not suspend legal deadlines or guarantee that the office will accept the case.
Reference sources
34 C.F.R. §300.146 · Ubicación privada por agencia pública / Public-agency private placement34 C.F.R. § 300.148 · Private placement and reimbursement34 C.F.R. §300.137 · Servicios equitativos / Equitable servicesBurlington, 471 U.S. 359 (1985)Florence County v. Carter, 510 U.S. 7 (1993)Forest Grove School District v. T.A., 557 U.S. 230, 247 (2009)20 U.S.C. §1412(a)(1), (3), (5), (10) · FAPE, Child Find, LRE, private schoolsDEPR · Carta Circular 017-2025-2026, pp. 3, 7, 9–10 · Servicios equitativos 2026–2027Rules must be read in context. This explanation may require updating and individual review.