This case raises the question of whether, pursuant to 20 U.S.C. § 1415(E)(ii), a hearing officer may find a denial of a free appropriate education solely because the school district's violations of the Act's procedural safeguards "significantly impeded the parents' opportunity to participate in the decisionmaking process regarding the provision of a free appropriate public education to the parents' child," or whether the parents must prove separately and additionally that the child was denied a free appropriate education or deprived of educational benefit as a matter of fact.

Whether a violation of the IDEA's procedures that significantly impedes parents' opportunity to participate in the decisionmaking process regarding the provision of a FAPE constitutes a denial of a FAPE