Due Process in Special Education

Marisha (00:01)

Hello there and welcome to the podcast. I'm really excited to have Angela Buchanan-Smogula with us today.

She is a founding partner of Khan and Smigula, a two-woman law firm specializing primarily in education law. And they represent a variety of schools, including public schools, which is where most of our audience kind of lives. But she also co-hosts a podcast that focuses on special education. It's called a special education teacher, administrator, and lawyer walk into a bar, all you ever wanted to know about special education.

So that is another amazing resource. And I'll link to the podcast in the show notes so you can find out more. this quick bio doesn't do Angela justice at all. So Angela, would you mind telling us just a little bit about your story? What led you to specialize in working with?

like in education law and a little bit of your journey there before we dive into all things due process.

Angela Smagula (01:05)

Sure.

Yeah, sure, no

problem. Thank you so much for having me. I really appreciate it. My entrance into special education law sort of takes a securitas route. I went to law school after working in publishing, actually, and then didn't take any administrative law classes, didn't take any education law classes, didn't even know that I was aware of special education from volunteering.

in my high school with students with special needs. But other than that, I sort of wasn't aware of it at all. And then I was a big ticket litigator in Boston for a number of years and ended up leaving that after having my first kiddo and went to work for a municipality, the city of Newton in Massachusetts. And through working there, that city's law

office was big enough that they represented everyone in the city, so they didn't have any outside representation, and that included the Newton Public Schools, which is a giant school system. It's the third largest school system in Massachusetts. And through that, I started doing education work and learning about special education and discipline and all the stuff that goes along with it, and I loved it. Really, it became...

sort of my life work in terms of focusing on sort of the grassroots nature of it from the school side. And that's kind of how it went. And the podcast that I have that you mentioned, and I appreciate that, and I hope people listen to, are two people that are much more knowledgeable than me actually about special education, an administrator and a teacher, friends of mine now through work.

And through that we've sort of carried on and in opening my own practice, part of what we do for schools is represent them with regards to special education. And that doesn't only include due process, which we're gonna talk about today. It also includes sort of like day to day work and guidance and being a thought partner. And the districts that I represent, I know it can be contentious between families and school districts.

And as a litigator, I don't mind that. But at the end of the day, the idea is to work collaboratively and assume good intentions. Parents want the best for their kid. School districts that are implementing special education want to do what they think is best for their students. And so if you go in with sort of that view, I think it's helpful.

Marisha (03:35)

Yeah, I love that you mentioned that because that has been a common thread in our interviews is that like we all want what's best for students. Like we don't become special education administrators to become rich and famous. Like there's definitely a mission behind that. And parents obviously want what's best for our kids. it's just figuring out sometimes it doesn't connect quite right, but that is the ultimate.

Angela Smagula (03:48)

Correct.

Marisha (04:00)

goal, which makes this probably a nicer area of the law to navigate potentially. I don't know.

Angela Smagula (04:08)

Yeah,

well, what I often equated to is like a marriage. So a public school system implementing special education for a student is, you know, K through 12 or potentially K through 22. And that's you have to work with people despite having potentially disagreements or having to come to some sort of negotiated collaborative agreement along the way. Sometimes it's going well and sometimes it's not. But it's it is a relationship.

that lasts sometimes longer than some marriages. So you need to be aware of that, and I think people are, and I think lawyers that become involved, either on the parent side or the school side, also need to be aware of that. It's not a situation where you're gonna burn it to the ground in order to win. That's not really the goal.

Marisha (04:53)

we don't want to burn our public schools to the ground. Well, maybe some of us do. I don't know. Okay, but that's a super helpful introduction.

Angela Smagula (04:56)

you

Marisha (05:04)

And then, so let's transition to chatting a little bit more about due process. So can we start with a super broad overview of kind of what due process entails within the context of special education? I know that's a big question, so you can kind of hone it in however you think makes the most sense, but.

Angela Smagula (05:24)

Right, so

due process is a legal procedure that, it's sort of the umbrella legal procedure that allows parents and guardians to challenge decisions that are made by schools regarding their child's IEP or their child's 504. And the reason due process is available, and you'll hear about due process in all sort of walks of life, but the reason it's here is that you're,

The education is a right and not a privilege. So if you have a right to something, like you have the right to free speech, you have the right to education, then along with that comes due process that allows you to engage in a way to make sure that you have that right. And so the IDEA, which is the governing, you know, statute with regard to special education, specifically IEPs,

has, allows for that, so speaks to that. So that, you know, when you have the, when education is a right and not a privilege, then you're entitled to certain things. And so that you can exercise your entitlement to that through the due process system. Does that make sense?

Marisha (06:35)

Yeah, that makes sense. so the laws are intended to protect our students to make sure that they have that right. like, how do the... So how are the laws set up to help enforce that?

Angela Smagula (06:51)

So the laws are set up to help enforce that because the IDEA requires all of the states to follow their statutory framework with regard to due process hearings. And so you have an outlet when you are dissatisfied with the school with regard to accommodations and services, not following the IEP, not providing an appropriate placement, not providing FAPE, not addressing behavioral or disciplinary issues appropriately.

When you have a disagreement with the school, the school doesn't just get to say, sorry, we're right. So it allows for another level of review. And so the states all have their own regulations. In Massachusetts, it's the CMR. And so each state has regulations that further implement what the IDA proposes or mandates in terms of due process. what that looks like, and states can always do more.

know, federal law lays sort of like the baseline of what must be done. So the IDA lays the baseline of what must be done. And then states can always do more. They cannot do less. And so as like the baseline, the IDA mandates that states set up administrative hearings. So it's usually under like the administrative setup within that state. hearings are held.

due process hearings are held with a third party, a hearing officer, depending on what it's called state by state, that then hears evidence. So it's not just opinion, it's not just, don't think this is right, it's not just the school doesn't get to say this is all we can afford, the family doesn't get to say my kid is, you know, requires this because I want it, right? It's based on witness testimony and evidence.

and a third party will determine, depending on what the issue is, but at the end of the day, you know, that a student is making effective progress in the least restrictive environment and receiving a FAPE, that's like the umbrella issue that can be brought to a hearing, but within that are lots of smaller issues that can also be brought.

Marisha (08:56)

And what are some examples of those smaller issues?

Angela Smagula (09:00)

So

it can be a sort of a number of things. It can be concerning whether the school is actually implementing the IEP as written. The IEP is a contract, serves as a legal document. And of course, schools are mandated to provide a free and appropriate education in the least restrictive environment. And they need to provide enough specialized instruction for the student to be making documented effective progress. So.

Any of those issues can be brought as narrow as you want or as broad as you want. Often placement is an issue. So the law requires that students are educated in as inclusive environment as possible, right? Because in the old days, not that long ago, special education students were siloed in separate classrooms. And so the law changed that.

Every child is unique and individual, right? And so what they need is also unique and individual. And so depending on their profile, their disability and their need for specialized instruction, where they fall on the continuum of inclusivity can be up for debate. There can be a difference of opinion about that. And that turns on sort of where your placement is. So that's often a big issue. There's also issues as it relates to discipline. If you listen to my podcast, that's...

one area that I can yammer on about forever, but special education students have the same rights as regular education students plus more. And so often there can be disagreements that can come to hearing about that as well. Essentially, anything that has to do with the creation and implementation of 504s or IEPs are

are gonna be fair game within a certain timeframe. So the statute of limitations, which is a limit on how long back you can go for claims. So like if I have a eighth grader that I'm concerned about in terms of making effective progress, documented effective progress in their program, I can't go back to fifth grade and talk about it in terms of.

evidence for purposes of eighth grade. I can go back that far historically and you'll see that because it's, you know, again a long story. It's a child's life. But in terms of actual claims and compensation for those claims, and by compensation I don't mean money, I mean placement or services or additional requirements that the school district has to do, it can only go back two years from the date that you file.

So if you have a concern about an implementation of your student's IEP and you're sitting in the fall of sixth grade, you shouldn't wait till high school to bring that claim. Does that make sense?

Marisha (11:50)

Yeah, so if a parent is having a concern, they need to bring it up within those two years. Okay, yeah, that makes sense. then, so what are the steps involved? because I'm, and we're looking at this from the perspective of...

Angela Smagula (11:57)

Correct.

Marisha (12:07)

the school district, like the special education administrators or school administrators. And so they wouldn't be filing complaints, but just to give them, in case they're curious about that process, what are the steps involved in filing a complaint and what does that typically look like?

Angela Smagula (12:25)

So sometimes school districts do file complaints, for sure. But what it looks like for either party to file a complaint is you do not have to have a lawyer to file a complaint. So parents can file, it's Latin called pro se, which means they file for themselves. Districts can also file pro se, but they often have lawyers available to them.

You have to file an actual written document that identifies the complaint that you're making, the name of the child, the name of the school district, and the remedy that you're looking for. And it doesn't have to be, you know, the best thing ever written. It doesn't have to include

every single thing that you're concerned about, but it has to include an identification of issues that you want the hearing officer to decide. And even if a parent is writing something pro se, the hearing officer will get the parties together, usually telephonically, and make sure that everyone's on the same page about what the issues are. And then there can be

motion practice about excluding issues that may not fall within the jurisdiction of the BSEA or that's sorry, that's the administrative hearing of the Bureau of Special Education Appeals. That's what it's called in Massachusetts. But any sort of administrative hearing will have areas of jurisdiction as it relates to what I said about special education being implemented pursuant to an IEP or a 504. And then

The school district has the opportunity to write a hearing response. Again, it doesn't have to be your entire argument because, again, the hearing officer is not going to make any decisions based on those filings. The hearing officer is going to make a decision on a hearing, at a hearing with actual live testimony and actual documentary evidence. But the filings are necessary to identify the players, the issues, the time frame.

all that kind of good stuff. And then, I'm sort of jumping ahead, but just to put a bookend on it, when you have an IEP due process hearing, can go over a number of days, and then the hearing officer can sort of find the following things. The hearing officer can find that the school district's proposed IEP or the issues surrounding the IEP are appropriate and deny the family's request for changes or more services.

The hearing officer can find that the school district's proposed IEP is not appropriate and actually tell the school district what changes need to be made. So amend the IEP. And then the hearing officer may find that the school district's proposed IEP is not appropriate and then order additional services, order a different placement, and legally make a decision that the school district has to follow.

Marisha (15:26)

Yeah, that makes sense. So they're either deciding if it's appropriate or not. And if it's not appropriate, it may result in updating the IEP or setting up additional services or just remediation for whatever that is.

Angela Smagula (15:40)

Correct, so compensatory

services or ordering a different placement. Like oftentimes the decisions are turned on the school district saying we're able to provide FAPE in the least restrictive environment in our public school. And a parent, for example, is saying like, no, my student needs an out of district placement in a special education school. And the hearing officer has the ability to order that based on the evidence. So it has become like a very

Marisha (15:56)

I see.

Perfect.

Angela Smagula (16:08)

What's the best way to put this? Steeped in statutes and regulations. So it's become a very legal process that often requires lawyers, which is great for people like me, maybe not so great overall for families and special educators. I always say when I'm prepping my witnesses, no one went into education to like,

prep with Angela and testify at trial. Like that's not why people go into special education and families trying to get services for their students. It's not their goal to also spend time and energy testifying about why they need it. no one's happy except for me, the lawyer, right? But so, you know, but because again, education is a right and not a privilege, it inherently involves the government and the state.

mandating that certain processes are followed. And when that happens and it becomes codified in statute or regulation or law, you know, it inherently requires process that often requires attorneys.

Marisha (17:15)

Yeah. Yeah. So do you, do you have any idea how many times someone files pro-save? Like does that, cause I guess you're allowed to do it, but do those filings tend to go well? Like what is a lawyer eventually or attorney eventually roped in?

Angela Smagula (17:39)

So there are cases that go all the way to decision that are pro se, for sure. What I would say is that it can be an, like the special education process, even attending team meetings is an overwhelming process for families. And again, it's because it's, the devil is in the details, right? So the school district.

Marisha (17:55)

Yes, absolutely.

Angela Smagula (18:03)

has certain responsibilities that they need to follow. They need to provide, they need to demonstrate effective progress in the least restrictive environment. The school district's view of effective progress is not the best possible thing ever. That's not what the law requires. And so a family member might think, I want the best possible thing required. So there's going to be inherently some...

potential conflict in that. And then in terms of like what is being offered as specialized instruction, I mean, it's just, and with the new IEP, you know, it's just very, it can be very overwhelming. So take that and multiply it by a hundred when you go to hearing, right? Because the hearing rules require a list of witnesses, like a list of documents, the ability to examine and cross examine witnesses. So,

The law allows for parents to go pro se, and actually the way that administrative hearings are set up, is some consideration made for pro se parents, But in my opinion, you're better served by having an attorney to work on your behalf, but of course then that becomes like a financial issue. Now.

Under special education law, this is one of the few statutes that exist that allows for fee shifting. And what that means is if you are the prevailing party at hearing, i.e. you win the majority of the claims, then the school district has to pay for your legal fees. So they do that to allow, you know, to open the door for more opportunities because you don't want the concept of

having to pay for a lawyer restrict you exercising your rights, but you have to win. So if you don't win, then you're still on the hook for your legal fees. So it can be sort of complicated in that

Marisha (19:55)

Thank

Yeah, yeah. do you feel like, like do attorneys in general, do they have a good, I'm just curious, like if a parent brings a case, is it often super clear of like, yeah, this will, like the hearing officer will, like we think this will be the hearing officer's decision. Like, is it easy to predict or is it less clear?

I don't know, does that question make sense?

Angela Smagula (20:31)

It does make sense. what I would say is that it's not. And because there's so many factors and both parties have dug in to their view that they're taking it to a third party. And usually there's going to be some opportunity. There is opportunity to resolve it short of a hearing. So if you actually are ending up at a hearing,

Marisha (20:35)

Okay, because there's so many factors, right?

Angela Smagula (20:57)

then I think it's not straightforward. And I think it's not a slam dunk for either side. Otherwise it would have been resolved short of that. That's not to say someone's not right and someone's not wrong. It's just that it's complicated and nuanced. prior to filing a hearing request for due process purposes, there's lots of opportunities within the law to resolve it short of that. And that looks like a

couple of things. You can do that at the team meeting level. You can do that at mediation level, like departments of eds in all states offer mediation that's free related to the due process within that state. So you can go to mediation. Also, when you file a hearing request, the law requires

the district and the parents to have a resolution meeting unless it's waived. So that's another opportunity without lawyers for people to come together and try and resolve the issue. Sometimes the threat of litigation by a family is enough for a school district to move forward. So there are lots of opportunities for these two parties to come to some sort of resolution.

short of a hearing.

Marisha (22:14)

Yeah, that makes sense. And then, gosh, there's five million directions we could take this. So I think my last question, just from your perspective, so let's say that a school district, like what tips or strategies or like what advice would you share with a school district administrator who is maybe navigating, like let's pretend it's their first

due process or just like tips for due process in general, like what would you say to district administrators in terms of maybe a couple like top considerations?

Angela Smagula (22:52)

So what I would say to district administrators is to involve their council, if they can, as early as possible. In terms of like, if you think there's concerns or sometimes if there's a disagreement about services and you're wondering sort of where to land on it. To partner with other administrators in your district that have had experience with that.

or that have had experience with the family, and partner with your counsel, if you can, to determine sort of what the issue is and can it be resolved or can we come to some sort of agreement prior to it getting to litigation, prior to a filing. Now, other tips and advice around that is that, you know, once there is a filing, we want to make sure from the school perspective that we have all our ducks in a row.

Like is our paperwork good? Are there procedural errors that are gonna be problematic for us or that are harmless? Like we wanna be able to go to hearing with the best possible position. And so what that means is listening to what the families have to say and understanding their position and not just saying they're wrong because you want them to be wrong or because you think you're right. So you have to have the ability to be thoughtful and flexible to the extent that it makes sense. And then,

from my perspective, and you would pick this up when you listen to my podcast and my two former colleagues now friends, is like, be prepared. So I prepare my special education administrators and teachers so that they understand what is important in terms of evidence and what is important in terms of the issues at hand.

I always emphasize telling the truth. You're testifying under oath. You must be honest. And at the same time, you must also provide the information that the hearing officer needs to hear with regard to why you're taking a position that's counter to the family. It can't just be that, like, that's what you think, right? It has to have evidence in support of that. And you have to have data. So data, data, data.

Like the data is most important for purposes of evidence because parents will feel how they feel and they will express concerns about progress, about programming, about instruction. And our responsibility from the school side is to be able to demonstrate and quell their concerns with data. And then if we disagree, we disagree.

And so that's why it's important not to sort of get bogged down in personalities or in long-term difficulties or historical difficulties. It's really about the data and the support for why we think this service is appropriate, why we think this placement is appropriate, and why we're defending that, short of saying the kid needs something different.

And at the end of the day, sometimes people are like, what's the big deal? Well, there's a financial component to it. But obviously, also, it's like, what is in the best interest of the child? And out of district placement is inherently a more restrictive setting. For some kids, that's fape. For some kids, it's not fape. And families and school districts can disagree on that.

Marisha (26:24)

Yeah, and that's the part where it gets all, that's where it gets so intricate because what's faked for one student isn't for the other. But then it really, that's why it does come down to the data of like, we seeing that progress? And yeah.

Have that evidence. That's one big takeaway.

Angela Smagula (26:43)

That's,

you know, like my clients will tell you that I'm all about documentation and all about data. And documentation is important too, again, as it goes to sort of procedural due process. So procedural due process is about following what the regulations and the statutes say in terms of what you have to do. You know this, everyone knows this, there's X number of days that you have to do an evaluation by when you get the consent and there's...

X number of days that you're allowed to discipline someone until you have to add more, you know, process to that. And if you, if you, if you don't have, if you make procedural errors, you know, the question becomes like, does that, is that a negative, enough of a negative impact on the student that something, that changes need to be made. So it's very important to make sure that you're following all the procedures because sometimes it's harmless error, but sometimes it's not.

and you want to be in the best position that you can be. And again, that process is there because that's what the student is entitled to, right? There's a reason you get handwritten notes if you're going to get the IEP 10 days later, you know? And there's a reason why you have 30 days to respond to the IEP. Like these are all, they're not just like there to make everyone's life difficult. They're there because...

Go back to like my friend put it on a t-shirt for me. Education is a right and not a privilege. And when you know that and you think about that, that should guide sort of all the decisions that you're making in terms of following all the rules and regulations.

Marisha (28:16)

That's great. And do you ever work with districts on, because it's simple when you boil it down like that. Just make sure you have your documentation and your data and keep the student's best interest in mind and thinking about education being a right.

But I think the implementation of this gets challenging, like in a school setting, in an imperfect world where we have staffing issues and funding issues and all of that. So have you, gosh, and this would probably be a whole other podcast too, but I guess I'll keep it simple. Like, do you ever work with districts in being more proactive in setting up those types of things or like auditing their?

current systems and processes or anything like that or no.

Angela Smagula (28:59)

Yes, so like,

you know, the state will do an audit on that as well when they do the state audit and they'll pick up on those things. But yes, I mean, we do a lot of, I do a lot of work around that and it's often sort of like learning by doing. So like a good example of that is, you know, when you offer something verbally in a meeting or in a conversation and then you don't document it anywhere. And then they later say like, I don't ever remember that. And they might not.

Marisha (29:03)

Yeah.

Angela Smagula (29:25)

remember that, right? But you need to document it so that you have it. it doesn't actually what I often say, one of my catchphrases is it doesn't really matter what the answer is. Like if you're asking for consent, you have to do it in writing. And it doesn't matter if they say yes or no, actually, it's more important that you that you made the offer in writing, because later we're going to have a disagreement about it. And we're going to want to be able to demonstrate that we for procedural purposes that we that we asked for consent.

that we made that offer, we heard them say that they want an evaluation, and that we responded, right? I can't tell you like how many conversations and disagreements I've had where they say they offered it, but there's no evidence of it. And the family doesn't remember. And it may well not be, and they deny it, and they say that it was never offered. And it may well be that they don't actually have a real memory of that.

because again, it's a stressful environment, especially if it's sort of contentious. So it's really important to document things and the answer almost doesn't matter.

Marisha (30:25)

Yeah, that's great. So I think we can. This was super helpful. I really appreciate. I know these questions were a little tricky and super broad. There's so many areas to dive into with this, but I feel like you did a really nice job of breaking things down and making them a little bit more digestible. So thank you. And then so if district administrators want to kind of learn more about.

Angela Smagula (30:39)

I'm so glad.

Marisha (30:48)

what you do, well, definitely share the link to the podcast. But is there, and we have the link to your practice website as well, or your law firm. Is there anywhere else you would want to send administrators?

Angela Smagula (31:01)

Yeah, mean, so I would recommend, shamelessly recommend listening to the podcast. There's a lot of episodes. I mean, we're on season, I think we're in season four, but you can go through the episodes and click on what you want and you can listen to them sort of like by interest. There's a lot of, mean, because we have an administrator and a teacher, like a very experienced administrator and a very experienced teacher, now administrator, I mean, multiple, multiple decades.

Marisha (31:07)

great resource.

Angela Smagula (31:28)

There's just a lot of really good specific episodes, like the one, two, threes of IEPs and about FAPE and about evaluations, like very, very specific episodes that I think would be helpful. We get a lot of feedback. Also, when we talk about these issues, like one of my co-hosts often tries to sort of like say directly, like, is helpful to teachers because of X or this is helpful. The takeaway we want you to have is why. So I think it's very, very helpful and informative.

If people have like individual questions that they want to raise with me, they can contact me on my LinkedIn, which I'm happy to have you include. Also, we have email that related to the podcast where people write in questions directed often at me or just in general that's also available to people. I'm happy to and we get like our listeners. It's interesting, like our platform.

indicates like where our listeners are from. And when we first started doing this, we thought it would be sort of very Massachusetts and New England centric, but it's not like we have a massive amount of listeners in like Illinois and a massive amount of listeners in like a town in Kansas. Like we have a lot of listeners and then we also have like international listeners as well, which is interesting too. So I'm happy to respond to any questions and I can provide you with the.

the email address that you can put in your show notes if that's helpful.

Marisha (32:49)

Yeah, that would be great. And I also will add a link to your LinkedIn profile. But yeah, so we'll have some great resources in the show notes. They'll be linked in the description for the episode. And yeah, think, is there anything else? I don't want to cut you off. Is there anything else you wanted to close out with or are you feeling?

Angela Smagula (33:09)

Well, I just wanted to say in terms of like the whole continuum of due process, like I did want to mention that if you disagree, if either party disagrees with the hearing officer's written decision and they have to write a decision that's often extremely detailed within a certain number of days, that is appealable in your state according to the regulations in your state, often to either state court.

or federal court, right? And federal court has jurisdiction because of the IDEA, state court has jurisdiction because of the state regs. So that's another layer of due process that's allowed for, for both parties for purposes of if you think they've gotten it, they've gotten it wrong.

Marisha (33:49)

So this could end up being quite a lengthy process.

Angela Smagula (33:54)

It is a lengthy

process. Now, what I will say is that the law requires and the feds have been pretty good on states, specifically Massachusetts, I'm aware of, of making sure that the administrative hearing officers follow their timelines, right? that, so, but it's still, you know, from the day that you file a hearing request, there's going to be extensions, reasonable extensions. There's going to be

a variety of things that that cause things to get delayed. So let's say you file January one. Let's say you have a hearing by the end of February, then they have to generate a decision within 60 days, like you're four months in. Right. And so there is there are like the ability on certain issues and we could do it as another podcast on that for emergency expedited filings. But

You know, it can be that you don't have a decision for months, even in the most efficient of processes. So, yeah, it is time consuming. What I would say again is that like the only person that loves litigation is me. No one else loves it. So, you know, at the end of the day, you know, you want to try and work collaboratively. There's also, I didn't mention, opportunity to work.

Marisha (34:57)

you

Angela Smagula (35:06)

collaboratively short of a hearing decision once you're within the hearing. So for example, in Massachusetts, we have something called a settlement conference that a different person at the agency runs that allows for you, after filing a hearing request, to potentially resolve the case. Also, hearing officers allow for something in Massachusetts and I know in other states called a pre-hearing conference where you can also try and resolve the case. The lawyers can talk to each other and try and resolve the case.

So there's lots of opportunities to do that. Sometimes filing a hearing request is the only way to get someone's attention. That can be true, but that doesn't mean that you're gonna definitely go to hearing. And again, it's very time consuming for both parties. It's very stressful for both parties. It's very expensive for both parties. And at the end of the day, you don't walk away and say like, see you later, bye. Because even if you're placing the student out, like you're still,

monitoring that placement. You're still responsible as a school district for that child's education, even if they're in an out of district placement that you've been told to place them in, or you have decided that you need to place them in. So it's a long standing relationship. Going back to what I said in the beginning, you know, hearings can take a lot out of people, all people, everybody but me, again.

Marisha (36:25)

Thank

Yeah, that was super helpful. Thank you for breaking that down and explaining it in such a clear way. And then, yeah, for anyone listening, thanks for joining us. Definitely check out the show notes for the resources mentioned. And thank you, Angela, for being so generous with your time and expertise. This was great.

Angela Smagula (36:45)

Thank you so much. I really enjoyed it.