Are Maine Public Schools Violating IDEA? And Other Questions About Maine’s S2C Pilot Program
In my last blog post, I discussed Maine’s Spelling to Communicate (S2C) Pilot program that is being funded by the Maine Department of Education and my reactions to it. S2C is a variant of Facilitated Communication (FC) that, like FC in the early 1990s, has spread across the U.S. like wildfire without apparent deference to the body of research that seriously calls into question authorship obtained using facilitator-dependent techniques and thoroughly discredits FC.
Proponents claim S2C isn’t FC since “traditional” FC was touch-based, whereas S2C is purported to be a “no-touch” technique.. But those of you who regularly follow our blog will know that the so-called no-touch forms of FC (like S2C) were born out of proponents’ desire to rebrand FC and make it look more “independent.” (See my blog post Clever Hand(s) Skepticism and “Ido in Autismland”).
Proponents have been successful in rebranding FC, so it can be confusing for those new to the topic to realize that S2C (and other variants) are, in fact, FC. Over the years, we have collected over 20 different pseudonyms for FC and listed them on the homepage of our website. The common denominator with all forms of FC is facilitator interference with letter selection. This interference comes through visual, auditory, and verbal cueing, and often facilitators are unaware of the extent to which these cues influence and control letter selection. To the facilitators, the FC-generated communications feel real. Many facilitators are unaware of the extent to which their own behaviors interfere with their clients’ ability to independently select letters. (See my blog post An FC Primer to learn more about facilitator cueing). Over time, facilitators start focusing on the “hits” (e.g., times when the FC-generated messages seem correct) and forgetting or ignoring the “misses” (e.g., times when the FC-generated messages are unintelligible, incorrect or inane).
With the reintroduction of FC into Maine’s schools (under the guise of S2C), it appears that Maine schools are on course to repeat history. I was (unfortunately) involved with FC as a believer when the technique was popular in Maine and across the United States in the early 1990s. So, for me, the news of the S2C Pilot program in Maine hit hard.
But…
…this time around, I’m on the skeptics’ side of FC/S2C/RPM. So, I reached out to some colleagues of mine for help. Together, we wrote a letter of concern intended for the superintendents and special education directors of Maine’s public schools. I’ve included the letter (below) and have permission from my colleagues to include their names along with mine in this blog post. I’m grateful for their support and for their willingness to speak out publicly against pseudoscience.
Since my last post, a contact (thank you!) sent me information obtained through a Freedom of Information Act (FOIA) request. The packet I received contains mostly emails in the planning stages of the project. Through those emails, I was able to pick out some key players in getting the money procured for the project: Elizabeth Vosseller (the “inventor” of S2C); Anna Shoenfeld, Vosseller’s Director of Operations; a superintendent (who uses S2C with her own child); an assistant superintendent; and officials at Maine’s Office of Special Education Services and Inclusive Education. At this point, I’m not releasing all the names (except to some government officials you might want to write to on your own), but I sent a letter of concern to every--or nearly every--superintendent and special education director across the state. I got the list off a government website, so I’m not sure how up-to-date my list was. Nonetheless, the letters went out to everyone I could think of, including the superintendent who I believe played a key role in getting the pilot program up and running. I know how the person responded based on the FOIA documents (the person wrote to Vosseller that her “blood was boiling” after receiving the letter my colleagues and I wrote), but as of the writing of this blog post, I have not heard from the superintendent directly.
Note: I wonder why the person was so mad? If S2C is not FC and the program is legitimate and evidence-based, the person should be able to respond to the letter with reliably controlled research to back up claims by proponents that S2C produces independent communication free from facilitator control. She should also be able to provide me with information demonstrating that the “spelling” program has evidence-based research to support the techniques being used by facilitators. The fact that she couldn’t easily back up her claims speaks volumes—especially considering that this person wrote a 2023 dissertation supporting S2C/RPM. I’ll leave a review of the dissertation for another day, but I will say that the document is shocking in its lack of critical analysis of FC/S2C/RPM. I find this a peculiar oversight since our website has been available to the public since February of 2021. A simple Google search would have given the person access to lists of Controlled Studies, Systematic Reviews, Critiques of FC, Opposition Statements, Critiques of Pro-FC articles, and more).
In any event, I believe I sent between 200-300 emails altogether and received replies from the superintendents of Lisbon, Winthrop, Yarmouth, and Skowhegan saying they were not using S2C in their schools. One of the four superintendents who responded specifically stated they were not participating in the pilot program. But that leaves a whole bunch of unanswered emails. As of the writing of this blog post, I was not able to confirm all of the school systems that are participating in the pilot program.
Image from ASHA’s website
However, thanks to the information in the FOIA request, I learned that the pilot program (ranging from educational technicians, special education teachers, and general education teachers) was offered to up to 12 educators across the state. According to the emails I’ve seen, the key recruitment for the program appeared to be in and around the St. George Municipal School Unit and the Augusta Schools.
Last year, one of our contacts (thank you!) sent me an April 2024 Lewiston Sun Journal article titled “Donna M. Perry: Face Time: Rebekah Carmichael-Austin: Giving Voice to others in Rangeley” that featured an S2C practitioner in the Rangeley, Maine area. Because of that, I wouldn’t rule out S2C use in that school system (with or without the pilot program). As of the writing of this blog post, however, I have not heard back from the Rangeley School District to confirm or deny FC/S2C use.
Also, according to the information in the FOIA request emails, I learned the initial cost for training is $3500 per person. The initial contract application gave a range of $50,000 to $200,000 for the pilot program, but I believe the final contract stated $50,000. I’ve included a screen shot of the first page of the service contract (below). Still, that’s a lot of money coming out of taxpayers pockets for a program that lacks scientific rigor.
Page 1 of the Service Contract for Maine’s S2C Pilot Program in the amount of $50,000.
I don’t have a lot more information to add at the moment, but I do have a lot of questions (listed below in no particular order). These questions are in addition to the information we included in our letter. Please let me know if I’ve left off anything from the list:
Were state officials apprised of S2C’s lack of scientific rigor during the application process? Were they made aware of S2C’s link with Facilitated Communication and were they given a list of organizations opposed to the use of facilitator-dependent techniques (including S2C)? (See Opposition Statements) and/or were they made aware that there is no reliably controlled research that supports proponent claims of independent communication? (See Systematic Reviews)
Is there a conflict of interest if a superintendent who already uses and believes in S2C pushes to get S2C into the school system? Should the decision to implement S2C in the school systems (or not) be made by individuals who can objectively look at the scientific evidence (or in this case, the lack of scientific evidence) regarding the technique in question? The FOIA packet only included individuals who were pro-S2C. Did the Pilot Program committee (at the state level or otherwise) make any attempt to research S2C and/or hear from any of S2C’s critics?
By introducing an unproven, disproven, pseudoscientific technique into the school systems, are Maine schools violating the Individuals with Disabilities Education Act (IDEA)? I believe the IDEA defines scientifically based research as “Research that involves the application of rigorous, systematic, and objective procedures to obtain reliable and valid knowledge relevant to education activities and programs.” As noted, S2C does not meet this definition. Is the use of S2C preventing individuals from having access to legitimate, evidence-based methods and techniques? (See my blog post Why Would a School System be so Dead Set Against S2C?)
If S2C is truly a “spelling” program (as marketed to the MDOE and, presumably to the school board members in the targeted school districts), what evidence-based methods are being used by facilitators to teach literacy skills? How do facilitators test for comprehension when S2C’s own guidelines recommend “presuming competence” in lieu of testing? (“Presuming competence” is a code word used by proponents of FC to mean “do not test”). What protections are in place to make sure the facilitators are not (overtly or covertly) “spelling” for their clients? (See my blog post An FC Primer to learn more about facilitator cueing)
Are supporters of the program aware that the use of FC long term has been shown to cause “abdication patterns” in individuals who have limited language and literacy skills before starting FC? In other words, students being subjected to FC “tune out” and allow the facilitators to do the work. Th longer FC is used, the more likely it is for the abdication patterns to appear. (See my blog post Abdication patterns in FCed individuals: a review of Bebko, Perry, and Bryson 1996)
Were the school board members that approved the program or the educators signing up for the program apprised of S2C’s lack of scientific rigor and the potential harms: facilitator cueing and control over letter selection, prompt dependency, false allegations of abuse, lost opportunity costs as individuals are prevented access to legitimate evidence-based communication methods and techniques? Are the board members, parents and educators aware that S2C proponents are taught that it’s “unethical” to participate in authorship tests? (See Katharine’s series: Spelling to Communicate Goes on Trial listed in the FC and the Legal System section of our website). Given FC’s long history of harms, shouldn’t facilitators want to be tested to make sure the FC-generated messages represent their students’ words and not their own?
Are there additional costs to maintaining the pilot program once it is up and running? We know from an analysis of a similar technique, Rapid Prompting Method (RPM) that costs above and beyond the initial training can be in the range of $19,000 per year for facilitators to remain “in good standing.” The journal Exceptional Children recently published a study called “An Economic Evaluation of Emerging and Ineffective Interventions: Examining the Role of Cost When Translating Research into Practice” by Gretchen Scheibel, Thomas L. Lane, and Kathleen N. Zimmerman. (Note: Vosseller trained as an RPM practitioner before starting her own version of FC/RPM rebranded as S2C).
Have the parents whose children will be subjected to S2C been fully informed about the Pilot Program (including its lack of scientific validity, potential harms, and the organizations who oppose its use)? Or is the S2C program being implemented without their informed consent? (See ASHA warns against Rapid Prompting Method or Spelling to Communicate)
Are parents aware that their children’s extant verbal and non-verbal communication skills may be discouraged, not encouraged when “spelling?” (See Katharine’s blog post An inside look at S2C: we actually discourage them from their speech while they are spelling)
Have parents given written consent to participate in a program that is (at best) experimental and (at worst) discredited and opposed by organizations such as the American Speech/Language/Hearing Association, American Association on Intellectual and Developmental Disabilities, Association for Science in Autism Treatment, and others? (See Opposition Statements)
Is reliably controlled authorship testing part of the Pilot Program? Will facilitators be required to participate in testing designed to separate their behaviors from those of their students to determine who is controlling letter selection? Will the tests include shielding the facilitator from the letter board or otherwise control for visual, auditory, or physical cues? (Controlled testing that blinds facilitators from test stimuli is the only reliable way to test for FC/S2C authorship and it is the one form of testing the majority of current-day facilitators refuse to participate in).
How will administrators reconcile the fact that licensed Speech/Language Pathologists are directed by their licensing organization (ASHA) NOT to use FC/S2C/RPM? (I believe this also applies to licensed psychologists and psychiatrists and Applied Behavior Analysis specialists as well).
Are government officials, school administrators, special educators, educators, and parents aware of the telepathy claims associated with S2C? Do they really want to open up that can of worms? (See articles about FC/S2C and telepathy in the Podcast section of our website)
What protocols are in place to test for authorship if allegations of abuse arise against educators, parents, caregivers or others?
Are administrators aware of the Lower Merion School District court case involving S2C? (Again, see Katharine’s series: Spelling to Communicate Goes on Trial listed in the FC and the Legal System section of our website).
From what I can gather from the FOIA emails, the following state officials were involved with procuring the Maine S2C Pilot Program:
Amanda Castner - Executive Assistant to the State Director of Special Services Office of Special Services and Inclusive Education. Email: amanda.castner@maine.gov
Erin Frazier - State Director of Special Services and Inclusive Education Office of Special Education Services & Inclusive Education Email: erin.frazier@maine.gov
And, finally, here is a copy of the letter we sent to Maine’s school administrators, special education directors, and other state officials. If you would like to adapt this letter to write your own letters, here is a link to the Maine Department of Education Staff Directory. Particularly if you live in Maine, you might also consider sending an email to the officials in your local school districts and the following people:
Maine Department of Education
Commissioner Pender Makin Emai: pender.makin@maine.gov
Deputy Commissioner Daniel Chuhta Email: daniel.chuhta@maine.gov
Associate Commissioner Megan Welter Email: megan.welter@maine.gov
Maine Government Oversight Committee
Senator Craig Hickman (Senate Chair) Email: craig.hickman@legislature.maine.gov
Representative Anne-Marie Mastraccio (House Chair) Email: Anne-Marie.Mastraccio@legislature.maine.gov
Maine Education and Cultural Affairs Committee
Senator Joseph Rafferty (Chair) Email: Joe.Rafferty@legislature.maine.gov
Representative Kelly Murphy (Chair) Email: Kelly.Murphy@legislature.Maine.gov
Dear (School Official/State Representative)
My colleagues and I are writing this letter to express concern for the training of select public school teachers in Maine in a technique called “Spelling to Communicate” (S2C). Many of the individuals who have signed on to this letter hold prominent positions in the field of autism, psychology, and/or speech/language development and have participated in reliably controlled authorship testing in facilitator-dependent techniques (e.g., FC/S2C and its variants) for over 30 years. Some also have served as expert witnesses in FC/S2C court cases. All are concerned that FC, under the pseudonym of S2C, is being reintroduced into the school systems without apparent deference for the existing scientific research that for almost 30 years has consistently shown that facilitators (not those being subjected to it) are the authors of FC-generated messages.
S2C is a variant form of facilitated communication (FC), a technique that was popular for use with nonspeaking, profoundly autistic individuals in Maine and throughout the United States in the early 1990s but was thoroughly discredited by the scientific community by 1995-1996 as noted in the PBS Frontline documentary Prisoners of Silence. Reliably controlled authorship testing of FC revealed that the assistant (called a “facilitator, “communication partner,” or “practitioner”) often inadvertently controlled letter selection primarily through physical touch. When the facilitators were “blinded” from test stimuli in controlled settings, the FC-generated responses were either unintelligible (e.g., the clients could not spell) or correctly spelled but divergent from the questions asked (e.g., facilitator guesses). In trials where the facilitator and their client were shown images (sometimes the same, sometimes different), the responses were consistently based on the facilitator’s pictures and not those shown to the individual being subjected to FC. (See links to controlled studies and systematic reviews below).
S2C purportedly differs from earlier “touch-based” forms of FC in that the facilitators hold a letter board in the air while the individual being facilitated extends a finger or pencil toward the board. In so-called “no-touch” forms of FC like S2C, facilitators still cue their clients, albeit now, by using much more limited physical touch than the original version relied upon. S2C and its offshoots rely extensively on visual cues (e.g., hand signals, head movements, shifts in body weight) and auditory cues. Auditory or verbal cues can include coaching the client to select a particular letter on the board by saying the sound of the letter at the end of a phrase encouraging the client to point to the board (e.g., “your turn-a” to cue selecting the letter “a”) and/or by getting the individual to point to a particular area of the board (e.g., “up, up, up” or “right next door”). The facilitators inevitably move the letter board they are holding in the air to aid in letter selection, even if some may be genuinely aware of the non-conscious “ideomotor response” and/or “Clever Hans effect” that precipitates these prompting movements. By controlling access to the letter board and providing cues, facilitators (covertly or overtly) are the arbiters of FC-generated messages as they judge whether a letter was or wasn’t selected and in ambiguous (and not so ambiguous) cases, which letter was selected, with decisions potentially based on which letter best fits the message the facilitator is (subconsciously) directing.
Additionally, there is no reliably controlled authorship testing for S2C that substantiates proponent claims of communication independence (Schlosser et al., 2019). In fact, prominent speech/language and autism organizations oppose the use of S2C (and other facilitator-dependent techniques) because of its undeniable similarities to FC and the complete lack of scientific evidence available to support it. (I’ve provided a list of organizations opposing S2C/RPM below with a link to a more comprehensive list of organizations opposing FC in general). Notably, the procurement application for the Maine S2C project importantly concedes that S2C is “evidence aligned” rather than the traditional “evidence based.” The traditional reasons cited by these organizations against FC include: prompt dependency, facilitator cueing and control over letter selection, lost opportunity costs (as individuals of S2C are often encouraged not to use extant spoken or nonverbal communication while “spelling” or use another evidence-based mode of augmentative and alternative communication [AAC]), potential harms (such as false allegations of abuse), and violation of a person’s human rights to communicate independently. Facilitator-dependent techniques such as S2C build dependence on the facilitator, not independence for the individuals being subjected to its use.
Permitting a variant of facilitated communication places speech-language pathologists in an ethical quagmire —caught between the rock of administrative policy and the hard place of professional integrity. As noted, the American Speech-Language-Hearing Association has made its position unmistakably clear: facilitated communication lacks scientific validity and should not be used. Endorsing it at the district level asks clinicians to cross a line drawn by their own profession, undermining both ethical practice and public trust. This policy doesn’t simply create tension; it forces highly trained professionals to choose between their employer’s directive and the scientific and ethical standards that define their field—a position no responsible clinician should be placed in.
You should also be aware that the use of facilitator or practitioner-dependent techniques like FC and S2C has generated lawsuits that generally fall into the following categories:
School staff members and school districts may face scrutiny for using discredited, unproven, or pseudoscientific or fad techniques in their classrooms (See Gorman et al., 2011). In a recent court case involving the Lower Merion School District in Pennsylvania, parents sued the school system for not implementing S2C. The court ruled in favor of the school district because the parents were unable to establish proof of communication independence via S2C and the school was not required to adopt techniques that lacked scientific rigor. The case was appealed twice. The lower court’s decision was upheld in the first appeal. In the second appeal, the parties settled after a failed authorship test was conducted on the stand. (Links below for more information). It should also be noted that in the court documents for this case, it was revealed that the State of Virginia’s Speech and Audiology Licensing Board fined S2C’s “inventor” Elizabeth Vosseller $8000.00 for practicing without a license from 2004-2017. (Links to information about FC and the legal system below).
School staff members open themselves up to false allegations of abuse (either as a facilitator who “supports” a child in spelling out messages against the child’s family or as a teacher or caregiver who is accused of abuse via FC-generated messages). To give just one example, in 2014 the Walled Lake School District in Michigan paid a million-dollar settlement in an abuse case based on FC-generated messages in which the falsely accused parents were jailed while the case was investigated (Anonymous, 2014).
School staff members who are not trained in or licensed as speech/language pathologists open themselves up to sanctions for practicing without a license.
In the procurement application (line 3), the applicant claimed that S2C was “unique in the country and there is no available price comparison for analysis.” However, in 2022, there was an economic evaluation completed of Rapid Prompting Method (RPM), a form of FC that is equivalent to S2C. (Vosseller trained first as an RPM practitioner before “inventing” her own version of the technique). According to the study, the associated costs for school districts to maintain facilitator training for RPM after the initial training were approximately $32,000 per student annually for a technique that lacked “strong empirical evidence of effectiveness.” (See Scheibel, Lane, and Zimmerman, 2022). These costs do not include the non-monetary costs of preventing individuals from accessing legitimate evidence-based forms of Augmentative and Alternative Communication (AAC). Because FC/S2C/RPM build dependence on the facilitator, not independence for those being subjected to the techniques, they are not recognized as legitimate, evidence-based forms of AAC. (See links to opposition statements below).
In closing, we would like the school districts in Maine and the State Department of Education to reconsider their decision to conduct a pilot program for S2C and/or require participants to undergo reliably controlled testing for authorship to ensure that the human rights of the individuals being subjected to S2C are not being violated. Reliably controlled testing (e.g., testing that separates facilitator behaviors from those of their client) is the only way to determine authorship with facilitator-dependent techniques and the only mechanism available to generate the necessary evidence to establish the merits of this methodology. With the introduction of FC (in the form of S2C) back into the school system, it appears Maine’s schools are repeating history by adopting a disproven/unproven technique without first scrutinizing it with scientific rigor.
If you would like further information regarding S2C, I would be glad to speak with you further and/or refer you to one of the experts below.
Best Regards,
Janyce Boynton, M.Ed. - Former facilitator and co-host of the skeptical website FacilitatedCommunication.org, Old Town, ME
Katharine Beals, Ph.D. - Adjunct Professor in the Autism Program Drexel University, Philadelphia, PA
Mark P. Mostert, Ph.D. - Senior Researcher, Able Americans, The National Center for Public Policy Research, Washington, D.C.
Evan Oxman - Associate Professor of Politics, Lake Forest College, Lake Forest, IL
Henry D. Schlinger, Jr., Ph.D. - Professor of Psychology, California State University - Los Angeles, 5151 State University Drive, Los Angeles, CA
Ralf Schlosser, Ph.D. - Professor Emeritus, Communication Sciences and Disorders, Northeastern University, Boston, MA
Howard C Shane, Ph.D. - Harvard Medical School, Boston Children's Hospital, Boston, MA
Mark Sherry, Ph.D. - Retired Professor, Disability Studies, University of Toledo, Toledo, OH
William Paul Simmons - Director and Professor of Human Rights Practice, University of Arizona, Tucson, AZ
Steve Sobel, MD - Retired, (former) Medical Director of Northwestern Counseling and Support Services, (Former) Assistant Clinical Professor of Psychiatry at University of Vermont, Colchester, VT
James T. Todd, Ph.D. - Department of Psychology, Eastern Michigan University, Ypsilanti, MI
Jason Travers, Ph.D., BCBA-D - Professor of Special Education, Temple University College of Education and Human Development Department of Teaching and Learning, Philadelphia, PA
References
Anonymous (2014). Michigan family awarded $3 million in lawsuit: Julian Wendrow falsely accused of assaulting 14-year-old autistic daughter. Click on Detroit News.
Gorman et. al. Psychology and Law in the Classroom: How the Use of Clinical Fads in the Classroom may Awaken the Educational Malpractice Claim https://digitalcommons.law.byu.edu/cgi/viewcontent.cgi?article=1281&context=elj)
Hemsley, B., Beals, K., Lang, R., Schlosser, R.W., Shane, H, Simmons, W., Skinner, S., Todd, J. (01 Oct 2025): Safeguarding the communication rights of minimally- or non-speaking people who are vulnerable to Facilitated Communication, Rapid Prompting (Spellers Method) and variants, Research and Practice in Intellectual and Developmental Disabilities, DOI: 10.1080/23297018.2025.2544116
Hemsley, B., Bryant, L., Schlosser, R.W., Shane, H.C., Lang, R., Paul, D, Banajee, M., Ireland, M. (2018). Systematic review of facilitated communication 2014-2018 finds no new evidence that messages delivered using facilitated communication are authored by the person with disability. Autism and Developmental Language Impairments, 3, 1-8. DOI: 10.1177/2396941518821570
Palfreman, J. (Producer). (1993, October 19). Frontline: Prisoners of silence. Boston, MA: WGBH Public Television.
Scheibel, Lane, and Zimmerman (2022). An Economic Evaluation of Emerging and Ineffective Interventions: Examining the Role of Cost when Translating Research into Practice. Exceptional Children. Volume 8 (3).
Schlosser, R.W., Hemsley, B., Shane, H. et al. (2019). Rapid prompting method and autism spectrum disorder: Systematic review exposes lack of evidence. Review Journal of Autism and Developmental Disorders, 6, 403–412.
Select organizations with statements opposing S2C/RPM include: American Association on Intellectual and Developmental Disabilities (AAIDD), American Speech-Language-Hearing Association (ASHA), Association for Science in Autism Treatment (ASAT), Australisian Society for Intellectual Disability (ASID), Centre for Augmentative & Alternative Communication, Irish Association of Speech & Language Therapists (IASLT), New York Office for People with Developmental Disabilities, Speech-Language & Audiology Canada (SAC), Speech Pathology Australia, University of Pretoria Centre for Augmentative and Alternative Communication (for a more complete list of organizations opposing FC/S2C/RPM, please visit: https://www.facilitatedcommunication.org/organizations-opposing-fc)
For more information about FC and the legal system, please visit: https://www.facilitatedcommunication.org/fc-and-the-legal-system
For more information about False Allegations of Abuse Cases, please visit: https://www.facilitatedcommunication.org/false-allegations
For more information about Controlled Studies, please visit: https://www.facilitatedcommunication.org/controlled-studies
For more information about Systematic Reviews, please visit: https://www.facilitatedcommunication.org/systematic-reviews