Hammill Institute on Disabilities

Teacher Biases in the Identification of Learning Disabilities: An Application of the Logistic Multilevel Model Author(s): Georgios D. Sideridis, Faye Antoniou and Susana Padeliadu Reviewed work(s): Source: Learning Disability Quarterly, Vol. 31, No. 4 (Fall, 2008), pp. 199-209 Published by: Sage Publications, Inc. Stable URL: http://www.jstor.org/stable/25474652 . Accessed: 16/01/2013 19:09
Your use of the JSTOR archive indicates your acceptance of the Terms & Conditions of Use, available at . http://www.jstor.org/page/info/about/policies/terms.jsp

.
JSTOR is a not-for-profit service that helps scholars, researchers, and students discover, use, and build upon a wide range of content in a trusted digital archive. We use information technology and tools to increase productivity and facilitate new forms of scholarship. For more information about JSTOR, please contact support@jstor.org.

Sage Publications, Inc. and Hammill Institute on Disabilities are collaborating with JSTOR to digitize, preserve and extend access to Learning Disability Quarterly.

http://www.jstor.org

This content downloaded on Wed, 16 Jan 2013 19:09:14 PM All use subject to JSTOR Terms and Conditions

BIASES IN THE IDENTIFICATION TEACHER AN APPLICATION OF LEARNING DISABILITIES: MODEL MULTILEVEL OF THE LOGISTIC
Georgios D. Sideridis, Faye Antoniou, and Susana Padeliadu

Abstract. The purpose of the present study was to investigate the presence of teacher biases with regard to identification of stu dents with learning disabilities (LD). Factors related to teachers' investigated. Results suggested that teacher gender is associated with biases with regard to identification of learning disabilities by
a factor children gender, age, and experience, along with children's gender, were

teachers as having an LD (who actually has LD) corresponds two

when rated

of 2:1.

In other words, by male and

every

child

who

is rated

by

female

other hand,
Furthermore, with regard

did not differentially predict

teacher age experience and did to policy mandates

teachers.

Students' not

identification
contribute schemes.

gender,

on

the

rates.
signif

icantly to student identification rates. The findings are discussed

classification

GEORGIOS D. SIDERIDIS, Ph.D., Department of Psychology, University of Crete. FAYE ANTONIOU, Ph.D., Department of Special Education, University ofThessaly. SUSANA PADELIADU, Ph.D., Department of Special Education, University ofThessaly.

Teachers'

reports

are

often

used

to

assess

various

behaviors

in students with

and without

disabilities

(Liljequist & Renk, 2007; Wingenfeld, Lackar, Gruber, & Kline, 1998). Based on the premise that teachers are very important adults in students' lives (Achenbach, 1991), they are asked to contribute their unique per spective regarding various aspects of students' behavior and achievement from preschool to college (Jensen, Mashburn & Henry, 2004; Temp, 1971). For 1980; example, their ratings are used for identification pur poses,

a disability (Fox & Lent, 1996; Miller, Missiuna, Macnab, Malloy-Miller, & Polatajko, 2001), the impor tance of their ratings is not debated (Rosenthal &

classification, or just assessment. Regardless of these ratings carry information regarding teach usage, ers' predictions of how students will behave and achieve in the future (Wood & Benton, 2005). Although there is evidence that general and special education teachers often "miss" characteristics defining

Jacobson, 1968; Rubovits & Maehr, 1973; Tenenbaum & Ruck, 2007), particularly because their estimations are core predictors of students' placement (Podell & Soodak, 1993; Proctor & Prevatt, 2003). In the present study,we evaluated the role of teachers in identifying students with learning disabilities (LD) and examined the possible presence of bias on their role of their personal part, including the moderating characteristics. The term bias in this study refers to the systematic difference in the ways by which teachers identify learning disabilities and the factors related to them. Those ways may affect teachers' assessment of
student performance.

Volume 31, Fall 2008

199

This content downloaded on Wed, 16 Jan 2013 19:09:14 PM All use subject to JSTOR Terms and Conditions

Teachers

Disabilities

as a Means

of Identifying

Students

with

and

Teacher ratings are often used for identification of stu dents suspected of having various disabilities. Teachers' in the identification process of students involvement with LD may now be greater than in the past, given the use of the responsiveness-to-intervention (RTI) model of & Linan-Thompson, (Haager, Calhoon, Holdnack, & Mostert, 2006; Vaughn & Fuchs, 2003). As Kavale et al. (2006) pointed out, the decision is based on "vague regarding identification 'clinical' (i.e., teacher) judgements about the level of 2007; Kavale, response" identification

mental

(p. 120). Judgments on the part of teachers are based on their skills, and training. It is expectations, perceptions, for teachers to provide unbiased estimates of imperative their students' ability, potential, and achievement. Several researchers have blamed teachers for overidenti fication of learning disabilities 1996). (e.g., Wong, Others have suggested that the number of students with overidentification primarily because of of learning disabilities (MacMillan, Siperstein, & Gresham, 1996) (see also Keogh, 2005). assist in teacher ratings commonly Nevertheless, disabilities The Learning identifying learning (e.g., retardation has declined

the consistency of (2007) examined teacher-reported problems for students in 21 countries. Using a sample of 30,957 teachers, results indicated that participating educators were fairly accurate in identify ing students with behavioral and emotional problems. Internal consistency estimates averaged .90, and gender effects (i.e., discrepancies or biases) ranged between 1%

educational For example, teacher biases experience. have been evident with minority groups (e.g., not call students as often as they did ing on Asian-American Caucasian see Schneider & Lee, 1990). students; Rescorla et al.

trait associations" strong negative (p. 91). The authors suggested the need for alternative methods of assessment that may produce more valid ratings as stereotypical ratings can be catastrophic for students'

and 5%, which were pretty small and within the range of what constitutes reliable responding. Overall, the authors concluded that teachers' reports were similar and consistent across countries, supporting a model of teachers as valid raters of student behavior. Another noteworthy finding is that parents' unwill is associated with ingness to respond to questionnaires bias on the part of teachers regarding the pres higher ence of social, emotional, attentional problems, and so forth, in their children (Stormark, Heiervang, Heimann, In other words, this Lundervold, & Gillberg, 2008). pattern of behavior from parents was linked to biased estimates on the part of teachers.

For Conger, & Xu, 2007). example, investigating the interrelationships between and teacher esti intelligence, academic achievement, mations of that achievement, Svanum and Bringle status (1982) found that teacher race or socioeconomic not affect the predictability of their ratings. This did finding was replicated by Abidin and Robinson (2002). In contrast, Messe, Crano, Messe, and Rice (1979) teacher ratings are biased by students' reported that status. Social class and race seemed socioeconomic to be the main factors that influence these ratings (Knotek, 2003; McLeskey, Waldron, & Wornhoff, 1990; Wehmeyer & Schwartz, 2001) as well as placement (gen tocols (Lorenz, Melby, eral vs. special education). That is, teachers in general education settings appear to be less reliable when pro viding ratings related to LD than special education teachers in special education settings (Vaughn & Fuchs, 2003). (2007) also studied the presence Chang and Demyan of minority stereotypes in teacher ratings. The authors noted, "Contrary to expectation, there was substantial congruence in the degree of uniformity and favorable ness of the stereotypic traits associated with blacks and revealing both strong positive

Inventory [LDDI]; Hammill, 1995) Disability Diagnostic and attention deficit hyperactivity disorder (e.g., et al., 1998). A crucial question is how well Dupaul their task, given the often dis teachers accomplish between ratings and observational pro crepant findings

Thus, research findings regarding the effectiveness of teachers in rating students' attributes and behaviors have been largely inconclusive, leaving unanswered as: Which such questions factors influence teachers' ratings? Are there specific teacher characteristics that play a prominent role in the validity of their ratings? Teachers' Ratings Studies Characteristics as Predictors of Their

have shown that teachers' the validity of their ratings. and Wishart Hanna, Rivard, Missiuna, gated teachers' accuracy in identifying influence

gender. Specifically, female teachers were more likely to the the severity of gross-motor problems; underscore was true of male teachers. With regard to fine opposite motor skills,males provided lower responses (were less concerned with) than female teachers, underscoring the significant interaction between teacher gender and type of motor problem with regard to degree of concern. An interaction between teacher gender and inappro priate student behavior was noted by Taylor, Gunter,

characteristics For example, (2007) investi children with coordination and behavioral problems. Using a sample teachers and eight scenarios demon of 152 Canadian different levels of motor and behavior prob strating lems, findings revealed differential effects due to teacher

whites, with participants

Learning Disability Quarterly

200

This content downloaded on Wed, 16 Jan 2013 19:09:14 PM All use subject to JSTOR Terms and Conditions

and Slate (2001) using videotaped scenarios showing students acting out. They engaged 186 teachers to view the scenarios and to complete a rating scale on inap propriate behaviors. Teacher gender was once again the most influential factor on perceptions. Specifically,

1987), although they pay more attention to male than to female students (Bellamy, 1994). Duffy, Warren, and Walsh (2001) reported that, regardless of the subject matter taught, female teachers interacted heavily with

1999). However, Hopf and boys (Hopf & Hatzichristou, Hatzichristou found that female educators were more sensitive than theirmale counterparts. This effect could be attributed to the fact that female teachers may be more expressive when interacting with students (Meece,

female teachers more often referred students with learn ing and behavioral problems; thiswas especially true for

race as less likely to have special than students of a different race. In another investigation, Tobias et al. (1983) found that this could be a result of teachers' experience in special education settings. Attitudes towards the placement of students with learning disabilities may affect not only teachers' esti mations but also the quality of their interactions with the students (Bender, Vail, & Scott, 1995). The quality of educational needs this interaction is not predictive by teacher characteris tics, such as perceptions of self-efficacy, knowledge of

(Tobias, Cole, Zibrin, & Bodlakova, 1982) found that neither teachers' nor students' races were significant predictors of biased estimations of student ability. This was not the case, however, in another study by the same researchers (Tobias, Zibrin, & Menell, 1983) in which concluded that teachers of a specific race estimated they students of their own

male students compared to female students. Regarding behavioral assessment, Ritter (1989) documented that male teachers were less accurate in identifying students' behavioral problems than female teachers, who showed more sensitivity in distinguishing problem behaviors. In terms of teaching experience, Stevens, Quittner, and Abikoff (1998) reported that special education teachers rated behavioral problems as less of a burden than did general education teachers. Further, according toMashburn and Henry (2004), the higher the level of

special education (Bender, Vail, & Scott, 1995; Stevens, students' Quittner, & Abikoff, 1998), but mostly by gender (Anderson, 1997). Teachers

Biases with Regard to Student Gender There is also evidence suggesting that more boys than girls are identified as having a disability (Anderson, 1997; Shaywitz, Shaywitz, Fletcher, & Escobar, 1990). Regardless of whether the identification refers to neu rological (e.g. autism, attention-deficit/hyperactivity, speech and language disorders) or learning and reading disabilities, boys are more often referred for special edu cation

and invalid ratings, and preschool teachers' ratings were less valid than kindergarten teachers' esti mates. Previous studies also noted that more experi enced elementary and secondary teachers are more able to handle students' challenging behaviors (Borg & & Davazoglou, Falzon, 1998; Kokkinos, Panayiotou, 2005). The most common characteristic that teachers rely their judgments seems to be their upon in making experience (Brennan O'Neil & Liljequist, 2002). Thus, teacher experience, as reflected by years of teaching in general education classrooms and age, comprised vari ables that were examined as predictors of classification rate. Neither knowledge of the disorders nor profes sional experience and educational background seems to play an important role in teachers' accuracy of attention to deficit symptoms or oppositional defiant disorder et al., 1998). (Stevens There is also compelling to suggest that evidence teachers' ethnicity does not influence their judgments (Abidin & Robinson, 2002). Judging the correctness of the referral estimations of almost 200 teachers with diverse ethnic backgrounds, Tobias and his colleagues

the teachers' education, themore accurate their ratings. In their study, preschool and kindergarten teachers rated children's skills to evaluate their readiness to attend school. Teachers with low levels of education and training produced systematically inflated estima tions

regard to student gender. Specifically, teachers were more concerned about gross-motor problems in boys than in girls. Conversely, were more concerned they with fine-motor problems in girls than in boys. Overidentification of boys has been replicated both in younger groups of children and in diverse special education fields. For example, Mashburn and Henry (2004) reported that preschool and kindergarten boys were systematically rated lower by their teachers in aca demic and communication skills than same-age girls. Along the same lines, Berry, Shaywitz, and Shaywitz (1985) observed biases in the evaluation of students with attention deficit/hyperactivity disorder, favoring boys over girls.

services than girls (Lieberman, Kantrowitz, & in Flannery, 2005). The disproportionate placement terms of student gender has been so salient that teacher biases have been suspected (Gillberg, 2003). For exam ple, Rivard et al. (2007) observed differential effectswith

Nevertheless, teacher biases must be more that an arti fact of the methodology used (Flannery, Liederman, In an attempt to find out Daly, & Schultz, 2000). whether the evaluation method plays a significant role in that difference, Flynn and Rahbar (1994) reported that methods requiring subjective estimations lead to

Volume 31, Fall 2008

201

This content downloaded on Wed, 16 Jan 2013 19:09:14 PM All use subject to JSTOR Terms and Conditions

& Baindbridge, 1990; 1999; Vogel, to due However, Schwartz, 2001). Wehmeyer increased awareness, this effect may no longer be as prominent (Abidin & Robinson, 2002; Gillberg, 2003). and Webb For example, Goodman (2006) found no 2001; & teacher

of special education referrals for higher proportions boys than for girls, and that objective methods are more accurate than more subjective ones. Biases in teacher ratings favoring girls over boys have been reported previously (Helwig, Anderson, & Tindal, Peterson

States, identifying students as having LD when they demonstrate a significant discrepancy between poten tial and achievement. Nineteen of the students with LD were educated in inclusive general education class

and referred for special education services. The defini tion of the disorder in Greece is identical to that of U.S. Department of Education currently used in the United

gender bias in student referrals. Similarly, et al. noted that student gender was not a sig Helwig nificant parameter in teachers' evaluations of their stu achievement. However, such bias in dents' mathematics assessment does appear in later ages (e.g., mathematics (Wimer, Ridenour, Thomas, & secondary education) Place, 2001). Thus, the findings from this line of research suggest that there may be biases when teachers rate boys com rea pared to girls based on false expectations or other sons. Shaywitz (1996) supported the finding that male vulnerability to reading disabilities is a result of referral and identification biases and has no genetic basis. Such biases may be due to the fact that boys tend to have and attentional disorders behavioral problems than girls, which lead teachers to overrefer boys and cli them with learning disabilities nicians to overdiagnose & Harris, 1998; Naiden, 1976; Share & Silva, (Mamlin et al., 1990; Ysseldyke et al., 1983). 2003; Shaywitz

schools were selected by stratified sam in order to reflect the representative pling techniques areas of Greece. One boy and one girlwere demographic selected randomly from each class by excluding stu dents who had a spoken language other than Greek as Participating their native language or had not been attending a Greek school since firstgrade. Student ratings were completed by 98 teachers during

rooms. They were receiving special education services in in typical addition to their education (general educa tion) settings. The participating students were in grades 3 to 9 as follows: grade 3 = 33 (16 girls, 17 boys), grade 4 = 39 = (17 girls, 22 boys), grade 5 39 (22 girls, 17 boys), grade 6 = 36 (18 girls, 18 boys), grade 7 = 29 (13 girls, 16 boys), = 40 = 30 (20 (15 girls, 15 boys), and grade 9 grade 8 Two hundred and seventeen students girls, 20 boys). spoke Greek as their native language; 29 were bilingual.

more

Apart from students' gender and behavior, which seem to be the main factors that influence teacher eval that students' uations, Anderson (1997) concluded a significant role through the also plays placement mediating role of disruptive and inattentive behavior in the general classroom (Leinhardt, Seewald, & Zigmond

hours, including 33 teachers of language 63 elementary school teachers, and 2 from inclu arts, sive classrooms. With regard to gender distribution, there were 61 females and 31 males (data on gender were missing for 6 teachers). Teachers were distributed across grades as follows: grade 3 = 15, grade 4 = 19, = = = = 17, 14, grade 8 18, grade 7 21, grade 6 grade 5 = 19 is larger than 100% because and grade 9 (the total out-of-school
some teachers

1982; Smart, Sanson, & Prior, 1996). The present study investigated the presence of teacher biases with regard to identification of students with LD. More specifically, the study was designed to answer the in an attempt to further following research questions resolve current contradictory research findings: 1. Does teachers' gender differentially affect their rat ings with regard to identification of LD? 2. Are teachers' age and experience, in addition to their gender, significant predictors of their student ratings? 3. Does children's gender bias teacher ratings?

teachers had 18.24 years of teaching experience. Sixty were teaching in elementary school units and 28 in sec ondary (data on setting were missing for 10 teachers). All teachers had fulfilled the requirements to teach in Greek public elementary or secondary schools. Procedures Teachers work and were well acquainted with students' the were asked to complete for Teachers Scale Disabilities Screening who achievement

com cant effects were observed across distributions were equal (chi-square to the null model that all /s pared = = 3.496, p .745). Teacher age ranged between 24 [6] and 58 years, with a mean of 43.13 years. On average,

taught

more

than

one

grade).

No

signifi

METHOD
Participants The sample consisted of 246 Greek public school students, 33 with a diagnosis of LD and 213 typical stu dents (125 boys, 121 girls). The students with LD were team of experts identified by a state multidisciplinary

Learning (Padeliadu & Sideridis, 2008). This scale is identical (in to the Learning Disabilities and concept) principle by Hammill Inventory (LDDI) developed Diagnostic see also Hammill & Bryant, 1998). (1995; of Ratings were collected during the last two months the academic year to ensure that teachers were knowl

Learning Disability Quarterly

202

This content downloaded on Wed, 16 Jan 2013 19:09:14 PM All use subject to JSTOR Terms and Conditions

edgeable of students' behaviors and achievement levels. The latter was a prerequisite for teacher participation; that is, teachers had to feel confident that they could properly rate students' performance and achievement. Teachers were not introduced to the concept of LD; instead they were asked to rate each item in terms of the = = never). always to 9 frequency of that behavior (1 Each subscale contained 17 to 20 items; the total num ber of items was 116. If a teacher was not able to com in achievement (e.g., mathematic plete a subscale the teacher who best knew a given secondary schools), in the corresponding field was student's achievement to complete the ratings. asked The

Level-2 Model Poj with

screening inventory refers to grades 3 through 9 and is composed of six subscales: listening, speaking, These reading, writing, reasoning, and mathematics. subscales correspond to specific areas of deficiency in the definition of learning disabilities from the National Joint Committee on Learning Disabilities (see Hammill, the involve, for example, 1990). Specific behaviors compre inability to discriminate between phonemes, hend text, and so on. Teachers supplied their own a section of a given information on demographic student's rating scale.

(Diaconis & Efron, 1983). the prevalence Bootstrapping of LD in the popula tion. Using a population-based model, the prevalence of LD in the Greek population was estimated to be 9.3%. However, to ensure that the sample's estimates of preva

ulation mean (Chernick, 2007; Efron, 1982) to ensure were not substantial biases due to participant that there selection

? (phi) being parameter, trans Then preva formed into log units and expressed as (30j. lence rates are a function of their intercept Poo, their error u0j, and any other predictor variables at level 2 of In this model the level-1 variance is the the model. of the Bernoulli variance ^ = (1 reciprocal cfoj). Results indicated that 9.3% of the students were iden tified as having LD. However, we bootstrapped the pop

Poo + Moj the prevalence

lence were unbiased, we bootstrapped the prevalence a nonparametric bootstrap and apply parameter using ing 1,000 replications. Results indicated that the sam ple's mean prevalence rates were 9.302% compared to 9.286% in the bootstrap distribution (i.e., the sampling distribution based on 1,000 replications) showing a bias of -0.0001, which is negligible. Figure 1 shows

Data

Analysis Multilevel random coefficient modeling (MRCM) was to evaluate whether a student's diagnosis employed could be predicted by teacher gender and other charac teristics (Kreft& de Leeuw, 1998; Roberts, 2003; Shin, 2004) or student character Espin, Deno, & McConnell, we fit the logistic multilevel istics. For that purpose, model with a binary dependent variable (Boomsma, 1986). Further, in order for the resultant logistic co efficient to be translated into percentage points, we employed the following formula (Bryk & Raudenbush, 1992; Raudenbush & Bryk, 2002):
Probability of an Outcome = ---

Using confidence intervals derived from the bootstrap the prevalence rates at 95% distribution, ranged between 5.58 and 13.02.

the sampling distribution of the prevalence data, indicating that the mean rate of iden tification was indeed an unbiased estimate of the effects. This analysis further substantiates population subsequent findings related to the biasing effects of teacher gender on identification of learning disabilities.

(Equation 1)
with

1 + exPHij}

to Teacher Gender Bias Due In order to test for teachers' biases due to their gender, the following multilevel fit to logistic model was the data using the Bernoulli function in HLM 6.1 (Raudenbush & Bryk, 2002): Level-1 Model = ProbabilityDlagnosis ^ = Log[(t>ij/(1 "<l>ij) Poj = Poo +P01 (Teacher Gender) + uq

r)ij being the logistic regression coefficient. The in the specifics are discussed separately for each model following.

RESULTS
Unconditional Model ofLD Identification
The model was applied to following unconditional the data to assess the mean ratings of LD prevalence a population-based model using (Choi, 2001; Raudenbush & Bryk, 2002; Singer & Willet, 2003), as follows: Level-1 Model = ProbabilityDiagnosis ^

Level-2 Model Poj Given that teacher gender was coded as 0 = females = and 1 males, the intercept reflects the estimates for males and the slope reflects those of female teachers. Results indicated that the log estimate for females was 1.98 units and that of males -1.06 units. The former was significantly different from zero, whereas parameter the latter approached significance but did not exceed it = This suggests that the prevalence rates of 0.90). (p

= Logfoy/O -<hj) Po|

Volume 31, Fall 2008

203

This content downloaded on Wed, 16 Jan 2013 19:09:14 PM All use subject to JSTOR Terms and Conditions

Figure 1. Distribution of simulated frequency distributions based on the parametric bootstrap and using 1,000 replications. The distribution shows the negligible bias in the probability of a student having a diagnosis of learning disabilities.

20-j

IHHHHm

-1-1-1-?l-1-1

0.04

0.06

0.08 Value

0.10

0.12

0.14

male

inflated judgments regarding identification of students having LD compared to female teachers. The bias intro duced by teacher gender was substantial, and for that reason a series of alternative hypotheses were investi gated to ensure that this finding is real and not an arti experience fact of other teacher or age). characteristics (i.e., teaching

for female teachers and 25.7% formale teachers. Given that population estimates were slightly below 10% (i.e., that male teachers produced 9.3%), it was concluded

identifying children as having LD were significantly different from zero. When transforming these logits into percentages using Equation 1, the prob ability of classifying students as having LD was 12.13% teachers

order

to evaluate

students' gender, data: Level-1 Model

the potential differential the following model was

effects of fit to the

= + + ry ProbabilityDiagnosis p0j Pij (Gender of Child) Level-2 Model = + Poj Yoo u0j = y10 +Y11 (Gender of Teacher) p^

to Student Gender Bias Due A number of studies have shown that student gender In influences teacher judgments (Rivard et al., 2007).

and yn- The pXj students' gender affects the Px, probability of identification. In other words, whether more girls than boys are identified as having LD. The term yii evaluates whether teacher gender affects the relationship between students' gender and diagnosis. In The term evaluates whether tests whether other words, the model moderates the relationship between students' teachers' gender gender

coefficients of interest here are

Learning Disability Quarterly

204

This content downloaded on Wed, 16 Jan 2013 19:09:14 PM All use subject to JSTOR Terms and Conditions

and probability of diagnosis (Aiken & West, 1991; Tate, 2000). Results indicated that both coefficients were non = = -0.019, p 0.367, suggest significant. Specifically, p^ that the probability of having LD was independent ing of a child's gender. Also, the term yn = 0.016, p = 0.448 was nonsignificant, suggesting that the relationship between a child's gender and the probability of an LD diagnosis was not affected by teacher gender teacher who provided the ratings).

DISCUSSION
This with disabilities. gated. study investigated the presence of teacher biases regard to identification of students with learning Factors related to teachers' gender, age, and along with students' gender, were investi

(i.e., by the

indicated that teachers' gender signifi biases their identification of learning disabilities, cantly with females being more lenient than males. The bias was in the magnitude of 2:1, with male teachers identi

experience, Results

Contribution of Teacher In order to testwhether

Age and Experience teacher characteristics

such of

age and years of experience working with students with special needs affected their judgments, the following multilevel logistic model was fit to the data: Level-1 Model = ProbabilityDiagnosis ^

fying two students as having LD for every one student identified by female teachers. This finding may be interpreted tomean that female teachers initiate more interactions with their students

- = Logfoy/O 4>ij) Poj

Poj

Level-2 Model Poo + P01 (Teacher's Age) + p02 (Teacher's Experience) u0j all

& Granstroem), and supportive, & Hatzichristou, than men. 1999) expressive (Hopf Einarsson and Granstroem found that Additionally, to male male teachers pay less attention students as caring (Einarsson

and especially pay more attention to boys (Einarsson & Granstroem, 2002). With regard to the more "positive" evaluations by female teachers, Noddings (1984) and noted that woman teachers are more (1982) Gilligan

with

so the results are reflected as ifvariables had undergone a z-score transformation. Results, as shown in Table 1, indicated that neither of these demographic variables was a significant predictor of prevalence rates.

|3S representing partial regression coefficients associated with teachers' age and experience, control ling for all other variables in the model. Age and teach ing experience were entered as a grand mean centered,

were

they grow older, a fact that may offer a logical expla nation of the results of this study. Thus, overrepresen tation of LD may partly be due to the gender of the we consider that the ratings of male teachers teacher (if compared to the baseline model). finding agrees with previous ratings showing substantial biases based on teacher characteristics such as psychopathology (Lovejoy, 1996) but not other char enhanced This

Table

1 Predicting Prevalence of Identification Rates Due to

Multilevel Random Coefficient Model Teacher Age and Years of Experience

Variables Coefficient Intercept (30

Intercept Level-2 Model Age y02 yoo -2.118

S.E.

t-ratio pdf

2.466

-0.859

68 0.394

Teacher's

-0.016 0.067

-0.240

0.811

68

Teacher's Experience Y03

0.030 0.040

0.740 0.862

68

Note. Coefficients reflect fixed effectsof themodel. S.E. = Standard error ofmeasurement.

Volume 31, Fall 2008

205

This content downloaded on Wed, 16 Jan 2013 19:09:14 PM All use subject to JSTOR Terms and Conditions

acteristics such as teaching specialty (general vs. special the education) (Liljequist & Renk, 2007). However, with those of Rescorla et al. present findings disagree (i.e., students with (2007) with a different population emotional

being important teacher resources (Liljequist & Renk, 2007). A third important finding relates to the fact that stu with differential dents' gender was not associated these ratings were not teacher ratings. In addition,

teacher ratings. A second important finding was that teachers' age and experience were not significant predictors of their identification ratings. This finding is troublesome and contradicts the literature, which points to these factors

problems) in that students referred for emo tional problems did not lead to substantially different

well. Unfortunately, this is always the case with ratings that may contain both a subjective and an objective part. Thus, ratings likely reflect a knowledge base that is due to various sources, including observations. If other sources of influence bias teachers' ratings, they should be systematically examined in a methodological study (beyond the scope of the present study). Nevertheless, teacher ratings represent a reality in our current use of If other criteria in learning disabilities. evaluative sources influence these ratings (besides those examined in the present study), we hope that they are randomly distributed across teachers, thus adding to the unsys tematic source of error (i.e., random error).

et al., 2007). This finding is extremely important given prior research confirming that teacher biases create mindsets and can be devastating for the development of (Rosenthal & prejudice in specific groups or populations Jacobson, Limitations Despite important findings, the present study is lim ited by a number of factors. First, although all students had a diagnosis of LD by an approved authority, it is well known that teams employ variable criteria (e.g., use different standardized assessments or place more 1968).

related to teacher gender. This agrees with past research in that the gender of the child was not a significant determinant of teachers' ratings of a disability (Rivera

No Child LeftBehind Act (2001) forhighly qualified

teachers (King-Sears, 2005). Teachers are increasingly and behavior. relied on to rate students' achievement As a result, if their ratings are lacking in validity, it can have serious implications for students' placement (Fierros &

for Practice Implications The fact that the present study found biases in teach ers is troublesome; especially, given the mandate by the

and subsequent well 2005) Bloomberg, the present findings using Greek being. Although teachers and students cannot be directly generalized to U.S. teachers, it is plausible that such an effectmay be in the two educational present given the resemblance and teachers' education (the Greek system has systems borrowed themain components of the U.S. educational system). Nevertheless, U.S. studies are needed to ensure

emphasis on Factor A than Factor B). For example, teams with experts on speech and language pathology than teams may rely more heavily on such measures that apply a discrepancy (Stanovich, 2005) or an RTI model (Fuchs & Deshler, 2007; Haager, 2007; Vaughn & Fuchs 2003). Thus, although all students had a diagno

sis of LD, we cannot verify the validity of these ratings significant beyond the fact that students demonstrated limitation pertains to the fact that only teachers' age, gender, and experience were tested. Thus, it is likely that other demographic variables may have effect. for the observed been gender responsible aid our understanding Inclusion of such variables may of the existence of biases by teachers. For example, A second Podell Pugach and Johnson (1995) and Tournaki and that low numbers of referrals by teach (2005) reported erswere predicted by their efficacy ratings; nevertheless, the opposite finding was reported by Soodak and Podell
sub-average achievement.

& the validity of teacher (Einarsson judgments Granstroem, 2002; Shinn, Tindal, & Spira, 1987). That is, teachers with low personal efficacy are more likely to mistakenly refer students for special education services (Einarsson & Granstroem). Training and practical guid ance may enhance teachers' personal efficacy and, in turn, influence the validity of their estimates. The U.S. of Education's emphasis on enhancing Department is important in this con teachers' content knowledge nection

that such an effect is present. Teacher awareness and training may be avenues for improving the accuracy of their ratings (Moore, 2008; Rivard et al., 2007). Teacher efficacy has proven to be to one of the most important factors contributing

(Boe, Shin, & Cook, 2007). Other suggestions for improving the validity of teacher ratings involve the use of brief, rather than lengthy, assessments (Henderson & Sugden, 1992) and instruments with

Furthermore, as two thoughtful reviewers of this arti cle suggested, the ratings by teachers may reflect not as just their observations but other sources of influence

(1993, 1996).

documented positive psychometric properties (Junaid, Harris, Fulmer, & Carswell, 2000). As Rivera et al. (2007) pointed out, 'Teachers have a critical role to play in the identification and manage ment of children" (p. 645) with and without disabili of ties. Future studies could enrich our understanding

Learning Disability Quarterly

206

This content downloaded on Wed, 16 Jan 2013 19:09:14 PM All use subject to JSTOR Terms and Conditions

the factors that contribute to valid teacher ratings or enhance the efficacy of teachers to be successful in their multidisciplinary role (Dembo & Gibson, 1985; Gibson & Dembo, 1984; Merrett, & Wheldall, 1993).

teacher and pupil. Scandinavian Journal of 46, 117-127. N. A. (2005). Restrictiveness and race in Fierros, E.; & Bloomberg, in for profit and non-profit char special education placements relationship Educational Research, ter schools in California. Learning Disabilities: Journal, 3, 1-16. Flannery, A Contemporary

between

REFERENCES
R. R, & Robinson, L. L. (2002). Abidin, Stress, biases, or profes sionalism: What drives teachers' referral judgments of students behaviors? challenging 4, 204-212. Disorders, with Journal of Emotional and Behavioral

K., Liederman, J., Daly, L., & Schultz, J. (2000). Male for reading disability is found in large sample of prevalence black and White children free from ascertainment bias. Journal

T. M. Achenbach, (1991). Manual for the teacher's report form and 1991 profile. Burlington: of Vermont of University Department Psychiatry. S. G. (1991). Aiken, L. S., & West, interpreting interactions. Newbury regression: Testing and Multiple Park, CA: Sage. bias and special education refer

of the International Neuropsychological Society, 6, 433-442. of reading failure M., & Rahbar, M. H. (1994). Prevalence Flynn, J. in boys compared with girls. in the Schools, 31, 66-71. Psychology children: Primer on devel Fox, A. M., & Lent, B. (1996). Clumsy coordination disorder. Canadian opmental Family Physician, 42, 1965-1971. Fuchs, we need D. to know about D., & Deshler, (2007). What to intervention be afraid to ask). (and shouldn't responsiveness Research & Practice, 22, 129-136. Learning Disabilities

K. G. (1997). Gender Anderson, rals. Annals 47, 151-162. of Dyslexia, Bias in the classroom: Bellamy, N. (1994).

Are we guilty? Science Scope, 17, 60-63. attitudes Bender, W. N., Vail, C O., & Scott, K. (1995). Teachers' toward increased effective mainstreaming: Implementing instruction for students with Journal of learning disabilities. 28, 87-94. Learning Disabilities, S. E., & Shaywitz, B. A. (1985). Girls with Berry, C A., Shaywitz, attention deficit disorder: A silent A report on behav minority? ioral and cognitive characteristics. Pediatrics, 76, 801-809.

M. H. (1984). Teacher S., & Dembo, Gibson, efficacy: A construct validation. Journal of Educational Psychology, 76, 569-582. C. (1982). In a different voice. Cambridge, MA: Harvard Gilligan, Press. University Gillberg, ception: 910. Goodman, Teacher vention. Haager, C. in attention, motor (2003). Deficits control, A brief review. Archives ofDisease in Childhood, G., & Webb, M. M. (2006). Reading bias and other factors that impact disability response and per 88, 904 referrals: to inter

teacher preparation Boe, E. E., Shin, S., & Cook, L. H. (2007). Does matter for beginning teachers in either special or general edu cation? Journal of Special Education, 41, 158-170. A. (1986). On the use of bootstrap and in Boomsma, jackknife covariance structure analysis models. 7, 205-210. Compstat, Borg, M. G, & perception Educational Brennan Falzon, J. M. (1998). of students' undesirable Secondary behaviors. school teachers' British Journal of by 39,

regarding using learners. English language Learning Disability Quarterly, 30, 213-218. M. S. (2007). D., Calhoon, B., & Linan-Thompson, Haager, learners and to intervention: English language response to special Introduction issue. Learning Disability Quarterly, 30, response to intervention with 151-153. Hammill, (LDDI). D. The Learning (1995). TX: Pro-Ed. Disability Diagnostic Inventory

Learning Disabilities: D. Promises (2007).

A Contemporary and cautions

Journal, 4, 59-70.

Psychology, 68, 67-79. L. (2002). used O'Neil, K., & Liljequist, Strategies teachers to rate student behaviour. in the Schools, Psychology 77-85. (1992). Hierarchical

Hammill,

Asia Pacific Education Review, 2, 44-55. approach. S. (1985). Teachers' sense of efficacy: An Dembo, M. H., & Gibson, factor in school The Elementary School important improvement. Journal, 86, 173-184. intensive Diaconis, P., & Efron, B. (1983). Computer statistics. Scientific American, 248, 116-130. Warren, K., & Walsh, Duffy, J., Gender of teacher, gender Sex Roles, 45, S79-S93. Dupaul, M., G. J., Anastopoulos, & McGoey, K. E. M. (2001). of student, A. D., (1998). Classroom and methods interactions: subject.

A. (2007). Teachers' F., & Demyan, stereotypes of asian, and white students. School Psychology Quarterly, 22, 91-114. Chernick, M. (2007). Bootstrap methods: A guide for researchers and practitioners. New York: Wiley. K. (2001). Latent variable in the hierarchical Choi, modeling in longitudinal framework studies: A fully Bayesian modeling Chang, black,

S. W. Bryk, A. S., & Raudenbush, Park, CA: Sage. Newbury D.

linear models.

On defining An disabilities: (1990). learning consensus. 74-84. Journal of learning Disabilities, emerging 23(2), D. D., & Bryant, B. R. (1998). Hammill, Learning Disabilities Austin, TX: Pro-Ed. Inventory Examiner's manual. Influence of ele R., Anderson, L., & Tindal, J. (2001). school gender on teachers' of mathemat mentary perceptions Diagnostic ics achievement. Journal of Educational Research, 95, 93-102. D. A. (1992). Movement Assessment S.; & Sugden, San Antonio, TX: Psychological for Children. Corpora C. Hatzichristou, in Greek schools. in mental Teacher (1999). British Journal gender-related of Educational

Austin, D. D.

Helwig,

Henderson, Battery tion.

D., & Hopf, influences

in

Psychology, 69, 1-18. Jensen, A. R. (1980). Bias Junaid, K., Harris,

classroom

use of theMABC checklist to identifychildren with motor

coordination 163. K. difficulties. Pediatric Physical Therapy, 12, 158

S., Fulmer,

testing. London: Methuen. A. (2000). Teachers' K., & Carswell,

disorder, deficit/hyperactivity normative data. Journal of Psychopathology Assessment, 20, 83-102. Efron, B. (1982).

Power, T. J., Reid, R., Ikeda, Parent ratings of attention factor structure and symptoms: and Behavioral

Kavale,

A.,

Responsiveness cific learning

M. P. J. A., & Mostert, Holdnack, to intervention and the identification disability: A Quarterly, Revisiting Quarterly, and critique 29, 113-127. classification 28, 100-102. alternative and

(2006). of spe proposal.

& Granstroem, Einarsson, C, tion in the classroom: The

Philadelphia: SIAM.

The jackknife, bootstrap, K.

and other resampling plans. interac age in the

Learning Disability B. K. (2005). Keogh, Learning Disability effective

identification.

(2002). Gender-biased influence of gender and

M. E. (2005). Are you highly qualified? The King-Sears, plight of

for students with special educators ties. Learning Disability Quarterly, 28, 187-188. learning disabili

Volume 31, Fall 2008

207

This content downloaded on Wed, 16 Jan 2013 19:09:14 PM All use subject to JSTOR Terms and Conditions

S. (2003). Bias in problem Knotek, solving and the social process of student study teams. The Journal of Special Education, 37, 2 14. C Kokkinos, Correlates M., of G., & Panayiotou, teacher appraisals A. M. (2005). Davazoglou, of students' behaviors. multilevel modeling. race

G. D. S., & Sideridis, (2008). Learning Disabilities EPEAEK. Screening for Teachers. YPEPTH: Peterson, S., & Baindbridge, J. (1999). Teachers' expecta gendered tions and their evaluation of student writing. Reading Research Padeliadu, and Instruction, Podell, D., & education Proctor, used 38, 255-271. Soodak, L. (1993). Teacher efficacy and bias in special referrals. Journal of Educational Research, 86, 247-253. four models B., & Prevatt, F. (2003). Agreement among for diagnosing disabilities. Journal of Learning learning

in the Schools, 42, 79-89. Psychology J. (1998). Kreft, I., & de Leeuw, Introducing Park, CA: Sage. Newbury Leinhardt, G, differences 74, 835-843. Lieberman,

Seewald, A. M., & Zigmond, N. (1982). in LD classrooms. Journal of Educational

Sex and

Psychology,

Pugach,

emotional of students' and behavioral ratings problems. Educational Psychology, 27, 557-571. R. D., & Xu, X. (2007). The F. O., Melby, Lorenz, J. N., Conger, between observational effects of context on the correspondence

vulner J., Kantrowitz, L., & Flannery, K. (2005). Male is not likely to be a myth: A call for ability to reading disability new data. Journal of Learning Disabilities, 38, 109-129. teachers' L., & Renk, K. (2007). The relationship among Liljequist, of student behaviour, and teachers' characteristics, perceptions

36, 459-466. Disabilities, L. J. (1995). Unlocking M. C, & Johnson, the expertise teachers through structured dialogue: extend among classroom Children, 62, 101, Exceptional ing research on peer collaboration. 110. S.W., and & Bryk, A. S. (2002). Hierarchical linear models: methods data analysis (2nd ed.). Thousand T. M., F.; Bathiche, Fombonne, M. C, Ginzburg, M., E., Fonseca, Liu, X., Leung, S., A., Ivanova, N., Frigerio, M., A., A.,

Raudenbush,

Applications Oaks, CA: Sage. L. A., Achenbach, Rescorla, Dumenci, Domuta, Kanbayashi, Roussos, L., Almqvist, A., Erol, N.,

Bilenberg,

Bird, H.,

A multi reports of hostile behaviour: ratings and questionnaire trait, multimethod Journal of Family Psychology, 21, approach. 498-509. aggressive Journal of Clinical Child Psychology, reports of discipline. 25, 33-42. F. M. D. L., Siperstein, G. N., & Gresham, (1996). A MacMillan, as a diag to the viability of mild mental retardation challenge nostic category. Exceptional Children, 62, 356-371. teacher Mamlin, M. Lovejoy, overactive C and (1996). Social inferences behaviour child inattentive regarding and their effects on

Y., Lambert,

P., Minaei,

Psychology Review, 36, 91-110. in of problem Teachers' behavior Ritter, D. (1989). perceptions education. and 55, 559 Children, special general Exceptional 564. Rivard, L. M., Understanding of children with L. (2007). Hanna, S., & Wishart, C, Missiuna, of the motor difficulties teachers' perceptions disorder coordination (DCD). developmental

T.; S., Weisz, J., A., Simsek, Z., Weintraub, Wolanczyk, F. (2007). Consistency R.; Verhulst, Zubrick, S. R., Zukauskiene, for students in 21 countries. School of teacher-reported problems

referral to teachers' N., & Harris, K. (1998). Elementary and pre-referral. Journal in light of inclusion special education of Educational Psychology, 90, 385-396. A. J.,& Henry, G. T. (2004). and Assessing school readiness: 16-30. kindergarten Issues and Practice, teachers' 23, rat

Mashburn,

in preschool and bias validity ings. Educational Measurement: McLeskey,

British Journal of Educational Psychology, 77, 633-648. and Roberts, K. J. (2004). An introductory primer on multilevel A Contem linear modeling. hierarchical Learning Disabilities: porary Journal, 2, 30-38. L. (1968). Pygmalion R., & Jacobson, Rosenthal, and Winston. New York: Holt, Rinehart, Rubovits, in the classroom.

23, 362-366. Journal of Learning Disabilities, on the of school influence Meece, J. L. (1987). The experiences L. In L. S. Liben & M. schemata. of gender development San (Eds.), Children's gender schemata (pp. 57-73). Signorella Francisco: Jossey-Bass. learn to man K. (1993). How do teachers F., & Wheldall, Merrett, learning disabilities. A study of teachers' opinions behaviour? age classroom their initial training with special reference to classroom Educational iour management. Studies, 19, 91-106. about behav

Factors S. A. (1990). N. L? & Wornhoff, J.,Waldron, of black and white students with the identification influencing

black and white. P., & Maehr, M. L. (1973). Pygmalion Journal of Personality and Social Psychology, 25, 210-218. bias in IQ-discrepancy Share, D. L., & Silva, P. A. (2003). Gender of reading disability. definitions and post-discrepancy Journal of Schneider, school 36, 4-14. Learning Disabilities, B., & Lee, Y. (1990). A model environment and home for academic of East-Asian success: The

students.

S. R., & Rice, W. L. A., Crano, W. (1979). D., Messe, Messe, of the predictive validity of tests of mental Evaluation ability for in elementary classroom Journal of grades. performance Educational Miller, Psychology, 71, 233-241. C L. T., Missiuna, J. J.,Malloy-Miller, A., Macnab, of children H. J. (2001). Clinical description Polatajko, coordination 68, disorder. Canadian Therapy, (2008). 5-15. elementary classrooms: preservice teachers for Challenging Journal of Science disabled cultural Teacher readers. T., & with of

and Education Quarterly, 21, 358-377. Anthropology S. E. (1996). Dyslexia. 373, 607-609. Scientific American, Shaywitz, M. (1990). B., Fletcher, J., & Escobar, S., Shaywitz, Shaywitz, in boys and girls. Journal of the of reading disability Prevalence American Medical Shin, J., Espin, hierarchical ment Association, 264, 998-1002. S. (2004). Use of S. L., & McConnell, C. A., Deno, measure and curriculum-based linear modeling

developmental Occupational F. M. Moore, urban biases

Journal

factors for academic for assessing growth and instructional students with learning difficulties. Asia Pacific Education Review, 5, 136-148. Shinn, M. R., Tindal G. A., & Spira, D. A. (1987). Special education referrals as an Index tests? Exceptional of teacher tolerance: Are teachers imperfect Children, and 54, 32-40.

elementary toward diverse 19, 85-109. (1976). Ratio Teacher,

Preparing science

students.

data analysis: Singer, J.,& Willet, J. (2003). Applied longitudinal

Modeling University Smart, D., change Press. event occurrence. (1996). New York: Oxford A., & Sanson, and reading disability and causal hypotheses. 363-383. Prior, M. behaviour Connections between

No Child LeftBehind Act of 2001. 20 U.S.C 6301 et seq. (2001).

N. Caring. A feminine approach (1984). Noddings, of California moral education. Berkeley: University to ethics Press.

Education, N. Naiden, The Reading

of boys 439-442.

to girls among

and

temporal Testing problems: Journal of Abnormal Child Psychology, 24,

Learning Disability Quarterly

208

This content downloaded on Wed, 16 Jan 2013 19:09:14 PM All use subject to JSTOR Terms and Conditions

Soodak, Special

L. C,

problems Soodak,

as

& Podell, D. M. (1993). Teacher in special education factors

efficacy and student referral. Journal of the efficacy: Toward and Teacher Will discrepancy field a disabilities

Education, 26, 66-81. L. C, & Podell, D. M. (1996). Teacher construct. of a multifaceted understanding

Tournaki, N., & Podell, D. M. (2005). The impact of student char acteristics of stu and teacher efficacy on teachers' predictions success. Teaching and Teacher Education, dents' 21, 299-314. as S., & Fuchs, L. (2003). Redefining Vaughn, learning disabilities inadequate problems. 146. response Learning to instruction: The Disabilities Research and potential promise and Practice, 18, 137

Teaching

12, 401-411. K. E. (2005). The future of a mistake: Stanovich, measurement to make the learning continue Education, pseudoscience? Stevens,

Learning Disability Quarterly, 28, 103-106. Factors influenc A. L., & Abikoff, H. (1998). J.,Quittner,

S. (1990). Gender differences Vogel, visual-motor abilities and academic with

in intelligence, achievement

language, in students

and ODD school teachers' ing elementary ratings of ADHD behaviors. Journal of Clinical Child Psychology, 27, 406-414. A., & Stormark, K. M., Heiervang, E., Heimann, M., Lundervold, bias from teacher C (2008). nonresponse Predicting Gillberg, in primary school children. health problems ratings of mental Journal of Abnormal Child Psychology, 36, 411-419. Svanum, S., & Bringle, R. G. (1982). Race, social class, and predic tive bias: An evaluation using WISC, of HLM WRAT, and teacher

A review of the literature. Journal of learning disabilities: 23, 44-52. Learning Disabilities, M., & Schwartz, M. (2001). Disproportionate represen Wehmeyer, in special education tation of males services: Biology, behaviour Wimer, and Treatment of Children, 24, 28-45. Education C. S.; Thomas, J. W., Ridenour, K., & Place, A. W. (2001). of boys and girls in elemen order teacher questioning Higher classroom. Research, 95, Journal of Educational tary mathematics 84-92. S. A., Lackar, D., Gruber, C. of the teacher-informant P., & Kline, R. B. (1998). student behavior survey. 16, 226-249. New York: or bias?

ratings. results.

Intelligence, 6, 275-286. Elaboration Tate, R. L. (2000).

Wingenfeld, growth modeling Research, 40, 53-75. Slate, J. R. (2001). Teachers' as a function Development

Behavioral background. 26, 146-151. Disorders, of the SAT for blacks and whites in thir Temp, G. (1971). Validity teen integrated institutions. Journal of Educational Measurement, 8, 245-251. H. R., & Ruck, M. D. Tenenbaum, tions different for racial minority students? 253-273. A meta-analysis. (2007). Are teachers' expecta than for European-American Journal of Educational Psychology, 99,

Florida Journal of Educational P. L., & Taylor, P. B., Gunter, tions of inappropriate student behavior ers' and students' and ethnic gender

predic of teach

B.Y.L. (1996). Wong, Academic Press.

Journal of Psychoeducational Assessment, The ABCs of learning disabilities.

S. L. (2005). Attributional to stu Wood, J. G., & Benton, responses dents with who fail. disorder attention-deficit-hyperactivity Teacher Education and Special Education, 28, 153-162. J., Thurlow, M.; Graden, Ysseldyke, S. (1983). Generalizations Deno, assessment and decision making: Institute. Exceptional Children J., Wesson, K.; Algozzine, B., & from five years of research on The University of Minnesota 4, 75-93.

Quarterly,

V. (1982). Teacher Tobias, S., Cole, C, Zibrin, M., & Bodlakova, student ethnicity and recommendations for special education referrals. Journal of Educational Psychology, 74, 72-76. C refer Tobias, S., Zibrin, M., & Menell, (1983). Special education to replicate student-teacher ethnicity Journal of Education Psychology, 75, 706-707. rals: Failure interaction.

Please D.

address

Sideridis,

Rethimno,

University 74100 Crete,

this article to: Georgios correspondence regarding of Crete, Department of Psychology, e-mail: sideridis@psy.soc.uoc.gr Greece;

Volume 31, Fall 2008

209

This content downloaded on Wed, 16 Jan 2013 19:09:14 PM All use subject to JSTOR Terms and Conditions