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The National Center on Dispute Resolution in Special Education

"Encouraging the use of mediation and other collaborative strategies to resolve disagreements about special
education and early intervention programs."

Sample Mediation Ground Rules

  1. We will take turns speaking and not interrupt each other.

  2. We will call each other by our first names, not "he" or "she."

  3. We will not blame, attack, or engage in put-downs and will ask questions of each other for the purposes of gaining clarity and understanding only.

  4. We will stay away from establishing hard positions and express ourselves in terms of our personal needs and interests and the outcomes we wish to realize.

  5. We will listen respectfully and sincerely try to understand the other person's needs and interests.

  6. We recognize that even if we do not agree with it, each of us is entitled to our own perspective.

  7. We will not dwell on things that did not work in the past, but instead will focus on the future we would like to create.

  8. We will make a conscious, sincere effort to refrain from unproductive arguing, venting, or narration, and agree at all times to use our time in mediation to work toward what we perceive to be our fairest and most constructive agreement possible.

  9. We will speak up if something is not working for us in mediation.

  10. We will request a break when we need to.

  11. We will point out if we feel the mediator is not being impartial.



DISCLAIMER: This web page was developed by the Consortium for Appropriate Dispute Resolution (CADRE), a project of Direction Service, Inc., Eugene, Oregon, pursuant to Grant No. 326D980002 with the U.S. Department of Education, Office of Special Education and Rehabilitative Services. The materials on this page were developed by others and the opinions expressed therein do not necessarily reflect the position or policy of the U.S. Department of Education, and no endorsement by the U.S. Department of Education should be inferred.

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