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OCR: petitioner's response to Shannon demonstrates. the educational neglect of children with disabilities continues Allowing courts to award reimbursement under the circumstarices of this case provides more of an incentive for parents to inappropriatcly utilize IDEA secure private education than does this Court's decision Burlington which itself imposes substantial barriers to such parents. The fact that parents first incur the expense rf private education itsclf a significant disincentive private placement the that they "do at their OWT financial risk. Burlington, 171 U.S ut 374. The Fourth Circuit recognized that this risk serves HA critical brake TT the speculative abuses cited by petitioner warning that 'parents whu unilaterally place their child ir unapproved private school bear substantia ...