dissenting in part.
The administrative law judge, who presided over the hearing on KE.’s claim she was denied free access to public education (FAPE) within the meaning of the Individuals with Disabilities Education Act (IDEA), concluded the School District failed to address KE.’s education-impeding behavioral challenges in her individualized education plan (IEP), thus preventing K.E. from receiving any meaningful educational benefit and denying her FAPE. I agree with the ALJ, and in reaching this conclusion, I suggest this court should be providing due weight to the administrative decision, not providing deference to the findings and decision of the district court. While I agree with the majority on several of the issues raised in this appeal, I cannot agree with the majority’s decision as to whether the district court afforded due weight to the ALJ and its ultimate conclusion as to whether K.E. made sufficient progress during her second-, third-, fourth-, and fifth-grade years to demonstrate she received some educational benefit. I dissent in part because I would conclude the district court failed to give due weight to the administrative proceedings and, based on an independent review of those proceedings, I would further conclude the record establishes K.E. was denied FAPE.
I
I do not agree with the majority affording deference to the district court on factual findings. Ante at 804-05. There are two levels of review following an administrative hearing on claims under the IDEA. First, the district court should make an independent determination of the issues based on a “preponderance of the evidence,” giving the administrative proceedings “due weight.” Hendrick Hudson Central School Dist. Bd. of Ed. v. Rowley, 458 U.S. 176, 206, 102 S.Ct. 3034, 73 L.Ed.2d 690 (1982). “[The] district court must give consideration ‘to the fact that the state hearing panel has had the opportunity to observe the demeanor of the witnesses,’ ” Blackmon ex rel. Blackmon v. Springfield R-XII Sch. Dist., 198 F.3d 648, 654-55 (8th Cir.1999) (quoting Fort Zumwalt Sch. Dist. v. Clynes, 119 F.3d 607, 610 (8th Cir.1997)), and should be careful not to “substitute [its] own notions of sound educational policy for those of the *812school authorities which [it] review[s],” because the district court lacks the “specialized knowledge and experience necessary to resolve persistent and difficult questions of educational policy.” Rowley, 458 U.S. at 206, 208, 102 S.Ct. 3034 (internal quotation marks and citations omitted).
After the district court has reviewed the administrative proceedings as to whether a school district offered FAPE, we treat the district court’s decision as a mixed question of law and fact and review it de novo. C.B. ex rel. B.B. v. Special Sch. Dist. No. 1, Minneapolis, Minn., 636 F.3d 981, 988-89 (8th Cir.2011); Fort Zumwalt, 119 F.3d at 611. There are some cases which, like the majority’s opinion, provide a level of deference to the district court indicating, unless there is a mistake of law, “the district court’s answer to this mixed fact/law question is reviewed for clear error.” E.S. v. Indep. Sch. Dist., No. 196, 135 F.3d 566, 569 (8th Cir.1998) (citing Yankton Sch. Dist. v. Schramm, 93 F.3d 1369, 1374 (8th Cir.1996)); accord Gill v. Columbia 93 Sch. Dist., 217 F.3d 1027, 1035 (8th Cir. 2000); Blackmon, 198 F.3d at 655; see also Mary T. v. Sch. Dist. of Phila., 575 F.3d 235, 241-42 (3d Cir.2009) (indicating on appeal from a state administrative decision under IDEA the appellate court reviews the district court’s factual findings for clear error); N.B. v. Hellgate Elementary Sch. Dist., 541 F.3d 1202, 1207 (9th Cir.2008) (“We review the district court’s findings of fact for clear error even when they are based on the written record of administrative proceedings.”). I would recognize these differing standards as an intracircuit split of authority, which I would resolve by choosing the “better approach.” See, e.g., United States v. LeBrun, 363 F.3d 715, 719 (8th Cir.2004); Toua Hong Chang v. Minnesota, 521 F.3d 828, 832 n. 3 (8th Cir.2008) (citation omitted) (‘When there is an intra-circuit split, we are free to choose which line of cases to follow.”); but see Williams v. Nat’l Football League, 598 F.3d 932, 933-35 (8th Cir.2009) (Colloton, J., dissenting from denial of rehearing en banc) (pointing out that other circuits have concluded the better practice normally is to follow the earliest opinion).
It stands to reason providing any deference to the district court in this context, in which the district court reviews an administrative decision based only on a written administrative record, seems misplaced. The district court is in no better position than an appellate court reviewing a written administrative record to make its independent judgment. It is the administrative tribunal, not the district court, which takes evidence, hears witness testimony firsthand, and judges credibility. See Blackmon, 198 F.3d at 654-55 (recognizing it is “ ‘the state hearing panel [who] has had the opportunity to observe the demeanor of the witnesses’ ”) (quoting Fort Zumwalt, 119 F.3d at 611). Thus, the district court is in no better position than is this court in reviewing the record and resolving the issues. We have implied this much when defining the standard of review in cases of similar procedural structure where the district court essentially acts as the first level of appellate review. As an example, in social security cases it is well settled our review of the district court’s decision is de novo. Martise v. Astrue, 641 F.3d 909, 920-21 (8th Cir.2011). We provide no deference to the district court, but instead focus on the findings and conclusions of the ALJ to determine whether they are supported by substantial evidence. Buckner v. Astrue, 646 F.3d 549, 556 (8th Cir.2011). Similarly, on appeal from a bankruptcy matter, we review the district court’s decision de novo, providing deference to the factual findings of the bankruptcy court, which heard the witnesses and took evidence in the first in*813stance. Advanced Control Solutions, Inc. v. Justice, 639 F.3d 838, 840 (8th Cir.2011) (“[W]e sit as a second court of review in bankruptcy matters, reviewing interpretations of law de novo, factual findings by the bankruptcy court for clear error, and matters committed to the bankruptcy court’s discretion for an abuse of discretion.”); In re Reynolds, 425 F.3d 526, 531 (8th Cir.2005) (“[T]his court sits as a second court of review; we therefore apply the same standards of review to the bankruptcy court’s decision as the district court does.”).
In fact, in the Eighth Circuit, the deferential standard was first applied to our review of a district court’s decision on an IDEA claim in Yankton School District v. Schramm, which states “[a] district court’s findings of fact must be upheld unless clearly erroneous.” 93 F.3d at 1374. However, Yankton, appears to have applied this deferential standard without explanation, citing Light v. Parkway C-2 School District, 41 F.3d 1223, 1229 (8th Cir.1994). Notably, Light was a distinctly different type of case in which parents filed suit directly to the district court challenging the suspension from school of their handicapped child as a result of the child’s violent behavior. Id. at 1226. The district court heal’d testimony first-hand and made its factual determinations based on its own observation of the witnesses and evidence. Id. Consequently, on appeal, we deferred to the findings of the district court, reviewing only for clear error. Id. at 1229. Unlike Light, the district court in Yankton, as well as in the present case, did not preside over the trial, take evidence, or hear and observe witnesses first-hand. 93 F.3d at 1372. As a result, it seems Yankton may have improvidently applied this deferential standard to a case where it is not appropriate. In my opinion, I see no reason to defer to the district court, particularly when the decision of the ALJ — who did hear witnesses and take evidence — -is merely afforded “due weight.” Instead, I would follow the more logical de novo standard when reviewing a district court’s decision in a case such as this one. See, e.g., C.B., 636 F.3d at 989 (“We review the district court’s decision de novo.”)-, T.F. v. Special Sch. Dist. of St. Louis County, 449 F.3d 816, 818 (8th Cir.2006) (reviewing the district court’s decision de novo, giving “due weight to the outcome of the administrative proceedings”) (internal quotation marks and citation omitted).
The application of a deferential standard in some IDEA cases may be appropriate where the district court hears additional evidence under 20 U.S.C. § 1415(i)(2)(C)(ii). See Lorenzen v. Montgomery County Bd. of Edu., 403 Fed. Appx. 832, 835 n. 5 (4th Cir.2010) (unpublished) (“In appeals under IDEA we generally conduct a modified de novo review, giving ‘due weight’ to the underlying administrative proceedings. However our cases also indicated that when a district court hears additional evidence in an IDEA proceeding ..., we apply a clear error standard of review.”) (internal citations omitted). However, the district court’s decision in this case was premised only on a review of the written record. And, where a district court’s decision is based solely on a written record, I would not afford any deference to its factual findings. I instead suggest this court review the district court’s decision under the more appropriate de novo standard, standing in essentially the same position as the district court, “rendering] an independent decision based on a preponderance of the evidence in the administrative record, ... givfing] ‘due weight’ to the results of the administrative proceedings and not substituting] its ‘own notions of sound educational policy for those of the school authorities which they review.’ ” C.B., 636 *814F.3d at 988-89 (quoting Rowley, 458 U.S. at 205-06, 102 S.Ct. 3034).
II
Having concluded our review is deferential to the ALJ and not the district court, I next turn to the issue at hand: whether K.E. was denied FAPE. The district court determined the School District provided FAPE to K.E., and the majority affirms. In reaching this conclusion, both the district court and the majority reason the School District developed IEPs adequately addressing K.E.’s unique needs and K.E. received some educational benefit. However, these determinations stand in stark contrast to the findings and conclusions of the ALJ, which I find to be supported by a preponderance of the evidence and therefore entitled to due weight. See Neosho R-V Sch. Dist. v. Clark, 315 F.3d 1022, 1028 (8th Cir.2003) (affirming the district court’s deference to the administrative panel’s decision where the record supported the decision). In giving those findings and conclusions due weight, I conclude the IEPs failed to adequately address KE.’s needs, inadequately defined necessary services, and were not properly implemented. As a result, K.E. was denied any meaningful educational benefit and, accordingly, was denied FAPE. I would therefore reverse the district court in part, and reinstate the ALJ’s decision on this issue.
The School District had an obligation to create an IEP reasonably calculated to provide educational benefit to K.E. See Rowley, 458 U.S. at 203, 102 S.Ct. 3034. “IDEA does not require that a school either maximize a student’s potential or provide the best possible education at public expense.” Fort Zumwalt, 119 F.3d at 612 (citing Rowley, 458 U.S. at 203, 102 S.Ct. 3034). IDEA is intended, instead, to “open the door of public education to handicapped children on appropriate terms.” Rowley, 458 U.S. at 192, 102 S.Ct. 3034. This court has held the School District need only provide the student with “ ‘some educational benefit’ and need not give her the best education possible.” Blackmon, 198 F.3d at 660 (quoting Rowley, 458 U.S. at 200, 102 S.Ct. 3034). However, the United States Supreme Court has qualified the educational benefit must be “meaningful.” Rowley, 458 U.S. at 192, 102 S.Ct. 3034. A student receives FAPE if the education (1) addresses the student’s unique needs, (2) provides adequate support services to allow the student to take advantage of the educational opportunities, and (3) is in accord with the individualized education program. See Rowley, 458 U.S. at 188-89, 102 S.Ct. 3034 (defining FAPE as “educational instruction specially designed to meet the unique needs of the handicapped child, supported by such services as are necessary to permit the child ‘to benefit’ from the instruction ... [and] such instruction and services ... comport with the child’s IEP”); see also Capistrano Unified Sch. Dist. v. Wartenberg, 59 F.3d 884, 893 (9th Cir.1995). I conclude the School District failed to meet any of these three requirements, and address them each in turn.
A
First, a school district is required to develop an IEP addressing the unique needs of a given child. E.S., 135 F.3d at 569 (holding IDEA requires schools to “provide a ‘free appropriate public education’ to all of its disabled students by formulating IEPs tailored to their unique needs”) (quoting 20 U.S.C. § 1412). A school district is not required to identify a student’s issues by name or official diagnosis so long as the IEP properly identifies and addresses the student’s disability. See, e.g., Pachl ex rel. Pachl v. Seagren, *815373 F.Supp.2d 969, 975 (D.Minn.2005); see also Cronkite ex rel. Cronkite v. Long Beach Unified Sch. Dist., No 97-55544, 1999 WL 196544, at * 1 (9th Cir. Apr. 1, 1999) (unpublished); O’Dell v. Special Sch. Dist. of St. Louis County, 503 F.Supp.2d 1206 (E.D.Mo.2007). Notably, behavioral issues constitute a unique need which may negate academic progress if left unattended by an IEP or behavioral intervention plan. See Neosho, 315 F.3d at 1029-30. According to the ALJ, the School District failed to address many of KE.’s unique needs because it failed to provide adequate goals and adaptations addressing K.E.’s behavioral issues.
The ALJ made several findings to support such a conclusion. Beginning with the School District’s evaluation in the spring of 2005 — K.E.’s first-grade year— the reports indicated K.E. needed repeated directions, shortened assignments, visual prompts, additional time for assignments and tests, seating with minimal distractions, and assistance with organization. The School District determined K.E. was not eligible for special education services at the time because she lacked a qualifying medical diagnosis, but in October 2005, once a diagnosis of ADHD was received, K.E. did qualify for services. Thereafter, an IEP was developed to deal not only with K.E.’s below-grade-level academic performance, but also to work on her independent work and social skills. Once K.E. qualified for special education services, the School District recognized various behavioral challenges in the years to follow in progress reports, teacher evaluations, and a functional behavior assessment. Beginning in third grade, evaluations from KE.’s doctors, which were reviewed by the School District, indicated K.E. had an impaired ability to follow directions, initiate tasks, manage and organize classroom materials and complete academic tasks in reading, writing and math. Even more, one report indicated K.E. suffered from bipolar disorder and articulated the consequent behavioral challenges. Despite the School District having reviewed this report, the behavioral challenges were unaddressed in KE.’s IEPs. As the ALJ found, the School District made “no acknowledgment that [KE.’s] mental health could affect her ability to perform, and no expression of the need to monitor her mental health.” Administrative Findings ¶¶21, 25, Appellant’s Add. at 8-9. The IEP failed to include any services based on KE.’s inability to consistently understand cues, follow instruction, process information, or comprehend social interactions. As the ALJ found, “[w]ith the exception of the alternate work setting, there were no adaptations or strategies to help the Student concentrate on her work or modulate her behavior, even though each of those issues was identified in the Evaluation Report.” Administrative Findings ¶¶ 22, 24, Appellant’s Add. at 8-9.
KE.’s inability to focus in class and be organized persisted in the following years. Behavior logs from 2007 indicated K.E. regularly failed to bring required materials to class, homework was often missing, and behavior logs were lost. K.E. also engaged in disruptive behavior. These issues were minimized on the rare occasion K.E. was assisted one-on-one by a paraprofessional/educational assistant (“EA”), as was reported by KE.’s classroom instructors, but otherwise were repeated on a regular basis. Without assistance, K.E. often felt overwhelmed or frustrated and had to leave class or move to a less distracting portion of the room. She was unable to focus on any one task for more than a few minutes. In 2007, K.E. also experienced an overall regression in writing and spelling, yet no changes were made to address KE.’s poor progress or to consider regularly providing one-on-one *816EA support despite the marked improvements made on the few occasions when one was made available. Then, in reports from 2008, K.E.’s instructors consistently indicated K.E. had difficulty sustaining attention, following directions, remaining quiet, working independently, completing assignments and staying organized. K.E. appeared to be impulsive, lacking self-control, and would shut down if given a reading or writing assignment. She continued to forget to bring materials to class and she also had difficulty with peers. One teacher indicated she felt KE.’s inappropriate behavior was increasing and was interfering with her education. K.E. even described the 2007-2008 school year as miserable because she often could not function at school. Yet, despite the lack of progress on improving or mitigating K.E.’s behavioral challenges under the former and existing IEPs, nothing was changed.
Even after receiving a formal diagnosis for bipolar disorder in the spring of 2008, the School District made minuscule changes to the IEP. The disability was updated from “Other Health Disabilities” to “Emotional or Behavior Disorder,” and the IEP better reflected KE.’s ongoing academic challenges. Yet, the functional skills goals remained the same with no changes to improve her independent work skills. The IEP did call for access to an EA within the regular classroom, but did not describe the manner or time for the EA support. Further, the IEP did not address any additional services to be offered based on this new diagnosis, or strategies to keep K.E. focused in class, remain quiet, work independently, complete assignments, stay organized, or maintain self-control.
More than one-half of a year after the School District received KE.’s formal diagnosis, the behavioral issues still persisted with little change to KE.’s IEP. In January 2009, the classroom instructor noted K.E. still found assignments difficult, she could not study for tests independently, and she had to be given modified assignments and tests. She could not focus on one thing for more than a few minutes, refused to do work she thought would be too difficult, and continued to blurt out and interrupt class.
Throughout K.E.’s time in the elementary school, her IEPs failed to address these behavior issues. As the ALJ found, “[w]ith the exception of the alternate work setting, there were no adaptations or strategies to help the Student concentrate on her work or modulate her behavior, even though each of those issues was identified in the Evaluation Report.” Administrative Findings ¶ 24, Appellant’s Add. at 8-9. The adaptations offered in the IEPs were for sensory breaks, repeating instructions, preferential seating, and other in-class techniques for regaining K.E.’s attention once it was lost. However, these techniques proved to be inadequate as the IEPs and progress reports repeatedly noted no improvement in her independent work skills, organization, or classroom behavior. In April 2008, after the School District was formally notified of the bipolar diagnosis, it did develop a behavioral intervention plan to incorporate into KE.’s IEP, but the plan only “responded” to bad behavior, failing to develop methods for avoiding the problematic behavior in the first instance. The plan proposed use of the “1, 2, 3, Magic” technique which is essentially a system of warnings, and used positive rewards for good behavior, tracking behavior using behavior logs. Specifically, the focus of the behavior intervention plan was to deal with verbal disruptions in class, negative verbal interactions with peers, and physical aggression toward peers. It did not adequately address the education-impeding behaviors which prevented K.E. from focusing in *817class and often causing her to need to leave the room.
These techniques were insufficient, particularly when considering that, as the hearing testimony established, a child with a mood disorder like K.E. cannot control her behavior or appreciate the consequences of bad behavior. As a result, warning and reward systems will not assist K.E. with her behavioral challenges. Yet, the IEPs and behavioral intervention plan focused on warning and reward systems, failing to provide strategies to help K.E. avoid misbehavior from the beginning. They did not include strategies for a teacher to follow when presenting a lesson in order to keep K.E. focused or to verify she understood the lesson or instructions. Nor was there any strategy to increase sensory stimuli in order to keep K.E.’s attention and help decrease her disruptive behaviors. Further, when independent work began, there were no strategies to ensure K.E. knew what tasks she should be accomplishing and to help her remain focused and organized so she did not become disruptive and could remain in the classroom for as long as possible. Without a plan to avoid a downward behavioral spiral before it started, K.E. often struggled with being attentive in class and her only remaining method of recovery from such bouts of bad behavior was to take breaks.
Even with these failures in K.E.’s education plan, the district court found the IEPs and behavioral intervention plan to be adequate. The crux of the district court’s determination was its conclusion the School District was not aware of KE.’s bipolar disorder because it had only received contradictory information as to whether K.E. actually suffered from the disorder at the time the education plans were developed, and the School District could only act on the information available at the time the IEPs were created. Consequently, according to the district court, because the School District only learned of KE.’s bipolar disorder in 2007 and did not receive a formal diagnosis until 2008, it was not obligated to address the disorder in her IEPs. The majority has adopted this conclusion of the district court. Such a reading of the record leads me to a contrary result, one which is in accord with the ALJ’s findings and conclusions.
The School District did not receive a formal diagnosis before the spring of 2008; however, prior to such time, the School District was provided several reports— starting with Dr. Miller’s in 2005 — indicating K.E. had been diagnosed with bipolar disorder. Also, KE.’s Parent informed the school on several occasions of KE.’s bipolar diagnosis, as recorded in KE.’s 2005 evaluation. During her second-grade year, K.E. was hospitalized for mental disorder, about which the school was made aware. In the beginning of her third-grade year, the school nurse received a medical order for medication administration which clearly indicated K.E. was taking the medicine because she had been diagnosed as bipolar. And in 2007, Dr. Ziegler’s report, which was discussed at an IEP meeting, noted KE.’s diagnosis of bipolar disorder. Jacqueline Stein, Director of Special Services for the School District, even admitted awareness of the bipolar diagnosis in 2007 based on Dr. Ziegler’s report. Thus, the record clearly establishes by a preponderance of the evidence the School District was informed of K.E.’s bipolar disorder early in her education, supporting the ALJ’s finding the School District knew of KE.’s condition and should have accounted for it in her IEPs and behavior intervention plan.
Even more, as the School District admits in briefing, it is not the formal diagnosis which determines the make-up of the *818IEP; it is the child’s unique needs. See Rowley, 458 U.S. at 188-89, 102 S.Ct. 3034; Appellant’s Br. at 25. Both Dr. Miller’s and Dr. Ziegler’s reports provided in-depth descriptions of KE.’s symptoms, including lack of ability to focus, behave, stay engaged in class, and be organized. As detailed above, many of the behavioral concerns attributed to bipolar disorder were observed and documented in KE.’s progress reports and IEPs yet were left unaddressed. Thus, regardless of whether the School District had a formal diagnosis, it was fully aware of K.E.’s unique needs created by the disorder. Yet, the School District failed to adequately address them. Consequently, regardless of whether the School District was cognizant of KE.’s bipolar diagnosis before 2008, it was aware of her education-impeding behavioral challenges and failed to address them in her IEP and behavioral intervention plan. In my opinion, this failure deprived K.E. of a significant educational benefit.
B
I would next conclude in addition to failing to account for KE.’s behavior issues in the IEPs, the School District also failed to provide necessary psychological and social work services to monitor KE.’s mental health and address issues arising from the cyclical nature of bipolar disorder. Under IDEA law, an IEP must include “a statement of the special education and related services ... to be provided to the child ... to advance appropriately toward attaining the annual goals” and “to be involved in and make progress in the general education curriculum.” 20 U.S.C. § 1414(d)(l)(A)(i)(IV). Psychological services and social work services are included in such related services “as may be required to assist a child with a disability to benefit from special education.” Id. § 1401(26)(A).
K.E. contended the School District failed to provide her with these services, and the ALJ agreed. The School District disagrees suggesting it could not have provided any of these extra services because it had not received a formal diagnosis at the time the disputed IEPs were created. It is recognized an IEP cannot be judged “exclusively in hindsight” because the court “must take into account what was, and was not, objectively reasonable when the snapshot was taken, that is, at the time the IEP was promulgated.” Roland M. v. Concord Sch. Comm., 910 F.2d 983, 992 (1st Cir.1990). However, giving due weight to the findings of the ALJ, and consistent with the discussion contained in the previous section, the School District was aware of KE.’s bipolar diagnosis and likewise aware her mood disorder affected her ability to focus, behave, and become educated. The School District could have informed KE.’s parents it required a formal diagnosis to address K.E.’s unique needs, however, it did not.
The record establishes K.E.’s mood dysregulation was a common issue both inside the classroom and during unstructured free time. The School District was aware from as early as KE.’s second-grade year the positive behavior incentives and the warning systems were not improving KE.’s behavior. Even without the advantage of hindsight, at a minimum, the School District should have considered psychological and social work services after receiving Dr. Ziegler’s report in 2007— the end of K.E.’s third-grade year — in which Dr. Ziegler identified education-impeding behavioral issues attributable to her mood disorder. It did not, and I would conclude the School District’s failure to provide, or at least consider, such services interfered with KE.’s ability to take advantage of the educational opportunities.
*819Additionally, as the ALJ found, the School District failed to provide K.E. necessary paraprofessional (“EA”) services. In reversing the ALJ, the district court concluded such services were not necessary because the classroom teacher was able to provide the needed one-on-one attention to K.E. to permit her to learn regardless. However, based on an independent review of the record, I would conclude otherwise. The lack of an EA often resulted in K.E. shutting down and declining to participate any time the classes involved reading and writing or unstructured time. Even more, when K.E. was in the classroom, she needed to be seated near the teacher, needed directions repeated, and needed someone to constantly keep her on track. When the teacher was unable to do this, K.E. would act out, not respond to warnings, and have to take a break — leaving class and losing education time. Progress reports showed this occurred two times a day on average. KE.’s ability to learn was significantly impeded by her inability to focus. As the ALJ found, and the School District’s own records and teacher feedback established, one-on-one work with an EA would have helped to correct the issue. Without such assistance, K.E. was denied the opportunity to receive any meaningful educational benefit.
C
Finally, the School District failed to fully implement the terms of the IEP. Even though the IEP included an EA in some environments during the fourth- and fifth-grade years, an EA was not provided. The ALJ determined this was a substantive violation of the IEP and it denied FAPE to K.E. The fact an EA was not provided was undisputed. Accordingly, this too contributes to the School District’s failure to provide FAPE.
In sum, I would conclude the School District failed to address each of K.E.’s unique needs resulting from her bipolar disorder, failed to provide adequate support for K.E.’s psychological needs and in-class needs, and failed to comply with the IEP as developed. Accordingly, I would hold KE.’s IEP was not reasonably calculated to provide, nor did the implementation of the IEP actually provide, K.E. any meaningful educational benefit.
Ill
Nevertheless, the majority holds K.E. was not denied FAPE because, regardless of any less than adequate plans, denial of special education services, and failure to provide an EA as listed in the IEP, K.E. made sufficient academic progress. The majority rejects KE.’s contention she did not make “adequate progress” academically, concluding “[t]he record ... does not support this characterization of K.E.’s academic progress.” Ante at 809. According to the majority, the record shows K.E. “made significant progress in reading, spelling, and math.” Id. To support its understanding of the record, the majority provides specific examples of achievements in each subject matter from the fall of K.E.’s third-grade year to the end of her fourth-grade year, including improvement in her reading fluency as well as in her ability to decode words, read clocks, count change, perform addition and subtraction, and skip-count. The majority concludes KE.’s progress evidences “some educational benefit.” I disagree. K.E. did make some progress in certain subjects and at certain times during the relevant years, but K.E. also regressed in some areas and overall her progress was trivial.
In 2005, KE.’s performance was measured by the School District to be below grade-level academically, indicating K.E. had below-average cognitive abilities and *820working memory. Later, in 2006, K.E. was tested and fell below the levels measured in 2005. Through the end of her second-grade year, K.E. showed some progress in reading, but writing and spelling did not improve and K.E. still struggled with developing accurate sentences using correct capitalization and punctuation. By the end of second grade, K.E. was able to decode words (although the report does not indicate which words or what difficulty) with 85% accuracy. She was able to read short stories orally with 83% accuracy, and answer literal questions about reading passages with 95% accuracy. K.E. could read first-grade material at 46 words per minute with 95% accuracy. She mastered 92 of the first 100 Fry words (words identified by Edward Fry as the most used words in reading and writing). With regards to spelling, K.E. met her goal of spelling words from her spelling list with 98% accuracy, but did not meet her goal of spelling those words on tests with 85% accuracy. K.E. continued to struggle with capitalization, beginning her sentences with a capital letter only 60% of the time. KE.’s progress report indicated from 2005 to 2006 K.E. made little progress in math as well as with her functional skills.
In the next year, from 2006 to 2007, K.E. went from reading consonant-vowel-consonant words with 95% accuracy to reading 5-6 letter words with sound blends with 90% accuracy. Her reading fluency also improved to reading a second-grade passage at 80 words per minute with 97% accuracy. Notably, the record does not indicate whether this reading pace is above- or below-average, but it is an improvement from her previous year. K.E. did fail to meet her goal of making logical inferences based on passages she reads. The objective was carried over to the next year. KE.’s ability to read Fry words increased as well. She could read the first 300 Fry words with as high as 88% accuracy by the end of third grade. However, K.E. regressed in spelling. She successfully spelled words from her list only 68% of the time, and completed her tests with only 60% accuracy. K.E. also failed to improve her capitalization and punctuation, still capitalizing her sentences only 60% of the time. In math, K.E. was able to read a clock to the half hour with 100% accuracy, and was able to read coins and determine their value. She was also able to perform one-digit subtraction with 100% accuracy.
Despite not having met several of her goals the previous year, in the fall of 2007, at the start of fourth grade, KE.’s goals were increased. For example, K.E.’s new goals focused on writing paragraphs even though she could not write complete sentences correctly. In March 2008, K.E.’s progress report showed some progress in reading as well as some improvement in spelling, but still no progress in writing. She continued to have ongoing trouble with capitalization and punctuation, struggled with writing her own sentences, and had poorly organized paragraphs. The report found her progress in math to be minimal. Specifically, K.E. had improved her reading slightly, reading 5-6 letter words with sound blends with 95% accuracy. She was reading at a fourth-grade level at 54 words per minute and 90% accuracy, and she was reading 105 words per minute with third-grade reading material with 100% accuracy. K.E. did not make progress on her Fry words, still working to learn the third set of 100. In spelling K.E. ranged from an 83% to 87% success level on spelling lists and tests. In math, K.E. learned to tell time to the minute with 85% accuracy. She was also able to identify coins with 100% accuracy, counting change up to $2.00 with 83% accuracy. K.E. also began to perform skip *821counting and performed two-digit subtraction with 80% accuracy. Her classroom teacher indicated K.E. was struggling in all academic areas. At the end of the school year in 2008, KE.’s reading performance had declined with the exception of a small increase in reading fluency and she made some progress in math, but there was no evidence of progress in writing.
In sum, each of these progress reports indicate small successes in various subjects throughout the years. However, when read as a whole, KE.’s progress spanning the four relevant academic years was trivial. She progressed from single-digit to multi-digit addition and subtraction, learned to tell time and count change, improved reading fluency and pace but continued to lag significantly behind others, and struggled with spelling and writing.
The lack of progress to be gleaned from these reports is echoed by KE.’s standardized testing scores. The school district conducted Northwest Evaluation Association (“NWEA”) testing several times each year on both reading and math. The RIT score received on the NWEA test each year is intended to be compared to scores from previous years’ testing to measure a student’s progress. KE.’s scores fluctuate dramatically. Beginning in the winter of KE.’s second-grade year — the first point in time relevant to KE.’s IDEA claims — K.E. had a math score of 180. This score dropped by the end of the school year to 173. K.E. then regressed over the summer to a 168, making it back up to a 177 by the spring of 2007, still several points below where she was in second grade. However, KE. did make some progress in her fourth-grade year; she returned in the fall with a 170, but reached 187 by the spring of 2008, and in January 2009 received a 193. By comparison, however, the average student in KE.’s grade started with a 186 in the winter of her second-grade year and rose to a 216 by January 2009. The progress in math seems as though it could be considered meaningful, but in contrast to her peers, K.E. regressed significantly. Her score in the winter of her second-grade year placed her in the 33rd percentile of her classmates. This percent dropped dramatically over the course of the next three years, placing her in the 6th percentile of her peers by the winter of her fifth-grade year.
KE. demonstrated a similar progression in her RIT scores in reading, but did make some positive movement in her percentile rank, albeit a seemingly small improvement. In the winter of her second-grade year, K.E. scored a 160, which dropped to 155 by the end of the year, rose to 164 at the end of her third-grade year, to 186 in fourth-grade, and finally reached a score of 191 by the winter of her fifth-grade year. However, like math, KE. still lagged significantly behind her peers, whose average score was 210 by the winter of fifth grade. The statistics on KE.’s annual progressions in reading indicated she progressed at a slower rate than did her peers, moving 2 points in her second-grade year, whereas her peers progressed 20 points, then 7 points in her third-grade year compared to her peers’ 17 points, and finally 9 points in her fourth-grade year in contrast to her peers’ 15 points. In terms of percentile, K.E. started in the 7th percentile in second grade, dropping to the 1st percentile by the end of the year, and then hovering between the 1st and 3rd percentile through the end of her fourth-grade year. K.E. did experience a significant leap from the fall of 2008 to January 2009 — the fall semester of her fifth-grade year — climbing from the 3rd to the 9th percentile.
*822Relevantly, this information was available to the ALJ during the administrative hearing. In its findings, the ALJ referenced some of these scores and interpreted KE.’s reading progress as “small,” with the math scores showing “more progress.” Regardless, the ALJ, being fully cognizant of the. progress reports and the standardized testing, found K.E. did not make meaningful progress, “suffering] a loss of educational benefit.”
Recognizing full well I lack the “specialized knowledge and experience” of the ALJ in this “difficult question[] of educational policy,” Rowley, 458 U.S. at 206, 208, 102 S.Ct. 3034, I would grant due weight to the ALJ and agree K.E. failed to make sufficient progress. Essentially, as I review the record, K.E. did make some progress from second to fifth grade, but when considering her progress spanned four academic years, it becomes trivial at best. It seems this minimal progress indicates K.E. has an ability to learn and progress, yet she was unable to make any significant or meaningful strides. When viewing her progress reports in their entirety from second grade forward, it becomes evident KE.’s ability to make any meaningful progress was stifled by her behavior. She was unable to focus on any one task for more than a few minutes, could not keep track of homework assignments, and needed extra time to complete in-class tasks because she could not focus. In my view, the record provides evidence of only “de minimis academic and social progress” and “any slight benefit obtained was lost due to behavior problems that went unchecked and interfered with [KE.’s] ability to obtain a benefit from [her] education.” Neosho, 315 F.3d at 1029; see also Fort Osage R-l Seh. Dist. v. Sims ex rel. B.S., 641 F.3d 996, 1004 (8th Cir.2011) (concluding a student who had “consistently progressed under previous IEPs and ... displayed no negative behaviors after the first, formal behavioral plan was implemented” received FAPE because her progress was not “illusory” nor was her “ability to progress undercut by unaddressed behavioral difficulties”).
IV
In summary, from December 2005 until the time she filed her amended complaint for a due process hearing in 2009, K.E. suffered from known behavioral issues which significantly interfered with her ability to derive any meaningful educational benefit from her schooling. Despite knowing of KE.’s behavioral challenges, I would conclude the School District failed to develop an IEP or implement a behavioral intervention plan capable of conferring some educational benefit upon her. I would further conclude the record establishes K.E. received no meaningful educational benefit during the relevant years of schooling, and I would thus hold K.E. was denied FAPE. I would therefore reverse the district court on this issue, and reinstate the ALJ’s decision in part.