AI's Impact On Vulnerable Populations- 3 Major Risks
Artificial Intelligence is reshaping how schools support students. For most, this shift feels like a tremendous opportunity. But for our most vulnerable students, including students in special education, the stakes continue to remain high. The real question is: will AI use close long-standing equity gaps, or widen them further?
It all depends on the school and the teacher.
The Three Major Risks
1. Risk of Neglect
Some educators and districts may avoid or underuse AI out of fear or lack of resources. When that happens:
Neurodivergent students in low-resource schools lose access to tools that could personalize instruction and improve communication.
Teachers remain buried in paperwork instead of gaining the time-saving supports AI could provide.
Innovation accelerates in well-funded schools, leaving others even further behind.
Neglect doesn’t protect vulnerable learners, but instead denies them access to potential breakthroughs.
2. Risk of Manufactured Authority
On the other end of the spectrum, some may over-rely on AI without proper checks:
AI hallucinations. Systems can generate convincing but fabricated data, references, or progress reports.
Uncritical trust. Teachers or administrators may accept AI-generated narratives about students without verification.
Pressure to “fill in the gaps.” Even without AI, educators sometimes feel compelled to “make up” progress-monitoring data. AI can make this easier to mask - creating loops of false evidence that look official but fail to reflect a child’s reality.
When manufactured authority is left unchecked, families and schools risk making legally and ethically flawed decisions that negatively affect a student's future.
3. Risk of Litigation
What safeguards and governance railings does your school have in place to ensure student and family rights are guaranteed? Without clear guidelines and governance, every district and school using AI to develop student IEPs and other documents is at risk of sharing legally protected student and family data.
Special education is one of the most legally protected areas of schooling. If AI leads to:
IEP goals that are not measurable or appropriate,
Services that do not match IDEA requirements,
Placement decisions that violate the Least Restrictive Environment (LRE), or
Data mismanagement that breaches FERPA, IDEA, or Section 504
…the result will not only be harm to students but also costly litigation. Districts could face lawsuits, OCR complaints, and reputational damage for failing to safeguard the rights of their most vulnerable learners.
The Promise of Innovation
Between those risks lies the real opportunity. Guided responsibly, AI will:
Personalize supports for reading, writing, executive function, behavior, and communication - see my book Universal Best Practices for All Learners here.
Streamline compliance work, freeing educators for more time with students.
Amplify student voices by giving new tools for expression.
Provide system-level insights that improve service delivery without overloading teachers.
Why Governance Matters
As outlined in our AI Governance in Special Education white paper, the key is not rejecting or blindly trusting AI - it’s governing it. Check out my White Paper "AI in Special Education: Governance Frameworks for IEP Teams".
Effective governance ensures:
Compliance with IDEA, Section 504, and OCR guidance.
Preservation of human judgment in all high-stakes decisions.
Accountability and transparency around how data is used.
Equity checks using tools like NAILEP to monitor inclusion (see my book).
Verification protocols so no fabricated data, whether human- or AI-generated, shapes a student’s IEP or trajectory.
The Path Forward
AI will not automatically make education more inclusive. Left unchecked, it can deepen inequities, generate false authority, or even expose districts to legal liability. But with thoughtful governance, it can reduce burdens, amplify student voices, and help create classrooms where every neurodiverse learner can thrive.
Download AI in Special Education: Governance Frameworks for IEP Teams
