The Supreme Court decision in "Endrew F. v. Douglas County School District" (2017) established a higher standard of what constitutes an appropriate education for students receiving special education. In contrast to the previous standard provided in the "Board of Education v. Rowley" (1982) decision, which established that "some benefit" (even minimal or trivial benefit) was acceptable, the "Endrew F." decision reflected a higher standard for the delivery of special education. Specifically, special education should result in measurable progress toward individualized education program goals. This article explores what it means for special education teacher educators to prepare teacher candidates to meet this higher standard. In particular, how a focus on instruction (i.e., the delivery of specially designed instruction) rather than a focus on access to the general curriculum is necessary in order for meaningful, measurable change to occur in the outcomes of students with high-incidence disabilities will be explored.