States are increasingly using value-added approaches to evaluate teacher effectiveness. There is much debate regarding whether these methods should be employed and, if employed, what role such methods should play in comprehensive teacher evaluation systems. In this article, we consider the use of value-added modeling (VAM) to evaluate special educators. We examine the potential difficulties that may be due to individualized needs and characteristics of students with disabilities, the context within which special education services are delivered, and aspects of VAM that have a differential impact on the value-added scores of special education teachers.