We conducted a systematic review of the evidence related to online instruction in writing for students with special needs with the purpose of determining whether the existing literature can provide a research base and responding to special education researchers' concerns about students with disabilities receiving instruction online. We identified 3 additional studies since the most recent review of the literature, published by Means, Tomaya, Murphy, Bakia, and Jones in 2009. The unique characteristics of the online environment afforded opportunities for embedded learning strategy activities, procedural facilitation cue sheets, and embedded text structure supports, that would have otherwise been impossible in a typical face-to-face environment. Online environments may provide unique features that support the writing of students with disabilities.