A primary focus of recent educational policymaking has been on improving measures of teaching effectiveness, attributable in part to recent federal policies such as the Race to the Top initiative and Investing in Innovation. To date, neither researchers nor practitioners have arrived at a consensus on the best methods for evaluating special educators. While value-added scores are likely not suitable for the majority of special education teachers, observation systems appear to be more promising because they can be used across a variety of instructional settings and formats. To illustrate the steps that would be necessary to validate observation systems for use with special educators, we examine the observation system being most commonly used in school districts--Charlotte Danielson's Framework for Teaching (FFT). Drawing on empirical research, we propose a definition of effective special education teaching, and we then use this definition to frame our investigation into FFT. We conclude with a series of recommendations for research that would establish the validity of using FFT to evaluate special educators. We also describe how the challenges specific to FFT would generalize to other observation systems.