held reimbursement available for private educational services beyond tuition at a private institution. See Payne v. Peninsula Sch. Dist., 653 F.3d 863, 877 (9th Cir.2011) (“If the measure of a plaintiffs damages is the cost of counseling, tutoring, or private schooling — relief available under the IDEA — then the IDEA requires exhaustion.”), cert. denied, — U.S. —, 132 S.Ct. 1540, 182 L.Ed.2d 161 (2012); Nieves-Marquez v. Puerto Rico, 353 F.3d 108, 124 (1st Cir.2003) (“[EJquitable remedies that involve the payment of money, such as reimbursements to parents for expenses incurred on private educational services to which their child was later found to have been entitled, remain available!)]”); Polera v. Bd. of Educ. of Newburgh Enlarged City Sch. Dist, 288 F.3d 478, 486 (2d Cir.2002) (<HOLDING>). We agree with these circuits that
holding that plaintiffs can obtain reimbursement for past or future educational expenses under the idea but not general damages such as compensation for lost earning power holding that damages are not relief that is available under the idea recognizing that the idea authorizes courts to order reimbursement of the costs of private specialeducation services in appropriate circumstances holding that by its terms the idea does not require exhaustion where the relief sought is unavailable in an administrative proceeding under the idea monetary damages are not available so exhaustion is not required holding reimbursement for private tutoring available under the idea