The Difference Between Implementation Issues and IEP Issues
By: Dr. Gabrielle Baker, President & Advocate
When a child with an IEP is struggling, one of the first things parents often hear is, "Maybe we need to reconvene the IEP team."
Sometimes that's exactly what needs to happen.
But sometimes the IEP isn't actually the problem.
Sometimes the IEP is appropriate on paper, but what is written in the document isn't what the student is actually receiving.
That's an important distinction because you can't fix an implementation problem by endlessly rewriting the IEP.
What Is an IEP Issue?
An IEP issue means there is a problem with the actual plan the team has developed for the student.
Maybe the goals don't address an area of need. Maybe the service minutes aren't sufficient. Maybe an accommodation the student needs isn't included. Maybe the specially designed instruction isn't specific enough. Or maybe the placement isn't providing the level of support the student requires.
For example, imagine your child has significant reading needs, but their IEP only provides 20 minutes of specialized reading instruction twice per week.
The school might be providing every single minute listed in the IEP exactly as written.
But your child still isn't making appropriate progress.
That may not be an implementation problem at all. The team may need to consider whether the IEP itself is insufficient to meet the child's needs.
Other potential IEP issues might include:
Goals that don't address all identified areas of need
Goals that aren't measurable
Insufficient service minutes
Missing accommodations
Inappropriate or vague specially designed instruction
A placement that doesn't provide the support the student needs
Progress monitoring that doesn't adequately measure the student's goals
Services that don't match the student's identified needs
In those situations, the conversation needs to focus on changing the IEP.
What Is an Implementation Issue?
An implementation issue is different.
The IEP may say exactly what your child needs, but the school isn't actually doing it.
For example, your child's IEP says they receive 30 minutes of specially designed reading instruction five days per week.
On paper, that sounds great.
But then you learn that reading instruction is frequently canceled when the special education teacher is absent, your child misses it for assemblies or other activities, or the "reading instruction" is actually being used as time to finish classroom assignments.
That's not necessarily a problem with what the IEP says.
That's a problem with whether the IEP is being implemented.
Implementation concerns can look like:
Service minutes regularly being missed
Accommodations not being provided
Assistive technology sitting unused
A behavior plan not being followed
Progress monitoring not being completed as required
Specially designed instruction being replaced with homework help or study hall
A student not receiving services in the setting specified by the IEP
Staff being unaware of accommodations or supports they're responsible for providing
Parents sometimes spend months asking for changes to an IEP when the bigger question should have been: Is the school actually doing what the current IEP already requires?
Start With the IEP
When a parent tells me, "They're not giving my child enough support," one of my first questions is usually some version of:
What does the IEP actually say?
That's where we have to start.
Pull out the current IEP and compare the document to what is happening in practice.
If the IEP says your child receives a particular service, ask how often that service is occurring.
If an accommodation is listed, ask your child whether they're actually receiving it.
If the IEP requires progress monitoring, ask to see the data.
If specially designed instruction is listed, ask what that instruction actually looks like.
Don't assume that because something appears on the IEP, it is happening consistently.
And don't assume that because something is happening consistently, it is enough.
Those are two separate questions.
The Data Can Help You Figure Out Which Problem You Have
Progress-monitoring data becomes especially important here.
Imagine your child's IEP provides a specific reading intervention five days per week, and the school has documentation showing that the intervention has been delivered consistently and with fidelity.
But your child's data shows very little progress over several months.
Now we may be looking at an IEP issue.
The team may need to consider whether the frequency, intensity, methodology, goals, or other aspects of the student's program need to change.
Now imagine the same child isn't making progress, but when you start asking questions, you discover the intervention has only been happening two or three times per week.
That's a very different conversation.
Before concluding that the intervention itself doesn't work, we need to know whether the child actually received the intervention the team agreed to provide.
Sometimes It's Both
Unfortunately, these categories aren't always clean.
A student can absolutely have an IEP that needs to be changed and have problems with implementation.
Maybe the student isn't receiving all of their service minutes, and even if they were, the current level of service still wouldn't be sufficient.
Maybe an accommodation isn't consistently being provided, but the student also needs additional accommodations that aren't currently listed.
Maybe the behavior plan isn't being followed with fidelity, but the existing plan is also based on outdated information and needs to be revised.
That's why parents shouldn't feel pressured to immediately accept a single explanation for why their child isn't progressing.
We need to look at the entire picture.
Ask Different Questions
If your child isn't making progress, don't stop at:
"Do we need to change the IEP?"
Ask:
What does the current IEP require?
Is every part of it being implemented consistently?
What data shows that the services and supports are actually being provided?
What does the progress-monitoring data show?
If the IEP is being implemented as written and my child still isn't making appropriate progress, what needs to change?
Those questions help separate what can otherwise become a very confusing conversation.
Because if the plan is appropriate but isn't being followed, we need to address implementation.
If the plan is being followed but isn't meeting the student's needs, we need to address the IEP.
And if both are happening, we need to address both.
Don't Keep Changing the Plan Without Asking Whether the Last One Was Followed
This is one of the biggest things I want parents to understand.
When a child isn't making progress, teams can sometimes jump quickly to another intervention, another accommodation, another goal, or another placement.
But before we decide the current plan failed, we should know whether the student actually received the plan.
Was the IEP implemented consistently and as written?
That answer matters.
An IEP can look excellent on paper and still fail a student if it isn't implemented. At the same time, perfect implementation can't make an inadequate IEP appropriate.
Parents need to know which problem they're dealing with so they can advocate for the right solution.
And if you're looking at your child's IEP and thinking, I don't even know which one of these problems we have, that's exactly the kind of thing an educational advocate can help you untangle.
