IEP Progress Reports: What Should Be Reported Vs. What Is Reported

What should be in Individualized Education Program (IEP) progress reports and what actually is in IEP progress reports often are two different things.

Imagine it is time for your annual work review. Your employer presents a report that states you didn’t make progress, or didn’t make enough progress, toward your goals for the year. However, when you read the report, there’s no data backing your employer’s decision, nor is there a performance plan for moving forward. You don’t know why you didn’t progress and you don’t know what you need to do in order to progress.

The same issues occur with IEP progress reports.

They should reflect the IEP, they should include data that supports degree of progress or failure to make progress, and they should include insight into why progress was or wasn’t made. With the latter, parents and educators can meet to decide if 1) the student still needs the goal; 2) if the student doesn’t need the goal; 3) if the goal needs to be adjusted; 4) if the student implementation or failure of implementation of accommodations, services, and/or related services impacted the student’s progress; and 5) if additional accommodations, services, and/or related services are needed for the student to make meaningful progress.

Federal Regulations

Federal regulations aren’t fun reads. Please stick with me on this one. There are quite a few that apply. Reading them will help clarify what should or shouldn’t be included in the IEP. The following are excerpts from 300.320 of the Individuals with Disabilities Education Act (IDEA), which provides a definition of an individualized education program.

Section 300.320(a)(3) of IDEA states that IEPs must include the following:

(3) A description of (i) How the child’s progress toward meeting the annual goals described in paragraph (2) of this section will be measured; and(ii) When periodic reports on the progress the child is making toward meeting the annual goals (such as through the use of quarterly or other periodic reports, concurrent with the issuance of report cards) will be provided;

That’s a clear statement. IEPs must include statements related to how and when progress will be measured and reported. So, let’s visit “paragraph (2)” mentioned above.

300.320(a)(2) of IDEA states that IEPs must include the following:

(2)(i) A statement of measurable annual goals, including academic and functional goals designed to (A) Meet the child’s needs that result from the child’s disability to enable the child to be involved in and make progress in the general education curriculum; and(B) Meet each of the child’s other educational needs that result from the child’s disability;(ii) For children with disabilities who take alternate assessments aligned to alternate academic achievement standards, a description of benchmarks or short-term objectives;

Combine paragraphs two and three and, again, you get another straightforward statement. IEPs must include statements of 1) how and when progress will be measured and 2) measurable annual goals that a) meet each of the child’s educational needs that result from the child’s disability; b) enable the child to make progress in the general education curriculum; and when applicable c) of benchmarks or short-term objectives.

Let’s look at a third excerpt from 300.320, specifically 300.320(a)(4), which states that the IEP must include the following:

(4) A statement of the special education and related services and supplementary aids and services, based on peer-reviewed research to the extent practicable, to be provided to the child, or on behalf of the child, and a statement of the program modifications or supports for school personnel that will be provided to enable the child (i) To advance appropriately toward attaining the annual goals;(ii) To be involved in and make progress in the general education curriculum in accordance with paragraph (a)(1) of this section, and to participate in extracurricular and other nonacademic activities; and(iii) To be educated and participate with other children with disabilities and nondisabled children in the activities described in this section;

When it comes to IEP progress reports, this is a piece to which you should pay attention: The IEP must include a statement of special education and related services that will be provided to enable the child to advance appropriately toward attaining the goals.

In other words: If a progress report states a student is not advancing appropriately, the report should include data for the special education and related services that are or are not working. Per 300.320(a)(4), if they are appropriate, the student should be progressing.

This applies to accommodations, too. Although accommodation isn’t defined in IDEA or Section 504 of the Rehabilitation Act of 1973 (Section 504) there’s a general understanding of what the word accommodation means and how they are applied.

Section 12182(a) of the Americans with Disabilities Act (ADA) states the following:

No individual shall be discriminated against on the basis of disability in the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of any place of public accommodation by any person who owns, leases (or leases to), or operates a place of public accommodation.

Section 12181(7)(J) of ADA states the following:

The following private entities are considered public accommodations for purposes of this subchapter, if the operations of such entities affect commerce (J) a nursery, elementary, secondary, undergraduate, or postgraduate private school, or other place of education;

Section 12181 and 12182 of ADA confirm that accommodations are the right of students in school since 1) no individual shall be discriminated against on the basis of disability in the full and equal enjoyment of the accommodations of any place of public accommodation and 2) schools are considered public accommodations.

The settlement agreement for The United States of America and the Park School agrees with this and states the following:

The ADA prohibits a place of public accommodation from discriminating against an individual on the basis of disability in the full and equal enjoyment of its goods, services and facilities.  42 U.S.C.  § 12182(a). . . .

Park School is a private school providing education to children in pre-kindergarten through eighth grade and is, therefore, a place of public accommodation covered by Title III of the ADA.  42 U.S.C. § 12181(7)(J).

If we wrap up the above, the schools are required to provide accommodations. Those accommodations impact goals, too, and thus data needs to be collected and shared about them, too.

And last, but not least, there’s the Every Student Succeeds Act (ESSA). December 2015, a reauthorization of the Elementary and Secondary Education Act of 1965 (ESEA), was passed. It ensures that school systems will prepare every child to graduate from high school for college and careers.

What follows below are examples of problems that arise with reporting.

The Report Should Include Data

If an IEP requires a student to do “X on 4 out of 5”, there’s a problem if the progress report states the student did X in “all data collected”.

“All” is not the same as “4 out of 5”.

What is the data?

If the school can’t provide you the data, there’s a problem. They should be able to cite and provide the data collected for the report. This is not an unreasonable request, but you might run into teachers who take offense to something as simple as a request for the actual data.

The Report Should Reflect the Goal

If an IEP requires a student to write three paragraphs containing X, Y, and Z in all subjects, on 4 out of 5 data samples for each subject, there’s a problem if the report states the student did this in History, but doesn’t mention any other subject.

It Isn’t the Student’s Responsibility to Provide Data to the School

If the progress report states that the student did not do X because he “didn’t attend Monday meetings with a teacher” or because he “didn’t finish all of his assignments”, there’s a problem.

It is the school’s responsibility to collect data. It is not the student’s responsibility to provide data to the school.

If there wasn’t data, then the school should have reported that the student “did X on 0 out of 5”.

IEP Progress Report Break Down

The following examples are pulled from a real IEP progress report, which includes goals, progress codes related to the goals, and comments related to the progress. The problems with the comments appear below them. Pay attention to the wording and measurements cited.

Annual Goal 1

Area of Need: Reading Comprehension

Goal: After reading a course-related text, [Student] will answer a variety of inferential questions across curriculum areas with at least 80% accuracy on 4 out of 5 data points, measured quarterly.

Progress Code: 4

Comments: [Student] was able to answer a variety of inferential questions across the curriculum with 80% accuracy on all data points collected. 

The Problems:

  • The comments don’t indicate that the student answered the questions “after reading a course-related text”. For all we know, the teacher could have asked questions after the students watched a video or after the teacher read a book out loud. There is no indication that data for a reading comprehension goal actually came from answers the student wrote after he read course-related text. Because this is a reading comprehension goal, the data has to indicate if the student read the text.
  • “All data collected” is not the same as “4 out of 5 data points”. “All” could equal one data point.
  • There is nothing indicating that the data collected was measured from that quarter. The way the goal is written, the data could have been collected the previous quarter or even the previous school year. That might seem like an extreme and unimaginable example, but when it comes to data collected by school divisions, fact often is stranger than fiction.
  • There isn’t a notice of the accommodations, services, or related services the student used. Did the student’s use of extended time help make the progress possible? What about the student’s use of large text or increased white space?

Short Term Objective 1

Area of Need: Reading Comprehension

Objective:

Given a piece of figurative language, [Student] will use a variety of strategies (close reading, visualizing, use of context) to determine and explain what at [sic] the figurative language means with 85% accuracy on 4 out of 5 opportunities, measured quarterly.

Progress Code: 2

Comments: [Student] was able to explain the meaning of presented figurative language on one assignment with 100% accuracy. Given four additional opportunities, [Student] did not provide and [sic] explanation of figurative language due to not completing the assignment.

The Problems:

  • “Presented” is not the same as “Given a piece”. This is a reading comprehension goal. Did the student read the “piece” he was given or was he presented with questions that followed the presentation of a video or book that was read out loud, or something else?
  • The goal doesn’t state that the student will “explain the meaning”. It states the student “will use a variety of strategies (close reading, visualizing, use of context) to determine and explain”. What strategies did the student use? How did the student use the strategies to determine and explain?
  • The comment indicates that the school is blaming the student for not providing it data. The school division’s failure to collect the data is why it doesn’t exist. In an entire quarter, it is hard to believe that the student didn’t have any other opportunities outside of the work he didn’t complete to exhibit his progress or lack of progress toward the goal. In addition, the comment states “the assignment”, not “assignments”. One assignment shouldn’t be the source of four data points.
  • If the school is, indeed, lacking data points because the student didn’t turn in any work (or turned in close to no work), that itself should be a data point. There’s no data in the report related to why the student didn’t turn in his assignments. Does the student need different and/or or additional services and related services? Does the student need different and/or new accommodations? Did his teachers fully implement his IEP? Did he have access to all of his accommodations and services? What about the related services? Were the assignments too hard? Did the student need more time? Since the student’s school is using a virtual format during COVID-related school building closured, does the student need access to a printer to print out the assignments? Does the student need access to a scanner to submit his work to class? Does the student need access to a larger monitor? Does the student suffer from screen fatigue? Does the student need help with organization? What about school avoidance? Is the student trying to avoid school? If yes, then Why? Is he trying to avoid specific teachers?

20 comments on “IEP Progress Reports: What Should Be Reported Vs. What Is Reported

    1. Rachael, Thank you for your comment. I’ll pull together some samples and post them to the site within the next two weeks. If you have any other questions and/or documents that would help for you to view, please let me know and I’ll pull those, too. Best, Callie

  1. Does a school district legally have to provide raw data on a progress report. If so, what is the regulation?

    1. Consider reverse engineering your question and look to the IEP to determine what should be in the progress report.

      Sec. 300.320(a)(3) states that the IEP will include, “(i) How the child’s progress toward meeting the annual goals described in paragraph (2) of this section will be measured; and (ii) When periodic reports on the progress the child is making toward meeting the annual goals (such as through the use of quarterly or other periodic reports, concurrent with the issuance of report cards) will be provided . . .”

      Hence, the progress report should include information from the measurement/s used to determine the child’s progress/lack of progress.

      If the IEP has solid tools for measurement, then you should look for the data collected from those measurements on the IEP. If the IEP states that the measurements will all come from “teacher observations” (as one example), you have a problem. Teacher observations are unreliable. How the teacher feels on the day of the observation, how the teacher feels about the student, whether the teacher is trained to measure the goal at hand, and so on, come into play when making observations.

    1. Thank you for your kind words. If there’s any other topic about which you’re interested in reading, please let me know.

      1. Can the school rely solely on class grades to show progress? The report card grades are padded, they get 100 just for turning assignments in, they get to correct mistakes for better grades, or for example he has a93 avg, but when a test study guide comes home, he gets 70% wrong yet does well on the test in school. Math probes for his IEP show mastery, Classroom benchmarks test done end of qtr showing no overall meaningful progress on his actual grade level for past 2.5 yrs.

        1. Michelle, No. The school district shouldn’t rely solely on class grades. Pursuant to 300.101(c), (1) Each State must ensure that FAPE is available to any individual child with a disability who needs special education and related services, even though the child has not failed or been retained in a course or grade, and is advancing from grade to grade.” Grades often are subjective. In addition, grades are “a” data point. There should be more than one type of data point.

  2. If the IEP states that a student will master A, B, C, D, E in 7 out of 10 trials based on data collection, teacher reports/feedback, observations and the teacher meticulously documents the A, B, and C, but then appears to run out of instructional time and does not document anything for D and E and then states ‘all concepts mastered’ and does not provide any evidence of documentation, instruction or assessment, is it reasonable for the parent to ask for the progress report to be amended to reflect actual progress. OBTW-student is educated and home and parent reports the concepts were not addressed. Does the practice of meticulous documentation for A, B and C with No documentation and no time in the grading period support parents concern that the ‘mastered all concepts’ is another Kick the Can down the road…

    1. The IEP progress report should address what is stated in the IEP. No matter what the reason – running out of instructional time, a pandemic, it rained meatballs and lollipops for weeks . . . – if the student didn’t achieve his or her goal, then the IEP progress report should address where the student is in terms of the goal. Pursuant to Sec. 300.320(a)(3), the IEP is supposed to include “A description of (i) How the child’s progress toward meeting the annual goals described in paragraph (2) of this section will be measured; and (ii) When periodic reports on the progress the child is making toward meeting the annual goals (such as through the use of quarterly or other periodic reports, concurrent with the issuance of report cards) will be provided.” If the school isn’t providing “periodic reports” that provide “the progress the child is making toward meeting the annual goals”, then the parent might question if the IEP is being fully implemented (assuming it is in compliance with 300.320). If the IEP doesn’t include a “description of when periodic reports” will be provided, pursuant to 300.320, then the parent might ask the school leadership about the school district’s compliance with IDEA.

  3. Good day my son’s iep progress report we just received he was given the score of #6 on every category and here in our state I’ll list the codes below. However being given #6 for every category doesn’t really help us figure out how he’s doing in regards to the overall iep and I’m skeptical because I’m thinking maybe this is a way I can’t really track it and make them accountable I’ve been having some challenging times with my youngest child school thank you in advance

    1. Lisa, Is there a comment next to the “6” or is there just a number? Did the school provide you the work samples, tests, evaluations, and/or anything it used to determine your child achieved a 6? ~Callie

    1. Lisa, Where are you located and what are the codes for where you live? In Fairfax County, VA, as one example, the codes of IEP progress reports range from 1 to 5. There is no 6. ~Callie

  4. This is an excellent article describing how to do a close reading on an IEP progress report and how to identify subtle wording changes that might indicate issues with how progress was measured. Thank you so much! I’ve been running into this issue, and this is happening more egregiously as we head into a 3 year reevaluation. I’ve pretty much been stonewalled when trying to resolve this with the school district, even when the information is blatantly incorrect.

    What would be very helpful in this article is what parents can do about it if this is happening. How can parents resolve this with the school district so that the right data is measured and reported, how can we correct misleading or incorrect information for the record so it will be considered by the team, and how can we make a convincing case if what is reported is not an accurate reflection of progress, etc?

    1. Thanks for your kind words, Liz. I’ll look at updating it in the future information.

  5. Hi Callie, This article was EXTREMELY beneficial for me. It clarifies the who, what, when, where and constant why’s of IEP progres reports. The struggle I have as a special education teacher in high school is the grouping of students. We group them in resource room based on their schedules, NOT similarity of needs. So as an educator, it is virtually impossible to work on specific IEP goals and objectives when the make up of the room has 5 kids in there with totally different needs. (Ex: students with math disabilities grouped together with students with reading disabilities.) IMPOSSIBLE! Now as a parent of a daughter with a disability that has multiple needs, fighting for her and challenging the school has been horrendous. The school essentially convinces the teachers and parents that “This is how it has always been done.” Using drop down menus for progress monitoring with no notation or data. The teachers, like cattle, will follow where they are told to go because if you don’t, there are consequences. Unfortunately for me (retaliation from school), and fortunately for my daughter (a strong IEP), going against the grain and questioning this data is unheard of because, “This is how it has always been done.” Callie, I really liked how you took what is happening now and compared it to what should be happening and WHY. Aligning it with ADA verbiage and what is being reported to what is actually reported was very powerful. The question I have is what to do next as a parent if data is not be presented even when you ask or if the school claims that drop down menu of (PS) Progressing Satisfactorily is enough. Thanks-Kelly

    1. Kelly, Thank you for your kind words. If the school refuses to provide you data, you can file a FERPA request to obtain access to your child’s educational records. If the school refused to provide the records, then you can file a state complaint, since IDEA has a FERPA section under it, too. All students (even those without IEPs or 504 Plans) can file a complaint with the USDOE’s SPPO.

      If your school provides you access to your child’s educational records, but the data isn’t there, you can file a complaint with the state on either the school continuing to withhold the records or on there not being any data in existence that supports the IEP progress report.

      In addition, if there’s no data supporting the IEP progress report “progress”, then you could ask the school how its IEPs are in compliance with IDEA? If they can’t show you, then that’s another complaint to consider writing.

      I’m not a lawyer and the above isn’t legal advice, but my own experience as a parent is that often the teachers don’t know IDEA or Section 504 or implementing state regs and sometimes they make decisions and/or take actions just because that’s how its always been done. You could try sharing the applicable sections of IDEA with them. If they continue to refuse, you could contact your state education agency for guidance, to include writing a complaint. I’ve done this a few times and have had success in some areas. However, I’m in Virginia, which USDOE nailed for failing to investigate credible allegations of noncompliance, so winning complaints in Virginia is difficult. The next course of action I’ve taken is to file with the Office for Civil Rights. Hopefully it doesn’t take that long or have to go that far. A few links that might help:
      How to Submit a FERPA Request
      How to file an Office of Civil Rights Complaint
      Sample State Complaint: Noncompliance of Evaluation Timeline and FAPE
      Sample State Complaint: Noncompliance, Student Records—Confidentiality
      USDOE SPPO web site

  6. Thank you for another great article! If I run into teachers who take offense to something as simple as a request for the actual data, on what basis should I file a complaint? DESE states there is no basis to find the IEP team in violation of not providing the parent the data behind the percentages in the progress reports. Thank you!

    1. Thanks, Ioana! Schools are required by law to provide parents full access to their child’s education records. Data counts as an education record, so parents who have been denied access to it could file a complaint under FERPA with USDOE’s SPPO office, which handles FERPA. If the child has an IEP, the parent could file a state complaint regarding FERPA noncompliance under IDEA, too. I’m assuming “DESE” that you mentioned stands for Missouri Department of Elementary and Secondary Education (also known as DESE). If this is correct, you can find more information about filing a state complaint with DESE here: https://dese.mo.gov/media/pdf/mo5003157 DESE has a form at this link. While there is no requirement under IDEA that such a form must be used, specific information must be included. Some helpful FERPA information regarding access to education records can be found here:

      It’s the Law: Confidentiality and Access of Student Records
      IDEA Sec. 300.613 Access rights
      §99.10 What rights exist for a parent or eligible student to inspect and review education records?

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