The IEP Is Written, But Is the School Actually Following It?

Perhaps you noticed your child’s IEP progress report came back showing their goals are not being met. Maybe your child said they haven’t met with the guidance counselor for social skills in a long time. What if the long-term substitute in an ICT class isn’t a special-education teacher. 

Many parents assume that once a child has an IEP, that is it, the hard part is done. I did. I assumed my son’s IEP was being followed, because why wouldn’t it be? That is not always the case. 

Is my child’s IEP actually being followed? It is a question many parents don’t think to ask. I didn’t think to ask this question at first. It wasn’t until another parent who had just found out her own child wasn’t being pulled by the guidance counselor, asked me at the playground whether my son was getting his time. 

A light bulb went off. I had never asked my son whether he was getting his IEP-mandated speech, OT, or his time with the guidance counselor. Turns out he hadn’t been seeing the guidance counselor nearly as often as he was supposed to. 

The accountant in me who loves to create an Excel file went to work. I went through my son’s IEP in detail, listed his services and management needs, and started asking him daily: did you have OT, did you have speech, did you take your test in a separate location, were you put in a small group for ELA or math. I was intentional about the questions, and I made them part of our walk home from school. I knew Tuesdays were OT, so that was my day to ask about that. And not only did I start keeping track of what he was actually getting, I got a lot more out of those walks home than I ever got from “what did you do in school today?” Which, his response was always “nothing.”

Compare what the IEP says, service by service, against what your child is actually receiving. Write down what you find, with dates. If your child’s IEP in fact is not being implemented, or they are not making progress, take that data you’re collecting and email the school. Sometimes, the school will work to make up services or perhaps an IEP meeting is needed to review what changes can be made to help your child access their education. 

A signed IEP is not a delivered IEP. A signed IEP also does not mean the accommodations or services are adequate for your child’s needs. 

What “IEP implementation” actually means

An IEP is not finished after the meeting or when everyone signs. Services and accommodations have to be implemented and progress has to be measured. If progress is not being made, the IEP team should meet to discuss what can be done. 

A few things to note, an IEP must state the related services, and accommodations that will be provided, along with the start date, frequency, and duration. For example: speech services in a small group, one time per week, for 40 minutes. The IEP must be available to any person who is responsible for implementing it, and they must be informed of responsibilities and of the accommodations, modifications, and supports that must be provided. 

That means it isn’t only your child’s main teachers who need to know about the accommodations, modifications, and supports. Depending on what your child needs, it can include cluster teachers (gym, art, music), lunch aides, substitute teachers. This will look different for every student.This will be different for each student. 

My daughter has an auditory processing disorder and often needs instructions repeated or broken down. To a gym teacher, or a substitute teacher, or even someone overseeing lunch, if she may appear to be defiant. She isn’t. My daughter is meticulous about following the rules. She just has to be able to understand the rules first. This plays out in different ways. A child who is sensitive to loud noises may need noise-canceling headphones at lunch and recess, which is relevant information for school staff who are not the classroom teacher. 

If your child has a 504 plan rather than an IEP, the same question applies. The difference between the two plans is real, but neither one implements itself.

Signs something in the IEP may not be happening

None of these prove a problem on its own. Together, they are worth a closer look.

• Progress reports arrive vague (“making progress,” “working on it”) with no data, or with numbers identical to last quarter.
• Your child says a session didn’t happen, or happened in a different room, in a large group, or a constant change of adults.
• A teacher doesn’t seem to know about an accommodation that’s written into the IEP, or work comes home without the modifications that are in the IEP.
• A related service (speech, OT, PT, counseling) has a substitute for weeks. 
• A goal quietly disappeared from the draft, or a service got reduced without explanation.
• Homework is getting harder rather than easier, or old behaviors are reappearing after school.
• Your child is pulled from a service to catch up on classwork.
• Services were rescheduled and you never got anything in writing about it.
• The team suggests a shortened day, a later start, or removal from a class, and the reason is about staffing or scheduling rather than about your child.

That last one is worth pausing on. When an offer would reduce your child’s access to school, it is fair to ask what supports would let them access the full day before agreeing to a shorter school day. 

One unusual day is not a pattern. A canceled session, a fire drill, or a provider out sick… those things happen to everyone. We aren’t talking about a few missed sessions. We are talking about patterns of regularly missed services. So start tracking what your child’s IEP requires and what actually happened.

One last sign is easy to miss because it feels like good news: sometimes what’s holding your child up is a wonderful teacher doing extra out of the goodness of her heart, rather than the service written in the plan. That kindness is real. But kindness is not a plan. That support disappears next school year when the teacher changes.  

My daughter gets overwhelmed when the classroom gets loud, or work gets too much to process and she becomes non verbal. Her very kind third-grade teacher worked out a hand signal my daughter could give her, and then she could go to the bathroom for a sensory break. This wasn’t documented in her IEP. And this very helpful accommodation didn’t follow with her to the next school year. 

Compare the written IEP with testing and other documents

This is the step that turns a feeling into something to act on. Pull the most recent complete IEP, including any amendments and written notices. Then build a simple side-by-side: what the document says, and what appears to be happening. Look at the goals on your child’s IEP year over year. Are they making progress? Are the goals being met? 

Compare any formal reports such as the neuroeducational, teacher’s reports, neuropsychological evaluations to the IEP. See what the teachers are indicating is needed versus what is on the IEP.  building the side-by-side so you can see the pattern. Does the formalized testing indicate a slow processing speed and the teacher mentions it takes your child longer to complete classwork or answer questions? 

That gap between what the testing says a child can do and what the school day actually produces is information. We lived a version of it when a 99th-percentile score sat next to a Level A reading level.

Those are connections that need to be made and supported put into your child’s IEP. Those connections are the heart of what we do in a record review.

What to document

Documentation is not about building a case against anyone. It is about being able to describe a pattern accurately six months from now, when nobody’s memory is reliable and the details have blurred together.

Write down the specifics:

• Date, and what happened. “March 4- child said no speech this week.”
• Who said what, in their words. Quote rather than characterize. “The teacher said she has not seen the accommodations page” is usable. 
• What the document says the service should be, next to what occurred.
• The impact you can observe. Homework takes ninety minutes. Refusal to go to school on Tuesdays. Reading level unchanged across two reporting periods. Called from the nurse with a headache on March 5; picked up early with a stomachache on March 9.
• Every phone call and hallway conversation should be followed by an email confirming it. Always summarize a conversation in an email afterward. After a call or a face-to-face conversation, send an email to the person. “Thank you for talking with me earlier. I want to confirm my understanding of our conversation. We talked about [x], and you said [y]. Please let me know if I’ve misunderstood anything.” Now it exists in writing, and the other person has had a fair chance to correct the record. And this becomes a part of your advocacy binder. All these emails get the conversation into the record. 

A clear timeline helps you see the pattern. If you haven’t started one, start a binder digital or physical, it doesn’t matter. What matters is that it exists before you need it. We can build the timeline for you, set up your digital or physical binder, and go through the weeds. 

If you have questions or concerns for the school, put your questions in writing. Keep emails polite, factual, and non-accusatory. If you get a phone call back instead, take the call, then send the confirmation email recapping what was said. Verbal answers are not preserved anywhere. Written ones are.

What to ask at an IEP meeting

If email does not resolve your concerns, you can request an IEP meeting. Put the request for an IEP meeting in writing. Lack of expected progress or implementation concerns is a legitimate reason to bring the team together.

Bring your questions on paper, and bring someone to take notes if you can. You cannot take good notes and stay present at the same time. Our guide to prepping for an IEP meeting covers the room itself.

Before signing any document, ask what your signature means. Attendance, participation, agreement, and consent are not necessarily the same thing, and state procedures vary. Review the proposed IEP after the meeting, before signing. Sit with it for a while. Read it carefully.

If some of your asks were not included in IEP including evaluation, placement, or you have concerns over FAPE ask for a prior written notice (PWN) explaining that decision. The PWN puts the school’s reasoning, and the information it relied on, in a document you can keep. A verbal “no” should not be the end of the record.

What to ask when the school says it is a staffing problem

Sometimes the honest answer is that the speech provider left in October, there’s no certified special-education teachers for that period, or the school does not have a resource room teacher. Staffing problems are real, it is widespread, and the school is likely as frustrated as you are.

But a staffing shortage does not erase the district’s obligation to make FAPE available and implement the IEP. 

A staffing issue is not your child’s problem. Keep the conversation on the plan rather than the vacancy:

• What is the plan for my child to receive this service while the position is open?
• Can the service be delivered by a contracted provider, another school, or by another staff member?
• What is the timeline for filling the position?
• How will the team track and address the sessions missed in the meantime?

Keep the focus less on what they can realistically do, and more on what the plan is to meet this child’s needs right now. Ask for that plan in writing.

When to move beyond informal emails

There is no rule that says one email is enough or that ten is too many. But there are signs that simply emailing with the school won’t resolve the issues. 

• You have written more than once, with specific questions, and received general answers or no answers at all. 
• The school acknowledges the issue, but provides no plan. 
• Records or data you requested have not been produced.
• Your child’s functioning is deteriorating including school refusal, regression, escalating distress.

Escalating does not mean becoming adversarial, and it does not mean the relationship with your school is over. It means moving the conversation to a level that has a timeline attached to it.

One exception to all of that patience: if this involves your child’s immediate safety, a disciplinary removal, a change of placement, a filing deadline that’s close, or a decision about pulling your child out of the school, don’t work politely up the ladder. Get individualized legal advice now.

A short overview of the formal options

There are many formal options when communication with the school is not helping. Which one fits, and how it works in your state, is exactly the kind of question to bring to a special-education attorney.

Prior written notice. Not a dispute process, but the foundation for one. When a district proposes or refuses action on your child’s identification, evaluation, placement, or provision of FAPE, prior written notice puts its position and reasoning into writing.

State complaint. A written, signed complaint filed with the state education agency, alleging a violation that occurred. The state generally has 60 days to investigate and issue a written decision. Some states have additional timelines on top of that federal baseline. Failure to implement an IEP is a common subject of these complaints.

Mediation. Voluntary, with a neutral mediator, at no cost to you.

Due process complaint and hearing. The formal adjudicative route, with its own filing requirements and timelines. Families usually pursue this with a special education attorney.

Private placement. If a family decides the school district cannot meet the child’s needs, the question of a private placement sometimes comes up. At times, families can seek to have the district pay tuition for a private placement. There are strict conditions around that, and they are easy to miss. Talk to a special-education attorney before you move on this. Private placement is not a step to take on information from an article.

Where this leaves you

You do not have to become a special-education expert to ask whether the plan is being followed. You need the IEP, a record of what you observe, notes, and the willingness to put your questions in writing. You are your child’s strongest advocate. 

We can help you make the connections, find the patterns, and learn to document what’s happening. But at the end of the day, you know your child best, and you’re in the best position to advocate for them. We can help you see the bigger picture.

Start with one line of the IEP this week. One service, one accommodation, one goal. Ask what has actually been delivered. Want more help or feeling overwhelmed? This is exactly what our services are here to help with. 

---

Raising Different Together provides parent-to-parent educational information, document organization, and advocacy preparation. We are not attorneys and do not provide legal advice or representation. Requirements, timelines, terminology, and procedures can vary by state and individual circumstances. For advice about your child’s specific rights, legal options, filing deadlines, or formal proceedings, consult a qualified special education attorney or local Parent Training and Information Center.