Domain:   Risk:
IEP Definition
Procedural
Substantive
PLAAFP
Annual Goal
Services
Progress
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Domain IF Condition THEN Outcome Legal Basis FAPE Risk
IEP Def.
IF
A student has a qualifying disability that adversely affects educational performance
Two-prong eligibility test: The student must (1) have one of IDEA's 13 recognized disability categories and (2) the disability must adversely affect educational performance. Both prongs must be satisfied before an IEP can be developed.
THEN
The student is entitled to a written IEP — a collaboratively developed plan outlining present levels, annual goals, services, and progress monitoring
IDEA §1414(d);
34 CFR §300.320(a)
High
IEP Def.
IF
A student is identified as eligible but does not receive a written IEP
THEN
The school is in direct violation of IDEA's FAPE mandate; an IEP is not optional once eligibility is established — it is the legal vehicle through which FAPE is delivered
IDEA §1412(a)(1);
Yell (2019)
High
IEP Def.
IF
An IEP is developed but not implemented as written
Third category of violation: Beyond procedural and substantive violations, implementation failure is a distinct FAPE concern. Courts have held that a school cannot claim FAPE when it fails to deliver the services it agreed to provide.
THEN
An implementation failure exists — a third violation category that can constitute a FAPE denial even when the IEP is procedurally and substantively sound
M.C. v. Antelope Valley (2017);
Yell (2019)
High
IEP Def.
IF
All required IEP components under §300.320(a) are present and high quality
THEN
The IEP functions as its intended purpose: a legally binding roadmap that guides the student's entire special education program and ensures accountability across all team members
34 CFR §300.320;
Bateman & Linden (2006)
Low
Domain IF Condition THEN Outcome Legal Basis FAPE Risk
Procedural
IF
An IEP is developed without required team members present
All three prongs are disjunctive — meaning any one is sufficient. Courts find FAPE denial when the violation: (1) impeded the child's right to FAPE, (2) significantly limited parental participation, or (3) caused a deprivation of educational benefit. The parent need only establish one. [IDEA §1415(f)(3)(E)(ii)]
THEN
A procedural violation exists; it rises to FAPE denial only if it: (1) impeded the child's right to FAPE, (2) significantly limited parental participation, or (3) caused a deprivation of educational benefit — all three prongs are disjunctive
IDEA §1415(f)(3)(E)(ii)
Medium
Procedural
IF
Parents do not receive prior written notice before a placement change
THEN
A serious procedural violation exists; it rises to FAPE denial only when one of the three §1415(f)(3)(E) prongs is met — not automatic, but significantly limiting parental participation is the most likely trigger here
34 CFR §300.503;
IDEA §1415(f)(3)(E)
High
Substantive
IF
An IEP meets all procedural requirements but goals are set at the student's current baseline
THEN
The IEP is substantively deficient — it fails the Endrew standard requiring it to be "reasonably calculated to enable progress." A goal targeting current performance expects no growth
Endrew F. (2017),
p. 999
High
Substantive
IF
A court applies only the de minimis benefit standard from Rowley
THEN
The analysis is legally outdated; Endrew F. (2017) unanimously replaced that floor with a child-specific, meaningful-progress standard calibrated to each student's individual circumstances
Rowley (1982);
Endrew F. (2017)
High
Substantive
IF
A student with significant disabilities is compared to grade-level peers to determine appropriate progress
THEN
The comparison is inappropriate; Endrew requires progress calibrated to the individual student's profile — grade-level comparison is an inappropriate benchmark for students with more complex needs
Endrew F. (2017)
Medium
Domain IF Condition THEN Outcome Authority FAPE Risk
PLAAFP
IF
Assessment sources are not identified in the PLAAFP
THEN
Data cannot be verified or compared at future IEP meetings — the entire IEP rests on an unverifiable foundation, undermining the reliability of every goal and service built from it
Yell (2019)
High
PLAAFP
IF
Oral reading accuracy is described qualitatively rather than quantified
Why the distinction matters: 100 wpm at 70% accuracy means 30 of every 100 words read incorrectly. 100 wpm at 95% accuracy means 5 errors per 100 words. These represent entirely different instructional profiles — one requires decoding intervention, the other fluency-building. Rate alone cannot distinguish them.
THEN
The fluency profile is incomplete; both rate and accuracy must be documented — the same rate at different accuracy levels signals completely different instructional needs
NRP (2000)
High
PLAAFP
IF
The PLAAFP omits underlying phonological or decoding skill deficits
THEN
The IEP team cannot select evidence-based interventions; addressing reading outcomes without identifying root causes produces services that are unlikely to close the achievement gap
NRP (2000);
Yell (2019)
High
PLAAFP
IF
The disability's impact on the general education curriculum is not explicitly stated
THEN
§300.320(a)(1)(i) is not met; the IEP must explain how the disability affects the child's involvement and progress in the general education curriculum — without this, the justification for services is legally weakened
34 CFR §300.320
(a)(1)(i)
High
PLAAFP
IF
Student and family input are absent from the PLAAFP
THEN
The document is incomplete as a collaborative product; §300.322 requires meaningful parent participation throughout IEP development, and best practice anchors PLAAFP data in family knowledge of the student
34 CFR §300.322;
Bateman & Linden (2006)
Medium
Domain IF Condition THEN Outcome Authority FAPE Risk
Goal
IF
An annual goal omits an accuracy criterion for oral reading fluency
THEN
The goal is not fully measurable; progress monitoring cannot confirm that growth — not just faster but inaccurate reading — has occurred
Bateman & Linden (2006)
High
Goal
IF
The target criterion in a goal matches the student's current baseline
THEN
The goal violates Endrew; a target identical to present performance expects no growth — the IEP team must set an ambitious, achievable target above the student's current level
Endrew F. (2017)
High
Goal
IF
Only one goal is written for a student with four distinct identified need areas
THEN
Three need areas remain unaddressed; IDEA requires measurable annual goals covering each academic and functional need identified in the PLAAFP — one goal cannot legally or educationally serve multiple independent need areas
IDEA §1414(d);
Yell (2019)
High
Goal
IF
A fluency goal is written but comprehension, inference, and main-idea needs are excluded
THEN
The IEP is substantively insufficient; fluency is a surface skill — the higher-order comprehension deficits affecting content-area performance remain unresolved and will continue to impede general education access
Yell (2019);
NRP (2000)
High
Goal
IF
A goal includes a condition, behavior, and timeline but no criterion for mastery
All four elements are required: (1) Condition — describes the context; (2) Student name; (3) Observable behavior or skill; (4) Measurable criterion — defines what mastery looks like. A goal missing any one element cannot be monitored or legally defended.
THEN
One of four required goal elements is missing; all four — condition, student name, observable behavior, and measurable criterion — must be present for a goal to be legally defensible
Bateman & Linden (2006)
Medium
Domain IF Condition THEN Outcome Authority FAPE Risk
Services
IF
The type of service is not specified in the IEP
THEN
The IEP is legally incomplete; without identifying the service category, providers cannot determine what instruction or support is authorized — the services statement is the binding commitment between school and family
34 CFR §300.320(a)(4)
High
Services
IF
Frequency and duration of services are omitted
THEN
The total service intensity is undefined; schools can deliver inconsistent amounts without violating the document — eliminating the accountability that protects students from under-service
34 CFR §300.320(a)(7);
Yell (2019)
High
Services
IF
Service location is not specified or is inconsistent with the LRE determination
THEN
A dual violation may exist: §300.320(a)(7) requires location to be documented in the IEP, and §300.114 requires the placement to reflect the LRE principle — both provisions must be independently satisfied
34 CFR §300.320(a)(7);
§300.114
High
Services
IF
The projected start date for services is not documented
Federal law requires only the start date. 34 CFR §300.320(a)(7) mandates the projected date for the beginning of services plus anticipated frequency, location, and duration. "Duration" means session length — not a service end date. End dates are common IEP form practice but are not a federal compliance requirement.
THEN
§300.320(a)(7) is violated; note that a projected end date is not explicitly required by federal law — "duration" in the regulation refers to session length, not a service termination date
34 CFR §300.320(a)(7)
Medium
Services
IF
All required service elements are present and operationally defined
THEN
The services statement is legally compliant and auditable — educators, families, and administrators share a verifiable record of what was agreed upon, and the document functions as the accountability tool it was designed to be
34 CFR §300.320;
Yell (2019)
Low
Domain IF Condition THEN Outcome Authority FAPE Risk
Progress
IF
The IEP does not describe how progress toward annual goals will be measured
THEN
§300.320(a)(3)(i) is violated; without a defined measurement method, there is no shared standard for what counts as progress and no mechanism to trigger corrective action when students fall behind
34 CFR §300.320
(a)(3)(i)
High
Progress
IF
The IEP does not state when progress reports will be provided to parents
THEN
§300.320(a)(3)(ii) is violated; while IDEA does not mandate a specific schedule, it requires the IEP to specify reporting timing — parents cannot serve as equal partners without timely, regular information
34 CFR §300.320
(a)(3)(ii)
High
Progress
IF
Monitoring data shows a student is not making expected progress midyear
THEN
The IEP team must act; §300.324(b) requires revision to address lack of expected progress — waiting until the annual review sacrifices instructional time that cannot be recovered and likely violates the Endrew meaningful-progress standard
34 CFR §300.324(b);
Endrew F. (2017)
High
Progress
IF
Progress is not monitored with objective, consistent data collection
THEN
The school cannot demonstrate whether the IEP is working, cannot identify when services need adjustment, and cannot show Endrew-level meaningful progress — the absence of data is itself an accountability failure
34 CFR §300.320(a)(3);
Yell (2019)
High
Progress
IF
Parents receive regular, data-based progress reports on each annual goal
THEN
IDEA's reporting requirement is met; parents can fulfill their role as equal partners, identify concerns early, request reviews if needed, and make informed decisions — the IEP's collaborative accountability function operates as designed
34 CFR §300.320(a)(3);
§300.324(b)
Low