IEP compliance checklist: components, deadlines, and the errors monitors flag
A compliant IEP comes down to three questions: does the document contain every component federal law requires, did every dated event happen on time, and does the paper trail prove both? This checklist covers the federal floor — the seven required components of 34 CFR §300.320 and the timelines around it. Your state adds requirements on top (shorter timelines, extra sections, its own forms), so treat this as the baseline every IEP must clear in all 50 states.
Part 1 — Document contents
Work down this table with the IEP open. Each row is a required element of the IEP under 34 CFR §300.320; the “pass test” column is what a reviewer actually checks for.
| Component | Pass test | Citation |
|---|---|---|
| Present levels (PLAAFP) | States how the disability affects involvement and progress in the general education curriculum, with current data — not last year's PLAAFP with new dates. | §300.320(a)(1) |
| Measurable annual goals | Each goal has a condition, observable behavior, and criterion, and traces back to a need named in the present levels. | §300.320(a)(2) |
| Progress measurement + reporting | Says how progress will be measured and when reports go home (e.g., quarterly with report cards) — and the reports actually go out on that schedule. | §300.320(a)(3) |
| Special education & related services | Services stated with frequency, location, and duration — 'as needed' or 'per teacher discretion' is not a service statement. | §300.320(a)(4), (a)(7) |
| Extent of nonparticipation | Explains the extent, if any, to which the student will NOT participate with nondisabled peers — an affirmative justification, not a blank. | §300.320(a)(5) |
| Assessment accommodations | Individual accommodations for state/district assessments; if the student takes an alternate assessment, why the regular one isn't appropriate and why that alternate was chosen. | §300.320(a)(6) |
| Transition (by age 16) | Beginning no later than the first IEP in effect when the student turns 16 (earlier in many states): measurable postsecondary goals based on age-appropriate transition assessments, plus the transition services to get there. | §300.320(b) |
Part 2 — Federal timelines
| Event | Federal rule | Citation |
|---|---|---|
| IEP in effect | At the beginning of each school year, for every eligible student | §300.323(a) |
| Annual review | IEP reviewed and revised not less than annually | §300.324(b)(1) |
| Reevaluation | At least once every 3 years (unless parent and school agree it's unnecessary); not more than once a year (unless both agree) | §300.303(b) |
| Transfer student (same state) | Comparable services immediately, until the district adopts the old IEP or writes a new one | §300.323(e) |
| Transfer student (out of state) | Comparable services immediately, until the district evaluates (if needed) and writes a new IEP | §300.323(f) |
Citations link to Part 300 of Title 34: §300.323, §300.324, §300.303. Many states shorten these windows or add their own (evaluation timelines, prior-written-notice periods, ESY decision deadlines) — always layer your state's rules on top.
Part 3 — The findings that actually get written up
- Expired annual review. The meeting happened 12 months and 6 days after the last one. Calendar the due date at the start of the year, then back up 30 days for scheduling.
- Goals that aren't measurable. See how to write measurable IEP goals — condition, behavior, criterion, consistency.
- Progress reports that never went out. The IEP promises quarterly reports; the file contains two. The reporting schedule in §300.320(a)(3) is a commitment, not boilerplate.
- Services without frequency/location/duration. “Resource support as needed” cannot be implemented or audited.
- Gen-ed teachers who never saw the IEP. Every implementing teacher needs access and needs to know their specific responsibilities (§300.323(d)) — keep documentation that accommodations were shared.
- Missed ESY consideration. Extended school year must be an individual determination, not a default “no” — see ESY eligibility.
FAQ
How often does an IEP have to be reviewed?
The IEP team must review the IEP periodically, but not less than annually, to determine whether the annual goals are being achieved (34 CFR §300.324(b)(1)). In practice: the next annual review is due within 12 months of the last one, and letting that date slip is one of the most common compliance findings.
How often must a student be reevaluated?
A reevaluation must occur at least once every 3 years, unless the parent and the school agree it is unnecessary — and may not occur more than once a year unless both agree otherwise (34 CFR §300.303(b)).
Does an IEP have to be in place on the first day of school?
Yes. At the beginning of each school year, the school must have an IEP in effect for every child with a disability in its jurisdiction (34 CFR §300.323(a)). An expired IEP on day one is an automatic finding.
Who has to be able to see a student's IEP?
Every regular education teacher, special education teacher, related service provider, and other service provider responsible for implementing the IEP must have access to it, and must be informed of their specific responsibilities and the accommodations, modifications, and supports it requires (34 CFR §300.323(d)).