IEPs must be based on accurate, objective, and measurable data to identify student needs and guide educational decisions.

When data is unclear, incomplete, or not measurable, the IEP may not be reasonably calculated to enable meaningful progress, as required under Endrew F. v. Douglas County School District, which held that an IEP must be “reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.”

In addition, public schools must ensure that students with disabilities are not excluded from participation in, denied the benefits of, or otherwise subjected to discrimination under any program or activity, as required under Title II of the Americans with Disabilities Act (ADA).

Warning Signs May Include:

| When Goals Are Not Measurable or Aligned

• Goals are not written in a way that can be objectively measured

• Goals are not clearly connected to the student’s identified needs

• Goals are overly broad or combine multiple skill areas

• Progress cannot be clearly tracked over time

| When Progress Is Not Clearly Measured

• Progress is described using general narrative statements instead of using objective data

• Progress monitoring lacks consistent, measurable criteria

• Data does not show whether the student is making progress

• Progress reports do not align with stated goals

| When Present Levels Are Incomplete or Unclear

• Present levels do not include objective, baseline data

• Strengths and needs are not clearly identified

• Areas of concern are not addressed

• Data is missing, outdated, or not tied to educational performance

When These Patterns Occur

• The student’s needs may not be clearly identified

• Goals may not address the student’s actual needs

• Progress may not be accurately measured

• Educational decisions may not be fully informed

Legal Foundations

The Individuals with Disabilities Education Act requires:

• Measurable annual goals and a way to track progress (34 C.F.R. § 300.320)

• Accurate present levels of academic achievement and functional performance

Under the Americans with Disabilities Act and Section 504:

• Students must have an equal opportunity to participate in and benefit from educational programs (28 C.F.R. § 35.130; 34 C.F.R. § 104.4)

When data is unclear or incomplete:

• Access to appropriate instruction may be limited

• Progress may not be meaningful or measurable

• Educational decisions may not address the student’s needs

When the IEP is not based on clear, objective, and measurable data, meaningful progress—and access to appropriate education—may be affected.