Monday, January 16, 2012
IEP Goals Must Be Comprehensive, Specific and Measurable
Under the Individuals with Disabilities Education Act (IDEA), an IEP must include a statement of measurable annual goals, including academic and functional goals designed to meet the child’s needs resulting from his or her disability so that the child can be involved in and make progress in the general education curriculum and meet each of the child's other educational needs that result from the child's disability. 20 U.S.C. § 1414(d)(1)(A)(i)(II). As this indicates, IEP goals may NOT be merely broad statements about what the team thinks that a child will accomplish in a year. Instead, a child’s (IEP) must specifically identify ALL of the child’s needs, detail how the school will meet them, and make objective measurements of his or her progress on each goal.
Goals that are not specific and measurable and do not include academic and functional goals, then IEP is defective and open to a challenge that it denies the child a FAPE. A student receives FAPE if the education (1) addresses the student's unique needs, (2) provides adequate support services to allow the student to take advantage of the educational opportunities, and (3) is in accord with the individualized education program. See Bd. of Educ. v. Rowley, 458 U.S. 176, 188-189 (U.S. 1982) (defining FAPE as "educational instruction specially designed to meet the unique needs of the handicapped child, supported by such services as are necessary to permit the child 'to benefit' from the instruction . . . [and] such instruction and services . . . comport with the child's IEP").
It is also important to note that schools must revise an IEP to address any lack of expected progress toward goals and/or in the general education curriculum, the results of new evaluation, or new information about the child provided by the child’s parents. 20 U.S.C. § 414(d)(4)(A)(11).