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IEP Compliance Checklist
for Case Managers

13 IDEA-Required Components — Check Every One Before You Finalize

Every IEP must include all 13 components required under the Individuals with Disabilities Education Act (IDEA). Missing even one can trigger a compliance complaint, procedural violation, or IEP re-write. Use this checklist before every finalization meeting.

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Compliance progress 0 of 13 components checked

All 13 components verified — this IEP is ready to finalize.

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Component 1
Present Levels of Academic Achievement and Functional Performance (PLAAFP)
Compliance Criteria

Describes current performance in all areas of need; uses objective, measurable data; describes impact on general curriculum access and participation.

Common Mistake

Vague statements without data — "struggles with reading" instead of measurable baselines like "reads at 2.3 grade level with 68% comprehension."

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Component 2
Measurable Annual Goals
Compliance Criteria

Goals are specific, measurable, achievable, relevant, and time-bound (SMART); address each area identified in PLAAFP; include criteria for mastery.

Common Mistake

Non-measurable goals — "will improve reading" — with no criteria for mastery, no measurement method, and no baseline comparison point.

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Component 3
Short-Term Objectives or Benchmarks (required for alternate assessment students)
Compliance Criteria

Intermediate, measurable steps toward each annual goal; provides milestones for monitoring progress throughout the year for students on alternate assessments.

Common Mistake

Skipping benchmarks entirely for students taking alternate assessments — this is a federal requirement that cannot be omitted for this population.

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Component 4
Special Education Services
Compliance Criteria

Each service listed with provider type, delivery model (push-in/pull-out), frequency (sessions/week), session duration, and projected start date.

Common Mistake

Vague service descriptions — "reading support as needed" — without specifying provider credentials, delivery model, or frequency of services.

<\!-- Item 5 -->
Component 5
Related Services
Compliance Criteria

All related services (speech-language, OT, PT, counseling, transportation) documented with the same specificity as special education services — provider, frequency, duration, location.

Common Mistake

Listing services without specifying minutes per session or frequency — "speech therapy weekly" fails the specificity requirement.

<\!-- Item 6 -->
Component 6
Supplementary Aids and Services
Compliance Criteria

Specific accommodations and supports needed to participate in general education settings; individualized to this student's needs, not copied from a generic list.

Common Mistake

Generic accommodation lists copied from prior IEPs without verifying they still reflect the student's current needs and general ed participation context.

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Component 7
Program Modifications and Supports for School Personnel
Compliance Criteria

Specific training, information, or support that general education teachers and other school staff need to implement the IEP effectively.

Common Mistake

Leaving this section entirely blank — a very common omission that creates compliance exposure, especially when gen ed teachers implement accommodations incorrectly.

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Component 8
Participation with Non-Disabled Peers (LRE Justification)
Compliance Criteria

Documents the extent of non-participation in general education; includes a specific, individualized justification for any time spent outside the general education setting.

Common Mistake

Checking "full inclusion" without documenting the basis, or removing a student from gen ed without an individualized written justification tied to their specific needs.

<\!-- Item 9 -->
Component 9
State and District Assessment Participation
Compliance Criteria

Documents which state and district assessments the student will take, any testing accommodations for each assessment, and alternate assessment eligibility with justification.

Common Mistake

Not specifying accommodations per assessment type — accommodations approved for classroom use are not automatically approved for state testing.

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Component 10
Service Dates and Duration
Compliance Criteria

Projected start date, projected duration, session frequency, and service location documented for each service — not just "for the school year."

Common Mistake

Missing projected end dates or unclear service frequency — "twice weekly" is ambiguous; "2 times per week, 30 minutes per session" is compliant.

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Component 11
Transition Services (age 16, or younger per state)
Compliance Criteria

Age-appropriate transition assessment results documented; measurable postsecondary goals for education/training, employment, and independent living; transition activities and services tied to goals.

Common Mistake

Generic transition goals not tied to the student's stated preferences and interests — "will attend college" without connection to assessment results or student input.

<\!-- Item 12 -->
Component 12
Transfer of Rights Notice (at least 1 year before age of majority)
Compliance Criteria

Student and parent notified of rights transfer one year before the student reaches the age of majority; notification documented within the IEP.

Common Mistake

Forgetting this requirement entirely for students approaching age of majority — it's one of the most frequently cited procedural violations in state compliance audits.

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Component 13
How Progress Will Be Measured and Reported
Compliance Criteria

Specific, objective measurement methods identified for each goal; a concrete reporting schedule to parents (at minimum as often as non-disabled peers receive report cards).

Common Mistake

Vague "teacher observation" as the sole measurement method with no reporting timeline — parents must be informed of progress at regular intervals, not just at annual reviews.

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