Compliance Corner – October 2022

By Cindy Soo Hoo, TAP Consultant


Last month, we discussed the requirement under the Individuals with Disabilities Education Act (IDEA) to include in a student’s Individualized Education Program (IEP) the Present Levels of Academic Achievement and Functional Performance (PLAAFP).  (34 CFR §§300.320 and 300.324).  A comprehensive PLAAFP enables the IEP Team to form a starting point to determine appropriate goals that would allow the child to make progress and participate in the general education curriculum.  The process of writing appropriate goals begins with a clear picture of what the child’s strengths are as well as areas of need. 

In addition to including Present Levels of Academic Achievement and Functional Performance, IDEA 34 CFR §300.320 requires an IEP to include the following: 

(2)(i) A statement of measurable annual goals, including academic and functional goals designed to –

(A) Meet the child’s needs that result from the child’s disability to enable the child to be involved in and make progress in the general education curriculum; and

(B) Meet each of the child’s other educational needs that result from the child’s disability;

(ii) For children with disabilities who take alternate assessments aligned to alternate academic achievement standards, a description of benchmarks or short-term objectives;

(3) A description of –

(i) How the child’s progress toward meeting the annual goals… will be measured; and

(ii) When periodic reports on the progress the child is making toward meeting the annual goals (such as through the use of quarterly or other periodic reports, concurrent with the issuance of report cards) will be provided;

IDEA specifically mentions the word “measurable”.  Barbara Bateman and Cynthia Herr, authors of Writing Measurable IEP Goals and Objectives, state the following:  “Measurable is the essential characteristic of an IEP goal or objective.  When a goal isn’t measurable, it cannot be measured.  If it cannot be measured, it violates IDEA and may result in a denial of FAPE to the child.”  (2006)  That only stands to reason.  If the goal is not measurable, then you can’t determine how the child responded to the goal that served as the basis for the instruction. 

A goal is a statement of what the student is expected to accomplish, typically within a 12-month period.  The goal should be challenging while at the same time attainable within that time frame.  This would be based on a comprehensive and concise PLAAFP.  It should also be an important skill for the student to learn in order to participate in the general education curriculum.  In other words, it needs to be relevant to what the student is expected to learn based on content standards for that student’s grade level.  Needless to say, it must also be individualized.  No two students are exactly the same even if two or more students have similar deficits in the same area(s). 

When developing a goal, the creator should keep in mind the following:

What behavior is being measured?

            How will progress be measured?

            When will progress be measured?

            How well will the child need to perform the skill?

            Are specific conditions required to teach or assess the goal?

To this end, it is important to keep in mind the components of a goal that help make the goal measurable.  They include:  the time frame by which the goal is to be achieved, the conditions that may be necessary in order to achieve the goal, the target behavior that will serve as the focus of the goal, the criteria for mastery and the method of evaluation by which progress will be assessed.

Let’s take a look at each of the components one by one:

Time Frame:  typically within one year; can be less than a year but never more than a year

Conditions:  different levels of support, strategies, materials, etc.

Behavior:  observable and requires some level of change such as increase, decrease, etc.

Criteria:  amount of change, timeline, to what extent, how well, etc.

Method of Evaluation:  curriculum-based measures, rubrics, % accuracy, length of time, etc.

So, what could that look like?  Let’s first examine a goal that stops short of being measurable:

Within a year, Henry will increase his math skills and perform on grade level. 

First and foremost, the above goal does not specify the skills that are to be targeted nor does it give us criteria or the evaluation method by which Henry will be assessed.  Citing grade level skills might provide some information about where the child is performing compared to classmates at the same grade level.  It does not, however, specify the actual skills the student will focus on.

Let’s contrast the above goal with a more comprehensive one:

Within one year and given geometric formulas, Henry will calculate the perimeter of two-dimensional figures with 80 percent accuracy in three out of five trials as measured by daily work and unit tests.

The above goal is more definitive.  It provides the reader with the supports Henry will be given (geometric formulas), the targeted skill (calculate the perimeter of two dimensional figures), the criteria by which Henry will have to perform the behavior (80 percent accuracy in three out of five trials) as well as the sources the evaluator will use to determine acquisition of the skill   (daily work and unit tests). 

Finally, it is important to monitor the student’s progress toward goals to ensure the student is on target and making appropriate progress.  This will give the teacher or other service provider information as to how the student is responding to the instruction and whether changes to the instruction is warranted or an IEP may need to be scheduled.  Carol Kosnitsky, a special education consultant, provides a practical definition of a goal.  She states:  “Measurable goals are not about what you will teach.  Measurable goals are about what you will measure to let you know the teaching has been effective.”

In conclusion, the clearer and more precise the PLAAFP is, the clearer and more precise the goal can be.  Keep in mind, goals should be relevant to what the student is expected to learn, measurable so progress toward the goals is able to be determined and actions need to be taken to remedy the situation should the student be struggling to reach the goal. 

The information included herein is not intended to provide legal advice.  Should you need legal advice or guidance on any issue involving special education, please contact the appropriate person for your district.

Announcement:  If needing a surrogate parent for IEP meetings or any other circumstances, please contact Lianne Pierce, Director of Ancillary Services, at or 505.344.5470, Ext 103.