
MTSS, 504, and IEP: Which One Does Your Child Need?
A plain-language map of the three main support systems schools use, when each applies, and how families can request the right one.

Progress reports arrive saying your child is making progress toward their goals. Federal law requires those reports to say something measurable, and most of them do not.
The progress report comes home with the report card. Next to each IEP goal, someone has checked a box marked "progressing" or written a sentence saying your child is working toward the goal. Nothing in it tells you whether your child is closer to the goal than they were in September.
Federal law requires more than that, and knowing what it requires changes what you can ask for.
Under 34 C.F.R. § 300.320(a)(3), every IEP must state how your child's progress toward each annual goal will be measured, and when you will receive periodic reports on that progress. Those two commitments are written into the document your team signed.
The reporting requirement is not satisfied by a checkbox. The IEP told you how progress would be measured, and the report is where the district shows you that measurement.
Open the report next to the IEP and check whether you can answer these.
Where did my child start? The IEP's present levels section contains a baseline. A goal that began at 40 percent accuracy and a report that says "progressing" tells you nothing until you know the current number.
Where is my child now? The report should give you the same kind of measurement the goal uses. If the goal is stated in words correct per minute, the report should give you words correct per minute.
Is that pace enough? A goal is annual. If your child needed to move from 40 percent to 80 percent across the year and sits at 45 percent in January, the trajectory says the goal will not be met, and that is information you are entitled to act on before June.
Ask for the data behind it, in writing.
The IEP names a measurement method. Whoever wrote "progressing" used something to reach that judgment, whether that is work samples, curriculum-based measures, a running record, or trial data. Ask for the underlying data for each goal, and reference the measurement method the IEP itself specifies.
Districts are generally able to produce this, because staff collect it to write the report in the first place. What families discover is that the data sometimes shows less movement than the summary word suggested.
Endrew F. v. Douglas County School District RE-1 (2017) requires an IEP reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances, and the Court rejected merely more than de minimis progress as the standard.
A progress report is where that standard becomes checkable during the year rather than after it. If the data shows your child moving at a rate that will not reach the goal, the IEP is not currently working as written. Under 34 C.F.R. § 300.324(b)(1)(ii)(A), the IEP team must revise the IEP to address any lack of expected progress toward the annual goals. The regulation sets no deadline for that revision and does not spell out a parent's right to call a meeting, so put the request in writing and cite the data.
Request an IEP team meeting in writing and say why: the progress data for specific goals indicates the current services are not producing the rate of progress the goal requires.
Bring the reports and the baseline. A meeting where you can point to a number in September and a number in January is different from a meeting where you say you feel worried.
Ask what the team proposes to change. More of the same service delivered the same way is a decision the team should have to explain, given data showing it has not worked so far.
Progress reports that say the same thing every period deserve attention. A child who was "progressing" in November, "progressing" in February, and "progressing" in May, without a single number attached, has generated three documents and no evidence.
That pattern is common, it is fixable, and asking for the data is what fixes it.
Our free IEP Audit reviews your child's IEP across six research-grounded areas, including whether goals are measurable enough for a progress report to mean anything. Families pay nothing. Book a New Family Registration call and we will walk you through how it works.
Assistance to States for the Education of Children With Disabilities, 34 C.F.R. § 300.320 (2017).
Assistance to States for the Education of Children With Disabilities, 34 C.F.R. § 300.324 (2017).
Endrew F. v. Douglas County School District RE-1, 580 U.S. 386 (2017).
Individuals with Disabilities Education Act, 20 U.S.C. § 1400 et seq. (2004).
Keep reading

A plain-language map of the three main support systems schools use, when each applies, and how families can request the right one.

Why measurable goals matter and how to tell whether your child's IEP goals would survive a substitute teacher.

We will have a table at the Sumner County Special Needs Collaborative expo on August 15. Bring your child's IEP and leave registered for a free audit, with the document already uploaded.