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Tool 34: The Goal-Bank Tell: Spotting a Goal Written for No Child in Particular

THE RULE

Under the Individuals with Disabilities Education Act (IDEA), an IEP is a written statement developed for each child with a disability (34 C.F.R. § 300.320(a)). Two of its parts are chained together, and the chain is the point of this tool.

First, the IEP must state your child’s present levels of academic achievement and functional performance - including how the disability affects your child’s involvement and progress in the general education curriculum (34 C.F.R. § 300.320(a)(1)).

Second, the IEP must contain a statement of measurable annual goals, academic and functional, designed to (A) meet the needs that result from your child’s disability so your child can be involved in and make progress in the general education curriculum, and (B) meet each of your child’s other educational needs that result from the disability (34 C.F.R. § 300.320(a)(2)(i)).

Read those two together. A goal must be measurable, and it must be designed to meet needs that result from this child’s disability. Those needs are what the present levels describe. So every goal has to be traceable back to a stated present level. A goal that traces back to nothing is not doing the job the regulation assigns it.

Three more rules close the loop:

• The IEP must describe how progress toward each annual goal will be measured, and when periodic reports will be given (34 C.F.R. § 300.320(a)(3)).

• In developing the IEP, the team must consider your child’s strengths, your concerns, the results of the most recent evaluation, and your child’s academic, developmental, and functional needs (34 C.F.R. § 300.324(a)(1)).

• The evaluation itself must be comprehensive enough to identify all of your child’s needs, “whether or not commonly linked to the disability category in which the child has been classified” (34 C.F.R. § 300.304(c)(6)). Services follow the child’s needs. They do not follow the label.

Nothing in the IDEA forbids a district from using goal-writing software. Districts use it, and some of the language it produces is fine. What the law requires is that the goal fit this child. Software does not know your child. The team does, and the regulation puts the duty on the team.

WHY IT MATTERS

A goal bank is a menu. You pick a disability category, a subject, and a grade band, and the software returns a sentence. The sentence is grammatical, measurable-sounding, and written for nobody.

The damage is quiet and it is expensive. A goal is a plan for how your child will spend a year. If the goal was chosen from a menu rather than built from your child’s data, then the year gets spent on the wrong thing - a skill your child already has, or a skill three steps ahead of where your child actually is.

There is a second cost. A goal with a borrowed baseline cannot be measured honestly. If the IEP says your child reads 40 words per minute and your child actually reads 22, then at the end of the year nobody can say whether the goal was met, missed, or meaningless. The progress report will say “progressing gradually” (Tool 68) and the file will look fine.

And there is a third cost, the one Endrew F. is about (Tool 33). A goal written for a category rather than a child is hard to defend as “appropriate in light of the child’s circumstances,” because no one ever consulted the circumstances.