← All tools

Tool 79: Transition Planning at 16 (or Earlier): a Plan that Must Say More Than “Will Attend College Fair”

THE RULE

The Individuals with Disabilities Education Act (IDEA) requires the IEP to grow a second half when your child gets old enough. The rule is at 34 C.F.R. § 300.320(b):

“Beginning not later than the first IEP to be in effect when the child turns 16, or younger if determined appropriate by the IEP Team, and updated annually, thereafter, the IEP must include - (1) Appropriate measurable postsecondary goals based upon age appropriate transition assessments related to training, education, employment, and, where appropriate, independent living skills; and (2) The transition services (including courses of study) needed to assist the child in reaching those goals.”

Read that slowly. It contains 5 separate commands.

One: a federal latest start. Transition content must appear in the first IEP in effect when the student turns 16, or younger if the team decides (34 C.F.R. § 300.320(b)). State law may require an earlier start. Do not assume planning must begin at 15 or that age 14 is universal.

Two: annual updates. The transition plan is updated every year, not written once and carried forward. Tool 32 shows how to catch copied goals wearing new dates.

Three: assessments first. The postsecondary goals must be “based upon age appropriate transition assessments.” The goals come out of the assessments. Assessments come first, in time and in logic. The regulation does not define what an age-appropriate transition assessment is. It requires one anyway, and it requires more than one area: training, education, employment, and, where appropriate, independent living skills.

Four: measurable postsecondary goals. These are not the annual IEP goals at § 300.320(a)(2). Annual goals are what your child will do this year, in school. Postsecondary goals are what your child will do after school ends. Both must be in the document. They are different sections and different sentences.

Five: transition services, including courses of study. Not a wish. A set of activities, and the classes your child takes on the way there.

“Transition services” has its own definition, at 34 C.F.R. § 300.43(a). It is “a coordinated set of activities” that is “designed to be within a results-oriented process,” focused on improving your child’s academic and functional achievement, to move the child from school to post-school life - including postsecondary education, vocational education, integrated employment, adult services, independent living, or community participation (§ 300.43(a)(1)). It must be “based on the individual child’s needs, taking into account the child’s strengths, preferences, and interests,” and it “includes” instruction, related services, community experiences, the development of employment and other post-school adult living objectives, and, if appropriate, acquisition of daily living skills and a functional vocational evaluation (§ 300.43(a)(2)).

Transition services may be special education or a related service (§ 300.43(b)). That means they can be written into the service page with a frequency and a provider, the same as speech or counseling (Tool 24).

Your child must be invited. If a purpose of the IEP meeting is to consider postsecondary goals and transition services, the district must invite the child (34 C.F.R. § 300.321(b)(1)). If the child does not attend, the district “must take other steps to ensure that the child’s preferences and interests are considered” (§ 300.321(b)(2)). Those steps are not optional and they are not a formality.

Outside agencies may be invited too. To the extent appropriate, and with your consent - or the consent of your child, once your child has reached the age of majority - the district must invite a representative of any participating agency likely to be responsible for providing or paying for transition services (§ 300.321(b)(3)). Vocational rehabilitation is the usual example.

If an outside agency does not deliver, the district must reconvene the IEP Team to identify alternative strategies (§ 300.324(c)(1)). The agency’s own obligations do not disappear either (§ 300.324(c)(2)).

WHY IT MATTERS

The transition page is the part of the IEP districts most often fill with sentences that mean nothing. “Student will explore career interests.” “Student will attend the college fair.” “Student will meet with the guidance counselor.” None of those is a measurable postsecondary goal. None of them is based on an assessment. None of them is a service with a provider and a schedule.

A transition page like that costs your child the last years of school. Those years are the ones with the most leverage. This is when a student can be taught to ride a bus, fill out an application, self-advocate to a professor, work a job with a coach, manage money, take medication, and speak for himself in a meeting. The IEP is the only document that can require any of it.

There is a second cost, and it is the one parents find out about too late. The transition services include the courses of study. The courses your child takes from 9th grade forward can decide which diploma is available at the end. A plan that never names a course of study is a plan that lets the schedule drift. By junior year the drift is a track, and the track has a name, and the name may not be the one you assumed. That is Tool 80, and it is the reason this tool comes first.

The assessments matter for the same reason. A 3-question interest survey handed to a 15-year-old in homeroom is not an evaluation of anything. It tells the team what your child has heard of, not what your child can do, needs, or wants. Goals built on that survey are guesses. Services built on those goals are filler.