Updated on
February 26, 2026
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February 26, 2026
A practical guide for IEP teams when a student has made no progress: writing present levels honestly, analysing what went wrong, rewriting goals, parent communication scripts, and legal requirements.
Slug: iep-no-progress-annual-review-guide
Word count target: 5,000-6,000 words
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Zero progress is not the worst outcome you can face in special education. Writing about it dishonestly is. When a student ends the year at exactly the same performance level they started, the IEP team has two choices: obscure that fact with vague language and wishful goals, or treat the flat trendline as diagnostic data and build a sharper plan from it.
The second approach is the only one that serves the student. It is also the only one that protects you legally.
This guide is written for the Sunday night before the Monday morning annual review. It covers the legal framework, the documentation language, the parent conversation, and the goal-writing adjustments that turn a difficult meeting into a productive one.
Before you write a single word of the revised IEP, you need to understand why the trendline is flat. There is almost always a reason. Attributing zero progress to "the severity of the disability" without investigation is both professionally weak and legally risky.
Burns (2004) identified instructional match as one of the strongest predictors of student response to intervention. When an intervention is pitched above or below a student's instructional level, progress stalls regardless of how skilled the teacher is or how frequently the sessions occur. A student whose reading fluency goal targets 80 words per minute when their current independent level is 30 words per minute is not failing. The goal was set at an unreachable distance.
Consider each of the following as a genuine hypothesis before the annual review:
Instructional match. Was the intervention operating at the student's zone of proximal development, or was it too far above independent level to produce growth? Curriculum-based measurement data will show this clearly. If the student's progress monitoring scores clustered near their starting baseline with no upward slope, the intervention difficulty level is the first variable to interrogate.
Intervention intensity. The National Center on Intensive Intervention (NCII, 2013) defines intensive intervention by the frequency, duration, and explicitness of instruction. A student receiving Tier 2 intervention twice a week for 20 minutes is not receiving intensive support. If the student's need is intensive and the dosage was not, the programming was mismatched to the need.
Implementation fidelity. Was the intervention actually delivered as designed? Substitutions, session cancellations, and deviation from the instructional sequence all reduce the likelihood of progress. Fidelity data is difficult to collect consistently in most schools, but anecdotal records of missed sessions, changes in personnel, or schedule disruptions are relevant here.
Co-occurring conditions. Students with one identified disability frequently have unidentified co-occurring conditions. A student identified for a specific learning disability in reading may also have executive function deficits that were never formally assessed. A student identified for ADHD may have an unrecognised anxiety disorder that suppresses performance without appearing in screening data. A lack of progress is sometimes the first clear signal that the disability profile is more complex than the original evaluation captured.
Attendance and medical factors. Progress monitoring data averages across the whole year. A student who missed 30 days of instruction due to illness, family circumstances, or school avoidance cannot be expected to meet annual goals designed for consistent attendance. Document this separately so the flat trendline is contextualised accurately.
Goal construction. Some annual goals are technically unachievable from the moment they are written, either because the baseline was overestimated, the expected growth rate exceeded what research supports for this disability category, or the goal conflated several distinct subskills that should have been sequenced rather than bundled.
Take 20 minutes before the meeting to run through this list with your progress monitoring data in front of you. Your hypothesis about the primary cause will shape every other section of the revised IEP.
Many teachers approach an IEP annual review following zero progress with the assumption that they have done something wrong. In most cases, they have not.
The Individuals with Disabilities Education Act does not guarantee that students with disabilities will make academic progress. It guarantees a free and appropriate public education (FAPE), defined through the lens of access to the general curriculum and specially designed instruction tailored to the student's unique needs.
The Supreme Court's ruling in Endrew F. v. Douglas County School District (2017) clarified the standard. The Court held that a child's IEP must be "reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances." This standard is sometimes summarised as "appropriately ambitious." It replaced the earlier, lower standard (which some courts had interpreted as requiring only minimal progress) with something more demanding. But it is still a standard of reasonable calculation, not a guarantee of outcomes.
Yell (2019) identifies the key legal protection for teachers: if the IEP was implemented with fidelity and was reasonably calculated to produce progress based on the available evidence at the time it was written, the school district has met its legal obligation even if the student did not actually progress. The obligation is in the design and the delivery, not solely in the outcome.
What creates legal vulnerability is not a flat trendline. It is:
- Writing goals that were never going to be achievable (setting the student up to fail on paper)
- Failing to collect and document progress monitoring data throughout the year
- Ignoring a flat trendline mid-year without any documented response (no IEP amendment, no team meeting, no change in approach)
- Describing present levels in ways that misrepresent the student's actual performance
If your progress monitoring data is complete, your intervention was delivered with reasonable fidelity, and you are now documenting the plateau honestly and adjusting the plan accordingly, you are doing exactly what IDEA requires. The annual review is the built-in mechanism for exactly this situation.
You can also strengthen your position by referencing MTSS and RTI frameworks in your documentation. A student who has moved through Tier 1, Tier 2, and now requires Tier 3 intensive intervention, with documented data at each stage, has a well-evidenced progression that supports the current IEP decisions.
The Present Level of Academic Achievement and Functional Performance is the section where most educators make their first mistake when progress has been zero. The instinct is to soften the language, add qualifying phrases, and avoid stating the flat trendline directly.
This instinct is understandable. It is also counterproductive.
A PLAAFP that obscures the reality of zero progress creates three problems. It gives parents inaccurate information about their child's performance. It makes it harder to justify the instructional changes you are about to propose. And it reduces the document's credibility as a legal record.
Write the PLAAFP using the following template as a starting frame, then adapt to your specific data:
"At the beginning of the [academic year], [student name] demonstrated [specific skill] at [precise baseline measure] as measured by [assessment tool or method]. The annual goal targeted [specific growth] by [date]. Progress monitoring data collected [frequency, e.g., every two weeks] using [tool] indicated that [student name] performed at [current level] at the end of the year, representing [X months/negligible/no measurable] growth over the intervention period. This rate of progress indicates that the current instructional approach requires modification. Contributing factors identified by the team include [list from your diagnostic analysis above]."
Notice what this template does. It is specific (it names the measure, the baseline, the target, and the outcome). It is honest (it names the gap between target and reality). It is analytical rather than defensive (it moves immediately to contributing factors, treating the data as information rather than accusation). And it is forward-pointing (the final phrase sets up the revised plan).
Here is a worked example:
"At the beginning of the 2024-25 academic year, Marcus demonstrated oral reading fluency at 42 words correct per minute (WCPM) on Grade 3 passages as measured by AIMSweb Plus. The annual goal targeted 70 WCPM by May. Progress monitoring data collected biweekly across 18 data points indicated that Marcus performed at 47 WCPM at the close of the year. Growth of 5 WCPM over 36 weeks falls significantly below the 28 WCPM gain targeted. Contributing factors identified by the team include 19 absences in the second semester, a personnel change in January that disrupted intervention consistency for six weeks, and emerging assessment data suggesting co-occurring working memory deficits that may require instructional accommodation."
This paragraph is uncomfortable to write. It will also protect you, inform the parents accurately, and build a coherent justification for the changes ahead.
Data-based individualisation (DBI) is the systematic process of using progress monitoring data to identify why an intervention is not working and to make targeted adjustments. Fuchs and Fuchs (2007) developed DBI as a response to the common failure mode in special education: implementing an intervention without a structured decision-making process for what to do when it does not produce results.
DBI asks four questions in sequence:
1. Is the student responding to the intervention? Look at the slope of the progress monitoring data. A flat or declining slope across at least six to eight data points signals non-response. A slope that started upward and then plateaued signals a different problem (the student may have reached a performance ceiling within that specific task type).
2. Was the intervention implemented as intended? Check your fidelity records, session logs, and any notes on personnel changes or schedule disruptions. If you cannot answer this question with documentation, that itself is a finding. Implementing an intervention without fidelity data is one of the most common gaps in special education practice.
3. Was the goal appropriately ambitious? Return to the baseline. Using Deno's (1985) curriculum-based measurement research, typical growth rates for students receiving intensive intervention are well-documented by grade level and disability category. If the goal assumed growth rates that exceed documented benchmarks for similar students, the goal was the problem, not the student.
4. Does the student need a different intervention, or a different version of the same intervention? Fuchs and Fuchs (2007) distinguish between "instructional modifications" (adjusting intensity, frequency, or pacing within the same approach) and "programme changes" (switching to a fundamentally different instructional methodology). Both are legitimate responses to non-response. The data should guide which is appropriate.
Run through this sequence with your data before the annual review meeting. Document your answers. This process is both good practice and a clear demonstration to parents that the team has analysed the plateau rigorously rather than simply writing new goals and hoping for different results.
Formative assessment tools can be embedded throughout the year to catch a plateau before it spans the full annual cycle. If your school does not currently have a decision rule for responding to non-response (for example, "if a student fails to show adequate growth after six consecutive data points below the aimline, convene a team meeting"), establishing one is a structural protection against the Sunday-night situation you are now in.
After running the DBI analysis, you are ready to write revised goals. The core principle is simple: next year's goals must be different from this year's goals in some substantive way. Writing identical goals for a student who made no progress is not just pedagogically unsound. It is legally indefensible under the Endrew F. standard.
The differences can be in any of the following dimensions:
Baseline accuracy. Use this year's end-of-year data, not the original baseline, as next year's starting point. This sounds obvious, but it is frequently done incorrectly. If Marcus ended the year at 47 WCPM, his IEP should not start from a baseline of 42 WCPM simply because that was the original entry point.
Goal ambition, recalibrated. The Endrew F. standard requires appropriately ambitious goals, not unreachable ones. Use the research on expected growth rates for students receiving intensive intervention to set a target that is genuinely ambitious and also grounded in what comparable students can achieve. The NCII provides benchmark data by disability category that is useful for this calibration.
Subskill sequencing. If a large goal (increase oral reading fluency to 70 WCPM) produced no progress, consider whether the goal needs to be broken into component subskills. Phonemic awareness, decoding accuracy, sight word recognition, and prosody are all separable skills that contribute to fluency. A student who did not improve fluency may have made growth in one of these subskills that is invisible in the fluency measure. Identify the foundational skill that needs to be secured before the composite skill can grow.
Instructional approach. If the analysis indicates that the current intervention is not the right match for the student, the goal needs to reflect a change in methodology. Document the new approach clearly: not just "specialised reading instruction" but the specific programme name, the instructional principles it is based on, and why it is a better match for the student's profile.
Frequency and duration. If the student was receiving 30 minutes per day and made no progress, this is not automatically an argument for more of the same. It may be an argument for a different intensity pattern (shorter, more frequent sessions rather than longer, less frequent ones), or it may signal that the frequency was actually insufficient. The NCII recommends a minimum of 30 minutes per day, five days per week, for intensive intervention (NCII, 2013). Check whether the actual delivery matched this.
Scaffolding in education literature is relevant here too. Vygotsky's zone of proximal development principle applies directly to goal-setting: a goal set at a level the student cannot access without significant support requires explicit scaffolding built into the plan, not just a target date.
Differentiation strategies may also need to be revisited at the goal level, particularly if the student's difficulty is in accessing the general curriculum rather than in a discrete skill area.
The language you use in the annual review meeting matters as much as the documents in front of you. The following table gives specific guidance on phrasing for the most common difficult moments.
| Situation | Do NOT say | DO say |
|---|---|---|
| Opening the meeting | "I know the data isn't great, but..." | "I want to start by sharing exactly what the progress data shows, and then we will look at what it tells us about next year's plan." |
| Presenting the flat trendline | "He didn't really make the progress we hoped." | "The data shows Marcus ended the year at 47 WCPM. The goal was 70. That is a 23-point gap we need to understand and plan for." |
| Explaining why progress stalled | "It was a hard year for everyone." | "We have identified three contributing factors: attendance in semester two, a personnel change in January, and new assessment information about working memory. Here is how the revised plan addresses each one." |
| Parent asks "Why didn't he learn to read?" | "We tried our best." | "That is exactly the right question. Let me show you what the data tells us about where the instruction needs to change." |
| Parent expresses frustration or anger | "I understand your concerns, but..." | "That frustration makes complete sense. [Pause.] Let me make sure you have all the information, and then let's talk about what changes specifically." |
| Parent asks about their legal rights | "You can request an IEE if you want, but..." | "Absolutely. You have the right to request an Independent Educational Evaluation at district expense. I can give you that information in writing today if you would like." |
| Explaining the new plan | "We're going to try some new things." | "The revised plan changes three things: the reading programme, the session frequency, and the way we will monitor and respond to data this year. Here is each one." |
| Closing the meeting | "Hopefully next year will be better." | "The goal for next year is [specific target]. We will review data every six weeks and meet if the growth rate falls below [decision rule]. You will receive a progress report in [month]." |
The pattern running through the "DO say" column is consistent: specific data, direct acknowledgement of difficulty, and concrete forward-planning language. Vague reassurance undermines trust. Precise information builds it.
The research on parent-professional communication in IEP meetings consistently finds that parents report feeling excluded from the process, that information is shared in inaccessible language, and that they leave meetings without a clear understanding of what is happening and why (Childre and Chambers, 2005). A meeting following zero progress amplifies every one of these risks.
Structure your parent communication in this sequence:
Step one: share the data first, without framing. Place the progress monitoring graph in front of the parent and describe what it shows: "This line shows where [student] started in September. This line shows where we aimed to be by May. This line shows where [student] actually is." Let the parent process the visual before you add interpretation.
Step two: acknowledge the emotional reality before you explain. Parents who have a child with a learning disability have frequently spent years in meetings where professionals explain before they listen. If a parent looks distressed, stop and say: "Before we go any further, I want to hear what this is like for you." This is not a delay. It is what makes the rest of the meeting productive.
Step three: share your analysis, not your excuses. There is a clear difference between explaining contributing factors analytically ("our data shows that the 19 absences in semester two account for approximately eight weeks of missed intervention") and making excuses defensively ("well, he missed a lot of school"). Use the DBI framework from the analysis section as your structure. Parents can hear difficult information when it is framed as investigation.
Step four: present the revised plan in specific terms. Not "we will try a new approach" but "we are recommending a switch from [Programme A] to [Programme B] because [Programme B] addresses decoding at the phoneme level, which the new assessment data identifies as the primary gap." Specificity communicates competence.
Step five: establish the monitoring promise. Tell the parent exactly how often they will receive progress data, what the decision rule is for convening a mid-year meeting, and how they can contact you if they have concerns between reviews. This last element is the most underused trust-building tool available to IEP teams.
Self-regulation in the classroom research is relevant to the student's perspective here too. If the student is old enough to participate meaningfully in the IEP meeting, their voice about what has and has not been helpful is both legally appropriate and practically valuable. Students who participate in their own IEP meetings demonstrate better self-advocacy and greater investment in their goals (Martin et al., 2006).
Sometimes zero progress is not a signal to adjust the programme. It is a signal to reexamine the underlying evaluation.
IDEA requires a triennial reevaluation for all students with disabilities, but the law also allows a reevaluation more frequently when warranted by the student's performance. A sustained plateau is one of the clearest warrants available.
Consider requesting a reevaluation when:
The disability category may be incomplete. A student identified solely for a specific learning disability in reading who has not responded to multiple evidence-based reading interventions may need evaluation for co-occurring processing disorders, intellectual disability, or hearing loss that was not identified at initial evaluation.
The student's profile has changed significantly. Executive function difficulties, mental health conditions, and trauma histories often emerge or escalate during the school years. A student who was accurately evaluated at age seven may look quite different at age 12 in ways the original evaluation did not capture.
Progress monitoring data is inconsistent with classroom observation. If a student performs near grade level in some structured settings but fails to maintain or generalise skills, the evaluation may need to assess processing, working memory, or executive function more specifically.
The team suspects a different primary disability category. A student identified for autism spectrum disorder whose primary barrier to progress is a specific learning disability in maths, for example, may need a reevaluation that refocuses the IEP around the right primary need.
A reevaluation does not invalidate the existing IEP. It provides better data for designing the next one. Frame it to parents as exactly that: "We want to make sure we have the most accurate picture of [student's] profile so that next year's plan is as precise as possible."
The 504 plan vs IEP distinction is also worth revisiting here. Occasionally, a student's needs are better served by a 504 plan with specific accommodations than by an IEP with specially designed instruction. A reevaluation is the appropriate mechanism for determining this.
The best protection against the Sunday-night crisis of next year is building a structure into this year's IEP that makes a year-long plateau impossible to miss. The following practices are all evidence-based and implementable within most school contexts.
Set a decision rule in the IEP itself. Batsche (2014) recommends writing the decision rule directly into the IEP document: "If [student] fails to demonstrate adequate growth as defined by [specific criterion] across [number] consecutive data collection points, the IEP team will convene within [timeframe] to review and modify the plan." This converts a passive hope for progress into an active monitoring commitment.
Collect progress monitoring data at minimum every two weeks. Deno (1985) established that curriculum-based measurement is most predictive of outcomes when collected frequently enough to generate a reliable slope. A single data point per month does not produce a usable trendline for six months. Eight data points collected every two weeks produces a usable trendline within three months. You would have caught and responded to this plateau before the annual review.
Use a visual graph, not a table of numbers. Progress monitoring data displayed as a graph with a goal line and an aimline is far more interpretable to teachers, parents, and administrators than a column of numbers. Most progress monitoring tools generate these automatically. If yours does not, a simple graph in Google Sheets takes less than five minutes to produce and is worth every one of those minutes.
Review data as a team, not in isolation. At minimum, a brief team check-in every six weeks on the progress monitoring data for students receiving intensive intervention is good practice. This does not need to be a formal IEP meeting. A 15-minute data review with the special education teacher, the classroom teacher, and any relevant specialist is sufficient. The purpose is to catch a flat trendline before it has been flat for six months.
Build mid-year IEP amendment into your calendar. If a student's data shows no progress by the six-week review, you have both the right and the obligation to reconvene the IEP team and amend the plan. Mid-year amendments are permitted under IDEA. They are far preferable to arriving at an annual review with a year of flat data and no documented response.
Cognitive load theory has practical implications for goal design as well. Goals that require students to manage too many simultaneous demands at once may fail not because the student lacks the underlying skill, but because working memory resources are exhausted before the skill can be practised to fluency. Chunking goals into smaller subskills, one at a time, reflects what the cognitive load literature tells us about skill acquisition.
A growth mindset framework for teachers is also worth considering here. Teams that interpret a flat trendline as "this student can't learn" will respond very differently from teams that interpret it as "this student has not yet responded to this approach." The framing of the data shapes the quality of the decision-making.
Students with ADHD present a particular diagnostic challenge at the annual review following zero progress, because ADHD-related barriers (attention dysregulation, self-regulation difficulties, impulsivity) can suppress the expression of skills that have actually been acquired. A student may have learned a decoding strategy but be unable to deploy it consistently in a testing context due to attentional demands.
If your student has ADHD and made no measurable progress, check the evidence-based accommodations for ADHD before concluding that the instructional intervention itself was the primary failure. Reduced-distraction settings, extended time, preferential seating, and chunked task presentation may unlock access to skills the student has acquired but cannot demonstrate under standard conditions.
If these accommodations were not in place, that is a contributing factor for the PLAAFP. If they were in place but not consistently implemented, that is a fidelity issue with the existing plan.
If you are reading this the night before an annual review, the single most important thing you can do right now is organise your progress monitoring data into a visual graph with a clear baseline, goal line, and the student's actual data points plotted over time.
Walk into the meeting with that graph. Refer to it. Let it be the centre of the conversation.
Data does not accuse anyone. It describes a situation and points toward what needs to change. A teacher who leads with data, names the contributing factors honestly, and presents a revised plan grounded in that analysis is doing their job with integrity. That is the full legal and professional standard, and it is achievable even when the news is difficult.
The student in front of you did not fail. The current programme did not produce the expected results. Those are two very different statements, and the first step toward a better outcome is being clear about which one is true.
Fuchs, L. S., & Fuchs, D. (2007). A model for implementing responsiveness to intervention. Teaching Exceptional Children, 39(5), 14-20.
Fuchs and Fuchs articulate the DBI framework that underpins responsible non-response decision-making. This paper remains the clearest practical guide to what teams should do when an intervention is not working, and why mid-year amendment is the correct response rather than continued implementation without change.
View study
Deno, S. L. (1985). Curriculum-based measurement: The emerging alternative. Exceptional Children, 52(3), 219-232.
Deno's foundational paper established the evidence base for curriculum-based measurement as a progress monitoring tool. The case for frequent, brief, standardised measurement rather than infrequent, long-form testing rests on this research, which showed that CBM slope predicts outcomes significantly better than snapshot assessment data.
View study
Burns, M. K., & Gibbons, K. (2008). Implementing response-to-intervention in elementary and secondary schools: Procedures to assure scientific-based practices. Routledge.
Burns and Gibbons synthesise the evidence on instructional match and its relationship to student learning rates. The chapter on diagnostic assessment of instructional level is particularly relevant for teams reviewing annual goals following zero progress, as it provides a framework for identifying whether the goal or the instruction was the primary mismatch.
View study
Yell, M. L., Katsiyannis, A., & Losinski, M. (2013). Endrew F. v. Douglas County School District: Implications for educators. TEACHING Exceptional Children, 50(1), 7-15.
This paper provides the clearest analysis of the legal implications of the Endrew F. standard for classroom practitioners. Yell et al. explain precisely what "appropriately ambitious" means in practice, the evidentiary record schools need to maintain, and the difference between a FAPE violation and an outcome that was disappointing but legally sound.
View study
Childre, A., & Chambers, C. R. (2005). Family perceptions of student centered planning and IEP meetings. Education and Training in Developmental Disabilities, 40(3), 217-233.
Childre and Chambers document the significant gap between how IEP teams perceive meetings and how families experience them. Their findings on communication, accessible language, and the role of parent voice in goal-setting are directly relevant to conducting an annual review following zero progress, where the communication challenge is at its most acute.
View study
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- Batsche, G. (2014). Multi-tiered system of supports for inclusive schools. In J. McLeskey, N. L. Waldron, F. Spooner, & B. Algozzine (Eds.), Handbook of effective inclusive schools. Routledge.
- Burns, M. K. (2004). Empirical analysis of drill ratio research: Refining the instructional level for drill tasks. Remedial and Special Education, 25(3), 167-173.
- Childre, A., & Chambers, C. R. (2005). Family perceptions of student centered planning and IEP meetings. Education and Training in Developmental Disabilities, 40(3), 217-233.
- Deno, S. L. (1985). Curriculum-based measurement: The emerging alternative. Exceptional Children, 52(3), 219-232.
- Endrew F. v. Douglas County School District, 580 U.S. 386 (2017).
- Fuchs, L. S., & Fuchs, D. (2007). A model for implementing responsiveness to intervention. Teaching Exceptional Children, 39(5), 14-20.
- Martin, J. E., Van Dycke, J. L., Christensen, W. R., Greene, B. A., Gardner, J. E., & Lovett, D. L. (2006). Increasing student participation in IEP meetings: Establishing the self-directed IEP as an evidenced-based practice. Exceptional Children, 72(3), 299-316.
- National Center on Intensive Intervention. (2013). Data-based individualization: A framework for intensive intervention. American Institutes for Research.
- Yell, M. L., Katsiyannis, A., & Losinski, M. (2013). Endrew F. v. Douglas County School District: Implications for educators. TEACHING Exceptional Children, 50(1), 7-15.
Slug: iep-no-progress-annual-review-guide
Word count target: 5,000-6,000 words
---
Zero progress is not the worst outcome you can face in special education. Writing about it dishonestly is. When a student ends the year at exactly the same performance level they started, the IEP team has two choices: obscure that fact with vague language and wishful goals, or treat the flat trendline as diagnostic data and build a sharper plan from it.
The second approach is the only one that serves the student. It is also the only one that protects you legally.
This guide is written for the Sunday night before the Monday morning annual review. It covers the legal framework, the documentation language, the parent conversation, and the goal-writing adjustments that turn a difficult meeting into a productive one.
Before you write a single word of the revised IEP, you need to understand why the trendline is flat. There is almost always a reason. Attributing zero progress to "the severity of the disability" without investigation is both professionally weak and legally risky.
Burns (2004) identified instructional match as one of the strongest predictors of student response to intervention. When an intervention is pitched above or below a student's instructional level, progress stalls regardless of how skilled the teacher is or how frequently the sessions occur. A student whose reading fluency goal targets 80 words per minute when their current independent level is 30 words per minute is not failing. The goal was set at an unreachable distance.
Consider each of the following as a genuine hypothesis before the annual review:
Instructional match. Was the intervention operating at the student's zone of proximal development, or was it too far above independent level to produce growth? Curriculum-based measurement data will show this clearly. If the student's progress monitoring scores clustered near their starting baseline with no upward slope, the intervention difficulty level is the first variable to interrogate.
Intervention intensity. The National Center on Intensive Intervention (NCII, 2013) defines intensive intervention by the frequency, duration, and explicitness of instruction. A student receiving Tier 2 intervention twice a week for 20 minutes is not receiving intensive support. If the student's need is intensive and the dosage was not, the programming was mismatched to the need.
Implementation fidelity. Was the intervention actually delivered as designed? Substitutions, session cancellations, and deviation from the instructional sequence all reduce the likelihood of progress. Fidelity data is difficult to collect consistently in most schools, but anecdotal records of missed sessions, changes in personnel, or schedule disruptions are relevant here.
Co-occurring conditions. Students with one identified disability frequently have unidentified co-occurring conditions. A student identified for a specific learning disability in reading may also have executive function deficits that were never formally assessed. A student identified for ADHD may have an unrecognised anxiety disorder that suppresses performance without appearing in screening data. A lack of progress is sometimes the first clear signal that the disability profile is more complex than the original evaluation captured.
Attendance and medical factors. Progress monitoring data averages across the whole year. A student who missed 30 days of instruction due to illness, family circumstances, or school avoidance cannot be expected to meet annual goals designed for consistent attendance. Document this separately so the flat trendline is contextualised accurately.
Goal construction. Some annual goals are technically unachievable from the moment they are written, either because the baseline was overestimated, the expected growth rate exceeded what research supports for this disability category, or the goal conflated several distinct subskills that should have been sequenced rather than bundled.
Take 20 minutes before the meeting to run through this list with your progress monitoring data in front of you. Your hypothesis about the primary cause will shape every other section of the revised IEP.
Many teachers approach an IEP annual review following zero progress with the assumption that they have done something wrong. In most cases, they have not.
The Individuals with Disabilities Education Act does not guarantee that students with disabilities will make academic progress. It guarantees a free and appropriate public education (FAPE), defined through the lens of access to the general curriculum and specially designed instruction tailored to the student's unique needs.
The Supreme Court's ruling in Endrew F. v. Douglas County School District (2017) clarified the standard. The Court held that a child's IEP must be "reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances." This standard is sometimes summarised as "appropriately ambitious." It replaced the earlier, lower standard (which some courts had interpreted as requiring only minimal progress) with something more demanding. But it is still a standard of reasonable calculation, not a guarantee of outcomes.
Yell (2019) identifies the key legal protection for teachers: if the IEP was implemented with fidelity and was reasonably calculated to produce progress based on the available evidence at the time it was written, the school district has met its legal obligation even if the student did not actually progress. The obligation is in the design and the delivery, not solely in the outcome.
What creates legal vulnerability is not a flat trendline. It is:
- Writing goals that were never going to be achievable (setting the student up to fail on paper)
- Failing to collect and document progress monitoring data throughout the year
- Ignoring a flat trendline mid-year without any documented response (no IEP amendment, no team meeting, no change in approach)
- Describing present levels in ways that misrepresent the student's actual performance
If your progress monitoring data is complete, your intervention was delivered with reasonable fidelity, and you are now documenting the plateau honestly and adjusting the plan accordingly, you are doing exactly what IDEA requires. The annual review is the built-in mechanism for exactly this situation.
You can also strengthen your position by referencing MTSS and RTI frameworks in your documentation. A student who has moved through Tier 1, Tier 2, and now requires Tier 3 intensive intervention, with documented data at each stage, has a well-evidenced progression that supports the current IEP decisions.
The Present Level of Academic Achievement and Functional Performance is the section where most educators make their first mistake when progress has been zero. The instinct is to soften the language, add qualifying phrases, and avoid stating the flat trendline directly.
This instinct is understandable. It is also counterproductive.
A PLAAFP that obscures the reality of zero progress creates three problems. It gives parents inaccurate information about their child's performance. It makes it harder to justify the instructional changes you are about to propose. And it reduces the document's credibility as a legal record.
Write the PLAAFP using the following template as a starting frame, then adapt to your specific data:
"At the beginning of the [academic year], [student name] demonstrated [specific skill] at [precise baseline measure] as measured by [assessment tool or method]. The annual goal targeted [specific growth] by [date]. Progress monitoring data collected [frequency, e.g., every two weeks] using [tool] indicated that [student name] performed at [current level] at the end of the year, representing [X months/negligible/no measurable] growth over the intervention period. This rate of progress indicates that the current instructional approach requires modification. Contributing factors identified by the team include [list from your diagnostic analysis above]."
Notice what this template does. It is specific (it names the measure, the baseline, the target, and the outcome). It is honest (it names the gap between target and reality). It is analytical rather than defensive (it moves immediately to contributing factors, treating the data as information rather than accusation). And it is forward-pointing (the final phrase sets up the revised plan).
Here is a worked example:
"At the beginning of the 2024-25 academic year, Marcus demonstrated oral reading fluency at 42 words correct per minute (WCPM) on Grade 3 passages as measured by AIMSweb Plus. The annual goal targeted 70 WCPM by May. Progress monitoring data collected biweekly across 18 data points indicated that Marcus performed at 47 WCPM at the close of the year. Growth of 5 WCPM over 36 weeks falls significantly below the 28 WCPM gain targeted. Contributing factors identified by the team include 19 absences in the second semester, a personnel change in January that disrupted intervention consistency for six weeks, and emerging assessment data suggesting co-occurring working memory deficits that may require instructional accommodation."
This paragraph is uncomfortable to write. It will also protect you, inform the parents accurately, and build a coherent justification for the changes ahead.
Data-based individualisation (DBI) is the systematic process of using progress monitoring data to identify why an intervention is not working and to make targeted adjustments. Fuchs and Fuchs (2007) developed DBI as a response to the common failure mode in special education: implementing an intervention without a structured decision-making process for what to do when it does not produce results.
DBI asks four questions in sequence:
1. Is the student responding to the intervention? Look at the slope of the progress monitoring data. A flat or declining slope across at least six to eight data points signals non-response. A slope that started upward and then plateaued signals a different problem (the student may have reached a performance ceiling within that specific task type).
2. Was the intervention implemented as intended? Check your fidelity records, session logs, and any notes on personnel changes or schedule disruptions. If you cannot answer this question with documentation, that itself is a finding. Implementing an intervention without fidelity data is one of the most common gaps in special education practice.
3. Was the goal appropriately ambitious? Return to the baseline. Using Deno's (1985) curriculum-based measurement research, typical growth rates for students receiving intensive intervention are well-documented by grade level and disability category. If the goal assumed growth rates that exceed documented benchmarks for similar students, the goal was the problem, not the student.
4. Does the student need a different intervention, or a different version of the same intervention? Fuchs and Fuchs (2007) distinguish between "instructional modifications" (adjusting intensity, frequency, or pacing within the same approach) and "programme changes" (switching to a fundamentally different instructional methodology). Both are legitimate responses to non-response. The data should guide which is appropriate.
Run through this sequence with your data before the annual review meeting. Document your answers. This process is both good practice and a clear demonstration to parents that the team has analysed the plateau rigorously rather than simply writing new goals and hoping for different results.
Formative assessment tools can be embedded throughout the year to catch a plateau before it spans the full annual cycle. If your school does not currently have a decision rule for responding to non-response (for example, "if a student fails to show adequate growth after six consecutive data points below the aimline, convene a team meeting"), establishing one is a structural protection against the Sunday-night situation you are now in.
After running the DBI analysis, you are ready to write revised goals. The core principle is simple: next year's goals must be different from this year's goals in some substantive way. Writing identical goals for a student who made no progress is not just pedagogically unsound. It is legally indefensible under the Endrew F. standard.
The differences can be in any of the following dimensions:
Baseline accuracy. Use this year's end-of-year data, not the original baseline, as next year's starting point. This sounds obvious, but it is frequently done incorrectly. If Marcus ended the year at 47 WCPM, his IEP should not start from a baseline of 42 WCPM simply because that was the original entry point.
Goal ambition, recalibrated. The Endrew F. standard requires appropriately ambitious goals, not unreachable ones. Use the research on expected growth rates for students receiving intensive intervention to set a target that is genuinely ambitious and also grounded in what comparable students can achieve. The NCII provides benchmark data by disability category that is useful for this calibration.
Subskill sequencing. If a large goal (increase oral reading fluency to 70 WCPM) produced no progress, consider whether the goal needs to be broken into component subskills. Phonemic awareness, decoding accuracy, sight word recognition, and prosody are all separable skills that contribute to fluency. A student who did not improve fluency may have made growth in one of these subskills that is invisible in the fluency measure. Identify the foundational skill that needs to be secured before the composite skill can grow.
Instructional approach. If the analysis indicates that the current intervention is not the right match for the student, the goal needs to reflect a change in methodology. Document the new approach clearly: not just "specialised reading instruction" but the specific programme name, the instructional principles it is based on, and why it is a better match for the student's profile.
Frequency and duration. If the student was receiving 30 minutes per day and made no progress, this is not automatically an argument for more of the same. It may be an argument for a different intensity pattern (shorter, more frequent sessions rather than longer, less frequent ones), or it may signal that the frequency was actually insufficient. The NCII recommends a minimum of 30 minutes per day, five days per week, for intensive intervention (NCII, 2013). Check whether the actual delivery matched this.
Scaffolding in education literature is relevant here too. Vygotsky's zone of proximal development principle applies directly to goal-setting: a goal set at a level the student cannot access without significant support requires explicit scaffolding built into the plan, not just a target date.
Differentiation strategies may also need to be revisited at the goal level, particularly if the student's difficulty is in accessing the general curriculum rather than in a discrete skill area.
The language you use in the annual review meeting matters as much as the documents in front of you. The following table gives specific guidance on phrasing for the most common difficult moments.
| Situation | Do NOT say | DO say |
|---|---|---|
| Opening the meeting | "I know the data isn't great, but..." | "I want to start by sharing exactly what the progress data shows, and then we will look at what it tells us about next year's plan." |
| Presenting the flat trendline | "He didn't really make the progress we hoped." | "The data shows Marcus ended the year at 47 WCPM. The goal was 70. That is a 23-point gap we need to understand and plan for." |
| Explaining why progress stalled | "It was a hard year for everyone." | "We have identified three contributing factors: attendance in semester two, a personnel change in January, and new assessment information about working memory. Here is how the revised plan addresses each one." |
| Parent asks "Why didn't he learn to read?" | "We tried our best." | "That is exactly the right question. Let me show you what the data tells us about where the instruction needs to change." |
| Parent expresses frustration or anger | "I understand your concerns, but..." | "That frustration makes complete sense. [Pause.] Let me make sure you have all the information, and then let's talk about what changes specifically." |
| Parent asks about their legal rights | "You can request an IEE if you want, but..." | "Absolutely. You have the right to request an Independent Educational Evaluation at district expense. I can give you that information in writing today if you would like." |
| Explaining the new plan | "We're going to try some new things." | "The revised plan changes three things: the reading programme, the session frequency, and the way we will monitor and respond to data this year. Here is each one." |
| Closing the meeting | "Hopefully next year will be better." | "The goal for next year is [specific target]. We will review data every six weeks and meet if the growth rate falls below [decision rule]. You will receive a progress report in [month]." |
The pattern running through the "DO say" column is consistent: specific data, direct acknowledgement of difficulty, and concrete forward-planning language. Vague reassurance undermines trust. Precise information builds it.
The research on parent-professional communication in IEP meetings consistently finds that parents report feeling excluded from the process, that information is shared in inaccessible language, and that they leave meetings without a clear understanding of what is happening and why (Childre and Chambers, 2005). A meeting following zero progress amplifies every one of these risks.
Structure your parent communication in this sequence:
Step one: share the data first, without framing. Place the progress monitoring graph in front of the parent and describe what it shows: "This line shows where [student] started in September. This line shows where we aimed to be by May. This line shows where [student] actually is." Let the parent process the visual before you add interpretation.
Step two: acknowledge the emotional reality before you explain. Parents who have a child with a learning disability have frequently spent years in meetings where professionals explain before they listen. If a parent looks distressed, stop and say: "Before we go any further, I want to hear what this is like for you." This is not a delay. It is what makes the rest of the meeting productive.
Step three: share your analysis, not your excuses. There is a clear difference between explaining contributing factors analytically ("our data shows that the 19 absences in semester two account for approximately eight weeks of missed intervention") and making excuses defensively ("well, he missed a lot of school"). Use the DBI framework from the analysis section as your structure. Parents can hear difficult information when it is framed as investigation.
Step four: present the revised plan in specific terms. Not "we will try a new approach" but "we are recommending a switch from [Programme A] to [Programme B] because [Programme B] addresses decoding at the phoneme level, which the new assessment data identifies as the primary gap." Specificity communicates competence.
Step five: establish the monitoring promise. Tell the parent exactly how often they will receive progress data, what the decision rule is for convening a mid-year meeting, and how they can contact you if they have concerns between reviews. This last element is the most underused trust-building tool available to IEP teams.
Self-regulation in the classroom research is relevant to the student's perspective here too. If the student is old enough to participate meaningfully in the IEP meeting, their voice about what has and has not been helpful is both legally appropriate and practically valuable. Students who participate in their own IEP meetings demonstrate better self-advocacy and greater investment in their goals (Martin et al., 2006).
Sometimes zero progress is not a signal to adjust the programme. It is a signal to reexamine the underlying evaluation.
IDEA requires a triennial reevaluation for all students with disabilities, but the law also allows a reevaluation more frequently when warranted by the student's performance. A sustained plateau is one of the clearest warrants available.
Consider requesting a reevaluation when:
The disability category may be incomplete. A student identified solely for a specific learning disability in reading who has not responded to multiple evidence-based reading interventions may need evaluation for co-occurring processing disorders, intellectual disability, or hearing loss that was not identified at initial evaluation.
The student's profile has changed significantly. Executive function difficulties, mental health conditions, and trauma histories often emerge or escalate during the school years. A student who was accurately evaluated at age seven may look quite different at age 12 in ways the original evaluation did not capture.
Progress monitoring data is inconsistent with classroom observation. If a student performs near grade level in some structured settings but fails to maintain or generalise skills, the evaluation may need to assess processing, working memory, or executive function more specifically.
The team suspects a different primary disability category. A student identified for autism spectrum disorder whose primary barrier to progress is a specific learning disability in maths, for example, may need a reevaluation that refocuses the IEP around the right primary need.
A reevaluation does not invalidate the existing IEP. It provides better data for designing the next one. Frame it to parents as exactly that: "We want to make sure we have the most accurate picture of [student's] profile so that next year's plan is as precise as possible."
The 504 plan vs IEP distinction is also worth revisiting here. Occasionally, a student's needs are better served by a 504 plan with specific accommodations than by an IEP with specially designed instruction. A reevaluation is the appropriate mechanism for determining this.
The best protection against the Sunday-night crisis of next year is building a structure into this year's IEP that makes a year-long plateau impossible to miss. The following practices are all evidence-based and implementable within most school contexts.
Set a decision rule in the IEP itself. Batsche (2014) recommends writing the decision rule directly into the IEP document: "If [student] fails to demonstrate adequate growth as defined by [specific criterion] across [number] consecutive data collection points, the IEP team will convene within [timeframe] to review and modify the plan." This converts a passive hope for progress into an active monitoring commitment.
Collect progress monitoring data at minimum every two weeks. Deno (1985) established that curriculum-based measurement is most predictive of outcomes when collected frequently enough to generate a reliable slope. A single data point per month does not produce a usable trendline for six months. Eight data points collected every two weeks produces a usable trendline within three months. You would have caught and responded to this plateau before the annual review.
Use a visual graph, not a table of numbers. Progress monitoring data displayed as a graph with a goal line and an aimline is far more interpretable to teachers, parents, and administrators than a column of numbers. Most progress monitoring tools generate these automatically. If yours does not, a simple graph in Google Sheets takes less than five minutes to produce and is worth every one of those minutes.
Review data as a team, not in isolation. At minimum, a brief team check-in every six weeks on the progress monitoring data for students receiving intensive intervention is good practice. This does not need to be a formal IEP meeting. A 15-minute data review with the special education teacher, the classroom teacher, and any relevant specialist is sufficient. The purpose is to catch a flat trendline before it has been flat for six months.
Build mid-year IEP amendment into your calendar. If a student's data shows no progress by the six-week review, you have both the right and the obligation to reconvene the IEP team and amend the plan. Mid-year amendments are permitted under IDEA. They are far preferable to arriving at an annual review with a year of flat data and no documented response.
Cognitive load theory has practical implications for goal design as well. Goals that require students to manage too many simultaneous demands at once may fail not because the student lacks the underlying skill, but because working memory resources are exhausted before the skill can be practised to fluency. Chunking goals into smaller subskills, one at a time, reflects what the cognitive load literature tells us about skill acquisition.
A growth mindset framework for teachers is also worth considering here. Teams that interpret a flat trendline as "this student can't learn" will respond very differently from teams that interpret it as "this student has not yet responded to this approach." The framing of the data shapes the quality of the decision-making.
Students with ADHD present a particular diagnostic challenge at the annual review following zero progress, because ADHD-related barriers (attention dysregulation, self-regulation difficulties, impulsivity) can suppress the expression of skills that have actually been acquired. A student may have learned a decoding strategy but be unable to deploy it consistently in a testing context due to attentional demands.
If your student has ADHD and made no measurable progress, check the evidence-based accommodations for ADHD before concluding that the instructional intervention itself was the primary failure. Reduced-distraction settings, extended time, preferential seating, and chunked task presentation may unlock access to skills the student has acquired but cannot demonstrate under standard conditions.
If these accommodations were not in place, that is a contributing factor for the PLAAFP. If they were in place but not consistently implemented, that is a fidelity issue with the existing plan.
If you are reading this the night before an annual review, the single most important thing you can do right now is organise your progress monitoring data into a visual graph with a clear baseline, goal line, and the student's actual data points plotted over time.
Walk into the meeting with that graph. Refer to it. Let it be the centre of the conversation.
Data does not accuse anyone. It describes a situation and points toward what needs to change. A teacher who leads with data, names the contributing factors honestly, and presents a revised plan grounded in that analysis is doing their job with integrity. That is the full legal and professional standard, and it is achievable even when the news is difficult.
The student in front of you did not fail. The current programme did not produce the expected results. Those are two very different statements, and the first step toward a better outcome is being clear about which one is true.
Fuchs, L. S., & Fuchs, D. (2007). A model for implementing responsiveness to intervention. Teaching Exceptional Children, 39(5), 14-20.
Fuchs and Fuchs articulate the DBI framework that underpins responsible non-response decision-making. This paper remains the clearest practical guide to what teams should do when an intervention is not working, and why mid-year amendment is the correct response rather than continued implementation without change.
View study
Deno, S. L. (1985). Curriculum-based measurement: The emerging alternative. Exceptional Children, 52(3), 219-232.
Deno's foundational paper established the evidence base for curriculum-based measurement as a progress monitoring tool. The case for frequent, brief, standardised measurement rather than infrequent, long-form testing rests on this research, which showed that CBM slope predicts outcomes significantly better than snapshot assessment data.
View study
Burns, M. K., & Gibbons, K. (2008). Implementing response-to-intervention in elementary and secondary schools: Procedures to assure scientific-based practices. Routledge.
Burns and Gibbons synthesise the evidence on instructional match and its relationship to student learning rates. The chapter on diagnostic assessment of instructional level is particularly relevant for teams reviewing annual goals following zero progress, as it provides a framework for identifying whether the goal or the instruction was the primary mismatch.
View study
Yell, M. L., Katsiyannis, A., & Losinski, M. (2013). Endrew F. v. Douglas County School District: Implications for educators. TEACHING Exceptional Children, 50(1), 7-15.
This paper provides the clearest analysis of the legal implications of the Endrew F. standard for classroom practitioners. Yell et al. explain precisely what "appropriately ambitious" means in practice, the evidentiary record schools need to maintain, and the difference between a FAPE violation and an outcome that was disappointing but legally sound.
View study
Childre, A., & Chambers, C. R. (2005). Family perceptions of student centered planning and IEP meetings. Education and Training in Developmental Disabilities, 40(3), 217-233.
Childre and Chambers document the significant gap between how IEP teams perceive meetings and how families experience them. Their findings on communication, accessible language, and the role of parent voice in goal-setting are directly relevant to conducting an annual review following zero progress, where the communication challenge is at its most acute.
View study
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- Batsche, G. (2014). Multi-tiered system of supports for inclusive schools. In J. McLeskey, N. L. Waldron, F. Spooner, & B. Algozzine (Eds.), Handbook of effective inclusive schools. Routledge.
- Burns, M. K. (2004). Empirical analysis of drill ratio research: Refining the instructional level for drill tasks. Remedial and Special Education, 25(3), 167-173.
- Childre, A., & Chambers, C. R. (2005). Family perceptions of student centered planning and IEP meetings. Education and Training in Developmental Disabilities, 40(3), 217-233.
- Deno, S. L. (1985). Curriculum-based measurement: The emerging alternative. Exceptional Children, 52(3), 219-232.
- Endrew F. v. Douglas County School District, 580 U.S. 386 (2017).
- Fuchs, L. S., & Fuchs, D. (2007). A model for implementing responsiveness to intervention. Teaching Exceptional Children, 39(5), 14-20.
- Martin, J. E., Van Dycke, J. L., Christensen, W. R., Greene, B. A., Gardner, J. E., & Lovett, D. L. (2006). Increasing student participation in IEP meetings: Establishing the self-directed IEP as an evidenced-based practice. Exceptional Children, 72(3), 299-316.
- National Center on Intensive Intervention. (2013). Data-based individualization: A framework for intensive intervention. American Institutes for Research.
- Yell, M. L., Katsiyannis, A., & Losinski, M. (2013). Endrew F. v. Douglas County School District: Implications for educators. TEACHING Exceptional Children, 50(1), 7-15.
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