IEEs for Transition Assessments: What Parents Need to Know

Special education language often seems like alphabet soup in which everything has to begin with an “I.” There’s the IEP, or Individualized Education Program, and within it, the ITP, or Individual Transition Plan. The ITP is informed by transition assessments that help identify your child’s strengths, interests, preferences, and needs as they prepare for life after high school.

But what happens if you don’t think the school’s transition assessment was thorough enough? You can request an Independent Educational Evaluation (IEE) at public expense.

We sat down with Gwen Palafox, PhD, founder of Meaningful Growth and a transition expert who conducts IEEs, and Lisa Carey, a non-attorney education advocate and founder of Carey Advocacy, to learn about when it might be appropriate to request an IEE and what the benefit might be.

For many families, when the ITP comes up in an IEP meeting, it’s not always clear that an actual transition assessment took place. A parent might be shown a page of pictures of different jobs their child selected, along with a brief report stating that the student wants to work, live independently, or perhaps go to college someday.

But there may be little detail about what those goals actually mean for this particular student — or how their special education program will help them get there. It can leave parents wondering what the purpose was of all the paperwork and what the ITP is actually supposed to tell them.

Under IDEA, the ITP is required (at different ages depending on your state regulations) to be included in the IEP and to be based on an assessment related to training, education, employment, and, where appropriate, independent living skills.

Palafox tells us that transition planning as a whole is still “a newer concept.” But at its core, she says a transition assessment should answer: “What does a student want to look like as an adult, and what does that mean?”

“Following the legal requirements of a transition assessment, we want to make sure we’re hitting certain categories,” Palafox says. “And in a transition assessment, it’s employment, working, learning, postsecondary education, and living, if it’s appropriate. But I’ve never assessed a student where living wasn’t appropriate to assess or to write a goal for, and part of that reason is because the living skills are probably the biggest, the most amount of skills that a student really needs for their kind of adult life, or if we want to promote as high of independent functioning as possible, or if we want to play with interdependence, as much independence and as little dependence as possible. But you know, age appropriate.”

Carey tells us, “Basically the goal is to figure out what the student knows, what skills the student has, and what skills the student is missing, and look specifically at independent living, future education, and employment, and they should come up with some recommendations and some goals that are as general as ‘will go to college.’” As Carey explains, the important finding is, “What skills do we need to work on in order to be able to go to college, and some goals around those skills?”

That’s not always what families receive. Palafox says that sometimes the legal responsibility for transition assessment is met by “getting online and doing a career interest inventory and then calling it a day.”

“I think parents and sometimes students are not satisfied with the assessment because they feel like it doesn’t capture the vision of what [the student wants] to be as an adult, and that really should be driving the entire IEP,” she continues. “ITPs should drive the spirit and the vision of IEPs, and I think a lot of times they get forgotten.”

Carey also tells us that many transition assessments simply aren’t comprehensive. Often, the report has not included extensive interviews with the student, parent, and teachers or used any standardized assessment tools. Some reports consist of just a couple of paragraphs containing generic information that could apply to almost any young person.

When a transition assessment is completed at the same time as a triennial assessment, however, the school may be able to draw on information it already has. Carey explains, “If a psychoeducational assessment has already been done recently, they can use that information if they feel it’s appropriate, and then they are going to do assessments around the actual transition plan for the student.” For example, the school may use surveys, interviews with the student, and inventory checklists.

Not having a comprehensive transition report undermines the entire ITP process. Without being rooted in a person-centered assessment, the ITP can become a generic wishlist — go to college, have a job, move out of the family home. But when a child has a disability, families need a plan for how they’ll work toward those goals.

Palafox tells us that parents often come to her saying, “I was never asked.” And sometimes the student hasn’t been meaningfully included either: “The student was never asked directly. They were never observed.”

Palafox also says transition assessments are sometimes treated as one-time assessments, perhaps repeated every three years like a triennial evaluation.

“That’s fine, but transition assessments really aren’t meant to be a one-time event. They really need to be a yearly event, an annually updated event, to make sure that we’re capturing the trajectory and the real vision and goals of this student as an adult.”

Carey agrees that “most districts are only giving a survey or two.” Since this is standard practice in many schools, your IEP team may be surprised that your expectations for this process go deeper — you may even be told, “This is just how this is done.” So how do you know if your transition assessment is inadequate?

As Palafox explains in this clip, a good transition assessment looks at who the student is today, who they want to be, and how to close the gap between the two. It should draw from interviews with the student, family, and teachers who have worked extensively with the student, along with direct observation and standardized measures when appropriate.

IDEA gives parents a right to an independent education evaluation (IEE) at public expense for any assessment, and that includes a transition assessment. An IEE is essentially a second opinion conducted by a qualified evaluator who does not work for the school district.

If you believe your child’s transition assessment wasn’t comprehensive enough, you can request an IEE at public expense. Some states put limits on this. It’s a good idea for parents to make the request in writing so there is a record of it, and the school district must respond.

Usually, the district’s response comes in the form of a letter known as a prior written notice. If the school district refuses the parent’s request, the district or charter school must file for due process in order to justify its decision by proving to the hearing officer that its assessment was appropriate.

If the district agrees to the IEE, the parents will name their chosen assessor and provide the school district with their information so the district can set up the contract. In California, many SELPAs have criteria for IEEs, such as the distance they will pay for travel and the cost they will pay for the assessment.

Carey finds that, in practice, when an IEE is requested for a transition assessment, the district often asks for an opportunity to assess the student again first.

This can be frustrating because often the district already provided the parent with an assessment plan that included a transition assessment and presented the ITP. But when the adequacy of that transition assessment is challenged, it can suddenly feel as if the assessment never happened.

However, in Carey’s experience, it can be worth allowing the district to assess again because this has resulted in some of the best transition assessments she has seen.

Once you’ve secured the IEE, the next concern is, who does it?

Sadly, there is a scarcity of qualified transition assessors who provide IEEs. Palafox tells us, “There are several people in California; they’re just hard to find” on the organization list.

Your school district should also provide you with a list. Palafox says that it isn’t only licensed psychologists like her who can conduct these assessments; vocational services professionals may also be qualified to conduct a transition assessment.

Carey suggests asking a potential assessor whether they have previous experience assessing students with needs similar to your child’s. For example, have they worked with students with intellectual disabilities, students who use an AAC device, or students with a medically complex body?

School districts might also set limits on assessors, particularly when it comes to access for observations. Palafox tells us that districts can set requirements for observation, but those requirements should always be similar to what they would require of their own assessors.

For example, if the district’s assessment allowed three observations, your independent assessor should also be allowed the same amount of time. This can get complicated when the district’s own assessment neglected to include any observations. In that case, Palafox says you can look at previous assessments, such as a psychoeducational assessment or a functional behavioral assessment, to see what kind of access the district’s own evaluators received.

After the assessor has completed their observations, interviews, surveys, and other assessments, they will write a report and share their findings in an IEP meeting. They may also make recommendations for ways to change the ITP, the annual measurable IEP goals, and the services that support them. The school district has to consider those findings under 34 CFR §300.502(c).

Your IEP team — remember, this includes you — might collectively decide to ignore all of the recommendations or implement only some of them. Even when the recommendations are only partly implemented, however, the IEE can still be useful as a guide for the family. You might decide to pursue some of the goals outside of school through other providers.

In this clip, Palafox explains an important distinction: districts are legally required to consider the IEE, but they are not legally required to implement all of its recommendations.

For Palafox, the transition assessment can be a “North Star” for anyone involved with the student. For the family, it can also be used as a person-centered plan when planning services through other systems, such as the Regional Center's traditional service model or its Self-Determination Program (SDP) in California.

It’s also important to note that the IEE recommendations can become valuable evidence for a future due process claim if you believe that, by not following those recommendations, the school district is failing to provide FAPE.

The transition assessment process and the ITP are not only important during high school. They are also essential for students participating in 18–22 adult transition programs (ATPs). The ITP should continue to guide this stage as part of an individualized program. Many 18–22 ATP programs have little differentiation, but the IEP should still be individualized and targeted toward your child’s unique needs.

If you feel that your child’s transition assessment is not fit for purpose, requesting an IEE could be effective in resetting your team’s expectations, as well as supporting your child and your family with a student-centered plan that can drive your priorities over several years.

In Palafox’s way of thinking, a strong transition assessment can provide the roadmap to independence.